ML20136H080

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Forwards Rev 6 to 850910 Course of Action Providing Responses to NRC 851205 Request for Addl Info & Questions Re Valves AF-599,AF-608,MS-106 & Other safety-related Valves
ML20136H080
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 01/03/1986
From: Williams J
TOLEDO EDISON CO.
To: Harold Denton
Office of Nuclear Reactor Regulation
Shared Package
ML20136H086 List:
References
1231, NUDOCS 8601090237
Download: ML20136H080 (4)


Text

1 TOLEDO Docket No. 50-346 EDISON License No. NPF-3 JOEWILUAMS JR sn-vc. w a e Serial No. 1231 (419] P49 2300 M1912 G 5223 January 3, 1986 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, D.C.

20555

Dear Mr. Denton:

The enclosed materials comprise Revision 6 to the Davis-Besse Course of Action (COA) submitted to you on September 10, 1985 (Serial No. 1182).

This submittal provides Toledo Edison's responses to the NRC Request for Additional Information (nine questions) dated December 5, 1985 (Log

.No. 1879). This letter also provides Toledo Edison's responses to NRC

" Questions Relating To Davis-Besse Valves AF-599, AF-608 and MS-106 and Other Safety Related Valves", received via telecopy, dated December 13, 1985. This letter also provides the Davis-Besse Reactor Protection System Single Failure Analysis.

The NRC letter also requested that Toledo Edison provide written confirmation of information pertaining to the availability of reactor engineering expertise and Shift Technical Advisor (STA) participation in shift turn-overs. Written confirmation of these two subjects was previously provided in Toledo Edison letters dated December 9, 1985 (Serial No. 1227) and December 5, 1985 (Serial No. 1226), respectively.

Very truly yours, JA---

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PH (W. JOHNSTUN)

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8601090237 860103 PDR ADOCK 05000346 P

PDR THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO OHIO 43652

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g TABLE OF CONTENTS PAGE VOLUME 2 IV.

Appendices Appendix B.~1.1 - Charts of Organization.

1 Appendix B.2.1 - Reassignment of Performance Enhancement Program (PEP) and SALP Improvement Program Activities.

1

- Items which will be given high priority emphasis.

.2

- Items which will be completed as scheduled.

.4

- Items which will be integrated into the normal te course of business.

.6 Appendix C.I.1 - NUREG 1154, Table 5.1 Equipment Deficiencies

- Index of Findings, Corrective Actions and Generic Implications Reports.

.2 Appendix C.I.2 - Reliability of Safety Related Valves.

.1 Appendix C.I.3 - Reliability of the PORV.

1 Appendix C.1.4 - Confirmatory Testing.

.I Appendix C.2.1 - Actions to Improve Decay Heat Reliability

- Actions Relating to Auxiliary Feedwater Which Will Be Accomplished Prior To Startup.

.2

- Actions Relating to Auxiliary Feedwater System Which Are Longer Term.

.8

- Action Related to the Auxiliary Steam System.

.8

- Actions Related to the Motor-Driven Feedwater Pump.

.8 Appendix C.2.2 - Actions Related to SFRCS.

.1 Appendix C.2.3 - Probabilistic Evaluation of AFWS Reliability.

.1 Appendix C.3.1 - Transient Analysis Program Results.

.1 Appendix C.3.2 - Analyses of Event Effects on Equipment.

.1 Appendix C.3.3 - Single Failure Evaluations.

.1 16 Appendix C.4.1 - Actions Related to Operating Procedures and Training.

.1

- Overall Findings.

.2

- Specific Findings

.9

- Classification and Reporting of Events.

.24 iii Rev. 6 LY

TABLE OF CONTENTS PAGE Appendix C.4.2 - Effect of Physical Security Provisions on Operations.

1 Appendix C.S.1 - Specific Actions Related to Control Room Deficiencies.

1 Appendix C.7.1 - Selection of Systems for the System Review and Test Program.

1

- Development and Implementation of the Restart Test Program.

22

- System Review and Test Program Results.

29 Appendix III.1 - Actions to be Implemented by Toledo Edison.

1 Pre-Startup Commitment Tracking Report

  • Post-Startup
  • Summary (Level 2) Schedule of Activities to be Completed Prior to Restart Appendix III.2 - NRC Questions and TED Responses.

1

  • TED Response to NRC Maintenance
  • Safety Evaluation Report Regarding The Maintenance Improvement Program at Davis-Besse TED Responses to Request for Additional Information - 32 Questions 2
  • TED Responses to NRC Evaluation of Root Causes Findings Reports TED Responses to Request for Additional l

Information Concerning Maintenance Dated l

December 5, 1985 (Log No. 1879) l l6

  • TED Responses to Request for Additional l

Information - Questions Relating to Davis-Besse l

Valves AF 599, AF 608 and MS 106 and Other l

Safety Related Valves (rec'd via telecopy l

December 13, 1985) l iv Rev. 6 i

to ensure that they were effectively channelized and that no single failure could impair the performance of any other RPS channel in its own power division.

This reevaluation has concluded that a single failure in the RPS can not prevent the system from performing its safety function. Based on the above, it is determined that the Davis-Besse RPS, including system modi-fications addressed above, meets the single failure criteria of IEEE-279-1971.

The results of this analysis are provided in Attachment 3 to this Apu ndix.

16 Safety Features Actuation System A design analysis of the Davis-Besse SFAS was performed to determine the susceptibility of the system to single failures and to identify any set of conditions where, given a single random failure, the SFAS safety function may be compromised. The review encompassed all components actuated by the SFAS, sensors associated with SFAS, and associated electrical power trains. The results of this analysis are provided in Attachment I to this reponse.

The approach and methodology used for this analysis are consistent with those contained in Section 6 of IEEE 379-1977 and ANSI /ANS-58.9-1981.

Systems (both process as well as electrical power systems) and components which constitute the SFAS were reviewed in this analysis.

Where system operation was required for completion of an SFAS function, the components were reviewed at the system level and verification of system independence was made.

Appendix C.3.3 3

Rev. 6

)