ML19319B798
| ML19319B798 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 09/12/1978 |
| From: | Jeffery Grant TOLEDO EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19319B641 | List: |
| References | |
| NUDOCS 8001270264 | |
| Download: ML19319B798 (4) | |
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TOLEDO
% EDISON September 12, 1978 JAMES S. GRANT u, en,.a,n Docket No. 50-346
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License No. NPF-3 Serial No. 1-32 Mr. J.G. Keppler, Director U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Keppler:
Toledo Edison acknowledges receipt of your August 23, 1978 letter and enclosures Appendix A and Report 78-17, referencing apparent deviations from Davis-Besse Nuclear Power Station Unit 1 commitments to the NRC listed as " Infractions" in Appendix A.
Infraction:
1.
10 CFR 20.201(b) requires a licensee to make or cause t
to be made such surveys as may be necessary for him to comply with the regulations in 10 CFR Part 20.
Sec-tion 20.203(b) requires radiation areas be conspicuously posted.
Contrary to the above, surveys were not performed at the perimeter fence of the Rad Waste Storage Pad after addi-tional drums of compacted radioactive waste material were placed on the pad and existing drums rearranged on June 27, 1978.
Consequently, a 13 mr/hr radiation area exterior to the fence which resulted from the placeme.1t and re-arrangement of the drums was not posted as a radiation area.
Response
Corrective action Laken and results achieved.
Upon discovery of this condition, the drums were rearranged properly, the area was resurveyed and properly posted.
Corrective action to be taken to avoid further noncompliance.
This incident was reviewed with all Chemis ;y and Health Physics personnel, stressing the importance of radiation surveys and adherence to procedures.
The date when full compliance will be achieved.
Full compliance was achieved on July 5, 1978.
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Docket No. 50-346 Serial No. 1-32 September 12, 1978 Page 2 Infraction:
2.
Technical Specification 6.8.1 requires that written pro-cedures be established, implemented, and maintained covering the activities referenced below:
The applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, November, 1972.
Surveillance and test activities of safety-related equip-ment:
a.
Contrary to the above, Emergency Procedure EP 1202.03, Step 3.2, was not implemented in that the Auxiliary Transformer Breaker to 13.8 KV Bus was not opened l.clor to transferring unit loads to startup trans-formers when "A" bus transfer was first attempted on November 29, 1977.
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Response
Corrective action taken and results achieved.
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The individuals responsible for not following Step 3.2 of EP 1202.03 have been informed of the importance of adherence to procedures.
Corrective action taken to avoid further noncompliance.
Operators have been given a lecture on the incident and its consequences. As well as routing to concerned per-sonnel on a " Required Reading List," a description and analysis of the event. As a result of your inspector's concerns, a more detailed description of the event will be routed on a " Required Reading List."
The date when full compliance will be achieved.
Full compliance will be achieved by September 30, 1978.
b.
Contrary to the above, Test Procedure 800.00, Section 5.10, was not implemented in that the capability of the incore detectors for determining worst case thermal
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above 75% of rated power on January 20, 1978.
Response
Corrective action taken and results achieved.
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Corrective action in this case did not apply since the fuel loading was changed subsequent to 1/20/78.
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Mr. J.G. Keppler
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Docket No. 50-346 Serial No. 1-32 September 12, 1978 Page 3 Corrective action to be taken to avoid further noncompliance.
Administrative controls will be implemented which include:
1.
Improved criteria for determining incore failure.
2.
Guidance to insure conservative values are used for failed incore detectors in high power assemblies or other critical assemblies used for test data.
Personnel involved have been informed of the importance of adherence to procedures.
Date when full compliance will be achieved.
Full compliance will be achieved by October 15, 1,/8.
s c.
Contrary to the above, as of June 29, 1978, procedure
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AD 1801, Section 2.2.11, was not implemented in that
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the Company Nuclear Review Board had not reviewed any completed test results and reported its findings and recommendations to the Vice President Facilities De-velopment and the Station Superintendent.
Response
Corrective action taken and results achieved.
The CNRB has scheduled to review current and future Power Escalation Sequence Tests and report its findings and recommendations to the Vice President Facilities Develop-ment and the Station Superintendent.
Corrective action to be taken to avoid further noncompliance.
Individuals involved have been made aware of these require-ments.
The date when full compliance will be achieved.
Full compliance will be achieved within 30 days of the completion of the Power Escalation Sequence Testing and resolution of associated test deficiencies.
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Mr. J.G. Keppler Docket No. 50-346 Serial No. 1-32 September 12, 1978 Page 4 An overview of these infractions reveals they are generically instances of failure to follow procedures. This concern is being treated as described in our response of July 24, 1978 to Report 78-13, and as discussed in the NRC OIE Management Meeting of August 16, 1978.
Yours very truly, 5
3 James S. Grant Vice President, Energy Supply JSG/TDM/WHG/ daw l
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Docket No. 50-346
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Toledo Edison Company ATTN:
Mr. James S. Grant Vice President - Energy Supply Edison Plaza 300 Madison Avenue Toledo, OH 43652 Gentlemen:
This refers to the inspection conducted by Mr. J. S. Creswell of this office on Aprl1 4-7, May 17-19, 25, June 27-30, July 20-21, and July 27-28, 1978, of activities at Davis Besse Nuclear Plant authorized by NRC Operating License No. NPF-3 and to the discunion of our findings with Mr. T. Murray at the conclusion or the inspec-O tion.
