ML062300025

Regulatory Commitment Change Summary Report for the Davis-Besse, Unit 1 (Dbnps), for May 18, 2002 - May 31, 2006

ML062300025
Person / Time
Site:	Davis Besse
Issue date:	08/15/2006
From:	Bezilla M FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
32849
Download: ML062300025 (36)

Text

FENOC 5501 North State Route 2

FirstEnergyNuclear OperatingCompany Oak Harbor,Ohio 43449 Mark B. Bezilla 419-321-7676 Vice President- Nuclear Fax

419-321-7582 Docket Number 50-346 License Number NPF-3 Serial Number 3284 August 15, 2006 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001

Subject:

Regulatory Commitment Change Summary Report (May 18, 2002 - May 31, 2006)

Ladies and Gentlemen:

The FirstEnergy Nuclear Operating Company (FENOC) hereby submits the attached Regulatory Commitment Change Summary Report for the Davis-Besse Nuclear Power Station, Unit Number 1 (DBNPS), as discussed in NEI Commitment Management guidance and implemented by the DBNPS commitment management procedure.

The DBNPS commitment changes identified between the dates of May 18, 2002 and May 31, 2006 are included in Attachment I of this report. This report includes a description of the identified commitments, a summary of the changes made to the commitments, and a brief statement describing the basis for the change. FENOC has reviewed and implemented the commitment changes and has determined that the submittal of this report is the only required notification regarding changes to commitments listed in the attached summary.

This report covers four years of commitment changes due to a missed submittal of a Regulatory Commitment Change Summary Report in 2004. This missed submittal was documented in the DBNPS Corrective Action Program. The last submittal of a Regulatory Commitment Change Summary Report was on November 18, 2002 (Serial 2824).

Attachment 2 identifies that there are no commitments contained in this letter. If there are any questions or if additional information is required, please contact Mr. Gregory A. Dunn, Manager-FENOC Fleet Licensing, at (330) 315-7243.

Sincerely yours, KJN/kjn Attachments cc: DB-l NRC/NRR Project Manager Regional Administrator, USNRC Region III DB-1 NRC Senior Resident Inspector Utility Radiological Safety Board

,AoDl

Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 1 of 34 COMMITMENT COMMITMENT NUMBER I SOURCE I DATE DESCRIPTION CHANGE REASON FOR CHANGE DESCRIPTION 001094, 001095, 001102 Outlines the events during a Overpressurization controls were DB-SP-10030, HPI Pump 1 Mode Serial Letter 0220 cooldown or plant startup in which implemented through procedural 5 Enhanced Baseline Testing in 2/18/1977 operator actions prevent the controls by isolating the BWST Piggyback, was used in 13RFO to possibility of overpressurization (borated water storage tank) develop a curve and to obtain and identifies when the HPI (high suction to the HPI pump in DB- additional data for rotor dynamics pressure injection) system will be SP-1 0030. analysis, including critical speed.

tested. This test was an infrequently performed test that was cancelled after 13RFO so no permanent commitment change was made.

001483 All nuclear safety related Commitment closed. With current programmatic (audit)

GL 83-028, Serial Letter 1000 administrative procedures are reviews in place, a separate in-line 11/07/1983 reviewed and approved by the review of procedures by Quality Quality Assurance department Assurance is redundant and and implementation is verified unnecessary.

during audits.

001487 Audit reports are reviewed and Commitment closed. This commitment was redundant GL 83-028, Serial Letter 1000 approved by the Supervisor - with the intent of the requirements 11/07/1983 Supplier Quality Unit and of ANSI N45.2.12-1977.

distributed to management of the audited organization.

Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 2 of 34 COMMITMENT COMMITMENT NUMBERISOURCE IDATE DESCRIPTION CHANGE REASON FOR CHANGE 001500 All procurement documents Procurement documents are The Procurement Engineer is GL 83-028, Serial Letter 1000 identified as Q-list, fire protection reviewed/approved by tasked with this activity and may 11/07/1983 and/or ASME must be Procurement Engineering. request a formal review by other reviewed/approved by the Facility disciplines as deemed necessary.

Engineering Department and by the Quality Engineering Department.

001727 The procedure for loss of all AC Commitment closed. The licensed operator GL 81-004, Serial Letter 0720 power is covered in the requalification program is now 6/02/1981 requalification training during the designed using the Systematic standard and emergency Approach to Training (SAT) operating procedure training. Any process that determines training procedure revisions will be needs based on job analysis and covered in a method appropriate needs analysis.

to the magnitude of the revision.

001945 In order to prevent another Replaced the high radiation locked Each lock is stamped (into the IR 79-003, Serial Letter 1-0053 occurrence of unlocked high area book with the Barricade and metal of the lock) with a unique 3/26/1979 radiation areas, the location of all Barrier Posting and Integrity identifying number that areas greater than 1000 MR/HR Checklist. Deleted the tags on the corresponds to the key.

have been locked and these areas locks.

are logged in the high radiation locked area book. These areas have special locks labeled with a tag.

II Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 3 of 34 COMMITMENT COMMITMENT NUMBERISOURCEIDATE DESCRIPTION CHANGE REASON FOR CHANGE 002998 The Conditions Adverse to Quality Commitment closed. The Corrective Action Program IR 84-012, Serial Letter 1-0463 program implements the maintains this compliance as it 9/20/1984 requirements of 10 CFR 21. requires a determination if the condition is reportable under 10 CFR 21, and if required, completion of a 10 CFR 21 Decision Checklist.

003251 Adequate procedural guidance Commitment closed. The practice of using a test outline IR 84-028 had been added to prevent the has been discontinued. Approved 1/18/1985 use of a test outline instead of a procedures are used to perform test procedure. testing.

003520 The Technical Specifications Deleted hand delivery of report The subject report is available on-LER 86-031, Serial Letter 1-0674 Surveillance Specialist will and that Friday's list will include line to anyone, including the shift 10/13/1986 maintain a current list of all tests which will be late up to and manager and department heads surveillance tests that will go late including Monday. and is kept current.

during the next 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This list will be hand delivered daily to the shift manager and appropriate department heads. Friday's list will include tests which will be late up to and including Monday.

1) 9 Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 4 of 34 COMMITMENT COMMITMENT NUMBER I SOURCE I DATE DESCRIPTION CHANGE REASON FOR CHANGE 004716 A general inspection of The inspection is performed when The station has the capability to IEB 80-024, Serial Letter 1-0179 containment is required to be there are indications of open identify leakage and differentiate 1/05/1981 performed by Plant Startup system leakage. which system is leaking. To limit Procedure prior to reaching dose and for safety reasons criticality on each plant startup. related to low containment oxygen (This inspection is for water levels, this change was made to damage from open system inspect affected areas in leakage.) containment when there are indications of open system leakage.

004848 When loose parts are suspected, Deleted all references to the crash The crash cart was rarely used GL 85-002, Serial Letter 1161 the Vibration & Loose Parts "crash cart and equipment located on it. and created a physical nuisance 6/24/1985 cart" is dispatched to further to store in the Control Room.

analyze the noise and determine Newer equipment is available in the location of the suspected the Metrology Lab and no longer loose part. needs to be stored on a crash cart.

005558 Pumps which may be used to Delete primary transfer pumps as These pumps were abandoned in GL 87-012, Serial Letter 1423 control RCS (reactor coolant part of this commitment. place by plant modification 9/23/1987 system) inventory include.., the 95-0050-00, Abandon Primary primary transfer pumps. Water Storage Tank (and System).

I)

Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 5 of 34 COMMITMENT COMMITMENT NUMBER I SOURCE I DATE DESCRIPTION CHANGE REASON FOR CHANGE DESCRIPTION CHANGE REASON FOR CHANGE 006761 An updated list of abbreviations, Commitment closed. The philosophy for the use of Serial Letter 1368 acronyms, and symbols will be acronyms and abbreviations has 4/20/1987 available after the control room changed and their use should now indications and controls are re- be minimized. When used, it is labeled. When the list is available, more appropriate to have the it should be added to the writer's acronym/abbreviation defined guide. Plant abbreviations and within the procedure itself so end acronyms are included in the users can easily locate the writer's guide. definition.

009319 The mechanical stops of valves Deleted the specific settings The valve position is controlled by LER 78-019 DH14A and DH14B are now identified in the commitment. test procedures and changes 3/07/1978 tagged to prevent incorrect depending on the test results.

resetting of these stops. The The Engineering Change Request correct settings should be 47 process controls the procedure degrees open for DH14A and 45 changes and tag changes degrees open for DH14B. required to reflect the new valve settings.

009551 Establish controls so that Commitment closed. Controls are in place to ensure IR 86-005 regulatory applicability this action is completed. The 4/18/1986 determinations are written on use- Corrective Action Program as-is and repair condition reports. includes instructions on what documentation is required for a use-as-is or repair disposition.

V)

Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT Attachment I MAY 2002 - MAY 2006 Page 6 of 34 COMMITMENT COMMITMENT NUMBER I SOURCE I DATE DESCRIPTION CHANGE REASON FOR CHANGE 011711 The condition report procedure Commitment closed. The Corrective Action Program IR 84-028, Serial Letter 1-0401 was revised to include the requires Regulatory Affairs to 1/06/1984 notification of the Regulatory review all new condition reports Affairs section if the engineering for a reportability determination.

evaluation indicates the system or Also, the SRO notifies/involves component is unable to perform its Regulatory Affairs as required for intended safety function. Operability Determinations or hardware dispositions.

011735 Initiate complete air flow balance Changed to periodically monitor The appropriate frequency is SRTP HVAC-NRR-2 of the control room HVAC system, the supply and return. determined and controlled by the 9/30/1986 including vibration testing of all Preventive Maintenance Program rotating equipment. Preventive to ensure equipment reliability.

maintenance activities have been initiated to quarterly monitor the supply and return air fans vibration.

