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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217P2061999-10-26026 October 1999 Forwards for First Energy Nuclear Operating Co Insp Rept 50-346/99-17 on 990928-1001.Insp Was Exam of Activities Conducted Under License Re Implementation of Physical Security Program.No Violations Identified ML20217N3851999-10-20020 October 1999 Forwards RAI Re Licensee 990521 Request for License Amend to Allow Irradiated Fuel to Be Stored in Cask Pit at Davis-Besse,Unit 1.Response Requested within 60 Days from Receipt of Ltr ML20217N2321999-10-15015 October 1999 Requests NRC Approval to Use Alternative to Requirements of 10CFR50.55a(f)(4)(ii).Licensee Requests Extension to Specified Schedule for Implementing Updates to IST Program ML20217G9201999-10-14014 October 1999 Discusses Utils Request for Approval of Quality Assurance Program Changes PY-CEI-NRR-2438, Informs That DBNPS & Pnpp Staffs Have Modified or Withdrawn Several of Positions Proposed within Re Request for Approval of Qap.Revised Positions Encl1999-10-14014 October 1999 Informs That DBNPS & Pnpp Staffs Have Modified or Withdrawn Several of Positions Proposed within Re Request for Approval of Qap.Revised Positions Encl ML20217F8371999-10-0808 October 1999 Forwards Insp Rept 50-346/99-10 on 990802-0913.One Violation Occurred Being Treated as NCV ML20217A5641999-09-30030 September 1999 Informs of Completion of mid-cycle PPR of Davis-Besse on 990901.Informs That NRC Plans to Conduct Addl Insps to Address Questions Raised by Issues Re Operator Errors & Failure to Commit to JOG Topical Rept on MOV Verification ML20212L0691999-09-30030 September 1999 Forwards,For Review & Comment,Copy of Preliminary ASP Analysis of Operational Condition Discovered at Unit 1 on 981014,as Reported in LER 346/98-011 ML20216J6701999-09-24024 September 1999 Forwards Post Examination Documentation for Written Operator Initial License Examination Administered at Davis-Besse Nuclear Power Station on 990920.Without Encls ML20212D3501999-09-21021 September 1999 Forward Copy of Final Accident Sequence Precursor Analysis of Operational Event at Plant,Unit 1 on 980624,reported in LER 346/98-006 05000346/LER-1998-001, Forwards Rev 1 for LER 1998-001,which Updates Corrective Actions & Revises Completion Date Re Implementation of Changes to Plant Emergency Operating Procedure.List of Commitments Attached1999-09-0909 September 1999 Forwards Rev 1 for LER 1998-001,which Updates Corrective Actions & Revises Completion Date Re Implementation of Changes to Plant Emergency Operating Procedure.List of Commitments Attached ML20216E5961999-09-0707 September 1999 Forwards Application for Amend to License NPF-3,revising Tech Specs 3/4.3.2.1,safety Features Actuation Sys Instrumentation & Associated Bases 3/4.3.1 & 3/4.3.2,reactor Protection Sys & Safety Sys Instrumentation ML20211P3001999-09-0707 September 1999 Forwards FEMA Transmitting FEMA Evaluation Rept for 990504 Emergency Preparedness Exercise at Davis-Besse Nuclear Power Plant.No Deficiencies Identified.One Area Requiring C/A & Two Planning Issues Identified ML20211K6681999-08-30030 August 1999 Forwards Copies of Certified Personal Qualification Statement - Licensee (NRC Form 398) for Operator Candidates Listed Below.Without Encls ML20211K6611999-08-30030 August 1999 Forwards Copies of Operator License Renewal Applications for Individuals Listed.Operators Have Successfully Completed Appropriate Operator Requalification Training Program at Dbnps.Without Encls ML20211K0951999-08-30030 August 1999 Forwards Request for Addl Info Re Fire & Seismic Analyses of IPEEE for Davis-Besse Nuclear Power Station,Unit 1. Response Requested within 60 Days ML20211H0201999-08-25025 August 1999 Forwards semi-annual FFD Rept for 990101-0630 for DBNPS, Unit 1,IAW 10CFR26.71(d) ML20211D1171999-08-20020 August 1999 Forwards Insp Rept 50-346/99-09 on 990623-0802.Violations Identified & Being Treated