IR 05000346/1996009
| ML20128K806 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 10/04/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20128K795 | List: |
| References | |
| 50-346-96-09-EC, 50-346-96-9-EC, NUDOCS 9610110193 | |
| Download: ML20128K806 (24) | |
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l U. S. NUCLEAR REGULATORY COMMISSION
REGION III
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Docket No:
50-346 License No:
NPF-3 J
Report No:
50-346/96009
Licensee:
Toledo Edison Company
Facility:
Davis-Besse Nuclear Power Station
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Location:
5503 N. State Rte. 2 Oak Harbor, OH 43449 Date:
September 26, 1996 Inspector:
D. Schrum, Reactor Engineer Approved by:
R. N. Gardner, Chief Engineering Branch 2 Meetina Summary Enforcement Conference on September 26. 1996 (Report No. 50-346/96009(DRS))
Areas Discussed: Apparent violations identified during the inspection were discussed, along with corrective actions taken or planned by the licensee.
The apparent violations involved the failure to provide post-fire safe shutdown capability (normal shutdown path or an alternate path) which was free of fire damage and adequately protected in accordance with 10 CFR 50, Appendix R, Section III.G., " Fire Protection of Safe Shutdown capability."
9610110193 961004 Y
PDR ADOCK 05000346 G
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DETAILS
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Persons Present at Conference Centerior Energy / Toledo Edison
J. Wood, Vice President, Nuclear
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J. Lash, Plant Manager
B. Donnellon, Engineering Director J. Freels, Manager, Regulatory Affairs
J. Rogers, Manager, Plant Engineering
D. Lockwood, Compliance Supervisor C. Hennge, Plant Engineer T. Stallard, Operations Support
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Cleveland Electric Illuminatina Companv/ Perry K. Jury, Compliance Section Head L. McQuire, Design Engineering Commonwealth Edison Company D. Roberts, Fire Protection Engineer U. S. Nuclear Reaulatory Commission W. Axelson, Acting Deputy Regional Administrator, RIII B. Clayton, Acting Deputy Director, DRS, RIII R. Gardner, Chief, Engineering Branch 2, RIII G. Marcus, Project Director, NRR/PDIII-3 S. West, Chief, Plant Systems Branch, NRR D. Schrum, Regional Inspector, RIII P. Pelke, Enforcement Specialist, RIII M. Satorius, Office of Enforcement, NRR L. Gundrum, Project Manager, NRR S. Stasek, Davis-Besse Senior Resident Inspector K. Zellers, Davis-Besse Resident Inspector E. Schweibinz, Lead Engineer, RIII D. Butler, Regional Inspector, RIII M. Urano, Regional Inspector, RIII T. Tongue, Project Engineer, RIII K. Green-Bates, Regional Inspector, RIII II.
Enforcement Conference An enforcement conference was held in the NRC Region III office on September 26, 1996.
This conference was conducted as a result of the findings of an inspection conducted from June 24 to July 11 and August 14-15, 1996, in which apparent violations of NRC regulations were identified.
Inspection findings were documented in Inspection Report
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m No. 50-346/96008(DRS) transmitted to the licensee by letter dated
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September 12, 1996.
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The purpose of this conference was to discuss the apparent violations, l
root causes, contributing factors, and the licensee's corrective
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actions.
l During the enforcement conference, the licensee acknowledged the l
violations. The licensee's presentation included some new information, a synopsis of the issues, investigation results, safety significance, i
and corrective actions.
The NRC acknowledged the licensee's corrections i
to Inspection Report 50-346/96008. However, with respect to item 8 of
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the corrections, our inspection determined that the licensee's review of ins 92-18, 92-82, and 95-27 did not result in adequate responses to the issues discussed in the ins. A copy of the licensee's handout and inspection report corrections are attached to this report.
Attachments: As stated i
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Corrections to NRC Inspection Report No. 50-346/96008 (DRS):
1.
Page 2, Section F1.1.b, Third Paragraph:
Davis-Besse's initial evaluation of IN 92-18 was comoieted in April 1994.
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2.
Page 3, Section F1.1.b.1, item 2:
The circuit for HP 31 was not modified. Drawings were changed to show the breaker in the open position, depowering the MOV.
3.
Page 3, Section F1.1.b.1, item 2:
The sentence reading "This could result in the plant's subcooling margin being exceeded" should be changed to reflect that this is the
" minimum adeouate subcooling margin."
4.
