ML19340E129

Responds to NUREG-0737.Util Working W/Oh State Univ on Feasibility Evaluation of long-term Program to Phase Out Need for Shift Technical Advisor.Commitment Supersedes All Previous Commitments

ML19340E129
Person / Time
Site:	Davis Besse
Issue date:	12/30/1980
From:	Crouse R TOLEDO EDISON CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.1, TASK-1.C.5, TASK-1.D.1, TASK-2.K.2.09, TASK-2.K.2.10, TASK-2.K.2.11, TASK-2.K.2.13, TASK-2.K.2.16, TASK-TM 670, TAC-12453, TAC-44912, TAC-44983, TAC-45054, NUDOCS 8101060473
Download: ML19340E129 (17)

Text

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TCLEDO h EE)lEiC)fu

" C ~ "0 P C "CE Docket No. 50-346 t e % v4* t 4.c e w am:295n' License No. NPF-3 Serial No. 670 December 30, 1980 Director of Nuclear Reactor Regulation Attn:

Mr. Darrell G. Eisenhut, Director Division of Licensing Nuclear Regulatory Co= mission Washington, D.C.

20555

Dear Mr. Eisenhut:

On October 31, 1980, Clarification of TMI Action Plan Requirements (NUREG 0737), was issued. The document identifies a compilation of the recommendations to be completed on co==ercial facilities that resulted from the accident of March 28, 1979 at the Three Mile Island, Unit 2 facilities.

This letter provides Toledo Edison's plans concerning these recommenda-tions for the Davis-Besse Nuclear Power Station Unit 1. of this letter gives a tabular listing consistent with that of Enclosure 1 of NUREG 0737.

The specifics identified are current plans particular to the Davis-Besse facility. It is noted however, and identified where appropriate, that Toledo Edison is involved in on-going discussions concerning several of these items. Details describing the Davis-Besse commitments not already completed are provided by notations on Attach-ment 1.

As a generic response consideration, an extre=ely large amount of informa-tion is identified in NUREG 0737 as being due on January 1, 1981.

In reviewing this information, none appears to be of critical importance i

relative to that date.

Since some organizations supporting Toledo Edison activities physically close their doors over the holiday period and most others are supported by a reduced staff, January 1, 1981 sub-

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mittals in general will be made on January 9, 1981.

This will allow time to greatly enhance the accuracy of the submitted information as well as allow the reduced staffs to adequately support other on-going high priority activities.

/ /

THE TCLEDO EDISCN COMPANY EDISCN PLAZA 300 MADISON AVENUE TOLEDO. CHiO 43552 M *] h 8101060 L. /

4 4 Several recommendations require outages to implement.

For the purpose of commitments in this letter, these items are being reflected as scheduled during currently planned outages. One such outage commonly referenced is the 1982 refueling outage. The current schedule identifies commence-ment of for this outage at the end of February, 1982. Toledo Edison considers the implementation of items during this refueling outage to be acceptable alternate dates to January 1, 1982 if such implementation requires a plant outage.

i The schedules here reflect our current plans assuming successful design, j

procurement, qualification, installation and approval activities. These commitments supersede all previous commitments concerning these items.

Any permutations in these activities will be reflected in future schedule l

revisions as they are identified.

Very truly yours, RPC/TJM 6

db d/6-7 cc:

DB-1 NRC Resident Inspector 4

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10 CFR 50.54 (f)

SUBMITTAL IN RESPONSE FOR DAVIS-BESSE NGCLEAR POWER STATION UNIT 1 FACILITY OPERATING LICENSE NO. NPF-3 This letter is submittal in confonr.ance with 10 CFR 50.54 (f) relating to Mr. D. G. Eisenhut's letter of October 31, 1980. This deals with

" Clarification of TMI Action Plans Recuirements", (NUREG 0747).

Vice-President, Nuclear Sworn to and subscribed before me this dayofDecember,19[0

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PAGE 1

of 9

DB-1 NUREG 0737 TMI ACTION PLAN ITEMS TOLEDO ITEM EDISON NO.