012113 Health Physics procedure was Verbal permission is obtained The name of the management Serial Letter 1-0132 revised to include more stringent from Chemistry and Radiation individual who provides verbal 5/23/1980 requirements for entering locked Protection Supervisor. Deleted permission is more strictly defined.

high radiation areas. These the requirement to use two Electronic alarming dosimeters did include verbal permission from a different types of survey meters. not exist when this commitment Chemistry and Healthy Physics was made. The use of this new management individual and a equipment eliminates the need for requirement to use two different two survey meters.

types of high range survey meters.

ii Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 7 of 34 COMMITMENT COMMITMENT NUMBERISOURCEIDATE DESCRIPTION CHANGE REASON FOR CHANGE DESCRIPTION CHANGE 012319 Condition Report procedure Commitment closed. The Corrective Action program IR 88-012, Serial Letter 1-0839 corrected any interpretive addresses this aspect and the 10/25/1988 problems with the condition report creation of the electronic process process to ensure that these types for initiating and processing of a of problems (i.e. once a condition condition report also helps prevent report is initiated it must be the situation of not processing any processed) do not recur in the that have been initiated.

future.

012617 Create a PM which will provide Changed the frequency to 24- Frequencies are adjusted in SRTP CAC-RR-1 maintenance in accordance with month interval and modified the accordance with the Preventative 9/26/1986 the manufacturer's commitment to have the frequency Maintenance program based on recommendations for backdraft of the PM determined and system/component performance dampers. Incorporate the controlled by the Preventative and maintenance feedback.

requirements of the American Maintenance Program.

Warming and Ventilating Manual.

Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 8 of 34 COMMITMENT COMMITMENT NUMBER I SOURCE I DATE DESCRIPTION CHANGE REASON FOR CHANGE 012638 Preventive Maintenance Changed to periodically perform The appropriate frequency is SRTP HVAC-RR-2 procedures have been developed the PMs. determined and controlled by the 9/30/1986 for both trains of CREVS. Every Preventive Maintenance Program three months PM 1188 and 1189 to ensure equipment reliability.

are performed to verify proper oil level and ensure adequate charge on the system in both air-cooled and water-cooled modes.

012676 PM 2604 performs an annual Deleted the requirement to inspect A review of the maintenance SRTP HVAC-NRR-7 check of the control dampers. PM these components annually. history did not demonstrate a 9/30/1986 3075 and PM 2994 annually check reliability problem. The frequency the calibration of the chilled water of preventive maintenance is control string. PM 2635 will determined and controlled under annually check the calibration of the Preventive Maintenance the switchover instrument string. program.

11 Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 9 of 34 COMMITMENT COMMITMENT NUMBERISOURCEIDATE DESCRIPTION CHANGE REASON FOR CHANGE 012763 In order to improve response Commitment closed. Preventive actions have remained IR 81-003 times on audit finding reports, as an integral part of the licensee 4/17/1981 "Prompt Response to Internal structure and the corrective Audit Finding Reports" procedure actions to prevent recurrence has been prepared and approved have been effective. This is implementing more stringent covered by the Corrective Action requirements regarding audit program. In addition, the FENOC finding report (AFR) response, Quality Assurance Program tracking and time extensions. Manual commits to Regulatory Guide 1.144, "Auditing of Quality Assurance Programs for Nuclear Power Plants".

013043 The Davis-Besse requalification Commitment closed. The licensed operator Serial Letter 0816 program does mandate an requalification program is now 5/10/1982 accelerated requalification for any designed using the Systematic operator scoring less than 80% Approach to Training (SAT) overall. In addition, the operator is process that determines training removed from license duties needs based on job analysis and during the accelerated needs analysis. Remediation is requalification. part of the SAT process and is required prior to returning an operator to licensed duties.

Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 10 of 34 COMMITMENT COMMITMENT NUMBER I SOURCE I DATE DESCRIPTION CHANGE CHANGE REASON FOR REASON FOR CHANGE CHANGE 013351 The auxiliary feedwater high Commitment closed. A Technical Specification change IR 86-030 speed stop has been increased so was made to reduce required 3/18/1987 that minimum speed during auxiliary feedwater flow and high surveillance testing is not less speed limiter setpoints were than 3582 rpm. increased in the surveillance test procedures. The calculation and engineering change modification processes control any changes to setpoints in the procedures.

013442 Procedure for performance of Deleted the option of suspending This was part of a common IR 84-001, Serial Letter 1-0431 surveillance & periodic tests was the test. process initiative.

5/22/1984 modified to instruct the shift manager to either hold or suspend the test if it cannot be completed.

41 Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 11 of 34 COMMITMENT COMMITMENT NUMBERISOURCEIDATE DESCRIPTION CHANGE REASON FOR CHANGE 013558 Procurement procedure contains Procurement technical and quality This minimizes the risk of IR 85-007 instructions to ensure that requirements are updated on the conflicting information.