Page 5, Section F1.1.b.3:
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The description for valve DH2733 should be changed to "DH Pump 1 Borated Water Storage Tank (BWST) Suction Valve."
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5.
Page 5, Section F1.1.b.3:
The description for valve SW1366 should be changed to " Containment Air Cooler (CAC) 1 in Isolation Valve."
6.
Page 5, Section F1.1.b.4, item 2:
The last sentence should read ".so ins were closed one to two years after they were issued." Furthermore, this paragraph implies that DB takes one to two years to review all ins, when in fact the average time for completion of an IN review has been 95 days (for ins issued since 1990).
7.
Page 7, Section F1.2.b, Fourth Paragraph:
The PORV Block Valve power circuitry is protected by radiant energy shields in the containment annulus, however no credit is taken in the analysis for this protection.
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Corrections to NRC Inspection Report No. 50-346/96008 (DRS):
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Page 7, Section F1.2.b.2, Second Paragraph:
Contrary to this paragraph, the ins associated with Thermo-Lag were reviewed in a timely manner (IN 92-82 review was completed in 73 days, and IN 95-27 review was completed in 118 days).
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Page 7, Section F1.2.c, Third Paragraph:
The compensatory actions for the containment and annulus radiant energy shields were implemented during the plant shutdown on
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April 8,1996, and were therefore in place when the conference call with the NRC occurred on April 16,1996.
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e, Page 2 DAvtsune esucuAn Powu suno
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Davis-Besse Xuclear Power Station Predecisional Enforcement Conference Presentation i
to the U.S. Xuclear Regulatory Commission i
September 26,1996 i
i GNTERIOR i
ENERGY i
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DISCUSSION TOPICS
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oVice President Introduction e Radiant Energy Shields e Motor Operated Valve (MOV)
Hot Shods
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DAVIS-BESSE NUCLEAR POWER STATION
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Radiant Energy Shields Introduction e
10 CFR 50 Appendix R, Fire Protection Program Radiant Energy Shields Required to Be Noncombustible
e DBNPS Installs Radiant Energy Shields Utilizing Thermo-Lag During 1990 Refueling Outage
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Containment Circuits
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- Containment Air Cooler Fans 1 and 3
- Pressurizer Level Channel 2 Annulus Circuits
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- Containment Air Cooler Fans 1 and 2
- Pressurizer Vent Line Stop Valve (RC200)
- RC Loop 2 High Point Vent Valve (RC4610A)
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- Pressurizer PORV (RC2A)
l e Thermo-Lag Believed to Meet Appendix R Requirements
"""E!vYacy DAVIS-BESSE NUCLEAR POWER STATION
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Radiant Energy Shields Introduction
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e NRC Bulletin 92-01 Dated June 24,1992 Addressed Thermo-Lag 1 and 3-Hour Rated Fire Barriers Compensatory Measures Required e NRC Information Notice 92-82 Dated Dec. 15,1992 j
Combustibility Issue Raised for Thermo-Lag Radiant Energy Shields
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e NRC Information Notice 95-27 Dated May 31,1995 n Industry-Sponsored Approach for Combustibility Rejected
Thermo-Lag Stated to Be Combustible i
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E[wS"acy
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Radiant Energy Shields IndustryInitiatives i
o Generic Fire Enc urance Testing i
e Chemical Com aosition Testing e Com austibility Evaluation Screening Guice j
o Development of New Fire Mocels and i
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Analysis Strategies e Formation of Inc ustry Task Forces and Working Groups
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$NYRGY DAVIS-BESSE NUCLEAR POWER STATION
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Radiant Energy Shields IndustryInitiatives o Key Players Individual Licensees
NRC Staff
NUMARC/NEl EPRI l
Winston and Strawn Vendors Fire Pro',cction Experts l
l herwrsgge, DAVIS-B ' 3SE NUCLEAR POWER STATION
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Radiant Energy Shields DBNPS Approach I
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i e Participation in Industry Initiatives
o Evaluation of Best Approach for DBNPS Upgrade Existing Barriers Based on Additional Testing Replace Thermo-Lag 'With Alternate Material i
Relocate or Modify Circuits Obtain Regulatory Relief Safe Shutdown Re-Analysis Credit Additional Operator Actions
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Radiant Energy Shields Missed Opportunities i
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e Compensatory Measures Not Established for Radiant Energy Shields i
Following Review of IN 92-82
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e Compensatory Measures Not
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Established for Radiant Energy Shielcs Following Review of IN 95-27 i
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Radiant Energy Shielc.s Compensatory Measures
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o Containment
