ML081650364: Difference between revisions

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| issue date = 06/20/2008
| issue date = 06/20/2008
| title = RAI Related to Improved Technical Specifications Conversion
| title = RAI Related to Improved Technical Specifications Conversion
| author name = Wengert T J
| author name = Wengert T
| author affiliation = NRC/NRR/ADRO/DORL/LPLIII-2
| author affiliation = NRC/NRR/ADRO/DORL/LPLIII-2
| addressee name = Allen B S
| addressee name = Allen B
| addressee affiliation = FirstEnergy Nuclear Operating Co
| addressee affiliation = FirstEnergy Nuclear Operating Co
| docket = 05000346
| docket = 05000346
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:June 20, 2008 Mr. Barry S. Allen Site Vice President FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station Mail Stop A-DB-3080 5501 North State Route 2 Oak Harbor, OH 43449-9760  
{{#Wiki_filter:June 20, 2008 Mr. Barry S. Allen Site Vice President FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station Mail Stop A-DB-3080 5501 North State Route 2 Oak Harbor, OH 43449-9760


==SUBJECT:==
==SUBJECT:==
DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO IMPROVED TECHNICAL SPECIFICATIONS CONVERSION (MD6398)  
DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO IMPROVED TECHNICAL SPECIFICATIONS CONVERSION (MD6398)


==Dear Mr. Allen:==
==Dear Mr. Allen:==


By letter to the Nuclear Regulatory Commission (NRC) dated August 3, 2007, FirstEnergy Nuclear Operating Company (FENOC) submitted a request to an application requesting to amend the operating license, for the Davis-Besse Nuclear Power Station, Unit No. 1. FENOC has proposed to revise the current technical specifications to the improved technical specifications consistent with improved standard technical specifications (STS) as described in "Standard Technical Specifications Babcock and Wilcox (B&W) Plants," Revision 3.1. STS Revision 3.1 is the December, 2005, update to NUREG-1430, which was published June 2004.  
By letter to the Nuclear Regulatory Commission (NRC) dated August 3, 2007, FirstEnergy Nuclear Operating Company (FENOC) submitted a request to an application requesting to amend the operating license, for the Davis-Besse Nuclear Power Station, Unit No. 1. FENOC has proposed to revise the current technical specifications to the improved technical specifications consistent with improved standard technical specifications (STS) as described in Standard Technical Specifications Babcock and Wilcox (B&W) Plants, Revision 3.1. STS Revision 3.1 is the December, 2005, update to NUREG-1430, which was published June 2004.
 
The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff, it was agreed that you would provide a response within 30 days from the date of this letter.
The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff, it was agreed that you would provide a response within 30 days from the date of this letter.
The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC=s goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-4037.
 
Sincerely,
The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC
                                                /RA/
=s goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-4037.
Thomas J. Wengert, Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-346
Sincerely,       /RA/
Thomas J. Wengert, Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation  
 
Docket No. 50-346  


==Enclosure:==
==Enclosure:==


Request for Additional Information  
Request for Additional Information cc w/encl: See next page


cc w/encl:  See next page Mr. Barry S. Allen     June 20, 2008 Site Vice President FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station Mail Stop A-DB-3080 5501 North State Route 2 Oak Harbor, OH 43449-9760  
Mr. Barry S. Allen                                       June 20, 2008 Site Vice President FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station Mail Stop A-DB-3080 5501 North State Route 2 Oak Harbor, OH 43449-9760


==SUBJECT:==
==SUBJECT:==
DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO IMPROVED TECHNICAL SPECIFICATIONS CONVERSION (MD6398)  
DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO IMPROVED TECHNICAL SPECIFICATIONS CONVERSION (MD6398)


==Dear Mr. Allen:==
==Dear Mr. Allen:==


By letter to the Nuclear Regulatory Commission (NRC) dated August 3, 2007, FirstEnergy Nuclear Operating Company (FENOC) submitted a request to an application requesting to amend the operating license, for the Davis-Besse Nuclear Power Station, Unit No. 1. FENOC has proposed to revise the current technical specifications to the improved technical specifications consistent with improved standard technical specifications (STS) as described in "Standard Technical Specifications Babcock and Wilcox (B&W) Plants," Revision 3.1. STS Revision 3.1 is the December, 2005, update to NUREG-1430, which was published June 2004.  
By letter to the Nuclear Regulatory Commission (NRC) dated August 3, 2007, FirstEnergy Nuclear Operating Company (FENOC) submitted a request to an application requesting to amend the operating license, for the Davis-Besse Nuclear Power Station, Unit No. 1. FENOC has proposed to revise the current technical specifications to the improved technical specifications consistent with improved standard technical specifications (STS) as described in Standard Technical Specifications Babcock and Wilcox (B&W) Plants, Revision 3.1. STS Revision 3.1 is the December, 2005, update to NUREG-1430, which was published June 2004.
 
