ML20058F463
| ML20058F463 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 10/31/1990 |
| From: | Shelton D CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1-936, NUDOCS 9011080297 | |
| Download: ML20058F463 (3) | |
Text
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CENTERNNt M
ENERGY Donald C. SheMon 300 Madison Avenue Vce Presdent Nuclear Toledo, OH 436520001 Davis Besse (419)249 2300 i
Docket Number 50-346 l
License Number NPF-3 l
Serial Number 1-936 c
October 31, 1990 i
l United States Nuclear Regulatory Commission l
Document Control Desk Washington, D. C.
20555 i
Subj ect : Response to initial NRC Systematic Assessment of License Performance (SALP) 8 Board Report L
Gentlemen:
Toledo. Edison Company (TE) has reviewed the initial SALP 0 Board Report (Inspection Report No. 50-346/90001) for the Davis-Besse Nuclear Power Station, covering the period March 1, 1989 through June 30, 1990.
The SALP fransmittal letter (Log Number 1-2360), dated September 20, 1990, stated that TE may provide vritten comments to the NRC within 30 days after
- the October.2, 1990, SALP 8 meeting.
l Attached are TE's comments concerning the SALP 8 report.
These comments include corrections to apparent errors of fact contained in the report.
If you have any questions regarding this matter, please contact Mr. R. V.
Schrauder, Manager - Nuclear Licensing, at (419) 249-2366.
Very truly yours, j
/d/m%
KAF/mmb cci
-P. M. Byron, DB-1 NRC Senior Resident Inspector A. B. Davis, Regional Administrator, NRC Region III A.11. Hsia, NRC/NRR Davis-Besse Backup Project Manager l
M. D. Lynch, DB-1 NRC Senior Project Manager C. J. Paperiello, NRC Region III Deputy Administrator Utility Radiological Safety Board 9011080297 901031 PDR ADOCK 05000346 3
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PNU opvotmg companies f6IfC Clevelond Electne lilummotmg Toledo Edison
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' Dock 3t Nu;bir 50-346
High Dose Rates Due to MU2B Failure On Page 12, in the Radiological Controls Analysis (paragraph 6), the SALP report states that higher than projected total station dose was experienced during the sixth refueling outage due to increased inservice inspection (ISI) vork, emergent vork, and failure of letdown isolation valve MU2B.
During a September 21, 1990 conference call to Region III staff, Toledo Edison explained that the failure of MU2B vas not the cause of higher Reactor Coolant System (RCS) pump and piping dose rates following the January 26, 1990 trip. The chemistry data and radiation survey data collected following the trip indicated that no significant increased dose rates were seen on the RCS piping and pump surfaces.
In addition, the crud burst which occurred following the trip was lover than experienced during previous shutdowns.
Therefore, because only minor plating out of radioactive cobalts occurred in the RCS, high dose rates were not observed. The reference to MU2B should be removed from the final SALP 8 report.
B.
Check Valve _ Maintenance Program On Page 14, in the maintenance / Surveillance Analysis (paragraph 11), the SALP report states: " Concerns were raised regarding check valve corrective and preventive maintenance. The licensee is developlag a check valve maintanance program which emphasizes valves judged most likely to fail. However, the NRC inspection determined that the maintenance program as presently constructed did not adequately consider the valves of greates'. safety significance."
During the March 28, 1990 ISLOCA meeting with the NRC, Toledo Edison responded to those specific findings and open items discussed in the ISLOCA inspection' report (IR 89-201).
Following the meeting, Toledo Edison submitted a response (Serial-1793, dated April 27, 1990) stating that the check Valve Reliability Program at Davis-Besse was initiated in 1986. This was approximately the same time that INPO was preparing SOER 86-03 on check valve performance. The program initially consisted of a review of approximately 200 check valves in 15 of 34 systems containing valves from the System Review and Test Program,- Elements of the program include testing, inspection, and design review._ Toledo Edison's goal is' to have a comprehensive prioritized check valve Preventive / Predictive Maintenance Program with a basis similar to that developed for motor operated valves (HOVs) and air operated valves (A0Vs)'at Davis-Besse.
In addition,' Toledo Edison has assumed a very aggressive and proactive role in various industry activities relating to check valves.
Toledo Edison's " Check Valve Reliability Program" does establish a
.prioritization scheme based on the valve's safety function as well as its service conditions.
This program was provided to the NRC staf.
during the ISLOCA inspection.
Furthermore, the check valve 6 1
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i Dock;t Nu:ber 50-346 I
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' S;rici Nu;ber 1-936 1
Page 2 prioritization issue was not raised by the NRC during the March 28, 1990 meeting with the NRC staff concerning Toledo Edison's check valve I
program.
Toledo Edison was unaware that the NRC staff had taken exception to the prioritization of check valves at Davis-Besse until the initial SALP 8 report was issued.
Therefore, the final SALP report should be revised to reflect these comments.
C.
Management Changes On Page 24, in the Safety Assessment / Quality Verification Analysis (paragraph 15;, the SALP report states that numerous management changes during the assessment period resulted in some loss of continuity in L
direction. Toledo Edison is aware of no area where a loss of continuity occurred as a result of management change.
Accordingly, the statement should be deleted..
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