5/14/1985 procurement quality requirements computer only.

are updated on the computer and in procedures when they are changed.

013560 Training department procedures Commitment closed. Use of personnel performance IR85-004 were written and implemented to and feedback to evaluate and 3/27/1985 address the documentation of the modify training programs is a evaluation of operator and senior requirement of accreditation. This operator exams and the inclusion has been captured as part of a of identified deficiencies into process that is subject to a succeeding lesson plans. regulated revision/review process.

11 Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 12 of 34 COMMITMENT COMMITMENT NUMBERISOURCEIDATE DESCRIPTION CHANGE REASON FOR CHANGE 013644 One procedure will provide a Commitment closed. Preventive actions have remained IR 85-030, Serial Letter 1-0604 consistent mechanism for as an integral part of the licensee 1/27/1986 identifying items which are structure and the corrective potentially adverse to quality. actions to prevent recurrence Trending of condition reports will have been effective. The be required to ensure that Corrective Action Program and the significant problems will be Quality Assurance Program identified even if systems are not Manual addresses these items.

determined to be inoperable.

013664 Procedure was revised to include QC maintains hold/witness points This was a result of a change in IR 05-028, Serial 1-0600 several QC (Quality Control) via a database in SAP. A process for QC.

12/26/1985 verification hold points which will statement was added to the allow for appropriate QC review of procedure that the work document the BISCO boot seal fabrication has been processed through QC and installation. for determination of QC Hold/Witness Points.

vt a Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 13 of 34 COMMITMENT COMMITMENT NUMBER I SOURCE I DATE DESCRIPTION CHANGE REASON FOR CHANGE 013722 Develop a station administrative Commitment closed. The Request for Assistance COA Section 2.B.3 Rev. 6 procedure to assure that identified procedure was cancelled. These 1/03/1986 concerns will be formally elevated types of requests are handled as to appropriate levels of part of the Corrective Action engineering and management for Program for issues pertaining to resolution, will have required conditions adverse to quality and response dates, will identify part of the FENOC Activity individuals responsible for Tracking program for issues that resolution and for implementing do not pertain to conditions resolution. adverse to quality.

013755 A dedicated surveillance function Commitment closed. With the current implementation of COA Section App.3.2 Rev. 6 is established to supplement the the internal assessment process 1/03/1986 formal audit program. (continuous assessment) a surveillance function is not needed.

Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 14 of 34 COMMITMENT COMMITMENT NUMBERISOURCEIDATE DESCRIPTION CHANGE REASON FOR CHANGE 013756 Develop a nuclear mission Commitment closed. The Request for Assistance COA Section App.3.2 Rev. 6 procedure "Request for procedure was cancelled. These 1/0311986 Assistance" that contains mission types of requests are handled as wide requirements in this area. part of the Corrective Action Program for issues pertaining to conditions adverse to quality and part of the FENOC Activity Tracking program for issues that do not pertain to conditions adverse to quality.

014274 Procedure requires justification for These requirements were The Request for Assistance IR 86-022 engineering evaluations transferred to the Corrective procedure was cancelled and the 11/07/1986 commensurate with the level of Action Program. Corrective Action Program used to detail of the original question. address these types of requests.

.1 Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 15 of 34 COMMITMENT COMMITMENT NUMBER I SOURCE I DATE DESCRIPTION CHANGE REASON FOR CHANGE 014832 Verify that samples for offsite Commitment closed. Davis-Besse can perform the Serial Letter 1066 laboratory analysis will be required analyses and an offsite 8/14/1984 transported using licensed laboratory is not required.

carriers. Identify the offsite laboratory or laboratories expected to be used.

014872 Valves in the fire protection Commitment closed. This is part of the Fire Hazards Serial Letter 1685 system are locked in the open Analysis Report now.

7/31/1989 position and inspected monthly to verify their position.

.1 Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 16 of 34 COMMITMENT COMMITMENT NUMBER ISOURCE IDATE DESCRIPTION CHANGE REASON FOR CHANGE 014979 Licensed operators will be trained Commitment closed. The licensed operator Serial Letter 1368 on future revisions of EP 1202.01 requalification program is now 4/20/1987 prior to implementation or prior to designed using the Systematic returning control room duties after Approach to Training (SAT) absences. Minor editorial process that determines training procedure revisions will be exempt needs based on job analysis and from this training requirement. needs analysis. Significant changes to DB-OP-02000 (EP 1202.01) would trigger a needs analysis under this process to determine what additional skills and knowledge the operators may need as a result of the procedure change.

015037 Procedures are developed to Commitment closed. Preventive actions have remained COA Section App.3.2 Rev. 6 implement the Quality Assurance as an integral part of the licensee 1/03/1986 Program requirements and to structure and the corrective define responsibilities for inter- actions to prevent recurrence divisional nuclear program have been effective. This is an activities. In particular, these integral part of the Corrective procedures address the Action Program.

communication for identification, review, and disposition of condition reports.

Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 17 of 34 COMMITMENT COMMITMENT NUMBER I SOURCE I DATE DESCRIPTION CHANGE REASON FOR CHANGE 015050 Qualitative fit test will be Changed to Quantitative fit test The quantitative fit test is a better IR 84-019, Serial Letter 1-0488 performed in accordance with and substituted bending at the method as it verifies a fit factor of 12/14/1984 NUREG-0041, Section 8.5. This waist for running in place. 1000 for full factor respirator.

section requires the individual Davis-Besse environment permits undergoing respirator fit testing to bending, therefore, running in perform several simulated work place is not utilized.

activities including "running in place".

015094 The Maintenance Training Commitment closed. Maintenance training programs Serial Letter 1-0674 department now reviews are part of the accreditation 10/13/1986 procedure changes to determine process. Training materials are the need for craft training. maintained based on meeting the requirements of ACAD 02-001, Accreditation Objectives and Criteria, criterion 6.5. 10 CFR 50.120 requires that nuclear power stations obtain and maintain accreditation and Davis-Besse UFSAR section 13.2.1 commits the station to 10 CFR 50.120 and identifies that the maintenance training programs are accredited. This has been captured as part of a process that is subject to a regulated revision/review process.

Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 18 of 34 COMMITMENT COMMITMENT NUMBER I SOURCE I DATE DESCRIPTION CHANGE REASON FOR CHANGE 015257 Periodically (annually) review Commitment closed. The Industrial Security Plan was Serial Letter 1437 Physical Security and superseded by the Physical 10/29/1987 Contingency Plans and Security Plan that implemented procedures to evaluate their new requirements under NRC potential impact on plant and Order 03-086.

personnel safety.

015461 Identifies conditions, limitations, Commitment closed. This commitment existed to Serial Letter 1953 and restrictions that apply to the ensure compliance to an NRC 7/12/1991 use of MSA GRM-I canisters for approved exemption to 10 CFR radio-iodine protection. 20. Davis-Besse is following the code and chose not to utilize this approved exemption.

Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 19 of 34 COMMITMENT COMMITMENT NUMBER I SOURCE I DATE DESCRIPTION CHANGE REASON FOR CHANGE 015555 Test requirements for heat Removed DB-PF-04729, This test does not test/determine GL 89-013, Serial Letter 1-1022 exchangers included in Containment Air Cooler Monitoring nor obtain data that can be used 9/09/1993 performance test program. Test, from the GL 89-013 to determine the heat transfer performance test program. capability of the Containment Air Changed PM 5536, 5537 and Coolers (CAC) as requested by 5538 to clean inside the tubes at GL 89-013. Also, the frequency of interval determined by the the PMs is determined and Preventive Maintenance program. controlled by the Preventive Maintenance program.

015845 Modification packages were Changed to "a five point check The data package set points were IR 90-010 sampled and evaluated. As a from the Technical Specification changed to account for the fuel in 7/20/1990 result of one of these reviews on low level set point to the high level the tanks that is not usable. The the EDG (Emergency Diesel trip set point". alarming level will be more Generator) Fuel Oil Storage Tank conservative and the data derived Level Indication, data packages from the level indicators will be LI/LT4891 and LI/LT4892 were more accurate.

changed to incorporate the concerns of the inspection team.

This change included a five point check from 32,000 gallons to 39,850 gallons.

%I &

Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 20 of 34 COMMITMENT COMMITMENT NUMBER ISOURCEIDATE DESCRIPTION CHANGE REASON FOR CHANGE 016304 Training of workers on the proper Commitment closed. This commitment existed to Serial 1965 use and the limitations of the ensure compliance to an NRC 7/29/1991 GMR-I canisters will be performed approved exemption to 10 CFR prior to canister issuance. 20. Davis-Besse is following the code and chose not to utilize this approved exemption.

016350 An annual quality assurance Commitment closed. This commitment originated as a Serial Letter 1-0957 surveillance of randomly selected result of a reduction in 7/31/1991 procedures will be conducted. commitment to the quality The annual surveillance will assurance program description a provide assurance that number of years ago. This activity procedures are being maintained was deleted during the current. development of the FENOC Quality Assurance Program Manual. The NRC approved this change.

Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 21 of 34 COMMITMENT COMMITMENT NUMBER I SOURCE I DATE DESCRIPTION CHANGE REASON FOR CHANGE 016400 The administrative procedure A multi-disciplined technical This change was part of a new LER 91-002 governing surveillance test review is not performed. A common process.

10101/1991 scheduling will be revised to change in frequency is defined as include requirements for a multi- an intent change and, as such, will disciplined technical review when receive a technical review by an surveillance test frequency individual assigned by the section requirements are relaxed. manager. The section manager will approve the change.