as Noncited Violations ML20211G3911999-08-20020 August 1999 Forwards Update to Estimated Info for Licensing Action Requests Through 010930,re Administrative Ltr 99-02, Operating Reactor Licensing Action Estimates PY-CEI-NRR-2411, Informs That Firstenergy Nuclear Operating Co Has Developed Corporate QA Program Manual for Davis-Besse Nuclear Power Station & Perry Nuclear Power Plant,As Discussed on 990318 Between Util & Nrc.Revised USAR Pages,Encl1999-08-19019 August 1999 Informs That Firstenergy Nuclear Operating Co Has Developed Corporate QA Program Manual for Davis-Besse Nuclear Power Station & Perry Nuclear Power Plant,As Discussed on 990318 Between Util & Nrc.Revised USAR Pages,Encl ML20211J9201999-08-13013 August 1999 Urges NRC to Find Funds for Stockpiling Radiation Pills for Residents Living Near Plant ML20211B0161999-08-13013 August 1999 Forwards SE Accepting Evaluation of Second 10-year Interval Inservice Insp Program Request for Relief Numbers RR-A16, RR-A17 & RR-B9 for Plant,Unit 1 ML20210T1061999-08-12012 August 1999 Forwards Preliminary NRC Forms 398 & 396 for Listed Candidates,Per Operator License Exam Scheduled for Week of 990913.Encl Withheld ML20210S6071999-08-11011 August 1999 Provides Final Response to NRC RAI Re GL 98-01, Y2K Readiness of Computer Systems at Npps ML20210P8051999-08-0909 August 1999 Forwards Insp Rept 50-346/99-15 on 990712-16.No Violations Noted.However,Several Deficiencies Were Identified with Implementation of Remp,Which Collectively Indicated Need for Improved Oversight of Program IR 05000346/19980211999-08-0606 August 1999 Refers to NRC Insp Rept 50-346/98-21 Conducted on 980901- 990513 & Forwards Nov.Two Violations Identified Involving Failure to Maintain Design of Valve & Inadequate C/A for Degraded Condition Cited in Encl NOV 05000346/LER-1998-009, Forwards LER 98-009-01,IAW 10CFR50.73(a)(2)(ii)(B). Commitments Made by Util Are Encl1999-08-0606 August 1999 Forwards LER 98-009-01,IAW 10CFR50.73(a)(2)(ii)(B). Commitments Made by Util Are Encl ML20210H6101999-07-30030 July 1999 Informs That Region III Received Rev 21 to Various Portions of Davis-Besse Nuclear Power Station Emergency Plan.Revision Was Submitted Under Provisions of 10CFR50.54(q) in Apr 1999 ML20210H0491999-07-28028 July 1999 Forwards Application for Amend to License NPF-3,revising TS 3/4.7.5.1, Ultimate Heat Sink, to Allow Plant Operation in Modes 1-4 with Water Temp Less than or Equal to 90 F ML20210G5521999-07-28028 July 1999 Provides Addl Response to 980923 OL Licensing Exam Rept 50-346/98-301 Re OL Exam Administered in Aug 1998.Results of Root Cause Investigation & Corrective Actions,Discussed ML20210G3831999-07-27027 July 1999 Forwards Application for Amend to NPF-3,changing TSs 6.4, Training, 6.5.2.8, Audits, 6.10, Record Retention, 6.14, Process Control Program & 6.15, Odcm ML20211P3071999-07-26026 July 1999 Forwards Final Rept for 990504 Biennial Radiological Emergency Preparedness Exercise for David-Besse Power Station.No Deficiencies Identified for Any Jurisdiction During Exercise ML20210G4391999-07-26026 July 1999 Forwards Application for Amend to License NPF-3,revising Tech Specs 3/4.3.2.1, Safety Features Actuation Sys Instrumentation, & Associated Bases 3/4.3.1 & 3/4.3.2, Reactor Protection Sys & Safety Sys Instrumentation ML20210G7151999-07-26026 July 1999 Forwards Application for Amend to License NPF-3,revising TSs 3/4.3.3.1, Radiation Monitoring Instrumentation, 3/4.3.3.2, Instrument - Incore Detectors & 3/4.3.3.9, Instrumentation - Waste Gas Sys Oxygen Monitor ML20210G5151999-07-26026 July 1999 Forwards Application for Amend to License NPF-3,revising Tech Specs for Implementation of 10CFR50,App J,Option B for Type B & C Containment Leakage Rate Testing ML20210G3211999-07-26026 July 1999 Forwards Written OL Exam & Supporting Matl for Exam to Be Administered at DBNPS During Week of 990913.Listed Encls Withheld from Public Disclosure Until After Exam Complete