ML20141M333
| ML20141M333 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 08/06/1992 |
| From: | Shelton D CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1-993, NUDOCS 9208110350 | |
| Download: ML20141M333 (3) | |
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ENERGY Doneed C. Shelton 300 Madison Avenue'.
3 Vce President Nuclear Toledo, OH 436520001 Davis-Besse (419)249-2300 Docket Number 50-346 License Number NPF-3 s
L Serial Number-1-993 1
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August 6, 1992 i
li United States Nuclear Regulatory Commission-Document Control-Desk I
Washington, D. C.-
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Subj ect : Response to Inspection Report Number-50-346/920007 I-Gentlemen:
Toledo' Edison (TE) has received Inspection-Report 920007 (Log Number i
1-2700) dated July 7, 1992, and'provides the following response.
Deviation Updated Safety Analysis Report (USAR) section 9.5.4.2 5
92007-01:
states in part, that the fuel oil-storage system meets the l
requirements of ANSI N195-1976.
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Section 7.5 of ANSI N195 requires strainers to-be provided'in the fill line_of'each supply' tank.
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Co.trary to the above, strainers vere not= installed in the fill lines of the day-tanks.
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Section 8(d) of ANSI N195 requires high level: alarms to be provided~ for supply _ tanks.
_ Contrary to the above, high level alarms were not-L installed on the fuel: oil storage. tanks.
Response:- Reason for the Deviation These deviations' occurred because of an oversight in-the review and development of the Davis-Besse Nuclear Pover-Station _(DB-1) FSAR during the original licensing process-
. and the ' subsequent development of the LUSAR,. since the FSAR-4 and USAR do not adequately reflect the diesel fuel oill 3-storage system design or TE's commitments:vith regard to the j ]Q O 9"[
design. These deviations'do not present any safety concerns since the present system design adequately supports the
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operability of the-Emergency Diesel Generators.
'Operanno componies 9208110350 920806
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PDR ADOCK 0S000346 1
? Cieveland Electnc muminanng Toiect. Ectson :
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f Docket Numbar 50-346'
.t License Number-NPP-3 Serial Number 1-993 Pege 2 On January 28 and 29,-1976Ldiscussions between the NRC Staff and TE vere held to review the design of the.diecel oil storage ar.d transf er system. _ As-a result of these discussions, Amendment 33 (Revision 17) to the DB-1 Final Safety' Analysis Report (FSAR) was submitted-on March 1, 1976. Revision-17 of the FSAR states:
"The system meets ANSI proposed standard.N195, " Fuel Oil Systems for Standby Diesel Generators," vith the following exceptions.
a.
No overflow line is provided from the day tanks back to the storage tank.
b.
No level indication is provided'for the storage tanks. The level in these tanks vill be determined
. at specified intervals by sounding the tanks.
Between sounding intervals,-indication of any circumstance requiring investigation is provided by the high/lov level alarm.
c.
No pressure indicator is provided at the-discharge of the transfer pumps.- Properioperation of these pumps can be verified by observing the fill rate in the day tanks."
ANSI proposed standard N195 vas utilized as;the original design standard since ANSI N195-1976 was not published until April 12, 1976.
In December 1976, the NRC documerted its approval of the LB-1 design in Section 9.6.3 of the DB-1 Safety Evaluation Report (SER).
Amendment 33 to the DB-1 FSAR was specifically mentioned, however, TE's commitments i
to &NSI N195-1976 or ANSI proposed N195. vere not mentioned.
Design reviews in' support-of system modifications and USAR.
- revisions, developmeat of System Descriptions, and
-independent audits failed to identify these diacrepancies.
However, TE considers this to be-an isolated occurrence as TE believes existing administrative controls,: reviews and audits are sufficient to identify and correct deviations fro.a USAR commitments.
Corrective Steps Which-Have Been Taken and Results Achieved USAR Change Notice (UCN)92-061 has been initiated to rerlect the current system design and provide further clarification of TE's commitments with regard to the design of the diesel. fuel. oil storage and. transfer system..This UCN vill'be included in the next periodic update of the DB-1 USAR as r2 quired by 10 CFR 50.71(e).
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Docket Number 50-346 4
License Humber NIF-3 s
Serial Number 1-993 Page 3 Corrective Steps Vhich Mill Be'Taken To Avoid Further Deviations In addition to the USAR-revision noted above, TE vill provide for sufficient water and sediment filtration during tank filling. This vill be accomplished using a portable filtering skid.
Procedure revisions to-procedure DB-OP-06273 necessary to etfect this change vill be
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completed by September 1, 1992.
At was mentioned earlier,-TE believes this to be an isola'ed occurrence.
As such, existing administrative controls, periodic reviews and audits are sufficient to prevent future deviations from TE's commitments.
Date When Corrective Actions Vil) Be Complete All corrective actions associnted with the identified deviations vill be completed by July 1993, the scheduled submitted'date for the next revision of the DB-1 USAR.
Should you have any questions or require additional information, please contact Mr. Robert V. Schrauder, Manager - Nuclear Licensing, at (419) 249-2366.
Very truly yours, NKP/dle cc:
A. B. Davis,. Regional Administrator, NRC Region'III J. B. Hopkins, NRC Senior. Project' Manager V. Levis, DB-1 NRC Senior Resident Inspector I
Utility Radiological Safety Board l'
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