016682 Pre-job briefs will be performed Pre-job brief will be performed as Briefing attendees are determined LER 92-002 R1 except for frequently performed determined by the work group based on the scope and nature of 5/08/1992 PMs and routine shop work. supervisor and the work group work. There may be times when Personnel to be present at the supervisor will also determine or Operations or Maintenance may pre-job brief as a minimum include recommend attendees for the pre- not be required to attend the brief, the discipline maintenance job brief. depending on the work scope and supervisor and Operations SRO. potential impact on the plant.

Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 22 of 34 COMMITMENT COMMITMENT NUMBER ISOURCE IDATE DESCRIPTION CHANGE REASON FOR CHANGE 016912 Low level radioactivity was found Changed to periodically change The appropriate frequency is IR 92-015 on HEPA filters near personnel out the pre-filter. determined and controlled by the 10/09/1992 clothing change out area. The Preventive Maintenance Program vent pre-filter will be changed out to ensure equipment reliability.

every six months.

016935 Control room programmer lamp Deleted "programmer lamp fault" The programmers have been Serial Letter 2183 fault light will illuminate if any of and added "electronic trip" changed to solid state devices, 11/10/1993 the contacts for any control rod eliminating the lamp fault light.

groups programmer opens.

Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 23 of 34 COMMITMENT COMMITMENT NUMBER ISOURCE IDATE DESCRIPTION CHANGE REASON FOR CHANGE 017029 To address root cause of boric MU40 is required to be closed, not The final resolution of the IR 92-019 acid addition from seat leakage MU363. condition report identified that 2/1011993 past MU23, a temporary MU40 was to be closed while procedure change was issued to performing recirculation of BAAT.

close manual isolation valve MU363 is not required to be MU363 when recirculating a closed.

BAAT. This was to provide an additional isolation to prevent inadvertent addition of boric acid to the makeup tank when the BAAT (Boric Acid Addition Tank) system is pressurized.

017069 To prevent future pressure The inlet isolations are kept This was a result of a condition Telecon NLD93-05186 transients from occurring, changes closed. report that requires that the CAC 4/01/1993 must be made to prevent a void (containment air cooler) operating from forming in the high elevations procedure be changed to have the of the piping or slowly collapse inlet isolations closed while the any voids formed. In the CAC is in Standby.

procedures, the inlet valves are kept open.

Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 24 of 34 COMMITMENT COMMITMENT NUMBER ISOURCE I DATE DESCRIPTION CHANGE REASON FOR CHANGE 017160 Increase the operating speed of The high speed stop for AFW This was a result of Engineering IR 93-009, Serial Letter 1-1014 AFW (auxiliary feedwater) Pump Pump 1-1 has been changed to Change Package 03-0411 (design 6/15/1993 1-1. This will raise the pump 3676 (3666 to 3686) rpm. change).

operating parameters to a point well above the minimum values such that instrument uncertainties are not significant. The high speed stop for AFW Pump 1-1 has been increased from 3600 to 3700 rpm.

017161 Increase the operating speed of Procedures were changed to This was a result of Engineering IR 93-009, Serial Letter 1-1014 AFW (auxiliary feedwater) Pump reflect that the high speed stop for Change Package 03-0411 (design 6/15/1993 1-1. This will raise the pump AFW Pump 1-1 has been changed change).

operating parameters to a point to 3676 (3666 to 3686) rpm.

well above the minimum values such that instrument uncertainties are not significant. Procedures will be revised to change the acceptance criteria for AFW pump testing to allow for instrument uncertainties and to specify that measured pump flow and discharge pressure will be used to demonstrate pump operability.

Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 25 of 34 COMMITMENT COMMITMENT NUMBER I SOURCE I DATE DESCRIPTION CHANGE REASON FOR CHANGE 017321, 017322 Locking mechanisms for the CAC Commitment closed. CAC SW Inlet Valves (SW64, LER 93-006, Serial Letter 1-1036 (containment air cooler) SW SW65, SW68, SW69, SW72, 3/14/1994 (service water) inlet valves will be SW73) were removed from the fabricated. Once fabrication is plant as a result of Boric Acid complete the valves will be locked Corrosion (Engineering Work open and controlled under the Package, EWR 02-0343-00).

Locked Valve program. Their removal facilitates deleting them from having to be locked open and controlled under the Locked Valve program.

017422 Develop more definitive The acceptance criteria was This was determined by adding a GL 89-013, IR 93-016 acceptance criteria for heat changed for ECCS RM CLRS calculated value from Proto-Power 12/29/1993 exchanger performance and (emergency core cooling system Calc #03-013 of 50 gpm, a system flow testing. (ECCS RM room coolers) to be greater than degradation due to fouling value of CLRS shall be greater than or 90 gpm. 15 gpm, instrument error value of equal to 100 gpm.) 22.9 gpm plus a rounding value of 2.1 for a total value of 90 gpm.

This is in compliance with UFSAR Table 9.2-1, Note 1.