ML20210C4381999-07-20020 July 1999 Forwards Insp Rept 50-346/99-08 on 990513-0622.Unidentified RCS Leak Approached TS Limit of 1 Gallon Per Minute Prior to Recently Completed Maint Outage.Three Violations of NRC Requirements Identified & Being Treated as NCVs ML20209G3681999-07-15015 July 1999 Advises That Info Submitted in & 990519 Affidavit Re Design & Licensing Rept,Davis-Besse,Unit 1 Cask Pit Rack Installation Project,Holtec Intl, HI-981933,marked Proprietary,Will Be Withheld from Public Disclosure ML20207H6401999-07-0909 July 1999 Discusses Closure of TAC MA0540 Re Util Responses to RAI on GL 92-01,rev 1,suppl 1, Rv Structural Integrity. Staff Has Revised Info in Rvid & Releasing It as Rvid Version 2 ML20209D1341999-07-0808 July 1999 Forwards Notice of Withdrawal of Application for Amend to Operating License.Proposed Change Would Have Modified Facility TSs Pertaining to Allowable as-found Pressure Lift Setting Tolerance of Two Pressurizer Code Safety Valves 05000346/LER-1998-012, Forwards LER 98-012-01,which Is Being Submitted to Provide Addl Info Re 981018 Occurrence.Commitment List Attached1999-07-0707 July 1999 Forwards LER 98-012-01,which Is Being Submitted to Provide Addl Info Re 981018 Occurrence.Commitment List Attached ML20209C3981999-07-0101 July 1999 Responds to NRC Re Violations Noted in Insp Rept 50-346/98-21.Corrective Actions:Developed Rev to Boric Acid Control Program & Work Process Guideline on Plant Leakage ML20209B5821999-06-24024 June 1999 Provides Justification for Rev to Completion Date for One of Insp follow-up Items Cited in Insp Rept 50-346/98-03, Designated as Inspector follow-up Item 50-346/97-201-10 ML20196G1251999-06-23023 June 1999 Responds to NRC RAI Re GL 98-01, Y2K Readiness of Computer Sys at Nuclear Power Plants ML20196E5321999-06-17017 June 1999 Forwards Addl Info Re Relief Request RR-A16 to Support NRC Approval of Relief Request ML20195K2751999-06-16016 June 1999 Forwards Safety Evaluation Re GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves ML20196A6601999-06-16016 June 1999 Forwards Master Decommissioning Trust Agreements Revised After 1990 for Ohio Edison Co,Cleveland Electric Illuminating Co,Toledo Edison Co & Pennsylvania Power Co Re Bvnps,Units 1 & 2,DBNPS,Unit 1 & Perry Unit 1 ML20195F9071999-06-10010 June 1999 Forwards Application for Amend to NPF-3,changing Tech Specs 3/4.6.4.4, Hydrogen Purge Sys, TS 3/4.6.5.1, Shield Bldg Emergency Ventilation Sys & TS 3/4.7.6.1, Crevs ML20195F8851999-06-0707 June 1999 Withdraws 950929 License Amend Application,Proposing Mod to Allowable as-found Pressure Lift Setting Tolerance of Two Pressurizer Code Safety Valves ML20207G0751999-06-0707 June 1999 Forwards Insp Rept 50-346/99-04 on 990323-0513.Violations Occurred & Being Treated as non-cited Violations,Consistent with App C of Enforcement Policy 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217N2321999-10-15015 October 1999 Requests NRC Approval to Use Alternative to Requirements of 10CFR50.55a(f)(4)(ii).Licensee Requests Extension to Specified Schedule for Implementing Updates to IST Program PY-CEI-NRR-2438, Informs That DBNPS & Pnpp Staffs Have Modified or Withdrawn Several of Positions Proposed within Re Request for Approval of Qap.Revised Positions Encl1999-10-14014 October 1999 Informs That DBNPS & Pnpp Staffs Have Modified or Withdrawn Several of Positions Proposed within Re Request for Approval of Qap.Revised Positions Encl ML20216J6701999-09-24024 September 1999 Forwards Post Examination Documentation for Written Operator Initial License Examination Administered at Davis-Besse Nuclear Power Station on 990920.Without Encls 05000346/LER-1998-001, Forwards Rev 1 for LER 1998-001,which Updates Corrective Actions & Revises Completion Date Re Implementation of Changes to Plant Emergency Operating Procedure.List of Commitments Attached1999-09-0909 September 1999 Forwards Rev 1 for LER 1998-001,which Updates Corrective Actions & Revises Completion Date Re Implementation of Changes to Plant Emergency Operating Procedure.List of Commitments Attached ML20216E5961999-09-0707 September 1999 Forwards Application for Amend to License NPF-3,revising Tech Specs 3/4.3.2.1,safety Features Actuation Sys Instrumentation & Associated Bases 3/4.3.1 & 3/4.3.2,reactor Protection Sys & Safety Sys Instrumentation ML20211K6611999-08-30030 August 1999 Forwards Copies of Operator License Renewal Applications for Individuals Listed.Operators Have Successfully Completed Appropriate Operator Requalification Training Program at Dbnps.Without Encls ML20211K6681999-08-30030 August 1999 Forwards Copies of Certified Personal Qualification Statement - Licensee (NRC Form 398) for Operator Candidates Listed Below.Without Encls ML20211H0201999-08-25025 August 1999 Forwards semi-annual FFD Rept for 990101-0630 for DBNPS, Unit 1,IAW 10CFR26.71(d) ML20211G3911999-08-20020 August 1999 Forwards Update to Estimated Info for Licensing Action Requests Through 010930,re Administrative Ltr 99-02, Operating Reactor Licensing Action Estimates PY-CEI-NRR-2411, Informs That Firstenergy Nuclear Operating Co Has Developed Corporate QA Program Manual for Davis-Besse Nuclear Power Station & Perry Nuclear Power Plant,As Discussed on 990318 Between Util & Nrc.Revised USAR Pages,Encl1999-08-19019 August 1999 Informs That Firstenergy Nuclear Operating Co Has Developed Corporate QA Program Manual for Davis-Besse Nuclear Power Station & Perry Nuclear Power Plant,As Discussed on 990318 Between Util & Nrc.Revised USAR Pages,Encl ML20211J9201999-08-13013 August 1999 Urges NRC to Find Funds for Stockpiling Radiation Pills for Residents Living Near Plant ML20210T1061999-08-12012 August 1999 Forwards Preliminary NRC Forms 398 & 396 for Listed Candidates,Per Operator License Exam Scheduled for Week of 990913.Encl Withheld ML20210S6071999-08-11011 August 1999 Provides Final Response to NRC RAI Re GL 98-01, Y2K Readiness of Computer Systems at Npps 05000346/LER-1998-009, Forwards LER 98-009-01,IAW 10CFR50.73(a)(2)(ii)(B). Commitments Made by Util Are Encl1999-08-0606 August 1999 Forwards LER 98-009-01,IAW 10CFR50.73(a)(2)(ii)(B). Commitments Made by Util Are Encl ML20210G5521999-07-28028 July 1999 Provides Addl Response to 980923 OL Licensing Exam Rept 50-346/98-301 Re OL Exam Administered in Aug 1998.Results of Root Cause Investigation & Corrective Actions,Discussed ML20210H0491999-07-28028 July 1999 Forwards Application for Amend to License NPF-3,revising TS 3/4.7.5.1, Ultimate Heat Sink, to Allow Plant Operation in Modes 1-4 with Water Temp Less than or Equal to 90 F ML20210G3831999-07-27027 July 1999 Forwards Application for Amend to NPF-3,changing TSs 6.4, Training, 6.5.2.8, Audits, 6.10, Record Retention, 6.14, Process Control Program & 6.15, Odcm ML20210G4391999-07-26026 July 1999 Forwards Application for Amend to License NPF-3,revising Tech Specs 3/4.3.2.1, Safety Features Actuation Sys Instrumentation, & Associated Bases 3/4.3.1 & 3/4.3.2, Reactor Protection Sys & Safety Sys Instrumentation ML20210G7151999-07-26026 July 1999 Forwards Application for Amend to License NPF-3,revising TSs 3/4.3.3.1, Radiation Monitoring Instrumentation, 3/4.3.3.2, Instrument - Incore Detectors & 3/4.3.3.9, Instrumentation - Waste Gas Sys Oxygen Monitor ML20210G5151999-07-26026 July 1999 Forwards Application for Amend to License NPF-3,revising Tech Specs for Implementation of 10CFR50,App J,Option B for Type B & C Containment Leakage Rate Testing ML20211P3071999-07-26026 July 1999 Forwards Final Rept for 990504 Biennial Radiological Emergency Preparedness Exercise for David-Besse Power Station.No Deficiencies Identified for Any Jurisdiction During Exercise ML20210G3211999-07-26026 July 1999 Forwards Written OL Exam & Supporting Matl for Exam to Be Administered at DBNPS During Week of 990913.Listed Encls Withheld from Public Disclosure Until After Exam Complete 05000346/LER-1998-012, Forwards