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n Within one hour, establish a fire watch to inspect affected fire barrier at least once per eight hours, or n Monitor containment air temperature at least once per hour i
e Annulus
During Modes 3,4,5, or 6, within eight hours, establish a fire
watch to inspect affected fire barrier at least once per eight hours n During Modes 1 or 2, no inspection required due to ALARA concerns t
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Radiant Energy Shields Safety Significance
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e Low Probability Low Combustible Loading n Lack of Ignition Sources n Fire Detection With On-Site Fire Brigade Response Thermo-Lag Radiant Energy Shields Afford Some Protection Hourly Fire Watches iii Mechanical Penetration Room 4 n Manning of Areas During Refueling Outages e Minimal Consequences Cold Shutdown Can Be Attained Without Affected Equipment Reduced Risk During Plant Shutdown crursegn_
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e Radiant Energy Shields Corrective Actions
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e Additional Fire Watches Established During Shutdown for 10RFO L
o Compensatory Measures Established for Startup From 10RFO Containment Temperature Monitoring Annulus Video Camera
"EIEu"acs DAVIS-8 ESSE NUCLEAR POWER STATION
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Radiant Energy Shields CorrectiveActions e Com 3ensatory Measures WiI Continue Pending Achievement of Permanent Resolution Containment
- Replace With Alternate Material During Next Refueling Outage Annulus
- Eliminate Use of Radiant Energy Shields During Next f
Refueling Outage Via:
l e Installation of 3-Hour Rated Fire Barriers Using i
Alternate Materials, or
e Alternative Approach Such As Circuit Relocation crwrmgge
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MOV Hot Shorts Introduction
e IN 92-18 Issued February 28,1992 Regarding Hot j
Shorts for Control Room Fires e DB Evaluation of IN 92-18, Consistent With NUMARC Perspective and Due to the Low Probability, Decided That No Action Was Required e implementation of Generic Letter 89-10, Safety Related MOV Testing, Completed October,1995 e DB Informed by NRC March 20,1996 That NUMARC Position on IN 92-18 Is Not Acceptable l
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MOV Hot Shorts Safety significance
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e Low Pro 3 ability Event e Defense in Death Fire Detection
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Fire Suppression l
Control Room Continually Manned j
On-Site Fire Brigade Response
i Hourly Firewatches Throughout the Plant l
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MOV Hot Shorts Safety Significance o Minimal Consequences Operator Action i
- Symptom-Based Emergency Operating Procedures Mitigate the Event j
- Operator Training Emphasizes Symptom Mitigation
- Alternate Lineups Are Available e Simple; Generally Requiring One or Two Valve
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Manipulations
e Familiar; Operators Routinely Perform Manipuiations During Surveillance Testing
- Designated Safe Shutdown Equipment Operator No Pressure Boundary Integrity issues
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MOV Hot Shorts Corrective Actions
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e Corrective Action Document initiated Based on Reconsideration i
of IN 92-18 e Appropriate Compensatory Measures Verified to Be in Place
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e Expanded Scope of Review Included All Fire Areas 88 MOVs Evaluated (53 Additional MOVs)
47 MOVs Not Susceptible l
25 MOVs Eliminated by System Reanalyais n 16 Remaining MOVs Required Resolution
- Procedures modified for 6 MOVs to use alternate valves or flowpaths
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- 3 MOVs modified prior to restart
- 1 MOV depowered
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- 6 MOVs which are not time-line critical scheduled for resolution by end of 1996; compensatory measures established
" " EIwYacy DAVIS-BESSE NUCLEAR POWER STATION
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Root Cause
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e Focused on Long-Term Resolution anc
Prior Technical Positions During Evaluation o= IN 95-27 Failed to Consider Operability of Radiant Energy Shields
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e Focusec on Incustry Position of Low Pro 3 ability for MOV Hot Slorts Technical Review at the Time Was Deemed Adequate R
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Corrective Actions to Prevent L
Recurrence
i e Reaffirm Expectations Regarding Information i
Notice Evaluations
o Modified Information Notice Review Process
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to Utilize Corrective Action Process l
Prompt Operability and Reportability Review l
Structured Timeline for Resolution
Prompt Significance Review i
- Based on Significance, Actions Receive
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Multi-Discipline Review l
Independent Review at Closeout l
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Corrective Actions to Prevent Recurrence
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l e Planning an External Peer Assessment of Industry Experience Program (IN & OE)
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e Revisiting a Sample of Information Notice Responses Where Inc'ustry Guidance Was Usec
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