ML040890175
| ML040890175 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 10/24/2003 |
| From: | Myers L FirstEnergy Nuclear Operating Co |
| To: | Caldwell J NRC/RGN-III |
| References | |
| 1-1330, IMC 0350 | |
| Download: ML040890175 (29) | |
Text
- 7 CahuA.4 5501 North Stare Route 2 lear operating company Oak Ha&& Ohio 43449 I i I /
L W J LewH?A&ers 419-321-7599 ChiefOperating Officer F a : 419-321-7582 Docket Number 50-346 License Number NPF-3 Serial Number 1-1330 October 24,2003 Mr. James L. Caldwell, Administrator United States Nuclear Regulatory Commission, Region I11 801 Wanenville Road Lisle, I11 60532-435 I
Subject:
Final Report: Results of the Extent of Condition Review, NRC IMC 0350 Restart Checklist Item 3.i, "Process for Ensuring Completeness and Accuracy of Required Records and Submittals to the NRC"
Dear Mr. Caldwell:
Enclosed is a copy of the final report summarizing the results of FirstEnergy Nuclear Operating Company's (FENOC) extent of condition review associated with Inspection Manual Chapter (IMC) 0350 Restart Checklist Item 3.i, "Process for Ensuring Completeness and Accuracy of Required Records and Submittals to the NRC."
FENOC performed an extent of condition review of a sample of submittals from the Davis-Besse Nuclear Power Station, Unit 1 (DBNPS) to the NRC, made between January 1996 and March 2002 (Completeness and Accuracy Review). This review consisted of verification of the statements of fact contained in the submittals in the sample population and resolution of discrepancies identified during the review.
Initially, the review identified that statements in six separate NRC submittals may have contained information that was not complete and accurate in all material respects as required by 10 CFR 50.9(a). It has been determined that none of the potential inaccuracies or omissions have significant implications for public health and safety or common defense and security, and therefore, the conditions were not reported under 10 CFR 50.9(b). However, in accordance with FENOC administrative procedures, those six submittals that contain potential incomplete or inaccurate information were reported in FENOC's letters dated July 15,2003 (FENOC letter Serial Number 1-1324), August 15,2003 (FENOC letter Serial Number 1-1325) and September 15, 2003 (FENOC letter Serial Number 1-1328). Upon further evaluation under the FENOC Corrective Action Program, however, FENOC has determined that of the six documents
Docket Number 50-346 License Number NPF-3 Serial Number 1-1330 Page 2 identified, four of the documents contain i all material respects.
One of these four incomplete or inaccuratc ed the apparent deletion of potentially critical information from the A e of Occurrence section of Licensee Event Report (LER)97-004 prior to the su information was deleted without sound basis and this deletion may have contribut being incomplete and inaccurate (ref: FENOC letter Serial Number 1-1325: ted FENOC to expand the scope of the Completeness and Accuracy 1 e focused review of select submittals. This focused review involved ether any other potentially incomplete or inaccurate information may tted or introduced during the development of submittals during the peril 996 to December 2000. The results of this focused review found several potentia pancies, none of which are material or reportable under 10 CFR 50.9(b).
FENOC either has taken or will take corre a result of the Completeness and Accuracy Review effort. For example, FE actions to ensure that future regulatory submittals are complete and accurate in all ts. In April 2003, the procedure for preparation of outgoing correspondence ta to require that the statements of fact for applicable regulatory submittals bc ed before the submittal can be issued.
Additionally, site supervisory personnel hi ining to ensure that they are cognizant of the requirements of 10 CFR cations of not complying with those requirements.
The Completeness and Accuracy Review j crutiny of over 2,200 statements of fact. Of those statements scrutinized, o ber (about 0.2 per cent) contain potentially material inaccuracies or omissi none was found to have significant implications for public health and safety o and security. These results indicate that there were no widespread noncomplia matic concerns associated with the preparation, review, and submittal of NRC DBNPS. Therefore, FENOC concludes that the results of this review, ir esults of FENOC's other activities under the Davis-Besse Return to easonable assurance that the plant can be restarted and will operate: (1) e public health and safety or common defense and security; and (2) in c mpliance with applicable NRC regulations and requirements.