LER 98-012-01,which Is Being Submitted to Provide Addl Info Re 981018 Occurrence.Commitment List Attached1999-07-0707 July 1999 Forwards LER 98-012-01,which Is Being Submitted to Provide Addl Info Re 981018 Occurrence.Commitment List Attached ML20209C3981999-07-0101 July 1999 Responds to NRC Re Violations Noted in Insp Rept 50-346/98-21.Corrective Actions:Developed Rev to Boric Acid Control Program & Work Process Guideline on Plant Leakage ML20209B5821999-06-24024 June 1999 Provides Justification for Rev to Completion Date for One of Insp follow-up Items Cited in Insp Rept 50-346/98-03, Designated as Inspector follow-up Item 50-346/97-201-10 ML20196G1251999-06-23023 June 1999 Responds to NRC RAI Re GL 98-01, Y2K Readiness of Computer Sys at Nuclear Power Plants ML20196E5321999-06-17017 June 1999 Forwards Addl Info Re Relief Request RR-A16 to Support NRC Approval of Relief Request ML20196A6601999-06-16016 June 1999 Forwards Master Decommissioning Trust Agreements Revised After 1990 for Ohio Edison Co,Cleveland Electric Illuminating Co,Toledo Edison Co & Pennsylvania Power Co Re Bvnps,Units 1 & 2,DBNPS,Unit 1 & Perry Unit 1 ML20195F9071999-06-10010 June 1999 Forwards Application for Amend to NPF-3,changing Tech Specs 3/4.6.4.4, Hydrogen Purge Sys, TS 3/4.6.5.1, Shield Bldg Emergency Ventilation Sys & TS 3/4.7.6.1, Crevs ML20195F8851999-06-0707 June 1999 Withdraws 950929 License Amend Application,Proposing Mod to Allowable as-found Pressure Lift Setting Tolerance of Two Pressurizer Code Safety Valves ML20207F4231999-06-0202 June 1999 Forwards Rev 1 to DBNPS Emergency Preparedness Evaluated Exercise Manual 990504, IAW 10CFR50.4.NRC Evaluated Exercise Has Been Rescheduled for 991208,since NRC Did Not Evaluate 990504 Exercise ML20207E9561999-05-28028 May 1999 Forwards Update to NRC AL 98-03,re Estimated Info for Licensing Activities Through Sept 30,2000 ML20207E2521999-05-28028 May 1999 Forwards Rev 18,App A,Change 1 to Davis-Besse Nuclear Power Station,Unit 1,industrial Security Plan IAW Provisions of 10CFR50.54(p).Encl Withheld,Per 10CFR73.21 ML20207E7801999-05-21021 May 1999 Forwards Application for Amend to License NPF-3,allowing Use of Expanded Spent Fuel Storage Capacity.Proprietary & non- Proprietary Version of Rev 2 to HI-981933 Re Cask Pit Rack Installation Project,Encl.Proprietary Info Withheld ML20206N0231999-05-0606 May 1999 Forwards License Renewal Applications for Davis-Besse Nuclear Power Station,Unit 1 for ML Klein,Cn Steenbergen & CS Strumsky.Without Encls ML20206D2421999-04-28028 April 1999 Forwards Combined Annual Radiological Environ Operating Rept & Radiological Effluent Release Rept for 1998. Rev 11, Change 1 to ODCM & 1998 Radiological Environ Monitoring Program Sample Analysis Results Also Encl PY-CEI-NRR-2382, Forwards 1998 Annual Rept for Firstenergy Corp, for Perry Nuclear Power Plant & Davis-Besse Nuclear Power Station.Form 10-K Annual Rept to Us Securities & Exchange Commission for FY98 Also Encl1999-04-21021 April 1999 Forwards 1998 Annual Rept for Firstenergy Corp, for Perry Nuclear Power Plant & Davis-Besse Nuclear Power Station.Form 10-K Annual Rept to Us Securities & Exchange Commission for FY98 Also Encl ML20206B8831999-04-17017 April 1999 Forwards 1634 Repts Re Results of Monitoring Provided to Individuals at Davis-Besse Nuclear Power Station During 1998,per 10CFR20.2206.Without Repts ML20205K5641999-04-0707 April 1999 Forwards Response to NRC 980415 RAI Re GL 96-06, Assurance of Equipment Operability & Ci During Design-Basis Accident Conditions. Rept FAI/98-126, Waterhammer Phenomena in Containment Air Cooler Swss, Encl ML20205K3871999-04-0707 April 1999 Forwards Copy of Application of Ceic,Oec,Ppc & Teco to FERC, Proposing to Transfer Jurisdictional Transmission Facilities of Firstenergy Operating Companies to American Transmission Sys,Inc.With One Oversize Drawing ML20205J1171999-03-29029 March 1999 Forwards Rev 1 to BAW-2325, Response