TITLE DESCRIPTION COMMITHENT REMARKS I.A.1.1 Shift Technical Advisor

1. On duty Completed

2. Tech Specs Completed

1. TECo Ltr 9/16/80

3. Trained per LL Cat. B 1/1/81

4. Describe long term 6/30/81

1. See Note 1 program I.A.I.2 Shift Supervisor Delegate non-safety Completed Responsibilities duties I.A.1.3 Shift Hanning

1. Limit Overtime Completed

2. Min Shift Crew 7/1/82 I.A.2.1 Immediate Operator

1. SRO Experience Completed Upgrading

2. SR0's be RO's 1 year Completed

3. Three month on-sh'ift Completed training

4. Modify Training Completed

5. Facility Certifica-Completed tion I.A.2.3 Administration of Train-Instructors complete Completed ing Programs SRO Exam I.A.3.1 Revise Scope and

1. Increase scope Completed

1. TEco Ltr 8/4/80 3

Criteria for Licensing

2. Increase passing Completed

1. TECo Ltr 8/4/80 Exams grade

3. Simulator Exams

1. See Note 2

2. TECo Ltr 8/4/80 I.C.1 Short Term Accident

1. SB LOCA Completed and Procedures Review

PAGE 2

of 9

DB-1 NUREG 0737 TMI ACTION PLAN ITEMS TOLEDO ITEM EDISON NO.

TITLE DESCRIPTION COMMITMENT REMARKS I.C.1

2. Inadequate Core (Cont.)

Cooling

a. Reanalyze and pro-TBD

1. See Note 3 pose guidelines

b. Revise procedures 1st refueling

1. Outage considered impor-6 months after tant due to the radical NRC Approval change in procedures after 1/1/82

3. Transients and Accidents

a. Reanalyze and TBD

1. See Note 3 propose guide-lines

b. Revise procedures 1st refueling

1. Outage considered 6 months after important due to the NRC Approval radical change in after 1/1/82 procedures I.C.2 Shift and Relief Turn-Implement shift turn-:

Completed over Procedures over checklist I.C.3 Shift Supervisor Clearly define super-Completed Responsibility visor and operator responsibilities I.C.4 Control Room Access Establish Authority, Completed Limit access I.C.5 Feedback of operating Licensee to implement 1/1/81 experience procedures I.C.6 Verify correct per-Revise performance 1/1/81 formance of operating procedures 4

activities I.D.I' Control room design Preliminary assessment

1. TECo will respond after reviews and schedule for cor-NRC issues NUREG 0700 recting deficiencies (final) and proposed

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PAGE 3

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DB-1 NUREG 0737 THI ACTION PLAN ITEMS TOLEDO EDISON ITEM NO.

TITLE DESCRIPTION COMMITMENT REMARKS

1. TEco will respond after I.D.2 Plant-Safety-Parameter

1. Description NRC issues NUREG 0696 Display Console

2. Installed (Revision 2) and pro-

3. Fully Implemented 4

posed schedule implemen-tation II.B.1 Reactor-Coolant-System

1. Design Vents 07/01/81

1. Note 4 Vents

2. Install Vents 1st refueling (LL Cat. B) outage after 1/1/82 I

3. Procedures

1. Note 5 II.B)2 Plant Shielding

1. Review Designs Completed

1. TECo Ltr. Serial No. 601 of March 21, 1980 4

2. Plant Hodification Not Required

1. No further modifications:

i (LL Cat. B) proposed from the study of II.B.2.1.

No further submittals required t

i

3. Equipment Qualifi-

1. Note 6 cation II.B.3 Post Accident Sampling

1. Interim System Completed i

2. Plant Hodification Refueling Outage 1. No further submittal (LL Cat. B) 1982 required j

i

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of 9

DB-1 NUREG 0737 TE1I ACTION PLAN ITEMS TOLEDO TEM EDISON 0.

TITLE DESCRIPTION COMMITMENT REMARKS I.B.4 Training for Mitigating 1., Develop Training Pro-TBD

1. Note 7 Core Damage gram

2. Implement Program a.

Initial TBD

b. Complete TBD

'I.D.1 Relief and Safety Valve

1. Submit Program Completed Test Requirements

2. RV&SV Testing (LL Cat. B)

a. Complete testing

1. Note 8

b. Plant specific report

3. Block Valve Testing

1. Note 8

[I.D.3 Valve Position Indica-

1. Ir. stall Direct Indi-

1. Installation

1. TEC Acoustic Monitors tion cations of Valve complete

2. Qualification program Position

2. Qualif. Data unde rway in March 1982 1. TECo Ltr. 9/16/80

2. Tech Specs Completed II.E.1.1 Auxiliary Feedwater

1. Short Term TBD

1. Actions are to be deterc mined based on NRC revic System Evaluation as yet not complete

2. Long Term TBD II.E.1.2 Auxilia ry Feedwater

1. Initiation System Initiation

a. Control Grade Not Applicable

1. See II.E.1.2.1.b.

and Flow

b. Safety Grade Complete

1. Original plant design

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of - 9 DB-1 NUREG 0737 THI ACTION PLAN ITEMS TOLEDO ITEM EDISON NO.