9%

Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 26 of 34 COMMITMENT COMMITMENT NUMBER ISOURCE IDATE DESCRIPTION CHANGE REASON FOR CHANGE 017534 Upper management and quality Commitment closed. Preventive actions have remained Serial Letter 1-1036 assurance are involved in the as an integral part of the licensee 3/14/1994 timeliness of corrective actions for structure and the corrective significant conditions adverse to actions to prevent recurrence quality. have been effective. The Corrective Action Program addresses this as an integral part of the program.

017678 Modify procedure prerequisites to No trending is required for SFSEQ The SFSEQ 1, 2, 3, and 4 relays Serial Letter 1-1033 include PM test by voltage drop 1, 2, 3, and 4. are replaced every 24 months and 1/28/1994 measurements on these relays relay contacts are tested quarterly GE type HFA and SFSEQ 1, 2, 3, by voltage drop measurements

& 4 relays. Trending of (with zero voltage drop criteria degradation is required. specified) under the PM program.

Based on this conservative replacement interval, combined with quarterly testing of the relay contacts, no trending is required.

41I s Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 27 of 34 COMMITMENT COMMITMENT NUMBER I SOURCE I DATE DESCRIPTION CHANGE REASON FOR CHANGE 017843 A list of critical periodic tests has Remove DB-PF-03012, ECCS This procedure was upgraded to a IR 85-025 been compiled. These critical (emergency core cooling system) scheduled surveillance test and is 12/17/1985 periodic tests have been identified Integrated Train 2 Leakage Test, no longer a periodic test.

as "critical" on the ST/PT as a critical periodic test.

(surveillance tests/periodic tests) computer schedule.

017902 Improved 10CFR50.59 program An alternative to the computer- This is a process improvement.

IR 94-016, Serial Letter 1-1063 by implementing a new computer- based training was added. This 3/10/1995 based training program and alternative is an instructor-led revising the procedure and presentation. The site training screening form. section administers both courses.

Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 28 of 34 COMMITMENT COMMITMENT NUMBER ISOURCE IDATE DESCRIPTION CHANGE REASON FOR CHANGE 018733 The 18 month surveillance test The frequency was changed back The test frequency was changed LER 97-008 (SFAS Interchannel Logic Test) to monthly for SFAS. from monthly to quarterly in 4/17/1997 was performed and completed License Amendment 230. This satisfactorily with no equipment change was reported in the deficiencies. The combination of Commitment Change Summary this test and the existing quarterly Report (May, 1998 - May, 2000).

tests provide an overlapping This change of frequency applied check of all required two-out-of- to ARTS (anticipatory reactor trip four logic in the output modules of system) only. The SFAS SFAS (safety features actuation frequency remained monthly so system). The 18 month the commitment text was surveillance test will continue to corrected to reflect monthly for be performed on a quarterly SFAS and quarterly for ARTS.

frequency along with the quarterly tests so that a complete check of the two-out-of four logic gates in the individual SFAS output modules is performed.

019092 Procedure was revised to specify Deleted the specific survey This supports using new IR 97-012, Serial Letter 1-1144 the survey instrument to be instrument and added "use the equipment as existing instruments 12/4/1997 utilized, an Extender 2000W, and appropriate G-M tube survey become obsolete, like the to require two independent instrument". Extender 2000W.

radiological surveys for all radioactive material shipments.

Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 29 of 34 COMMITMENT COMMITMENT NUMBER I SOURCE I DATE DESCRIPTION CHANGE REASON FOR CHANGE 019094 The condition report process Commitment closed. This was a result of an analysis IR 97-009, Serial Letter 1-1142 procedure will ensure that a conducted under the Corrective 11/14/1997 condition report identifying an Action Program.

increase in CDF (core damage frequency) beyond the non-risk significant criteria defined in EPRI will be elevated to a category requiring management oversight.

019125 The condition report procedure Commitment closed. Preventive actions have remained Serial Letter 1-0658 requires the designated on-shift as an integral part of the licensee 8/29/1986 SRO to review each condition structure and the corrective report immediately after actions to prevent recurrence generation for conditions affecting have been effective. The plant operations. Corrective Action program covers this issue as an integral part of the program.

a, 1 Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 30 of 34 COMMITMENT COMMITMENT NUMBER I SOURCE I DATE DESCRIPTION CHANGE REASON FOR CHANGE 019129 Valves DH10 and DH26 were Commitment closed. The normal position of DH10 LER 97-016 verified to be in the correct changed from a closed valve to a 1/16/1998 position which satisfies SR 4.5.2. locked open valve and the normal These valves will be added to the position of DH26 changed to a monthly ECCS valve verification locked closed valve.

surveillance procedure.

019340 Additional enhancements will be Commitment closed. Current Quality Assurance audit IR 98-010, Serial Letter 1-1169 made to the current audit system is more rigorous and has 7/27/1998 schedule to separate certain more depth to ensure activities activities into audit separate from that require audit are the Radiation Protection audit. accomplished.