Additionally, based upon the criteria estab FENOC will perform an expanded sample 53 submittals dated between January 1996 of the issues identified to date by the revie i
shed in th Completeness and Accuracy Project Plan, eview. TI is expanded sample review will consist of md March,2002. Based on the conclusion that none rs have si&ificant implications for public health and safety or common defense and security, th expanded Jsamplereview will be performed post-restart and will be completed by March 3 1 2004.
Qocket vumber 50-346 License Number " 7 - 3 ..'
Serial Number 1-1330 Page 3 If you have any questions or require further information, please contact Mr. Kevin L. Ostroswki, Manager-Regulatory Affairs, at (419) 32 1-8450.
Sincerely yours, cws Enclosures cc: USNRC Document Control Desk John A. Grobe, Chairman NRC 0350 Panel DB-1 Senior NRC/NRR Project Manager DB-1 Senior NRC Resident Inspector Utility Radiological Safety Board
Docket Number 50-346 License Number NPF-3 Serial Number 1-1330 FINAL REPORT: RESULTS 01 NRC IMC 0350 RE "PROCESS FOR ENSURING REQUIRED RECORDS I HE EX ENT OF CONDITION REVIEW, ART C CIUIST ITEM 3.1,
~ M P L $ ENESS AND ACCURACY OF (D SUB ITTALS TO THE NRC" iages follbw)
Docket Number 50-346 h e n s ; Number NPF-3 Serial Number 1-1330 Page 1 Results of 10 CFR 50.9 Extent of Condition (EOC) Review I. Purpose of 10 CFR 50.9 Completeness and Accuracy Review In Inspection Report 50-346/02-08 (dated October 2,2002), the U.S. Nuclear Regulatory Commission (NRC) identified several apparent violations of 10 CFR 50.9 involving documents that, based on information available at the time, contained information that was not complete and accurate in all material respects. To provide additional assurance that other documents provided to the NRC did not contain similar deficiencies, FirstEnergy Nuclear Operating Company (FENOC) performed a review of a sample of submittals from the Davis-Besse Nuclear Power Station, Unit 1 (DBNPS) to the NRC made between January 1996 and March 2002. The intent of this review is to provide additional assurance that prior NRC submittals are complete and accurate in all material respects. This review is part of item 3.i on the NRC's Restart Checklist:
"Process for Ensuring Completeness and Accuracy of Required Records and Submittals to the NRC," and is hereafter referred to as the Completeness and Accuracy Review.
- 11. Initial Completeness and Accuracy Review A. Review Methodology
- 1. Document Selection The initial review focused on submittals in the following categories:
Responses to NRC Generic Letters (GLs);
0 Responses to NRC Bulletins; 0 License Amendment Requests (LARs), including amendments to LARs and responses to requests for additional information; 0 Changes to licensing basis documents such as the Quality Assurance Program, Emergency Plan, and Security and Safeguards, and 0 Licensee Event Reports (LERs).
The review considered documents submitted to the NRC between January 1, 1996, and March 6,2002. The year 1996 was selected as the starting point because, as indicated in the Management and Human Performance Root Cause Analysis Report on the Failure to Identify the Reactor Pressure Vessel Head Degradation (August 13,2002), the change in safety focus at Davis-Besse appears to have begun in the mid-1 990s. March 6,2002, was selected as the terminal point because that was the date of discovery of the degradation of the Davis-Besse reactor pressure vessel (RPV) head.
Docket Number 50-346 License Number NPF-3 Serial Number 1- 1330 Page 2 Within each of the five c uments listed above, a 20 percent sample of documents was initial tailed scrutiny. The documents selected for detailed review were mart sample" using the following criteria:
0 Preference for doc technical or safety issues as distinct from administrati 0 Preference for do k-significant structures, systems, and components; and 0 Preference for d higher risk for an error based upon such s e d , short period available for paration of the document during a period In addition, several o re subsequently added to this review 0 Submittals prepa roved by individuals involved in a Bulletin 200 1-01; ses to the NRC's October 1996 CFR 50.54(f) Regarding the is Information"; and t
FENOC's response to 98-004, "Potential for Degradation of the Emergency Core Cooli System abd the Containment Spray System After a Loss-of-Coolant Accide t Because :of Construction and Protective Coating Deficiencies and Foreig Material iin Containment."
