ML081650364

RAI Related to Improved Technical Specifications Conversion

ML081650364
Person / Time
Site:	Davis Besse
Issue date:	06/20/2008
From:	Wengert T J NRC/NRR/ADRO/DORL/LPLIII-2
To:	Allen B S 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, 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

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 exper ience 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 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.

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.