ML20199B125

Discusses Info Submitted Re 120-day Response to GL 96-06, Assurance of Equipment Operabiltiy & Containment Integrity During DBA Conditions, Per Implementation of Mods.If Commitments Revised,Revised Response Should Be Submitted

ML20199B125
Person / Time
Site:	Davis Besse
Issue date:	11/05/1997
From:	Hansen A NRC (Affiliation Not Assigned)
To:	Jeffery Wood CENTERIOR ENERGY
References
GL-96-06, GL-96-6, TAC-M96803, NUDOCS 9711180224
Download: ML20199B125 (5)

Text

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,j NUCLEAR REGULATORY COMMISSION WASHINGTON D.C. 3066H001 -

'g*****,d November 5, 1997 Mr. John K. Wood Vice President - Nuclear, Davis-Besse Centerior Service Company c/o Toledo Edison Company Davis Besse Nuclear Power Station 5501 North State Route 2 Oak Hart >or, OH 43449-9760

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION, UNIT 1 - INFORMATION PERTAINING TO IMPLEMENTATION OF MODIFICATIONS ASSOCIATED WITH GENERIC LETTER 96-06, " ASSURANCE OF EQUIPMENT OPERABILITY AND CONTAINMENT INTEGRITY DURING DESIGN-BASIS ACCIDENT CONDITIONS" (TAC NO. M96803)

Dear Mr. Wood:

The staff issued Generic l.etter (GL) 96-06 on September 30,1996. The GL requested-licensees to determine: (1) if containment air cooler cooling water systemr. are susceptible to either waterhammer or two-phase flow conditions during postulated accident conditions; and (2) if piping systems that penetrate the containment are susceptible to thermal expansion of fluid so that overpressurization of piping could occur. By letter dated January 28,1997, as supplemented by letters dated February 28, July 28, and September 30,1997, you submitted your 120-day response to GL 96-06. The staff is currently performing a detailed review of your response.

Implementing corrective actions to resolve the GL 96-06 issues can have a significant impact on outage schedules and resources. Some licensees have indicated that it would be prudent to take more time to better understand the specific concems that have been identified in order to optimize whatever actions are needed and to assure that they do not ultimately result in a detriment to safety. Current issues and ongoing efforts that could influence a licensee's decision in planning corrective actions include:

1. Risk implications of installing relief valves to deal with the thermal overpressurization issue;

2. Feasibility of using the acceptance criteria contained in Appendix F to Section lil of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (AS'ME Code) for the permanent resolution of the GL 96-06 issues;

3. Ongoing tests by the Electric Power Research Institute to support a generic resolution of the overpressurization of piping issue; and EC FRE CBlTES CDPy ,

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4. . Questions regarding the staff's closure of Generic Safety lasue 150,."Overpressurization

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of Containment Penetrations."  ;

Risk insights and industry initiatives that are being considered or that may be proposed could -

also influence the course of action that licensees take to resolve the GL 96-06 issues.- ,

Licensees are responsible for assessing equipment operability, determining actions, and establishing schedules that are appropriate for resolving the specific conditions that have been identified. In determining the appropriate actions and schedules for resolving GL 96-06 issues, licensees should consider, for example, the continued validity of existing operability determinations, compensatory actions required to maintain operability, the safety significance associated with the specific nonconformances or degraded conditions that have been identified, risk insights, and the time required to complete any generic initiatives and/or plant-specific actions (for example, engineering evaluations, design change packages, material procurement, and equipment modification and installation).

Also, analytical solutions employing the permanent use of the acceptance criteria contained in the ASME Oode, Section lil, Appendix F (or other acceptance criteria) may present viable altematives to plant modifications and can be used where appropriate, justifed, and l evaluated in accordance with NRC roouirements such as 10 CFR 50.59, as applicable.

l Licensees may find the revised guidance contained in GL 91-18, "Information to Licensees Regarding Two NRC Inspection Manual Sections en Resolution of Degraded and Nonconforming Conditions and on Operability," Revision 1, dated October 8,1997, helpful in determir ing appropriate actions and schedules. Although adjustments in schedules may be warranted on the basis of these (and other) considerations, specific actions that have been defined and are clearly needed should not be delayed without suitable justification.