- 2. Process i
The Completeness and Acc acy Revim process is shown on Figure 1. Reviews were conducted by one or n @retechnioally competent individuals not involved in drafting, reviewing, or conc rring with the submittal under consideration. The review was performed in ac -lordance with DBNPS procedure NG-RA-00804, "NRC Communications," achment 2. After identification of the SOFs, t
technical reviewers determi ed whether each Statement of Fact (SOF) could be verified by a contemporane IJS source document. If contemporaneous information could not be lo&aited,more current information was used to substantiate the SOF. Exanlples of acceptable source documents discussed in Attachment 2 to NG-RA-OdB04 include:
0 Approved and controllei1 design documents, calculations, specifications, vendor manuals, or dradngs;
Docket Number 50-346 License Number NPF-3 Serial Number 1-1330 Page 3 0 Updated Safety Analysis Report, Technical Specifications, or system descriptions; approved procedures, program documents, policies, or standards; and 0 Approved modification packages, training records, Control Room logs, work orders, and Condition Report (CR) root cause analyses.
Reviewers were required to identify information that was inconsistent with a SOF, whether supporting documents included relevant information that was omitted fiom the document submitted to the NRC, and to determine whether subsequent correspondence with the NRC corrected any materially inaccurate or incomplete statements that were identified. Discrepancies were then entered into a Discrepancy Log.
Incomplete or inaccurate SOFs that were identified during this process were evaluated to make a determination of whether the inconsistent information would have been material to the NRC at the time they were made. The basis for this determination was then entered into a Discrepancy Log. Discrepancies were then reviewed by a multi-discipline team to determine the proper disposition. Those SOFs that were not considered material but required some corrective action were documented in a CR and addressed through the FENOC Corrective Action Program. Those SOFs considered to be material inaccuracies or omissions were also documented in a CR and the NRC notified in accordance with NG-RA-00804 and FENOC procedure NOP-LP-4007, "NRC Correspondence Review and Approval Process." In making these determinations, FENOC employed the definition of "materiality" endorsed by NRC case law and cited in the Statement of Considerations for Section 50.9: whether the information has a natural tendency or capability to influence an agency decision maker.l B. Site-Wide Questionnaires Through a questionnaire distributed via a site-wide e-mail, FENOC also requested personnel to identify any submittals to the NRC that may have contained incomplete or inaccurate information. These questionnaires identified a total of seven potential deficiencies. A review of these potential deficiencies showed that they had previously been identified in the FENOC Corrective Action Program. FENOC determined that none of the issues identified in the questionnaires were incomplete or inaccurate in any material respect or have a significant implication for public health and safety or common defense and security.
1 Virginia Electric & Power Company (North Anna Power Station, Units I and 2), CLI 22, 4 NRC 480 (1976), affd, 571 F.2d 1289 (4th Cir. 1978). See also 52 Fed. Reg. 49362,49363 (1987).
Docket Number 50-346 License Number NPF-3 Serial Number 1-1330 Page 4 1
C. Results An overview of the Completeness d Accuraqy Review results is shown on Table 1. A total of 70 documents were review during this process encompassing more than 2,200 SOFs. Technical reviewers generawd more thqn 200 discrepancies that ultimately resulted in the generation of 25 CR$. Of those CRs, FENOC initially determined that six concerned information that was not! omplete apd accurate in all material respects. Upon 1d fbrther evaluation, however, FEN0 determined that only four of the CRs actually concerned material inaccuracies an or OmissiQns(Le., approximately 0.2 percent of the SOFs). Table 2 is a summary of th /25 CRs. 4 s mentioned above, FENOC has initially determined that none of the issues i the 25 C$s have a significant implication for public health and safety or common defen 4: and security. If FENOC determines during the course of subsequent reviews that m y of the inpiccuracies and/or omissions are material or have a significant implication fo public health and safety or common defense and security, then FENOC will notify t 9 NRC in accordance with the applicable regulatory or FENOC administrative reportin tequiremeats.