to RAI Re RPV Integrity, Per GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity. Rev Includes Corrected Values in Calculations PY-CEI-NRR-2377, Submits Decommissioning Repts for Bvps,Units 1 & 2,Davis- Besse Nuclear Power Station,Unit 1 & Perry Nuclear Power Plant,Unit 1,per 10CFR50.75(f)(1)1999-03-29029 March 1999 Submits Decommissioning Repts for Bvps,Units 1 & 2,Davis- Besse Nuclear Power Station,Unit 1 & Perry Nuclear Power Plant,Unit 1,per 10CFR50.75(f)(1) ML20205F5961999-03-27027 March 1999 Forwards Comments on Preliminary Accident Sequence Percursor (ASP) Analysis of 980624 Operational Event at Dbnps,Unit 1, as Transmitted by NRC Ltr ML20205D4791999-03-26026 March 1999 Forwards Rept Submitting Results of SG Tube ISI Conducted in Apr 1998.Rept Includes Description of Number & Extent of Tubes Inspected,Location & Percent wall-thickness Penetration for Each Indication of Imperfection ML20205L2031999-03-26026 March 1999 Submits Correction to Dose History of Tj Chambers.Dose Records During 1980-1997 Were Incorrectly Recorded Using Wrong Social Security Number.Nrc Form 5 Not Encl ML20205C7371999-03-25025 March 1999 Certifies That Dbnps,Unit 1,plant-referenced Simulator Continues to Meet Requirements of 10CFR55.45(b) for Simulator Facility Consisting Solely of plant-referenced Simulator.Acceptance Test Program & Test Schedule,Encl ML20205E3551999-03-19019 March 1999 Requests That Proposed Changes to TS 6.8.4.d.2 & TS 6.8.4.d.7 Be Withdrawn from LAR Previously Submitted to NRC ML20204J6361999-03-17017 March 1999 Forwards Firstenergy Corp Annual Rept for 1998 & 1999 Internal Cash Flow Projection as Evidence of Util Guarantee of Retrospective Premiums Which May Be Served Against Facilities PY-CEI-NRR-2375, Forwards List That Details Util Insurers,Policy Numbers & Coverage Limits for Two Power Plants,Per Requirements of 10CFR50.54(w)(3) Re Reporting of Property Insurance Coverage1999-03-15015 March 1999 Forwards List That Details Util Insurers,Policy Numbers & Coverage Limits for Two Power Plants,Per Requirements of 10CFR50.54(w)(3) Re Reporting of Property Insurance Coverage ML20204E6821999-03-12012 March 1999 Requests That Listed Changes Be Made to NRC Document Svc List for Davis-Besse Nuclear Power Station,Unit 1 1999-09-09
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Davis-Besse Nuclear Power Staten
'l DE Y 5501 North State Route 2 m Oak Harbor. Ohio 43449 4760 Quy G. Compbell 4193214588 Vee President - Nuclear Fax:419321-8337 Docket Number 50-346 License Number NPF-3 Serial Number 1-1188 July 1, 1999 United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555
Subject:
Response to Inspection Report Number 50-346/98021 (DRP)
Ladies and Gentlemen:
The FirstEnergy Nuclear Operating Company (FENOC) is in receipt of Davis-Besse Special Inspection Report (IR) Number 50-346/98021 (DRP) [NRC letter number EA 99-138, FENOC Log Number 5487], dated June 4,1999. The cover letter transmitting the IR identifies two apparent violations and provides FENOC the opportunity to respond, request an enforcement conference, or inform the NRC that information in the IR and Licensee Event Report (LER)98-009 adequately addresses the issues.
The FENOC has reviewed the IR and agrees with the facts as stated. Further, LER 98-009 will be supplemented to reflect updated information collected during the recent mid-cycle outage inspections and from the finite element analysis performed for Pressurizer Spray valve RC-2, all of which has been identified in the IR. We believe these documents contain the information specified on page 2 of the IR 98-021 cover letter, and accordingly, there is no need for a predecisional enforcement conference or an additional response to provide the specified information. However, we would like to provide some clarification of the evaluations performed during the degraded condition identification and our perspective on the classification of the apparent violations.