TITLE DESCRIPTION COMMITMENT REMARKS 4

II.E.1.2

2. Flow Indication (Cont.)

a. Control Grade Completed

b. LL A Tech Specs Completed

c. Safety Grade Refueling 1.

per 2.1.7.b. response Outage 1982 in TEco Ltr. 3/21/80 2.

Note 16 II.E.3.1 Emergency Power For

1. Upgrade Power Supply Completed

1. Original plant design Pressurizer lleaters

2. Tech Specs Not Required

1. TECo Ltr.

II.E.4.1 Dedicated Hydrogen

1. Design Completed

1. Original design for 112 Penetrations '

Dilution System

2. Install Completed

1. Original design for H

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2 Dilution System II.E.4.2 Containment Isolation 1-4 Imp. Diverse Isola-Completed

1. Original plant design Dependability tion i

5. Catst. Pressure Set-point

a. Specify Pressure 01/09/81 J

b. Modifications 1st. planned outage after NRC Approval if required

6. Catmt. Purge Valves Complete

7. Radiation Signal on Complete

1. Original design l

Purge Valves

8. Tech Specs Complete

1. Part of current Tech.

Specs

2. No further action req.

II.F.1 Accident - Monitoring

1. Noble Gas Monitor Refueling outage 1982 4

PAGE 6

of 9

DB-1 NUREG 0737 TMI ACTION PLAN ITEMS TOLEDO ITEM EDISON NO.

TITLE DESCRIPTION COMMITMENT REMARKS II.F.1

2. Iodine / Particulate Refueling (Cont.)

Sampling Outage 1982 t

3. Containment liigh Refueling Monitor Outage 1982 4

4. Containment Pressure Refueling 4

Outage 1982

5. Containment Water' Refueling Level Outage 1982

6. Containment liydrogen 01/01/82 i

II.F.2 Instrumentation For

1. Subcool Meter Complete j

Detection of Inadequate

2. Tech Specs (LL Cata)

Complete Core Cooling

3. Install Level Instru-

1. Note 9 ments (LL Cat. B)

II.G.1 Power Supplies For

1. Upgrade to Emerg.

Complete Pressurizer Relief Source Valves, Block Valves,

2. Tech Specs Complete and Level Indicators II.K.1 IE Bulletins 79-05, 06, 08 TBD

1. No action requ' ed pending NRC revaew II.K.2 Orders on B&W Plants

8. Upgrade AFW System Completed

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DB-1 NUREG 0737 TMI ACTION PLAN ITEMS TOLEDO ITEM EDISON NO.

TITLE DESCRIPTION COMMITMENT REMARKS II.K.2

9. FEMA on ICS Completed (Cont.)

10. Safety-Grade Trip Ist Refueling 1.

Note 17 (Final - ARTS) 6 months after NRC approval if no changes

11. Operating Training, Completed Drilling

13. Thermal Mechanical 01/09/81 Report

14. Lift Frequency of 1/9/81 1.

See II.K.3.7 PORVs & SVs

15. Effect of Slug Flow Completed i

on OTSGS

16. RCP Seal Damage completed

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17. Voiding in RCS Completed i

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19. Benchmark Analysis Completed of Seq. AFW Flow

20. System Response to Completed SB LOCA 1

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DB-1 NUREG 0737 THI ACTION PLAN ITEMS TOLEDO ITEM EDISON NO.

TITLE DESCRIPTION COMMITHENT REMARKS II.K.3 Final Recommendations,

1. Auto PORV Isolation B&O Task Force

a. Design

1. Note 10

b. Test / Install TBD 4

2. Report on PORV 01/9/81 4

Failure

3. Reporting SV & RV Completed

1. TECo Ltr. 6/26/80 Failures & Challenges

5. Auto Trip of RCPs

a. Proposed Modifi-TBD

1. Note 11 cations

b. Modify TBD

7. Eval of PORV Open-1/9/81 ing Probability

.11. Justify use of Not Applicable

1. NUREG 0611 3.2.4.d Certain PORV j

17. Voiding in RCS Completed

1. Under NRC staff review

30. SB LOCA Methods

a. Schedule outline TBD

1. Note 12

b. Model TBD

c. New Analyses TBD I

31. Compliance with TBD

1. See II.K.3.30.

CFR 50.46 1

9

40. RCP Seal Damage Completed 1.

See II.K.2.16

PAGE 9

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DB-1 NUREG 0737 TMI ACTION PLAN ITEMS TOLEDO

' ITEM EDISON NO.