The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff, it was agreed that you would provide a response within 30 days from the date of this letter.
The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff, it was agreed that you would provide a response within 30 days from the date of this letter.
The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC=s goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-4037.
 
Sincerely,
The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC
                                                /RA/
=s goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-4037.
Thomas J. Wengert, Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-346
Sincerely,       /RA/ Thomas J. Wengert, Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation  
 
Docket No. 50-346  


==Enclosure:==
==Enclosure:==


Request for Additional Information cc w/encl: See next page DISTRIBUTION:
Request for Additional Information cc w/encl: See next page DISTRIBUTION:
PUBLIC   LPL3-2 R/F RidsNrrDorlLpl3-2 RidsNrrPMCGoodwin RidsNrrPMTWengert RidsNrrLAEWhitt RidsAcrsAcnw&mMailCenter RidsNrrDirsItsb RidsOgcRp RidsRgn3MailCenter RidsNrrDorlDpr   ALewin, NRR ADAMS Accession Number:
PUBLIC                   LPL3-2 R/F             RidsNrrDorlLpl3-2             RidsNrrPMCGoodwin RidsNrrPMTWengert       RidsNrrLAEWhitt         RidsAcrsAcnw&mMailCenter       RidsNrrDirsItsb RidsOgcRp               RidsRgn3MailCenter     RidsNrrDorlDpr                 ALewin, NRR ADAMS Accession Number: ML081650364 OFFICE       LPL3-2/PM             LPL3-2/PM       LPL3-2/LA         LPL3-2/BC NAME         CGoodwin             TWengert         EWhitt             RGibbs DATE         6/19/08             6/19/08         6/19/08           6/20/08 OFFICIAL RECORD COPY
ML081650364
 
OFFICE LPL3-2/PM LPL3-2/PM LPL3-2/LA LPL3-2/BC  
 
NAME CGoodwin TWengert EWhitt RGibbs DATE   6/19/08 6/19/08 6/19/08 6/20/08 OFFICIAL RECORD COPY Davis-Besse Nuclear Power Station, Unit No. 1 
 
cc: Manager, Site Regulatory Compliance FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station Mail Stop A-DB-3065 5501 North State Route 2 Oak Harbor, OH  43449-9760
 
Director, Ohio Department of Commerce Division of Industrial Compliance Bureau of Operations & Maintenance 6606 Tussing Road P.O. Box 4009 Reynoldsburg, OH  43068-9009
 
Resident Inspector U.S. Nuclear Regulatory Commission 5503 North State Route 2 Oak Harbor, OH  43449-9760
 
Stephen Helmer Supervisor, Technical Support Section Bureau of Radiation Protection Ohio Department of Health 35 East Chestnut Street, 7 th Floor Columbus, OH  43215
 
Carol O'Claire, Chief, Radiological Branch Ohio Emergency Management Agency 2855 West Dublin Granville Road Columbus, OH  43235-2206
 
Zack A. Clayton
 
DERR Ohio Environmental Protection Agency P.O. Box 1049 Columbus, OH  43266-0149
 
State of Ohio - Transportation Department Public Utilities Commission 180 East Broad Street Columbus, OH  43266-0573
 
Principal Assistant Attorney General Environmental Enforcement Section State Office Tower 30 East Broad Street, 25 th Floor Columbus, OH  43215
 
President, Board of County Commissioners of Ottawa County Port Clinton, OH  43252 
 
President, Board of County Commissioners of Lucas County One Government Center, Suite 800 Toledo, OH  43604-6506
 
The Honorable Dennis J. Kucinich United States House of Representatives Washington, D.C. 20515
 
The Honorable Dennis J. Kucinich United States House of Representatives 14400 Detroit Avenue Lakewood, OH  44107 
 
Joseph J. Hagan President and Chief Nuclear Officer FirstEnergy Nuclear Operating Company Mail Stop A-GO-19 76 South Main Street Akron, OH  44308
 