The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.
During this inspection, certain of your activities appeared to be in noncompliance with NRC requirements, as described in the enclosed Appendix A.
This notice is sent to you pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulation?. Section 2.201 requires you to submit to this office within twenty days of your receipt of this notice a written statement or explanation in reply, including for each item of noncompliance: (1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further non-compliance; and (3) the date when full compliance will be achieved.
In our letter to you dated June 28, 1978, we brought to your attention instances which we considered were symptomatic of a general degradation in adherence to your management control systems. Appendix A to this letter identifies additional matters which we feel relate to our stated concern. Although Od a1 y
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Toledo zdison Co=pany AUG 231978 we recognise that the matters described in Appendix A to this letter occurred prior to your July 24, 1978, response to our June 28, 1978 letter, we expect you to factor them into your contina=f review and upgrading of your management controls.
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In accordance with Section 2.790 of the ERC's " Rules of Fractice,"
Part 2. Title 10 Code of Federal Regulations, a copy of this letter, the enclosures, and your response to this latter will be placed in the NRC's Public Document Room, except.as follows. If the enclosures contain information that you or your contractors believe to be pro-prietary, you must apply in writing to this offica, within twenty days of your receipt of this letter, to vf.hhold such information fron public disclosure. The application mast include a full statement of
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the reasons for which the information is considered propriatary, and abould be prepared so that proprietary information identified in the application is ecatafami in an==elasure to the application.
We will gladly dfme=== any questions you have concerning this inspection.
Sincerely, l
I James G. Kapplar Director Rncinsures:
1.
Appendix A, Notics of Violation 2.
IE Inspection Raport No. 50-346/78-17 cc w/==e1=:
Mr. T. D. Murray, Station fiuperintendent Central Files Reproduction Unit NRC 20b FDR I4 cal FDR NSIC TIC U. Young Fark, Powar Siting Commission l
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N Appendix A NOTICE OF VIOLATION Toledo Fdison Company Docket No. 50-346 Based on the inspection conducted on June 27-30, 1978, it appears that certain of your activities were in noncompliance with NRC requirements, as noted below. The two items are Infractions.
1.
10 CFR 20.201(b) requires a licensee to make or cause to be made such surveys as may be necessary for him to comply with the regulations in 10 CFR Part 20.
Section 20.203(b) requires radiation areas be conspicuously posted.
Contrary to the above, surveys were not performed at the per-imeter fence of the Rad Waste Storage Pad after additional drums of compacted radioactive waste material were placed on the pad and existing drums rearranged on June 27, 1978.
Con-sequently, a 13 mr/Hr radiation area exterior to the fence which resulted from the placement and rearrangement of the p
drums was not posted as a radiation area.
2.
Technical Specification 6.8.1 requires that written procedures be established, implemented and maintained covering the activ-ities referenced below:
The applicable procedures recommended in Appendix "A" of Regulatory Guide 1.3 3, November, 1972.
Surveillance and test activities of safety-related equipment.
Contrary to the above, Emergency Procedure EP 1202.03, a.
Step 3.2, was not implemented in that the Auxiliary Transformer Breaker to 13.8 KV Bus A was not opened
'1 prior to transferring unit loads to Startup Transformers when "A" bus transfer was first attempted on November 29, 1977.
b.
Contrary to the above, Test Procedure 800.00, Section 5.10 was not implemented in that the capability of the incore detectors for determining worst case thermal conditions was not verified prior to escalating power
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above 75% of rated power on January 20, 1978.
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2-i Appendix A c.
Contrary to the above, as of June 29, 1978, procedure AD 1801, Section 2.2.11, was not implemented in that the Company Nuclear Review Board had not reviewed any completed test results and reported its findings and recommendations to the Vice President Facilities Development and the Station Superiatendent.
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION III Report No. 50-346/78-1,7 Docket No. 50-346 License No. NPF-3 f
Licensee: Toledo Edison Company Edison Plaza 300 Madison Avenue Toledo, OH 43652 Facility Name: Davis-Besse Nuclear Power Station, Unit 1 Inspection At: Davis-Besse Site, Oak Harbor, OH Inspection Conducted: April 4-7, May 17-19, 25, June 27-30, July 20-21, and July 27-28, 1978 W
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J. S.
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G. Phillip 8
Y haw & S Approved By:
J. F. Streeter, Chief f"/b 78 Nuclear Support Section 1 Inspection Summary Inspection on April 4-7, May 17-19, 25, June 27-30, July 20-21 and 27-28,1978 (Report No. 50-346/78-17)
Areas Inspected: Routine, unannounced inspection of startup testing and tour of outside areas. The inspection involved 142 inspector-hours onsite by three NRC inspectors.
Results: Of the two areas, one item of noncompliance was identified in one area (Infraction - failure to conduct radiation surveys - Paragraph 7) and an item of noncompliance (Infraction - failure to follow procedures, Paragraphs 2, 5b and 6) were identified in the other area.
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