&ý Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 31 of 34 COMMITMENT COMMITMENT NUMBER I SOURCE I DATE DESCRIPTION CHANGE REASON FOR CHANGE 019383 Containment Emergency Sump Commitment closed. Lead bricks have been removed IR98-009, Serial Letter 1-1172 visual inspection procedure has from the Containment Emergency 8/27/1998 been changed to include a Sump.

verification of the lead brick placement and proper spacing.

019819 Specific guidance will be provided Commitment closed. The old backup method took a Serial Letter 2633 to control room operators to suction from the hot leg. This 3/15/2000 ensure that no vapor entrainment method is no longer used. A new will damage the DHR/LPI (decay boric acid precipitation control heat removal/low pressure method was installed in injection) pump [for the backup accordance with an NRC BPC (boric acid precipitation approved exemption request.

control) method].

..

mks Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 32 of 34 COMMITMENT COMMITMENT NUMBER I SOURCE I DATE DESCRIPTION CHANGE REASON FOR CHANGE 019821 During implementation of the Commitment closed. The old backup method took a Serial Letter 2633 planned plant modification... suction on the hot leg and pumped 3/15/2000 procedural controls will be highly borated water through the established to ensure that the DHR Heat Exchanger. This no CCW (component cooling water) longer occurs with the new inlet flow to the DHR (decay heat method. A new boric acid removal) cooler is at least 95 precipitation control method was degrees Fahrenheit prior to installed in accordance with an establishing the backup BPC NRC approved exemption (boric acid precipitation control) request.

method.

019938 Include in the Auxiliary Feedwater Operators will perform the drain Water level indicators were LER 00-005 System procedure the weekly whenever the water level reaches installed on the AFPTs so that 7/07/2000 drain evolution. The procedure 2 inches. Operators can monitor the casing has a signoff to throttle open the water level at least once per 12 10 valves needed to perform the hour shift in modes 1 through 3.

drain activities for both AFPT 1 The 2 inch level will indicate that and 2. Once each of the drains no water has yet accumulated in has been completed, a signoff and the casing of the AFPTs.

an Independent Verification are required for restoration.

AL Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 33 of 34 COMMITMENT COMMITMENT NUMBER I SOURCE I DATE DESCRIPTION CHANGE REASON FOR CHANGE 021100 Establish criteria and modify Structures are addressed This was to clarify the use of an IR 03-010, Serial Letter 1-1336 appropriate procedures to restrict differently than Systems and At-Risk Change with respect to 11/23/2003 the use of At-Risk Changes in the Components regarding inservice Structures, Systems, and plant modification process. At- and out of service. At-Risk Components (SSCs).

Risk Changes shall only be used Changes can be used to alter or to alter SSCs that are out of modify a Structure when the service and physically isolated design and licensing bases from electrical and mechanical functions of the Structure are sources. maintained for plant conditions while the At-Risk Change is being implemented.

X-% ,7' 0 Docket Number 50-346 License Number NPF-3 DAVIS-BESSE NUCLEAR POWER STATION Serial Number 3284 REGULATORY COMMITMENT CHANGE

SUMMARY

REPORT MAY 2002 - MAY 2006 Page 34 of 34 List of Abbreviations Used ANSI American Nuclear Standards Institute ASME American Society of Mechanical Engineers COA Course Of Action associated with June 9, 1985 Loss of Feedwater Event at Davis-Besse CREVS Control Room Emergency Ventilation System DH Decay Heat GL Nuclear Regulatory Commission Generic Letter HVAC Heating, Ventilation, and Air Conditioning IEB Nuclear Regulatory Commission Information Bulletin IR Nuclear Regulatory Commission Inspection Report LER Licensee Event Report MU Make-Up NRC Nuclear Regulatory Commission PM Preventive Maintenance SAP Acomputer application used to store information about plant equipment and plant maintenance activities SERIAL Letter from Davis-Besse Nuclear Power Station to Nuclear Regulatory Commission SRTP Pre-Startup System Review and Test Program SW Service Water UFSAR Updated Final Safety Analysis Report

Docket Number 50-346 License Number NPF-3 Serial Number 3284 Page 1 of 1 COMMITMENT LIST THE FOLLOWING LIST IDENTIFIES THOSE ACTIONS COMMITTED TO BY THE DAVIS-BESSE NUCLEAR POWER STATION (DBNPS) IN THIS DOCUMENT. ANY OTHER ACTIONS DISCUSSED IN THE SUBMITTAL REPRESENT INTENDED OR PLANNED ACTIONS BY THE DBNPS. THEY ARE DESCRIBED ONLY FOR INFORMATION AND ARE NOT REGULATORY COMMITMENTS. IF THERE ARE ANY QUESTIONS OR IF ADDITIONAL INFORMATION IS REQUIRED, PLEASE CONTACT MR. GREGORY A. DUNN, MANAGER- FENOC FLEET LICENSING (330) 315-7243.

COMMITMENTS DUE DATE None N/A