David W. Jenkins, Attorney FirstEnergy Corporation Mail Stop A-GO-15 76 South Main Street Akron, OH  44308
 
Danny L. Pace Senior Vice President, Fleet Engineering FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH  44308
 
Manager, Fleet Licensing FirstEnergy Nuclear Operating Company Mail Stop A-GO-2 76 South Main Street Akron, OH  44308
 
Davis-Besse Nuclear Power Station, Unit No. 1 
 
cc:
 
Director, Fleet Regulatory Affairs FirstEnergy Nuclear Operating Company Mail Stop A-GO-2 76 South Main Street Akron, OH  44308
 
Jeannie M. Rinckel Vice President, Fleet Oversight FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH  44308
 
Paul A. Harden Vice President, Nuclear Support FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH  44308
 
James H. Lash Senior Vice President of Operations and Chief Operating Officer FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH  44308
 
Enclosure  REQUEST FOR ADDITIONAL INFORMATION
 
DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1
 
DOCKET NO. 50-346
 
In reviewing the FirstEnergy Nuclear Operating Company
=s submittal dated August 3, 2007 (Agencywide Documents Access and Management System Accession No. ML0722004510), related to revising the current technical specifications (CTS) to the improved technical specifications consistent with improved standard technical specifications (STS) as described in "Standard Technical Specifications Babcock and Wilcox (B&W) Plants", Revision 3.1, for the Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS), the NRC staff has determined that the following information is needed in order to complete its review:
 
A. Surveillance Requirement (SR) for Emergency Feedwater (EFW) System Steam Generator (SG) Control System
: 1. Please provide a basis that demonstrates how removal of the current SR 4.7.1.2.1.d from the Technical Specifications (TSs) would be in compliance with Title 10 of the Code of Federal Regulations (10 CFR) 50.36(d)(3). 
: 2. Please provide analyses to demonstrate that the EFW System would be operable without performing CTS SR 4.7.1.2.1.d. 
 
===
Background===
Criterion 3 of 10 CFR 50.36(d)(2)(ii) states that a TS limiting condition for operation (LCO) of a nuclear reactor must be established for "a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier." 
 
The EFW System is retained in the TSs per Criterion 3 of 10 CFR 50.36(d)(2)(ii). Current TSs require the EFW System SG Level Control System to be operable in order for the EFW to be capable of mitigating small break Loss of Coolant Accidents. 
 
Section 50.36(d)(3) of 10 CFR states that TSs will include SRs which "are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limit s, and that the limiting conditions for operation will be met."
 
SR 4.7.1.2.1.d contains testing, calibrations, and inspections associated with the EFW SG Level Control. It is unclear how the proposed deletion of SR 4.7.1.2.1.d from TSs will assure that the necessary quality of the EFW SG Level Controls are maintained, so that facility operation will be within safety limits, and that the LCOs will be met per 10 CFR 50.36(d)(3). 
 
B. LCO for Remote Shutdown Control Circuits and Transfer Switches
: 1. Please provide a basis that demonstrates how removal of the CTS LCO 3.3.3.5.2 from the TSs would be in compliance with 10 CFR 50.36(d)(2)(ii), Criterion 4. 
 