It is the staff's current position that licensees can use the ASME Code, Section lil, Appendix F, criteria for interim operability determinations for degraded and nonconforming piping and pipe supports until permanent actions have been identified and approved by the l

NRC (as applicable) for resolving the GL 96-06 issues. This guidance supplements the guidance provided by GL 91-18 for resolution of these issues.

In order to further facilitate resolution of the GL 96-06 issues, the NRC will participate in a '

public workshop on this topic later this fall. The workshop proceedings will be summarized by the NRC staff and made publicly available. The need for additional NRC guidance and generic communication will be considered upon completion of the workshop.

if you choose to revise your commitments for resolving the GL 96-06 issues, you should

. submit a revised response to the GL. Your revised response should include appropriate

. discussion of the considerations discussed above, the current resolution status, actions l-E t.

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.. JJohn K. Wood. Davis-Besse Nuclear Power Station, Unit 1 ,

Toledo Edison Company ,

cc:

Mary E. O'Reilly . .

Robert E. Owen, Chief

' Centerior Energy Corporation Bureau of Radiological Health 300 Madison Avenue Service Toledo, OH 43652.. Ohio Department of Health .

P.O. Box 118 James L. Freels . Columbus, OH 43266-0118-Manager - Regulatory Affairs Toledo Edison Company James R. Williams, Chief of Staff

- Davis-Besse Nuclear Power Station . Ohio Emergency Management Agency >

5501 North State - Route 2 2855 ^ West Dublin Granville Road Oak Harbor, OH 43449-g760 Columbus, OH - 43235-2206

' Gerald Chamoff, Esq. Donna Owens, Director

= Shaw, Pittman, Potts Ohio Department of Commerce and Trowbridge Division of Industrial Compliance 2300 N Street, NW. Bureau of Operations & Maintenance

- Washington, DC 20037 6606 Tussing Road c P.O. Box 4009 .

Regional Administrator Reynoldsburg, OH 43068-9009 U.S. Nuclear Regulatory Commission 801 Warrenville Road Ohio Environmental Protection Agency Lisle,IL 60523-4351 DERR.-Compliance Unit ATTN: Zack A. Clayton Robert B. Borsum P.O. Box 1049

. Babcock & Wilcox Columbus, OH 43266-0149 '

- Nuclear Power Generation Division 1700 Rockville Pike, Suite 525 -State of Ohio Rockville, MD 20852 Public Utilities Commission 180 East Broad Street Resident inspector . Columbus, OH 43266-0573 U.S. Nuclear Regulatory Commission 5503 North State Route 2 Attomey General Oak darbor, OH . 43449 - Department of Attomey

. 30 East Broad Street James H. Lash, Plant Manager- Columbus, OH 43216 Toledo Edison Company Davis-Besse Nuclear Power Station President, Board of County 5501 North State Route 2 Commissioner of Ottawa County Oak Harbor, OH. 4344g-9760 Port Clinton, OH 43252 Roy P. Lessy, Jr.

' Akin, Gump, Srauss, Hauer & Feld, LLP :

1333 New Hampshire Ave., NW., Ste. 400

. Washington, DC 20036 ,

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u remaining to be completed, and plans'being considered for final resolution of the GL' 96-06 issues.

Please contact me at 301415-1390 if you have any questions.  ;

Sincerely, Original sign-4 by: -

Allen G. Hansen, Project Manager Project Directorate lil-3 Division of Reactor Projects Ill/IV Office of Nuclear Reactor Regulation ,

Docket No. 50-346 cc: See next page DISTRIBUTION:

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. J. Wood remaining to be completed, and plans being considered for final resolution of the GL 96-04 issues.

Please contact me at 301415-1390 if you have any questions.

Sincerely, Original signed by:

Alien G. Hansen, Project Manager Project Directorate lll 3 Division of Reactor Projects Ill/lV Office of Nuclear Reactor Regulation Docket No. 50 346 cc: See next page DISTRIBUTION:

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