I 111. Focused Reviews 1%-
During review of the licensing file for a Li bnsee Event Report (LER), FENOC identified the removal of a relevant statement from a dra of the regtulatory submittal. As a result of that omission, FENOC performed a focused re iew of othqr regulatory submittals dated January 1996 through December 2000. These dates refl qt the tenune of the individual who made the comment that resulted in removal of the relevant stat ent - Jaduary 1996 through December 2000.' The submittals reviewed were selected based o risk and safety-significance and fell into the following categories: I Responses to NRC Generic Letters; Responses to NRC Bulletins; LARs, including amendments to LARs ;and responses to requests for additional information; LERs;and Other submittals, such as responses to Ohe NRC's 1996 demand for information pursuant to 10 CFR 50.54(f) (and supplements), Inpxvice InspectiodInservice Testing (ISUIST), and others that may be considered to be risk and potentially safety significant submittals.
The methodology of the Focused Review i6 shown on Figure 2. The applicable licensing file for each submittal was reviewed to identify any comments made during the submittal approval process. If resolution of a comment resulted in a potential omission or inaccuracy in the submittal the issue was entered in a Potential Issues Log. FENOC then performed a more
'The individual responsible for the comm~ntis no longer employed by FENOC.
Docket Number 50-346 Eicensd Number NPF-3 Serial Number 1-1330 Page 5 detailed evaluation of the comment resolution. If FENOC determined that there was in fact an omission or inaccuracy, or if it could not be definitively determined, then a CR was generated.
A. Results of Focused Review A total of 286 documents were reviewed during this process. Nine potential issues were identified, ultimately resulting in the generation of three CRs; an additional CR, which addresses one of the potential issues, had already been generated. A summary of these results is shown in Table 3. FENOC determined that none of these CRs involved material inaccuracies or omissions. FENOC also determined that none of the issues in the four CRs have a significant implication for public health and safety or common defense and security. If FENOC determines during the course of subsequent reviews that any of the inaccuracies andor omissions are material or have a significant implication for public health and safety or common defense and security, then FENOC will notify the NRC in accordance with the applicable regulatory or FENOC administrative reporting requirements.
IV. Further Expansion of EOC Reviews The Project Plan requires FENOC to increase the review sample size if any of the original documents contained statements that are inaccurate or incomplete in any material respect. The Project Plan requires that the sample size for that category of documents be expanded to include another 20 percent. If more than one document in that category contained statements that are inaccurate or incomplete in any material respect, then the balance of documents within the category (submitted between January 1996 and March 2002) will be verified.
Consequently, based on the results discussed above, FENOC will perform additional reviews on the following documents:
I Licensee Event ReDorts 1 39(100)
License Amendment Requests 9 (20)
Responses to Generic Letters 5 (20)
Total: 53
Docket Number 50-346 License Number NPF-3 Serial Number 1-1330 Page 6 Review of these documents is not required rior to restart because as discussed in Section VI, none of the material omissionshnaccuracie it0 date have a significant implication for public health and safety or common FENOC plans to complete these expanded reviews by March 3 1,2004.
V. Corrective and Preventive Action1 FENOC has taken and will take several shok-term corrective actions as a result of the
I I 0 8 LLZ P!J3S TO-96 I8 !ln((It] LI ELSSO-EO 6L8PO-EO Z II 0-EOO-66-EE-dN 0 *all E00-66 H37 I 1 OOZSO-EO 1 L 0-SO0-86-EE-dN 0 AaX 500-616 2137 01 E6PSO-EO I I I L6EZ P!J% 8000-96 >IVI 0 11 SOLZ P!J% t.000-I O HV7 c ZPSSO-0 I 1s 0- COO E E-dN 0 A 3 I l E00-00 H3-I I
Docket Number 50-346 License Number NPF-3 Serial Number 1-1330 Page 9
- 22. Misc. Serial 2593 18 0
- 23. Misc. Serial 2602 3 1 03-055 18
- 24. Misc. Serial 2604 6 0
- 25. Misc. Serial 26 16 3 1 03-05224
- 26. Misc. Serial 2621 32 2 03-05428,03-05430
- 27. Misc. Serial 2622 43 0
- 28. Misc. Serial 2627 2 0
- 29. Misc. Serial 2629 2 0
- 30. Misc. Serial 2730 10 0
- 31. Misc. Serial 2736 25 1 03-05267
- 32. LAR 01-0004 Serial 2737 26 0
- 33. LAR 01-0004 Serial 2752 1 0
- 34. LAR 0 1-0004 Serial 2764 1 0
.."?-
Docket Number 50-346 License Number NPF-3 Serial Number 1- 1330 Page 10
. - .... I Serial 2552 28 0
- 51. I LER 98-001, Rev 1 INP-33-98-001-1 39 0 BL 96-02 /Serial 2443 I 3 - I
- 53. IBulletin
Response
- 55. GL ResDonse GL 88-14 Serial 1-861 18 2 03-06706,03-06796
- 56. GL Response GL 96-06 Serial 2409 0 0
- 57. GL Response GL 96-06 Serial 2439 24 0 GLRes onse GL 96-06 Serial 2442 134 1 03-05950 GLRes onse GL 96-06 Serial 2554 43 1 03-05951
- 60. GL Response GL 96-06 Serial 2582 61 1 03-05952 GL 97-01 Serial 2439a 0 0 GL 97-01 Serial 2472 5 0 63.