===
Background===


LCO 3.3.3.5.2 requires that the control circuits and transfer switches be operable during Modes 1, 2, and 3. The control circuits and transfer switches provide the operator with sufficient instrumentation and controls to place and maintain the unit in a safe shutdown condition from
Davis-Besse Nuclear Power Station,        President, Board of County Unit No. 1                                Commissioners of Ottawa County Port Clinton, OH 43252 cc:
Manager, Site Regulatory Compliance        President, Board of County FirstEnergy Nuclear Operating Company      Commissioners of Lucas County Davis-Besse Nuclear Power Station          One Government Center, Suite 800 Mail Stop A-DB-3065                        Toledo, OH 43604-6506 5501 North State Route 2 Oak Harbor, OH 43449-9760                  The Honorable Dennis J. Kucinich United States House of Representatives Director, Ohio Department of Commerce      Washington, D.C. 20515 Division of Industrial Compliance Bureau of Operations & Maintenance        The Honorable Dennis J. Kucinich 6606 Tussing Road United States House of Representatives P.O. Box 4009 14400 Detroit Avenue Reynoldsburg, OH 43068-9009 Lakewood, OH 44107 Resident Inspector U.S. Nuclear Regulatory Commission        Joseph J. Hagan 5503 North State Route 2                   President and Chief Nuclear Officer Oak Harbor, OH 43449-9760                  FirstEnergy Nuclear Operating Company Mail Stop A-GO-19 Stephen Helmer                            76 South Main Street Supervisor, Technical Support Section      Akron, OH 44308 Bureau of Radiation Protection Ohio Department of Health                  David W. Jenkins, Attorney 35 East Chestnut Street, 7th Floor        FirstEnergy Corporation Columbus, OH 43215                        Mail Stop A-GO-15 76 South Main Street Carol OClaire, Chief, Radiological Branch Akron, OH 44308 Ohio Emergency Management Agency 2855 West Dublin Granville Road            Danny L. Pace Columbus, OH 43235-2206                    Senior Vice President, Fleet Engineering FirstEnergy Nuclear Operating Company Zack A. Clayton                            Mail Stop A-GO-14 DERR                                      76 South Main Street Ohio Environmental Protection Agency      Akron, OH 44308 P.O. Box 1049 Columbus, OH 43266-0149                    Manager, Fleet Licensing FirstEnergy Nuclear Operating Company State of Ohio - Transportation Department  Mail Stop A-GO-2 Public Utilities Commission                76 South Main Street 180 East Broad Street                      Akron, OH 44308 Columbus, OH 43266-0573 Principal Assistant Attorney General Environmental Enforcement Section State Office Tower 30 East Broad Street, 25th Floor Columbus, OH 43215


locations other than the control room. This capability provides protection against the possibility of the control room becoming inaccessible. 
Davis-Besse Nuclear Power Station, Unit No. 1 cc:
Director, Fleet Regulatory Affairs FirstEnergy Nuclear Operating Company Mail Stop A-GO-2 76 South Main Street Akron, OH 44308 Jeannie M. Rinckel Vice President, Fleet Oversight FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 Paul A. Harden Vice President, Nuclear Support FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 James H. Lash Senior Vice President of Operations and Chief Operating Officer FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308


NUREG-1430, "Standard Technical Specifications Babcock and Wilcox Plants," which provides guidance to NRC staff, contains LCO 3.3.18, "Remote Shutdown System."  The STS Bases for LCO 3.3.18 states that the Remote Shutdown System satisfies Criterion 4 of 10 CFR 50.36(d)(2)(ii).  
REQUEST FOR ADDITIONAL INFORMATION DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 DOCKET NO. 50-346 In reviewing the FirstEnergy Nuclear Operating Company=s submittal dated August 3, 2007 (Agencywide Documents Access and Management System Accession No. ML0722004510),
related to revising the current technical specifications (CTS) to the improved technical specifications consistent with improved standard technical specifications (STS) as described in Standard Technical Specifications Babcock and Wilcox (B&W) Plants, Revision 3.1, for the Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS), the NRC staff has determined that the following information is needed in order to complete its review:
A.       Surveillance Requirement (SR) for Emergency Feedwater (EFW) System Steam Generator (SG) Control System
: 1. Please provide a basis that demonstrates how removal of the current SR 4.7.1.2.1.d from the Technical Specifications (TSs) would be in compliance with Title 10 of the Code of Federal Regulations (10 CFR) 50.36(d)(3).
: 2. Please provide analyses to demonstrate that the EFW System would be operable without performing CTS SR 4.7.1.2.1.d.


Criterion 4 of 10 CFR 50.36(d)(2)(ii) states that a TS LCO of a nuclear reactor must be established for "a structure, system, or component which operating exper ience or probabilistic risk assessment has shown to be significant to public health and safety."
===Background===
Criterion 3 of 10 CFR 50.36(d)(2)(ii) states that a TS limiting condition for operation (LCO) of a nuclear reactor must be established for a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
The EFW System is retained in the TSs per Criterion 3 of 10 CFR 50.36(d)(2)(ii). Current TSs require the EFW System SG Level Control System to be operable in order for the EFW to be capable of mitigating small break Loss of Coolant Accidents.
Section 50.36(d)(3) of 10 CFR states that TSs will include SRs which are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.
SR 4.7.1.2.1.d contains testing, calibrations, and inspections associated with the EFW SG Level Control. It is unclear how the proposed deletion of SR 4.7.1.2.1.d from TSs will assure that the necessary quality of the EFW SG Level Controls are maintained, so that facility operation will be within safety limits, and that the LCOs will be met per 10 CFR 50.36(d)(3).
Enclosure


