ML20043G781

Forwards Info Re Implementation of NUREG-0737,Item II.F.2, Inadequate Core Cooling Instrumentation, Per NRC 900214 Safety Evaluation.Item II.B.1 Issue Re Reactor Vessel Head Vent Also Considered to Be Closed

ML20043G781
Person / Time
Site:	Davis Besse
Issue date:	06/12/1990
From:	Shelton D TOLEDO EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.1, TASK-2.F.2, TASK-TM 1814, NUDOCS 9006210127
Download: ML20043G781 (6)

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I TOLEDO EDISON l s cewe ter tem I

DONALD C. SHELTON

n. n euw P"W "* "33 Docket Number 50-346 License Number NFF-3 L

Serial Number 1814 June 12, 1990 United States Nuclear Regulatory Commission ,

Document Control Desk Vashington, D. C. 20555 Subject : Implementation Letter Report for NUREG-0737, Item II.F.2, Inadequate Core Cooling Instrumentation Gentlemen: ,

In response to the Nuclear Regulatory Commission (NRC) " Order for Modification of License" dated December 10,1982 (Log Number 1157), Toledo Edison (TE) provided information regarding installation of instrumentation to detect and monitor inadequate core cooling (ICC) conditions at the Davis-Besse Nuclear Power Station by letters dated March 23, 1983 (Serial Number 924) and April -

15, 1983 (Serial Number 935). Additional information was provided by TE letters dated December 8, 1983 (Serial Number 1003), February 10, 1984 (Serial Number 1025) and March 9, 1984 (Serial Number 1031) in response to a NRC request for additional information dated September 6, 1983 (Log Number 1360).

The NRC issued its Safety Evaluation related to ICC instrumentation and the Reactor Vessel Head Vent (NUREG-0737, Items II.F.2 and II.B.1) on February 14, 1990 (Log Number 3169). Final approval of the ICC instrumentation was withheld pending NRC approval of the implementation letter report as cited in

• Enclosure 3 of NRC letter Log Number 1360. Toledo Edison herewith, in Attachment 1, provides the implementation letter report for NUREG-0737 Item II.F.2. As stated therein, TE requests NRC final approval of the ICC installation at Davis-Desse.

In addition, as addressed in the Safety Evaluation transmitted by NRC letter Log Number 3169, the Reactor Vessel Head-To-Hot Leg Vent Line (Continuous Vent Line), which satisfies the Reactor Vessel Level Indication issue of l NUREG-0737, Item II.F.2, also complies with the NUREG-0737 Item II.B.1 issue L

related to the Reactor Vessel Head Vent. Therefore, Toledo Edison considers

! thic item to be closed also, i

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1 g THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADfSON AVENUE TOLEOO, OHIO 4365d

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.If_you have any questions, please contact Mr. R. V. Schrauder,. Manager -

Nuclear Licensing, at (419) 249-2366.

Very trul yours, hND i

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-cci P.'M. Byron, DB-1 NRC Senior Resident Inspector i A..B. Davis, Regional Administrator, NRC Region III T. V. Vambach, DB-1 NRC Senior Project Manager t

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Docket Number $0-346 1

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- Attachment 1 -

Page 1 E 1mplementation Report for NUREG-0737, item II.F.2, Inadequate Core Cooling Instrumen. *lon ,

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In accordance with NRC letter Log Number 1360 dated September 6, 1983, the  !

following provides information concerning completion of implementation of NUREG-0737, Item II.F.2. The disposition is provided following the NRC '

implementation report item identification.

Item 1) Notification that the system installation, functional testing, and 1 calibration is complete and test results are available for inspection.  ;

TE Disposttion a) Subcooling Margin Monitoring System  ;

The Subcooling Margin Monitoring System (T-Sat Meters) was installed via Facility Change Request (FCR)79-439. Installation, functional testing, calibration, and post installation testing tesults  !

documentation is available for inspection.

b) Core Exit Thermocouples

'ITie Core Exit Thermocouple (CET) System meeting the requirements of NUREG-0737 was installed under FCR 80-115. This FCR mod sd the existing CET System to provide Class IE installation from the i containment penetrations to the Contr01 Room. Subsequent. separation and isolation necessary to make the total installation Class 10 and environmentally qualified (to meet Regulatory Guide 1.97. commitments  ;

made in TE letters Serial Number 1460, dated December 31, 1987, and ,

Serial Number 1542, dated June 9, 1988), including the CETs and the ',

cables from the CETs to the containment penetrations, vere provided  :

via FCR 84-049. Installation, functional testing and calibration are complete and post installation testing results documentation is available for inspection.

.c) Hot Leg Level Honitoring System -

Hot Leg Level Monitoring System (HLLMS) vas installed by FCR 80-269.

The Loop 1 hot leg level is calculated by and is available for display on the plant computer. Due to initial unavailability of i analog input points in the plant computer, the Loop 2 hot leg level calculation was implemented on the Data Acquisition and Display _

System (DADS). The hot leg level input for Loop 2 is presently being  ;

implemented on the plant computer. Both Loop 1 and Loop 2 hot leg

• level displays are available in the control room via DADS.

