ML20062M482

Responds to NRC Re Violations Noted in IE Insp Rept 50-346/82-03.Corrective Actions:Fire Watch Established Until Obstruction Removed,Closure Mechanism Replaced & Combustibles Removed from safety-related Areas

ML20062M482
Person / Time
Site:	Davis Besse
Issue date:	04/30/1982
From:	Crouse R TOLEDO EDISON CO.
To:	Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20062M459	List: ML20062M482
References
1-263, NUDOCS 8208200116
Download: ML20062M482 (9)

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Docket No. 50-346 License No. NPF-3 TOLEDO

%ma EDISON Serial No. 1-263 RO4ARO P. CROUSE April 30, 1982 w e nvee<

%x%e (41912S9SM 1 Mr. C. E. Norelius, Director Division of Engineering and Technical Programs U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Norelius:

Toledo Edison acknowledges receipt of your April 1, 1982 letter (Log 1-609) and enclosures, Appendix, Notice of Violation and report 50-346/82-03 (DETP),

referencing various violations.

Following .an examination of the items of concern, Toledo Edison herein offers information regarding the items of violation.

Violation: Technical Specification Limiting Condition for Operation 3.7.10 requires that all penetration fire barriers protecting safety-related areas be functional at all times. If a penetration fire barrier is nonfunctional, a continuous fire watch must be es-tablished within one hour on at least one side of the af fected barrier.

Contrary to the above, on January 14 and 15, 1982, Fire Door Nos. 312, 319A, and 400 were observed in a nonfunctional condi-tion due either to obstruction or inoperable closure mechanism.

Although these fire doors protect areas containing cabling and/or equipment necessary f or caf e shutdown of the plant, no continuous fire watch was established on either side of the affected fire barrier.

Response: (1) Corrective action taken and results achieved - An investigation of our records indicated that Door No. 312 is not a designated fire door and further action is not-required.

Door No. 319A was obstructed as identified in the Notice of.

Violation. The responsible craf t foreman was contacted and the required fire watch established'until the obstruction was removed .

Door No. 400 did have an inoperable closure mechanism which had been identified previously by the Staton in DVR's 82-05 of 1-8-82 and 82-06 of 1-10-82. Work request 1C 104-22-82 was written on 1-13-82 to replace the existing closure mech- -f anism with a different type providing a stronger closing THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO. CHIO 43652 8208200116 820816 PDR ADOCK 05000346

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Docket No. 50-346 License No. NPF-3 Serial No. 1-263 Page 2 force. This was completed and the work request closed out on 1-15-82.

(2) Corrective action to be taken to avoid further noncompliance.

The Station has re-emphasized to all personnel the buportance of the proper use of fire barricr doors. All Station and Contractor department heads and foremen have been requested on various occasions to review with their assigned personnel the requirements for, and the procedures to be used concerning fire barrier doors (Station Superintendent memos ES1-1079 of 1-8-82 and 182-103A of 2-22-82). Written concurrence that these actions have been taken has been submitted by the various department heads.

In late February 1982, the Nuclear Training Department upgraded the General Orientation Training Program to elaborate on the hnportance of maintaining fire boundary integrity and the correct procedures to be followed with fire barrier penetrations.

A fire barrier door blockage in March, 1982 (See LER NP-33-82-16) resulted in disciplinary action being taken against the craft General Foreman and job foreman.

Station DVR's and LER's show a declir.ing trend in recent months over the December 1981 - January 1982 period in these types of violations as a result of the Station efforts to make the per-sonnel aware of the requirements for fire barrier integrity.

(3) The date then full compliance is achieved - The Station is pre-sently in full compliance of having all penetration fire barriers functional or a fire watch established.

Violation: Technical Specification 6.8.1.f requires that written procedures be established, hnplemented and maintained covering the fire protection program.

a. Administrative Procedure AD 1810.01, Control of Combustibles, requires that storage of combustible gases, lubricants, solvents, fuels, and paints shall be prohibited in safety-related areas.