The licensee has pointed out that the basis for this LCO in their CTS is fire protection. However, the NRC staff notes that Generic Letter (GL) 88-12, "Removal of Fire Protection Requirements from Technical Specifications," dated August 2, 1988, provided specific guidance on the removal of fire protection requirements from TSs. Although the NRC staff endorsed the removal of fire protection requirements from TSs, GL 88-12 stated that "any specifications related to the capability for safe shutdown following a fire, e.g., see Item 8(j) in En closure 1 to GL 81-12, are to be retained in TS."  Thus, GL 88-12 clearly supports the NRC staff's position that the remote shutdown capability m eets Criterion 4 of 10 CFR 50.36(d)(2)(ii), and should be retained in the DBNPS TSs.  
B.      LCO for Remote Shutdown Control Circuits and Transfer Switches
: 1. Please provide a basis that demonstrates how removal of the CTS LCO 3.3.3.5.2 from the TSs would be in compliance with 10 CFR 50.36(d)(2)(ii), Criterion 4.


===Background===
LCO 3.3.3.5.2 requires that the control circuits and transfer switches be operable during Modes 1, 2, and 3. The control circuits and transfer switches provide the operator with sufficient instrumentation and controls to place and maintain the unit in a safe shutdown condition from locations other than the control room. This capability provides protection against the possibility of the control room becoming inaccessible.
NUREG-1430, Standard Technical Specifications Babcock and Wilcox Plants, which provides guidance to NRC staff, contains LCO 3.3.18, Remote Shutdown System. The STS Bases for LCO 3.3.18 states that the Remote Shutdown System satisfies Criterion 4 of 10 CFR 50.36(d)(2)(ii).
Criterion 4 of 10 CFR 50.36(d)(2)(ii) states that a TS LCO of a nuclear reactor must be established for a structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.
The licensee has pointed out that the basis for this LCO in their CTS is fire protection. However, the NRC staff notes that Generic Letter (GL) 88-12, Removal of Fire Protection Requirements from Technical Specifications, dated August 2, 1988, provided specific guidance on the removal of fire protection requirements from TSs. Although the NRC staff endorsed the removal of fire protection requirements from TSs, GL 88-12 stated that any specifications related to the capability for safe shutdown following a fire, e.g., see Item 8(j) in Enclosure 1 to GL 81-12, are to be retained in TS. Thus, GL 88-12 clearly supports the NRC staffs position that the remote shutdown capability meets Criterion 4 of 10 CFR 50.36(d)(2)(ii), and should be retained in the DBNPS TSs.
It is unclear how the deletion of CTS LCO 3.3.3.5.2, which removes the capability for remote shutdown from the TSs, is in accordance with 10 CFR 50.36(d)(2)(ii), which requires TSs for items meeting Criterion 4.}}
It is unclear how the deletion of CTS LCO 3.3.3.5.2, which removes the capability for remote shutdown from the TSs, is in accordance with 10 CFR 50.36(d)(2)(ii), which requires TSs for items meeting Criterion 4.}}

Latest revision as of 16:47, 14 November 2019

RAI Related to Improved Technical Specifications Conversion
ML081650364
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 06/20/2008
From: Thomas Wengert
NRC/NRR/ADRO/DORL/LPLIII-2
To: Allen B
FirstEnergy Nuclear Operating Co
Wengert, Thomas
References
TAC MD6398
Download: ML081650364 (6)


Text

June 20, 2008 Mr. Barry S. Allen Site Vice President FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station Mail Stop A-DB-3080 5501 North State Route 2 Oak Harbor, OH 43449-9760

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO IMPROVED TECHNICAL SPECIFICATIONS CONVERSION (MD6398)

Dear Mr. Allen:

By letter to the Nuclear Regulatory Commission (NRC) dated August 3, 2007, FirstEnergy Nuclear Operating Company (FENOC) submitted a request to an application requesting to amend the operating license, for the Davis-Besse Nuclear Power Station, Unit No. 1. FENOC has proposed to revise the current technical specifications to the improved technical specifications consistent with improved standard technical specifications (STS) as described in Standard Technical Specifications Babcock and Wilcox (B&W) Plants, Revision 3.1. STS Revision 3.1 is the December, 2005, update to NUREG-1430, which was published June 2004.