Miscellaneous I 2438 Serial 1-1244
-500 4 0 03-06790,03-06791, 03-07359 1 E-Plan Serial 253 1 26 0 Submittals
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Docket N u m b e r 50-346 L i c c rise N umber N P F- 3 Scrial Niimbcr 1-1330 Page 12 Table 2 Condition Reports Generated During Completeness and Accuracy Review Process ResolutionlCorrective;.kction::'- $ " .
CR No.
03-01 718 I<csponse to CL 98-004 re containment coatings is Prepare supplementary response to Yes inacc lira t c and/or i ncom p le te , GL 98-04.
03-04879 Failure to consider prcvious events or conditions involving Revision to Regulatory Affairs Yes sanic underlying concern in "Failure Data" Section of LER. guideline to include broader consideration of previous similar events.
Supplement LER 99-003 to reflect prior overcooling events.
03 - 05 3 00 Failure to considcr prcvious events or conditions involving The evcnt of LER 98-005 does not No I Sail-ic iitidei.I>ifig cuitccui i n "Failure Data" secrion of LEK. have underlying concerns or reasoris that are sufficiently similar to those of LER 96-01 0 or LER 95-003.
Thcrcfore, it is appropriate to exclude these LERs from the Failure Data section of LER 98-005.
Revision to Regulatory Affairs gu i de I i ne to i nc I iide broade r consideration of previous similar c ven ts .
Docket N m d x r 50-346 License Number NPF-3 Serial Number 1330 Page 13 C Discrepancy Descriptio Category*
13-05224 Error i n reporting number of FFD tests performed in early A double data entry was made on the NO D 1999. Monthly FFD Testing Log on a particiilar day. The correct number was in fact reported to the NRC.
Monthly log corrected.
32-05267 Kclief request incorrectly stated pipe size and wall Relief Request applied to pipe wall No' thickness for certain pipe classes. thickness only, not to pipe sizes (diameters).
EOC Technical Reviewer misinterpreted requirement; none required.
03-05426 Could not locate document to support statement concerning Supporting calculation was No A integrity of a valve's body-to-bonnet connection. determined to contain sufficient information to allow a knowledgeable individual to draw the con c I us ion .
Prepare written technical validation for statement made.
03-05428 Response to NRC RAI cited wrong attachment of an Procedural guidance existed, only No D em erge 17 cy procedure the reference to the location was in error.
Submit supplement to RAI to correct citation.
03 - 05 it 30 l x h of supporting documentation for PSA and associated Subsequent 1999 PSA update and No A calculations. separate documentation generated.
Docket Number 50-346 1,iccnse Number NPF-3 Serial Number 1-1 330 Page 14 Material?,
I Categoryt.,
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. I r
! a >?y
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- 9. 03-05468 Key statement removed from draft LER.
I A R misstated environtiietitally qualified life of several Supplement LER 97-004 to include omitted statement.
Supplement LAR 96-0008 to correct Yes Yes G
cr c 0 Ill po ne I1t s. inaccuracy.
1 1 . 03-05518 Miscliaracterizatioti of "normal" operating practice in relief The key point of the basis for the No A re (1 11e 5 t . Relief Request was the FENOC commitment to maintain RCS pressure above 200 psig with valves DH 1 I a d DH12 open for four 11 oii rs .
Supplement relief request to include o t i l i tt ed i t i forma t i o t i ; crea t e supporting written docurrtctttatturi and attach to CR.