As clarification, a brief discussion of the operability evaluations that were performed during the time from initial discovery eithe first missing body to bonnet nut from the valve RC-2 up to the completion of the vendor evaluation of the most degraded condition is herein provided. Upon l/
discovery of the first missing body to bonne-t nut from the valve RC-2 on September 1,1998, the Control Room Shift Supervisor requested (via telephone conversation) a preliminary evaluation by Davis-Besse Nuclear Power Station (DBNPS) Design Engineering of the integrity of the valve {0 as a pressure retaining component. The preliminary verbal engineering evaluation addressed seismic, thrust and pressure Icads, and determined the function of the valve to maintain its 9907090282 990701 PDR ADOCK 05000346 G PDR
Docket Number 50-346
. License Number NPF-3
.' Serial' Number 1-1188 Page 2
' integrity would not be affected by one missing body to bonnet nut. This preliminary evaluation provided the Shift Supervisor with reasonable assurance of safety,in accordance with the guidance of NRC Generic Letter (GL) 91-18, Revision 1 (dated October 8,1997) and its attached NRC Inspection Manual, Part 9900: Technical Guidance," Resolution of Degraded and Nonconforming Conditions," and permitted continued operation. A fomial evaluation, with valve manufacturer concurrence, was provided on the next day (again in accordance with the guidance of GL 91-18) which confimied the preliminary evaluation conclusion. At the time the second body to bonnet nut was found to be missing on September 9,1998, the valve was immediately returned to the previously evaluated one body to bonnet nut missing configuration when the first missing nut was replaced, and the Shift Supervisor was apprised of the as-found body to bonnet nut condition. (The second missing nut was replaced on September 10,1999, but was not fully engaged as an effective fastener due to unrecognized thread interference with a previously corroded body to bonnet nut.) Since the body to bonnet nut configuration had been returned to an evaluated condition, there was no current operability issue; however, an evaluation of past operability with two body to bonnet nuts missing was requested. This engineering evaluation was completed, and determined that the valve bolted connection threads would have yielded causing a failure of the body to bonnet joint to maintain its integrity under maximum design pressure condition concunent with seismic loading with two body to bonnet nuts missing.
(The engineering evaluation determined that, absent seismic loading, the valve integrity would l have been maintained for all pressure conditions.) This previously existing condition was reported, as required by 10 CFR 50.72(b)(1)(ii)(B), on September 18,1998. On October 16, 1999, it was found that the body to bonnet nut installed on September 10,1999, was not fully engaged and another degraded nut was discovered to be degraded. Subsequently, on October 17, 1998, all eight body to bonnet nuts were replaced. This resulted in evaluation of this degraded cordgaration for past operability. As stated in LER 98-009, an evaluation of RC-2 in the configuration of having two missing body to bonnet nuts and a third body to bonnet nut in a degraded condition would be performed to assess past operability and safety significance. At no time did the DBNPS knowingly operate or perform any evaluation to operate in a configuration with more than.one body to bonnet nur missing. Upon discovery of each degraded configuration, the action was taken to return to an evaluated and acceptable configuration; i.e., no more than one body to bonnet nut degraded. The detailed evaluation, performed by the valve manufacturer, that determined the valve would not have compromised the integrity of the Reactor Coolant System Pressure Boundary (RCPB) was not performed to allow continued operation in these degraded conditions, but has been used for past operability and safety significance determinations only. The results of the detailed evaluation, which are also noted in IR 98-021, indicated that the valve would have been functional under all design basis conditions, and, therefore, there is no safety significance associated with the degraded configurations of valve RC-2. The DBNPS complied with industry guidance for degraded and nonconforming conditions and does not believe that example C.2(b) of the General Statement of Policy and Procedures for NRC Enforcement Action (NUREG-1600, Rev.1), Appendix B: Supplements - Enforcement Samples, Supplement I- Reactor Operations, is appropriate for consideration in these escalated enforcement actions.