The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff, it was agreed that you would provide a response within 30 days from the date of this letter.

The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC=s goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-4037.

Sincerely,

/RA/

Thomas J. Wengert, Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-346

Enclosure:

Request for Additional Information cc w/encl: See next page

Mr. Barry S. Allen June 20, 2008 Site Vice President FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station Mail Stop A-DB-3080 5501 North State Route 2 Oak Harbor, OH 43449-9760

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO IMPROVED TECHNICAL SPECIFICATIONS CONVERSION (MD6398)

Dear Mr. Allen:

By letter to the Nuclear Regulatory Commission (NRC) dated August 3, 2007, FirstEnergy Nuclear Operating Company (FENOC) submitted a request to an application requesting to amend the operating license, for the Davis-Besse Nuclear Power Station, Unit No. 1. FENOC has proposed to revise the current technical specifications to the improved technical specifications consistent with improved standard technical specifications (STS) as described in Standard Technical Specifications Babcock and Wilcox (B&W) Plants, Revision 3.1. STS Revision 3.1 is the December, 2005, update to NUREG-1430, which was published June 2004.

The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff, it was agreed that you would provide a response within 30 days from the date of this letter.

The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC=s goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-4037.

Sincerely,

/RA/

Thomas J. Wengert, Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-346

Enclosure:

Request for Additional Information cc w/encl: See next page DISTRIBUTION:

PUBLIC LPL3-2 R/F RidsNrrDorlLpl3-2 RidsNrrPMCGoodwin RidsNrrPMTWengert RidsNrrLAEWhitt RidsAcrsAcnw&mMailCenter RidsNrrDirsItsb RidsOgcRp RidsRgn3MailCenter RidsNrrDorlDpr ALewin, NRR ADAMS Accession Number: ML081650364 OFFICE LPL3-2/PM LPL3-2/PM LPL3-2/LA LPL3-2/BC NAME CGoodwin TWengert EWhitt RGibbs DATE 6/19/08 6/19/08 6/19/08 6/20/08 OFFICIAL RECORD COPY

Davis-Besse Nuclear Power Station, President, Board of County Unit No. 1 Commissioners of Ottawa County Port Clinton, OH 43252 cc:

Manager, Site Regulatory Compliance President, Board of County FirstEnergy Nuclear Operating Company Commissioners of Lucas County Davis-Besse Nuclear Power Station One Government Center, Suite 800 Mail Stop A-DB-3065 Toledo, OH 43604-6506 5501 North State Route 2 Oak Harbor, OH 43449-9760 The Honorable Dennis J. Kucinich United States House of Representatives Director, Ohio Department of Commerce Washington, D.C. 20515 Division of Industrial Compliance Bureau of Operations & Maintenance The Honorable Dennis J. Kucinich 6606 Tussing Road United States House of Representatives P.O. Box 4009 14400 Detroit Avenue Reynoldsburg, OH 43068-9009 Lakewood, OH 44107 Resident Inspector U.S. Nuclear Regulatory Commission Joseph J. Hagan 5503 North State Route 2 President and Chief Nuclear Officer Oak Harbor, OH 43449-9760 FirstEnergy Nuclear Operating Company Mail Stop A-GO-19 Stephen Helmer 76 South Main Street Supervisor, Technical Support Section Akron, OH 44308 Bureau of Radiation Protection Ohio Department of Health David W. Jenkins, Attorney 35 East Chestnut Street, 7th Floor FirstEnergy Corporation Columbus, OH 43215 Mail Stop A-GO-15 76 South Main Street Carol OClaire, Chief, Radiological Branch Akron, OH 44308 Ohio Emergency Management Agency 2855 West Dublin Granville Road Danny L. Pace Columbus, OH 43235-2206 Senior Vice President, Fleet Engineering FirstEnergy Nuclear Operating Company Zack A. Clayton Mail Stop A-GO-14 DERR 76 South Main Street Ohio Environmental Protection Agency Akron, OH 44308 P.O. Box 1049 Columbus, OH 43266-0149 Manager, Fleet Licensing FirstEnergy Nuclear Operating Company State of Ohio - Transportation Department Mail Stop A-GO-2 Public Utilities Commission 76 South Main Street 180 East Broad Street Akron, OH 44308 Columbus, OH 43266-0573 Principal Assistant Attorney General Environmental Enforcement Section State Office Tower 30 East Broad Street, 25th Floor Columbus, OH 43215

