ML20058F662
| ML20058F662 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 11/30/1993 |
| From: | Storz L CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| REF-GTECI-070, REF-GTECI-NI, TASK-070, TASK-70, TASK-OR 2191, GL-90-06, GL-90-6, NUDOCS 9312080219 | |
| Download: ML20058F662 (5) | |
Text
-
CENTERIOR ENERGY 1
300 Modson Avenue Louis F. Storr l
Toledo, OH 43652-0001 Vice President-Nuciecr i
419 149 2300 Dovrs-Besse i
i Docket Number 50-346 License Number NPP-3 l
Serial Number 2191 i
November 30, 1993 United States Nuclear Regulatory Commission I
Document Control Desk Vashington, D. C. 20555 Subj ec t : Generic Letter 90-06, Resolution of Generic Issue 70, Pover-Operated Relief Valve and Block Valve Reliability l
(TAC Number 77346)
^
i Gentlemen:
Nuclear Regulatory Commission (NRC) Generic Letter (GL) 90-06 (Toledo Edison Log Number 3267), dated June 25, 1990, provided the NRC staff's position resulting from the resolution of Generic Issue 70 (GI-70),
Pover-Operated Relief Valve (PORV) and Block Valve Reliability.
Generic Letter 90-06, also requested that Toledo Edison respond to
[
three NRC recommendations regarding GI-70 for the Davis-Besse Nuclear l
Power Station (DBNPS) Unit Number 1.
Toledo Edison (TE) provided its response by letter dated December 21, 1990 (TE Serial Number 1884). Toledo Edison was in general agreement i
with the NRC staff on two of the three recommendations, i.e.,
including j
the PORV and Block Valve within its Nuclear Quality Assurance Program, and including the "0RV and Block Valve within its American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Pump and f
Valve Testing Program and GL 89-10, Safety-Related Motor Operated Valve
[
Testing and Surveillance program.
However, TE took an alternative position with regards to the third l
recommendation regarding the incorporation of the model Technical Specifications on the PORV and Block Valve contained within GL 90-06.
Toledo Edison determined that the existing DBNPS Technical Specification contained appropriate requirements for the DBNPS's PORV i
and Block Valve design and operation, and that TE should not utilize
{
the NRC's generic model Technical Specifications. However, a proposed 1
change to the Technical Specification Bases was submitted to the NRC.by
~
I Letter Serial Number 2046, dated June 26, 1992, to add more discussion l
p g.!
of the functions of the PORV and Block Valve in the DBNPS system configuration.
,(j{.[
{
\\
Oweg Cortranies s
cteerd riectnc munna',ng 9312080219 931130
_j bedo Eoisan PDR ADOCK 05000346: M P
PDR-gj i
-i 1
- Docket Number 50-346 i
License Number NPF-3 Serial Number 2191 i
Page 2 1
The NRC's letter dated October 14, 1992 (Log Number 3850) responded to TE's submittal of December 21, 1990 (Serial Number 1884) and did not accept TE's position that the GL 90-06 model Technical Specifications
)
should not be incorporated. As a result of the NRC staff issuing I
similar letters to the other Babcock and Vilcox Owners Group (BV0G) utilities with operating plants, a BV0G initiative was formed with TE's
{
participation as described in TE's Letter Serial Number 2102, dated i
December 15, 1992, to the NRC. A telephone conference call was held between the NRC staff and BV0G representatives on December 17, 1992, and, as requested by the NRC staff during the conference call, a BV0G.
letter (Number OG-1128), dated January 18, 1993, was submitted to the NRC providing justification for the BV0G's position that the model l
Technical Specifications are inappropriate.
In addition to the BV0G letter, TE on its own initiative, submitted additional detailed technical and cost-benefit information to the NRC by letter dated i
Hay 26,1993, (Serial Number 2128), that further justified TE's l
position that the existing Technical Specifications, rather than those recommended by the GL 90-06 model Technical Specifications, are more appropriate to the DBNPS system design and operation.
As a result of learning in July 1993, that the NRC staff vas considering regulatory action against the BV0G plants that would require the incorporation of the GL 90 06 model Technical Specifications, TE requested a meeting with the NRC staff. The purpose of the meeting was for TE to present its position, initiate a dialogue l
vith the NRC technical reviewers, and address any questions. Toledo Edison met with the NRC staff on July 29, 1993, as documented by NRC correspondence dated August 3, 1993 (Log Number 4043).