TITLE DESCRIPTION COMMITMENT REMARKS II.K.3

43. Effect of Slug Flow See II.K.2.15 (Cont.)

III.A.1.1 Emergency Preparedness, Short-term Improvements Completed Short Term III.A.I.2 Upgrade Emergency

1. Interim TSC, OSC &

Completed Support Facilities EOF

2. Design TBD

1. TEco will respond after NRC issues NUREG 0696 Rev. 2

3. Modifications TBD i

III.A.2 Emergency Preparedness

1. Upgrade Emergency

1. Note 13 Plans to Apply to App. E, 10 CFR 50

1. Note 14

2. Meteorological Data l

III.D.I.1 Primary Coolant Outside

1. Leak Reduction Completed Containment

2. [ech Specs

1. TECo Ltr i

III.D.3.3 In-Plant Radiation

1. Provide Means to Completed Monitoring Determine Presence of Radioiodine

2. Modifications to completed Accurately Measure 1 2

III.D.3.4 Control Room

1. Review

1. Note 15 liabitability '

2. Modification TBD if required i

PD 138

l.

Docket No. 50-346 License No. NPF-3 Serial No. 670 December 30, 1980 i

4 Notes to Attachment 1 DB-1 NUREG 0737 TMI Action Plan Items Note 1 I.A.1.1.4 Shift Technical Advisor (STA)

Describe Long Term Program Toledo Edison is currently working with Ohio State University in a feasibility evaluation of a long term program that would phase out the need for the STA. The results of this evaluation will be available the second quarter of 1981. A description of the resulting long term program and detailed document comparison will be submitted at that time in lieu of the January 1,1981 requested date.

Note 2 I.A.3.1.3 Revised Scope and Criteria for Licensing Exams Simulator Exams Toledo Edison considers training at the Babcock & Wilcox simulator in Lynchburg, Virginia, an important part of initial and requalification operator training programs and intends to continue this activity in the future. However, we do not agree with the requirement of manditory NRC simulator examinations for all NRC license candidates. The present program provides adequate assurance that the operator will respond properly to abnormal plant conditivas. The requirement for more simu-lator time will likely over-load the simulator training facilities and will result in little additional benefit to the qualifications of opera-tors.

I Note 3 I.C.1,2&3 Short Term Accident and Procedures Review Inadequate Core Cooling Transients and Accidents i

This relates to the ongoing B&W Owners Group efforts in the Anticipated Transient Operating Guidelines program (AT0G). Many meetings have taken place between the Owners Group and the NRC staff with the most recent on December 16, 1980. During the discussion it was agreed the January 1, 1981 requested information will be fulfilled by the current guidelines generated for the Arkansas Nuclear One - Unit 1 facility.

Because the ATOG program is actually an extensive development of plant specific rather than generic guidelines, those relating to Toledo Edison's facil-ity will be unique but will utilize the same technique and methodology.

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l Note 4 II.B.1.1 Reactor Coolant System Vents i

Design Vents On January 30, 1980 (Serial No. 582) Toledo Edison committed to install remotely operated reactor coolant system vents on the high points of the reactor coolant hot legs as well as an additional vent path in the pressurizer. On April 15, 1980 (Serial No. 608) Toledo Edison further J

committed to pursue a vent for the reactor vessel head while identifying that it is not considered required or desired for a once through steam a

generator designed nuclear steam supply system. Toledo Edison is con-tinuing to review the head vent concern, with the intent to justify not installing this modification.

Note 5 II.B.I.3 Reactor Coolant System Vents Procedures Procedures for installed reactor coolant system vent operation are currently planned for January 1982. The resulting guidelines will be reflected in Davis-Besse Station procedures after NRC approval.

Note 6 II.B.2.3 Environmental Qualification 1

Toledo Edison is providing environmental qualification information and planned actions for all safety related equipment under activities related to the NRC ocder for modification of license concerning environmental qualification of safety-related electrical equipment dated October 24, 1980. All further correspondence will be taken in conjunction with that order and is applicable to this item. No further submittal will be made independently for NUREG 0737.