Davis-Besse Nuclear Power Station, Unit No. 1 cc:

Director, Fleet Regulatory Affairs FirstEnergy Nuclear Operating Company Mail Stop A-GO-2 76 South Main Street Akron, OH 44308 Jeannie M. Rinckel Vice President, Fleet Oversight FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 Paul A. Harden Vice President, Nuclear Support FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 James H. Lash Senior Vice President of Operations and Chief Operating Officer FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308

REQUEST FOR ADDITIONAL INFORMATION DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 DOCKET NO. 50-346 In reviewing the FirstEnergy Nuclear Operating Company=s submittal dated August 3, 2007 (Agencywide Documents Access and Management System Accession No. ML0722004510),

related to revising the current technical specifications (CTS) to the improved technical specifications consistent with improved standard technical specifications (STS) as described in Standard Technical Specifications Babcock and Wilcox (B&W) Plants, Revision 3.1, for the Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS), the NRC staff has determined that the following information is needed in order to complete its review:

A. Surveillance Requirement (SR) for Emergency Feedwater (EFW) System Steam Generator (SG) Control System

1. Please provide a basis that demonstrates how removal of the current SR 4.7.1.2.1.d from the Technical Specifications (TSs) would be in compliance with Title 10 of the Code of Federal Regulations (10 CFR) 50.36(d)(3).
2. Please provide analyses to demonstrate that the EFW System would be operable without performing CTS SR 4.7.1.2.1.d.

Background

Criterion 3 of 10 CFR 50.36(d)(2)(ii) states that a TS limiting condition for operation (LCO) of a nuclear reactor must be established for a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

The EFW System is retained in the TSs per Criterion 3 of 10 CFR 50.36(d)(2)(ii). Current TSs require the EFW System SG Level Control System to be operable in order for the EFW to be capable of mitigating small break Loss of Coolant Accidents.

Section 50.36(d)(3) of 10 CFR states that TSs will include SRs which are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

SR 4.7.1.2.1.d contains testing, calibrations, and inspections associated with the EFW SG Level Control. It is unclear how the proposed deletion of SR 4.7.1.2.1.d from TSs will assure that the necessary quality of the EFW SG Level Controls are maintained, so that facility operation will be within safety limits, and that the LCOs will be met per 10 CFR 50.36(d)(3).

Enclosure

B. LCO for Remote Shutdown Control Circuits and Transfer Switches

1. Please provide a basis that demonstrates how removal of the CTS LCO 3.3.3.5.2 from the TSs would be in compliance with 10 CFR 50.36(d)(2)(ii), Criterion 4.

Background

LCO 3.3.3.5.2 requires that the control circuits and transfer switches be operable during Modes 1, 2, and 3. The control circuits and transfer switches provide the operator with sufficient instrumentation and controls to place and maintain the unit in a safe shutdown condition from locations other than the control room. This capability provides protection against the possibility of the control room becoming inaccessible.

NUREG-1430, Standard Technical Specifications Babcock and Wilcox Plants, which provides guidance to NRC staff, contains LCO 3.3.18, Remote Shutdown System. The STS Bases for LCO 3.3.18 states that the Remote Shutdown System satisfies Criterion 4 of 10 CFR 50.36(d)(2)(ii).

Criterion 4 of 10 CFR 50.36(d)(2)(ii) states that a TS LCO of a nuclear reactor must be established for a structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

The licensee has pointed out that the basis for this LCO in their CTS is fire protection. However, the NRC staff notes that Generic Letter (GL) 88-12, Removal of Fire Protection Requirements from Technical Specifications, dated August 2, 1988, provided specific guidance on the removal of fire protection requirements from TSs. Although the NRC staff endorsed the removal of fire protection requirements from TSs, GL 88-12 stated that any specifications related to the capability for safe shutdown following a fire, e.g., see Item 8(j) in Enclosure 1 to GL 81-12, are to be retained in TS. Thus, GL 88-12 clearly supports the NRC staffs position that the remote shutdown capability meets Criterion 4 of 10 CFR 50.36(d)(2)(ii), and should be retained in the DBNPS TSs.

It is unclear how the deletion of CTS LCO 3.3.3.5.2, which removes the capability for remote shutdown from the TSs, is in accordance with 10 CFR 50.36(d)(2)(ii), which requires TSs for items meeting Criterion 4.