Although the
.NRC staff concurred with IS's concerns on the inappropriateness of shutdown commencement times of one or two hours as required by the model Technical Specifications, the NRC staff was not receptive to TE's position that additional requirements to the existing DBNPS Technical j
Specifications were inappropriate.
.l l
As discussed above and shown in the attached chronology, TE has made a good faith effort to resolve the GL 90-06 recommendations in a thorough i
and timely manner. To facilitate the timely resolution of the GL 90-06 recommendations, TE agrees to submit a proposed License Amendment to the NRC to incorporate Technical Specifications on the PORV and Block Valve based upon the model Technical Specifications in GL 90-06 and the 3
July 29, 1993, meeting with the NRC staff. This proposed License j
Amendment has been scheduled for submittal to the NRC by March 31, j
1994. This submittal vill also request withdrawal of the proposed Technical Specification Bases change submitted to the NRC by Toledo Edison letter Serial Number 2046, dated June 26, 1992.
?
l i
i
i
" Docket Number 50-346 License Number NPF-3 Serial Number 2191 Page 3 Should you have questions concerning this matter, please contact Mr. V.lliam T. O'Connor, Manager - Regulatory Affairs at (419) 249-2366.
i i
Very truly yours,
'I y
t,,
c1 ww i
~
DRV/amb Attachments cc:
J. N. H,nnon, NRC/NRR Project Director PD-III-3 J. B. ;bpkins, NRC/NRR DB-1 Senior Project Manager J. B. Martin, Regional Administrator, NRC Region III S. Stasek, NRC Senior Resident Inspector Utility Radiological Safety Board j
i 1
i i
I I
i i
.j
9 I
Docket Number 50-346 License Number NPF-3 l
Serial Number 2191 l
i RESPONSE TO GENERIC LETTER 90-06 FOR DAVIS-BESSE NUCLEAR POWER STATION UNIT NUMBER 1 This letter is submitted pursuant to 10CFR50.54(f).
Enclosed is Toledo Edison's additional response (letter Serial Number 2191) to the NRC's letter dated June 25, 1990, regarding Generic Letter 90-06, Resolution l
of Generic Issue 70, " Power Operated Relief Valve and Block _ Valve Reliability," and Generic Issue 94, " Additional Low-Temperature Overpressure Protection for Light-Vater Reactors."
j l
For:
L. F. Storz, Vice President - Nuclear By:
C' l
G. M. G1 ss,Tirector - Engineering
.l Sworn and subscribed before me this 30tiday of Nov.,1993.
M//hd i
Notary PubMe, State of-Ohio l
EVELYN L DRESS l
tmEnnc,sT/.iE OFCHO i
I/y0=&1r.Ephsdry28,19N i
4 i
1
. I I
l
-c,
-n
+
i i
i i
{
' Docket Number 50-346 I
License Number NPF-3 Serial Number 2191 l-!
CHRONOLOGY f
0F j
TOLEDO EDISON'S EFFORTS TO RESOLVE l
GENERIC LETTER 90-06 RECOMMENDATIONS f
I Date Description j
3 June 25, 1990 NRC issues Generic Letter 90-06 with a response (Log No. 3267) due in 180 days.
j December 21, 1990 Toledo Edison provides its responst. to NRC (Serial No. 1884) regarding Generic Letter 90-06 and commits to l
Technical Specification Bases change.
I 2
December 18, 1991 Toledo' Edison submits to the NRC.its proposed (Serial No. 1970)
Technical Specification Bases Change to Add More Discussion relating to PORV and Block Valve functions.
June 26, 1992 Toledo Edison submits to the NRC'a revised (Serial No. 2046) proposed Technical Specification Bases Change.
i October 14, 1992 NRC issues letter stating Technical Specification (Log No. 3850) changes are required.
December 15, 1992 Toledo Edison submits letter.to the NRC (Serial No. 2102) describing formation of BV0G initiative to I
resolve this generic issue.
I December 17, 1992 Toledo Edison participates in NRC Staff /BV0G 6
representatives telephone conference call to i
resolve issue.
I January 18, 1993 BV0G, with Toledo Edison's participation, submits (0G-1128) letter to NRC regarding its position.
i{
May 26, 1993 Toledo Edison, on its ovn' initiative, provides (Serial 2128) more detailed information in support of its i
position.
i' July 29, 1993 At Toledo Edison's request, NRC staff meets with I
Toledo Edison to discuss this issue.
1 J
l l
...,