Irrespective of the foregoing, we fully appreciate the importance of the issues raised by the t apparent violations and are committed to effective, comprehensive corrective action. However,
Docket Number 50-346
. License Number NPF-3
.' Serial Number 1-1188 Page 3 we do not believe that the apparent violations are indicative of recurring problems with the material control or the corrective action programs (example C.7 of Appendix B, Supplement I to NUREG-1600, Rev.1). A focused extent of condition walkdown conducted during the recent mid-cycle outage substantiated that the material control issue was isolated. Overall condition identification and resolution evaluations, as confirmed by IR 98-011 (dated September 3,1998) and internal assessments, corroborate the corrective action program was and is effective. The collective lack of sensitivity during maintenance and corrective action for the component bolting represented an unacceptable, but isolated, breakdown in the control of licensed activities to maintain the RCPB. Further, the extensive evaluation performed to determine the effect of the degradation as it related to the valve, and thereby, the RCPB integrity, shows there was ultimately no safety significance (i.e., the integrity of the RCPB would have been maintained during all design basis conditions); however, the regulatory significance remains. Nevertheless, based on the information contained in NRC Enforcement Guidance Document 98-009, "Use of Regulatory Significance for Escalated Enforcement," dated November 25,1998, regulatory significance in the absence of safety, safeguards, or environmental consequence in and of itself does not constitute an escalated enforcement action. Because the failure to properly implement the material control and corrective actions programs were isolated, and the integrity of the RCPB would have been maintained for all faulted conditions, there is no safety, safeguards, or environmental consequence associated with the apparent violations. For these reasons, we suggest escalated enforcement action is unnecessary.
It should be noted that none of the above discussion should be construed to mean that we are minimizing our awareness of the significance of these issues. We understand the concerns as presented and agree that conservative and consistent performance and decision making in each area of plant operation is necessary to ensure public health and safety. As noted in the IR, following the determination that boric acid corrosion was the most likely cause for the missing nuts on the body to bonnet bolting of valve RC-2, a thorough evaluation of the issue was conducted and extensive, effective corrective actions were developed. Greater sensitivity to the effects of boric acid corrosion on plant equipment were noted in the IR and integration of these ,
insights into plant processes and operational philosophy are being institutionalized by: !
- 1) developing a revision to the Boric Acid control program and the Work Process Guideline on !
plant leakage, including the benchmarking of industry standards and practices, to reflect higher standards for monitoring, evaluating, documenting and controlling boric acid leakage; and,
- 2) providing additional training to management and the technical staff to address the technical issues of boric acid control, the DBNPS Boric Acid Control Program and requirements, lessons learned from the RC-2 event, and industry experience. The DBNPS recognition that some plant maintenance practices required improvement, increased oversight, and additional assessment was also noted in the IR. We will continue to stress the use of a questioning attitude and conservative decision making in managing and resolving identified issues.
It should be further noted that additional corrective actions are presently being conducted or pursued in the area of management oversight, personnel training related to decision making at each level of management, and expectations of personnel in their tolerance of potentially degraded conditions. Initial communication in these areas has been completed, while others are being developed and will be ongoing.
i Docket Number 50-346
, License Number NPF-3
.' Serial Number 1-1188 Page 4 If you should have any questions or require additional information, please contact James L.
Freels, Manager- Regulatory Affairs at (419) 321-8466.
Very truly yours, W 3 h RMC/s Enclosure cc: J. E. Dyer, Regional Administrator, NRC Region UI K. S. Zellers, DB-1 NRC Senior Resident Inspector S. N. Bailey, DB-1 NRC/NRR Project Manager Utility Radiological Safety Board i
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. Docket Number 50-346
- . ' ' Lice'nse NuImber NPF-3 Serial 1-1188 Enclosure COMMITMENT LIST The following list identifies those actions committed to by the Davis-Besse Nuclear Power Station in this document. Any other actions discussed in the submittal represent intended or f
planned actions by Davis-Besse. They are described only as information and are not regulatory I commitments. Please notify the Manager- Regulatory Affairs (419-321-8466) at Davis-Besse of any questions regarding this document or associated regulatory commitments. ,
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COMMITMENTS DUE DATE LER 98-009 will be supplemented to reflect updated information 08/01/1999 collected during the recent mid-cycle outage inspections and from the
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finite element analysis performed for Pressurizer Spray valve RC-2 l I
Greater sensitivity to the effects of boric acid corrosion on plant 09/28/1999 l equipment were noted in the IR and integration of these insights into plant processes and operational philosophy are being institutionalized by '
developing a revision to the Boric Acid control program and the Work Process Guideline on plant leakage, including the benchmarking of industry standards and practices, to reflect higher standards for monitoring, evaluating, documenting and controlling boric acid leakage, Greater sensitivity to the effects of boric acid corrosion on plant 10/01/1999 equipment were noted in the IR and integration of these insights into plant processes and operational philosophy are being institutionalized by providing additional training to management and the technical staff to address the technical issues of boric acid control, the DBNPS Boric Acid Control Program and requirements, lessons learned from the RC-2 event, and industry experience.
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