I?. 03-05542 N o supporting documentation for statement in LER Supplement to LEK 00-003 may be No' C coiiccrtiiiig ability of pressure s\vitchcs to detect a steam required.
line break.
Could not locate vendor evaluation concerning prcssurixr Submit missing documents to No I:
o\ cr-cooling event. Records Management.
- 14. 03-05050 Response to G L 96-06 contained an ambiguous statement Statement correctly portrays the No A concerning pipe blockage or collapse. operational considerations of the service water system.
None required.
Docket Nuiiibcr 50-346 License Number NPF-3 Serial Number 1 - 1330
~1lcloslll-e 1 r-age 1 5
. . I . ,,
- I e . .
a,,., -,
_. . . DiscrepancyDesc Resolution/Corrective Action:
0-7-0595 I lies po 11s e to G L 96- 06 con t a i tied : Information provided to the N R C No E was judged to be accurate or 1 . Human crror/typographical error bounding .
- 3. I n cons istent IJ SA R descr i pt i oil.
0 3 - 05 95 9 L>ra\ving in responsc to GL 96-06 may be inaccurate. Inclusion ofthis detail had 110 effect No A on the evaluation performed due to the physical location of the details.
None required.
03-06706 Incorrect PM inspection frequency cited in response to Update response. No B GI, 88-14.
~~ ~~ ~
03-06790 Could not find supporting documentation re performance of Review determined that information No A design vcritication activities. provided is a minor discrepancy.
03-0679 1 Could not find supporting documentation re statement re Review determined that a No F Priority 1 drawings. nonconformance does not exist.
03-06796 Could not find supporting documentation re sizing of Under evaluation. No2 B safety-related accumulators.
03-07225 Statcment concerning valve rotor material removed from U ti der eva 1uat i o ti. No B draft s 11bin ittal .
~
03-07350 Co 11 Id not fi ti d s 11 p port i ng doc u mentation re agreement Under evaluation. N 0 C between controlled plant documents and actual configuration.
03-0762 1 Discrepancy in number of system reviews performed Under evaluation. No A
Docket Number 50-346 License Number NPF-3 Serial Number 1-1330 EnclosLlre 1 Page 16 24, 03-07621 Discrepancy in nunibcr of Design Basis Validation reviews Under evaluation. No' A perfor in ed .
1 5 . 03-07623 1 Could not locate support for the statement concerning Under evaluation. No2 H pcrli,rmance of staff reviews.
' C R addresses issiie(s) that w c r ~initially ' found to be matcrial, but upon further evaluation found not to be so.
'I ti it i a I i11ii t i o t i ; l'iirt h er c va I iiat i on is p I an n ed.
d c't c 1-111
Docket Numbcr 50-346 License Number NPF-3 Scrial Numbcr 1 3-30 Enclosurc 1 Page 17
- Legend for Table 2 Category Number of CKs Description A 8 Minor Technical or Factual Omission(s) 13 3 Condition Reports Remain Open C 2 Engineering/Operations Judgment D 2 Human Error E 1 Inadequate or Inconsistent Information F 4 Discrepancy Eliminated Upon Detailed Review G 4 Material Technical or Factual Omission 11 1 Inconclusive
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Docket Number 50-346 License Number NPF-3 Serial Number 1 - 1330 E11closurc 1 Page 19 Table 3 Overview of Focused Review Results Page' LLK 97-001. 3 Potent ial o miss io11. The statement deleted from the review and approval No KC\) 0. process does not affect the overall conclusion of the event reported in LER 97-004. The issue of whether the drawing shows the opening for the oil line would not have changed the description of the discrepancy identified in the LER.
LER 97-0 12 2 Comment removed reference. The statement deleted from review and approval No process does not affect the overall conclusion of the event reported in LER 97-012. Discussion of deviation from the USAR coinniitment to AISC would not have resulted in additional corrective action since the USAR deviation was a result of the issue.
LER 96-006 2 Statement removed from draft The statement deleted from review and approval No submittal. process does not affect the overall conclusion of the event reported in LER 97-006. Review of the NUREG 1022 supports the coiiclusion that this event is not reportable per 5 0.72(b)(2)(i).
