ML20043F609

Forwards Util Comments on NRC Insp Rept 50-346/90-12, Per 900601 Enforcement Conference Re Core Support Assembly Movement & Refueling Canal Draindown.Refueling Canal Draindown Procedure Provides Specific Draining Instructions

ML20043F609
Person / Time
Site:	Davis Besse
Issue date:	06/11/1990
From:	Shelton D TOLEDO EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
1-921, NUDOCS 9006150146
Download: ML20043F609 (3)

Text

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1 DONALD C. SHELTON

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j ' Serial Number 1-921 June 11. 1990 United States Nuclear Regulatory Commission Document Control Desk Vashington, D. C. 20555 Subj ec t: Toledo Rdison Comments on NRC Inspection Report Number 50-346/90012 Gentlemen:

During the June 1,.1990 Enforcement Conference regarding the Core Support

. Assembly (CSA) movement and the Refuuling Canal draindown, Toledo Edison provided clarifications and comments to NRC conclusions made in NRC Inspection l Report Number 50-346/90012 dated May 25, 1990. At the conclusion of the meeting, Toledo: Edison agreed to submit a letter documenting the issues-discussed. Attached are TE comments on-the inspection report.

'Should there by any questions concerning this matter, please contact Mr. R.~.V. Schrauder, Manager - Nuclear Licensing,-at (419) 249-2366.

Very truly youts, EBS/ssg-Attachment cc: P. M. Byron, DB-1 NRC Resident Inspector A. B. Davis, Regional Administrator NRC Region-III T. V.-Vambach, DB-l'NRC Project Manager I

9006150146 900611

'l p h PDR ADOCK 05000346 Q PDC p p- . THE TOLEDO EDlSON COMPANY EDtSON PLAZA 300 MADISON AVENUE TOLEDO. OHIO 43652

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' Docket Number 50-346 A '

. License Number NPF-3

-Serial Number 1-921 Attachment Page l'of 2 Comments on IR 50-346/90012 Toledo Edison provides the following comments to NRC Inspection Report Number 50-346/90012:

1. NRC Statement: (From page 8, 3rd paragraph)

"The normal method [for draindown] vas not utilized as the BVST recirculation pump vas out of service."

TE Response:

This statement is incorrect. The BVST recirculation pump was out of se: vi however, this had no impact on the decision to use the Decay Heat (Dh; p: " for draining the refueling canal. The DH pump vas used because it is < etble of draining the canal in a more timely manner. This method of draining was also used during the preivous refueling outage. The Refueling Canal draindown procedure (DR-0P-06023) provides specific instructions for draining the refueling canal using the DH pump,

2. NRC Statement: (From page 8, 4th paragraph)

"The operators were not aware of plant conditions."

TE Response:

This statement is misleading. As evidenced by the prompt act on taken, i

the operators were aware of general plant conditions but vere specifically not aware that the indexing fixture remained on the Reactor Vessel.

3. NRC Statement: (From page 8, 4th paragraph)

" Operational decisions were made by outage management."

TE Response:

This statement is incorrect. The detailed 6RF0 outage schedule consistently depicted the indexing fixture in place during the refueling canal draindown. Hisleading-information on the outage short interval overview schedule, provided at the Plan of the Day meeting for the time period of the draindovn, made it appear like the sequence had been changed. The schedule stated " install stairway / indexing fixture for shielding" after draining the refueling canal. This led operations personnel to believe that the indexing fixture had been removed but was intended to mean that the indexing fixture was al-2ady installed for shielding.

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, Lic:nsa Nu;b;r NPF-3 Serial Number 1-921

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!' .Page 2 of 2 .;

4. NRC Statement: (From page 8, 4th paragraph)

" Operators did not stop evolution to determine actual conditions, and did not assume responsibility."

TE Response:

This statement is misleading. When it was recognized.that the reactor vessel was draining more quickly than the' refueling canal the evolution was promptly stopped. Based on discussions with the Davis-Besse Senior Resident Inspector, both parts of this statement refer to operators not

-taking responsibility to stop the evolution once it was realized that level indicator LI-214 vas not reading accurately. Operators were aware j of the disparity between LI-214'and LI-1627 prior to the start of the i draindown. They assessed the level indicators available (LI-214, Refueling Canal Level Indicator LI-1627, and BVST Level Indicator) and determined that the draindown could be accornlished safely. Additionally, l personnel vere assigned to-visually monitor the progress of the draindown. 3 The accuracy of LI-214 had no bearing on this event. i l

5. NRC Statement:t '(From page 8, 4th paragraph) l "Operttors appeared to relegate their responsibilities." ,

I TE Responses- l Based on discussions at the Enforcement Conference, this statement refers ,

I to the Containment Coordinator visually observing the early stages of the draindown.- Toledo Edison reiterates that the operators did not relegate i their responsibility. The Shift Supervisor and Reactor Operator vere fully aware-that the draindown was their responsibility. They simply used competent resources available on-the shift to assist them in their duties.

This practice is also routinely employed-using systems engineers, chemistry and radiological controls personnel, and maintenance personnel, as' appropriate to the evolution, k

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