Note 7 j

II.B,4.1 Training for Mitigating Core Damage l

Develop Training Program Toledo Edison has joined with other owners of B&W nuclear steam supply systems to develop and implement this training program. We expect this program to be complete by October 1, 1981. However, the program is still under development and will not be available for January 1,1981.

As a result initial implementation r.ay not occur prior to April 1, 1981.

The program will be submitted when available.

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Note 8 II.D.I.2&3 Relief and Safety Valve Test Requirements RV and SV Testing Block Valve Testing Toledo Edison is participating in the EPRI PWR Safety and Relief Valve Test Program. On December 15, 1980, Mr. R. C. Yongdahl of Consumers Power Company submitted the current PWR utilities position on this item.

The Toledo Edison Company supports this position.

Note 9 II.F.2.3 Instrumentation for Detection of Inadequate Core Cooling (ICC)

Toledo Edison has reviewed the currently available systems that are identified as potential instrumentation to detect ICC. An evaluation was made in comparison to the guidelines for such a condition. Our evaluation remains that the currently installed capability is the most unambiguous system available for installation by January 1, 1982.

Toledo Edison is following the development of new potential systems, however, we cannot at this time commit to implementation beyond the current design.

Note 10 II.K.3.1&2 Final Recommendations of B&O Task Force Auto PORV Isolation Toledo Edison does not plan to modify the current PORV isolation capa-bility. A report will be submitted by January 9,1981 identifying that this modification, by itself, is not required. However, Toledo Edison is pursuing a plant reliability improvement that would combine an auto-matic PORV isolation with elimination of reactor trip on turbine trip conditions and returning of PORV lift and reactor pressure trip setpoint to their original values. This combined modification will be submitted when finalized.

Note 11 II.K.3.5 Final Recommendations of B&O Task Force Auto Trip of RCP's The B&W Owners Group is participating in a prediction program based on j

the L3-6 test at the Loss of Fluid Test Facility (LOFT). The pecgram effort is directed at justifying code work to illustrate an automatic trip of the reactor coolant pumps is not necessary. The results are to be submitted for NRC review. No plant modification is committed to at this time.

In the interim, Toledo Edison will continue to' manually trip the reactor coolant pumps as previously committed.

l Note 12 II.K.3.30 Final Recommendations of B&O Task Force l

SB LOCA Methods On December 16, 1980, the B&W Owners Group met with the NRC Scaff to j

discuss details of the areas of interest in small break evaluation methodology. As a result, a program to address these areas of interest shall be submitted by January 30, 1981.

i Note 13 i

III.A.2 Emergency Preparadness Upgrade to 10 CFR 50 Appendix E l

The revised Davis-Besse Emergency Plan developed for Appendix E sub-mittal is to be filed by January 2, 1981.

Its extent of compliance with NUREG 0654 will be discussed referencing the NRC letter of December 17, 1980 from Mr. R. W. Reid ( Log No. 645).

Note 14 i

III.A.3 Emergency Preparadness Meteorological Data The Davis-Besse Nuclear Power Station meteorological capability as installed is considered to fullfill the requirements of milestones (1),

(2) and (3) exercising the alternative compensatory measures under (3).

By July 1, 1981 a functional description of-the data gathering system will be provided justifying any positions not consistent with those identified or referenced in NUREG 0737.

Note 15 III.D.3.4 Control Room Habitability Review The Davis-Besse Unit 1 Control Room has been reviewed under General l

Design Criteria 19 and found acceptable during its operating license review. Toledo Edison is currently verifying the current applicability of the evaluated information. This verification is expected to be com-I l

plete by March 31, 1981. The results will be forwarded at that time.

l If any modifications are required, an implementation schedule shall be i

l provided.

I Note 16 II.E.1.2.2 Auxiliary Feedwater Flow Indication Safety Grade The next planned outage to support installation and testing of the safety grade flow indication is scheduled for the 1982 refuleing outage.

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This reflects a delay in the NRC schedule date of July 1,1981. This delay is not considered to present a significant concern due to the current design which has control grade flow indication off emergency power as backup to the redundant safety grade steam generator level indication. These level indicators are part of the safety grade level control system which is a Davis-Besse original design feature.

Note 17 KK.K.2.10 Safety Grade Trip Final Anticipatory Reactor Trip System (ARTS)

Toledo Edison commits to installation of the ARTS at the first refueling outage 6 months after NRC approval. The earliest installation therefore would be during the 1982 refueling outage expected at the end of February 1982. Until such installation the currently installed control grade anticipatory reactor trip system will remain in service.

PD 138D,

,