Docket N ~ i i i i 50-346 b~
License Number NPF-3 Serial Nunibcr 1-1330 t.:nclosurc 1 Page 20 Document Page tial Is
- 4. Misc.-- 3 Comments not incorporated. The comments were not incorporated and therefore, did N o Iiesponse to not affect the submittal. Based on discussion with the Intcgrated commentor, the comments were considered as Inspcction recommendations and not necessary requirement.
Iicport 96002 ,
5, I.ER 96-003 4 co ni mcn t N ot 111corpo r ated . During interview, commenter stated that it was not a No requirement to state every potential cause and that in his view testing done in the warehouse was irrelevant to our faiIure 0p:cp<riy K?,rtdiKlrrtestinub in the field.
10 t c n t i ii 1 omission . CR 03-08069 was initiated for further investigation. NO 10 t c n t i a1 omission CR 03-08137 was initiated for further investigation NO C o ni nic n t i nap p ro p r i ate1y CR 03-04879 was generated on June 20,2003, No dispositioncd. generated during the SOF review. This CK documented a potential inaccuracy where the Failure Data of LEK 99-003 did not reference LER 98-0 1 1 (i.e., reference of an overcooling event that occurred with the last three years).
The CR investigation determined that the missing failure data represented at most an inaccuracy. but does not constitute a material issuo. No further action uas req uired.
Docket N\ItIlbcr 50--346 License Number NPF-3 Serial Numbcr 1 - 1330 Page 22 VI. Analysis of Results of Review FENOC perfbrnied extensive reviews on 7 0 regulatoiy submittals that contained over 2,200 SOFs. In addition, questionnaires were distributed via a site-wide e-mail, which requested personnel to identify any submittals to the NRC that may have contained incomplete or inaccurate information. The reviews and c p estionnaires resulted in the generation of 25 CRs. Of those CRs, FENOC initially determined thii 1 six concerned information that was not complete and accurate in all material respects. Upori further evaluation, honyever, FENOC determined that only four of the CRs actually involved material inaccuracies and/or omissions. Thus, only about 0.2 percent of the SOFs had a material inac:i,:uracyor omission. FENOC also determined that none of the issues in those CRs have a sigriificant implication for public health and safety or coininon defense and security under 10 CFR 50.9(b).
FENOC also performed a focused review 01286 documents that were prepared, revised, or submitted by an individual responsible for one of the material inaccuraciedomissions described above. Nine potential issues were identified during this review, ultimately resulting in the generation of three additional CRs. FENOC determined that none of these CRs involved material inaccuracies or omissions. FENOC also determined that none of the issues in these Focused Re\ iew CRs have a significant implication for public health and safety or common defense and security.
When considered together, the material in~iccuracies/crmissionsidentified during these reviews indicate that there ere no widespread noncotnpliances or programmatic concerns associated with the prep ara t i on , rev i ew , and subInit t a 1 0f reg u 1ati) ry co rrespo nd ence at Davi s-B esse.
Moreover, none of the identified issues havc a significant implication for public health and safety or common defense and security under 10 CFR 50.9(b). If FENOC determines during the course of subsequent reviews that any of the inacwracies and/or omissions are material or have a significant implication for public health aiicl safety or common defense and security, then FENOC \ t r i l l notify the NRC in accordance with the applicable regulatory or I-ENOC adini ni s trat i re port ing requi I-ements.
\re I n suininar~~, the reviews did not identify a n y ~ S L I C li;.iving S significant implications for public hea 1th and s a fet y or coin mo n defense and ,(;curity . 1: 11 rt h crniore, und er tlie Davis- I3 esse I i et LI rn to Service Plan, FENOC has conducted cslcmivc rcviews to \.erif). that its systems. programs, and organizations arc ready to support safc ,md reliable operation. Thcse t-cvic\vs included rev i e\x;s LI ndc I t h c S ys t em s EI c;i 1t 11 Ass III.;] I IC: e PI an to p rov i d c atid i t i o na 1 assu ra n c e t h ;i t p I a n t systems can perform their safety fiinctions. Givcn thi. results of the Coniplctcncss a n d !\ccui-acy Re\,iew togcthcr \\.it11 the rcsults of the rc\ Lc\vsunclcr the Rctut-ii to Ser\,icc Plan. there is rensonablc assurance tlie plant can be restal :cd a n d \vi11 opcratc: ( 1 ) \ \ - i t h u t endangering tlic piiblic health and safbty o r coiiinion dcfcn:..(and s c c ! . ity; ~ ~ a n d (7)in compliance \i,ith applicable N RC rcgii la t io tis and reqiii rcnicnts.