Installation, functional testing, calibration and post installation testing results documentation for the implemented portion of HLt.HS is available for inspection.

d) Reactor Coolant Pump Honitoring System  ;

The Reactor Coolant Pump Monitoring System (RCPHS) softvate t impl mentation (for calculation of void fraction at the suction of the Reactor Coolant Pumps) is complete. Documentation of  :

installation is available for inspection.

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Docket Nu;ber 50-346 License Nu;ber NPF-3 Serial Nu;ber 1814 Attachment 1  !

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e) Reactor Vessel Head-To-Ilot Leg Vent Line j The Continuous Reactor Vessel Head-to-Hot Leg Vent Line (Continuous -l Vent Line or CVL) was implemented via FCR 84 002. Documentation of s installation, functional testing and calibration results is available l for inspection. Performance testing at the Babcock and Vilcox (B&V) l Multi-Loop Integrated System Test (MIST) f acility (MIST Test Number '

370199) was provided by TE in-letter Serial Number 1543, dated August 23, 1988, and was evaluated and documented by NRC, in its Safety Evaluation for NUREG-0737, Item II.F.2, dated February 14, 1990 (Log _ j Number 3169), as acceptable.  ;

Item 2) Summary of licensee conclusions baced on test results, e.g.: l a) the system performs in accordance with design expectations and within design error tolerances; or  ;

, b) descriptions of deviaticns from design performance specifications l and basis for concluding th3t the deviations are acceptable, j t

TE Disposition a) The Subcooling Margin Monitoring System performs in accordance with design expectations.  ;

b) The Core Exit Thermocouple System performs in accordance with design expectations.

c) The flot Leg Level Monitoring System performs in accordance with design expectations.

• d) The Reactor Coolant Pump Monitoring Syste:a sof tware-is in accordance with design and provides information per expectations.  ;

e) Performance testing at the MIST facility, as cited above, has provided reasonable assurance that the Continuous Reactor Vensel llead-to-Hot Leg Vent Line vill perform in accordance with design expectations. >

Item 3) Description of any deviations of the as-built system from previous design descriptions with any appropriate explanation.

TE Disposition  ;

a) No deviations of the as-built Subcooling Marg.in Monitoring System t from the previous design descriptions have been identified. .*

b) No deviations of the as-built Core Exit Thermocouple System from the previous design descriptions have been identified, c) No deviations of the Hot Leg Level Monitoring System from the previons design descriptions, other than as described above (Item 1c)-

and which are being corrected, have been identified.

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,.. l Docket Number 50-346 Li t nse N cber NPF-3 Serial Nu:ber 1814 Attachment 1 I Page 3  :

i d) No deviations of the Reactor Coolant Pump Monitoring System from the previous design descriptions have been identified. ,

e) No deviations of the continuous Reactor Vessel Head-To-liot Leg Vent [

Line from the previous design descriptions have been identified.

Item 4) Request for modification of Technical Specifications to include all [

ICC instrumentation for accident monitoring. '

TE Disposition .;

Technical Specification modificatiors have not tieen requested to include ICC '

instrumentation for accident monitoting. Technical Specification modifications may be proposed as part of the Technical Specification l Improvement Program following its conclusion.

Item 5) Request for NRC approval of the plant-specific installation. f TE Disposition  ;

Toledo Edison herewith requests NRC approval of the ICC instrumentation installation at Davis-Besse. ,

Item 6) Confirm that the E0Ps (Emergency Operating Procedures ) used for operator training vill conform to the technical content of NRC approved E0P guidelines (generic or plant-specific). .

TE Disposition Symptom-based Emergency Operating Procedures (EOPs) were implemented at Davis-Besse in December 1984. The BW Ovner's Group developed Abnormal i Transient Operating Guides (ATOG) for each plant and Davis-Besse's E0Ps were based upon the Davis-Besse plant specific ATOG. Davis-Besse performed a.

verification and validation program when E0Ps were implemented in accordance with the Procedure Generation Package (PGP). In March 1987, Davis-Besse submitted an upgraded PGP to NRC and received a Safety Evaluation Report (SER)

(Log Number 2915) concerning the PGP on May 3, 1989. Revisions to Davis-Besse's E0Ps are performed in accordance with the upgraded verification <

and validation program described in the PGP.

A NRC inspection of the Davis-Besse's E0Ps (Inspection Report Number 50-346/89-06, Log Number 1-2085, dated May 3, 1989)' concluded that, vitbin the scope of the inspection, the E0Ps were found adequate for continued operation of the facility. Although this was a limited inspection no serious ptoblemn with ICC instrumentation vere identified. One comment on guidance for monitoring instrumentation for Inadequate Core Cooling (ICC) vas incorporated into the E0Ps by revision dated April 22, 1990, i.

M,.: Docket

• Nu;ber 50n346-l License Nu:ber NPF-3

, Serial' Number 1814

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Attachment 1.

Page 4-The B&V Owner'sLGroup has performed an E0P review to determine and identify any differences between the generic guidance. Technical Basis Document (TBD),

and each B&V plant's EOPs. This report was issued in March 1990. The report concludes that'the ICC section of the Davis-Besse E0Ps meets the intent of the guideline. The B&W Owner's Group plans to notify the NRC of the completion of

- the E0P Reviev Project as part of the Safety and Performance Improvement Program (SPIP) for B&V plants.

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