Docket Number 50-346 Lken'e Number NPF-3 Serial Number 1-1330 Page 23 Additionally, based upon the criteria established in the Completeness and Accuracy Project Plan, FENOC will perform an expanded sample review. This expanded sample review will consist of 53 submittals dated between January 1996 and March 2002. Based on the conclusion that none of the issues identified to date by the reviews have significant implications for public health and safety or common defense and security, the expanded sample review will be performed post-restart and will be completed by March 3 1,2004.
VII. Conclusions In performing the Completeness and Accuracy Review effort, FENOC has reviewed over 2,200 statements of fact in 70 documents and found only a small number of material inaccuracies or omissions. An additional review of comments and their resolution performed on approximately 286 documents determined that none of the potential issues identified involved material inaccuracies or omissions. None of the findings from these reviews has significant implications for public health and safety or common defense and security. Therefore, FENOC concludes that the results of this review and subsequent corrective actions, in conjunction with the results of FENOC's other activities under the Davis-Besse Return to Service Plan, provide reasonable assurance that the plant can be restarted and will operate: (1) without endangering the public health and safety or common defense and security; and (2) in compliance with applicable NRC regulations and requirements.
Docket Number 50-346 License Number NPF-3 Serial Number 1-1330 COMbIITMENT LIST THE FOLLOWING LIST IDENTIFIES THOSE ACTIONS COMMITTED TO BY THE DAVIS-BESSE NUCLEAR POWER STA."TION (DBNPS) IN THIS DOCUMENT. ANY OTHER ACTIONS DISCUSSED IN THE ISUBMITTAL REPRESENT INTENDED OR PLANNED ACTIONS BY THE DBNPS. "THEYA W DESCRIBED ONLY FOR INFORMATION AND ARE NOT REGULATORY COMMITMENTS. PLEASE NOTIFY THE MANAGER - REGULATORY AFFAIRS (4 19-321-8450) AT THE DBNPS OF ANY QUESTIONS REGARDING THIS DOCUMENT OR ANY ASSOCIATED REGULATORY COMMITMENTS.
COMMITMENTS DUE DATE As mentioned above, FENOC determined &at none of the issues in None the 25 CRs had a significant implication f h public health and safety or common defense and security. If FENdC determines during the P
course of subsequent reviews that any o f t e inaccuracies andor omissions are material or have a significaqi implication for public health and safety or common defense and security, then FENOC will notify the NRC in accordance with the apdlicable regulatory or administrative reporting requirements.
Consequently, based on the results discussed above, FENOC will March 3 1,2004 perform additional reviews on the following documents:
Document Type Number (percentage of total population)
Licensee Event Reports 39 (100)
License Amendment Requests 9 (20)
Responses to Generic Letters 5 (20)
Total: 53 Review of these documents is not required prior to restart because as discussed in Section VI, none of the material omissions/inaccuracies had a significant implication for public hed th and safety or common defense and security.
FENOC has taken several actions to ensurg that future regulatory Completed 4/18/2003 submittals are complete and accurate in all !materialrcspects. For (See CR 02-04914, example, DBNPS procedure NG-RA-00804 was revi.;ed in CA 5 )
April 2003 to require that the SOFs in appLicable regulatory submittals be DroDerlv validated before thz submittal can be issued.
Moreover, site supervisory personnel have heen given training to Completed 7/30/2003 ensure that they are cognizant of the requirements of 10 CFR 50.9 (See CR 02-04914, and the implications of not complying with those recpirements. CA 10)
COMMITMENTS DUE DATE In addition, and where applicable, FENOC will submit to the NRC None supplements of those documents found to be inaccurate or incomplete in some material respect.
New employees will also receive training on the requirements of Completed 8/20/2003 10 CFR 50.9 as part of their New Employee Orientation. (See CR 02-04914, CA 11)
New supervisory personnel will also be trained on management Completed 7/28/2003 responsibilities related to completeness and accuracy. (See CR 04914, CA 14)