Also, this procedure requires that all wood used in safety-related areas shall be treated with a flame retardant and that combustion waste, scrap, debris and oil resulting f rom a work activity shall be removed from the plant following the completion of the work activity or the end of ti.e shift, whichever is sooner.

l Contrary to the above, on January 13 and 14, 1982, between the hours of 1600 and 2000, the inspectors observed the following violations of these requirements:

Docket No. 50-346 License No. NPF-3 s Serial No. 1-263 Page 3 (1) Accumulations of combustible materials including untreated wood, rags, trash, cardboard and paper in the following selected areas:

No. 2 Diesel Generator Room and Day Tank Room No. 1 Diesel Generator Room No. 1, No. 3 and No. 4 Penetration Rooms "B" Battery Room and Low Voltage Switchgear Room Auxiliary Shutdown Panel Room (2) Storage or accumulations of flammable liquids and/or gases in the following selected areas:

No. 1 Diesel Generator Room No. 4 Mechanical Penetration Room Diesel Generator Corridor

b. Administrative Procedure AD 1844.00, Maintenance, requires that a fire watch continuously monitor an area for a minimum of thirty minutes following open flame, cutting grinding or welding work.

Contrary to the above, on January 15, 1982, during the lunch break, the inspectors observed that no fire watch was posted in the No. 2 Diesel Generator Day Tank Room where welding operations had been taking place prior to the lunch break.

c. Administrative Procedure AD 1828.20, Fire Brigade Training, requires that each fire brigade team participate in at least one-fire drill each calendar quarter.

Contrary to the above, fire brigade drills were not conducted in the-first and third quarters of 1981-for any of the fire brigades.

Responne: Item (a)

(1) Corrective action taken and results achieved - The particular-areas mentioned in the Notice of violation plus the balance of-plant safety related areas were walked down by'the cognizant maintenance management personnel and craft _ foremen,~and all-combustible materials, flammable liquids and untreated wood were removed.

(2) Corrective actions to be taken to avoid further noncompliance -

Station-Superintendent memo 182-103A, referenced above, also required that house-cleaning requirements and control of com-bustibles be addressed with all Station and construction per-sonnel.

. Additional steps taken to gear up-for.the-increased activities of' pre-outage and. outage' work involved several aspects. Plant

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I Docket Noe 50-346  :

I License No. NPF-3 Serial No. 1-263 3

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{ operators were instrucced to be more aware of housecleaning  :

4 and fire hazzard probJ ems during their normal plant tours.  ;

The Station Fire Protection Coordinator has increased the '

scope and number of his plant tours and has incorporated into his program tours by the Station and craft Safety Co-ordinators. In parallel the upgraded General Orientation  :

i Training Program now addresses this topic.

(3) The date when full compliance is achieved - The Station is

! presently in full compliance with the requirements of AD 1810. i 01, Control of Combustibles, i Item (b)

(1) Corrective action taken and results achieved - The responsible craft foreman was contacted and the required fire watch was established and maintained per AD 1844.00, Maintenance.

a (2) Corrective action to be taken to avoid further noncampliance -

The Station considers this an isolated incident and one that

! cccurred during that period' when increased pre-outage activity was taking place. The actions and training previously described will.also preclude recurrence of this noncompliance.

(3) The date when' full compliance is achieved - The Station ~is presently in full compliance with the requirements of AD 1848.00, Maintenance, concerning the' establishment of a fire watch, item (c)

(1) Corrective action taken and' results achieved - The Fire Pro-tection Coordinator was instructed to insure that all required fire brigade drills and training:are scheduled and completed, and the necessary critiques.and records properly documented.

(2) Corrective action to be taken to avoid further noncompliance -

The Fire Protection Coordinator will. submit fire brigade drill and practice schedule to the _ Operations Engineer. for advance

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planning and concurrence' of dates. This will prevent drills not being held due to other scheduled ~ activities.

(3) The date when full compliance will be achieved - The Station -

is presently :in full compliance with the requirement to. hold quarterly fire brigade drills.'

Violation: 10 CFR 50.48 states, in part, "Each' operating nuclear power plant-shall have a fire protection plan that satisfies Criterion 3 of Appendix A to this part. . . Appendix R to this part~ established fire protection features required to satisfy Criterion 3 of Appen-dix A to this part. . ."In areas of the plant where the protection

Docket No. 50-346 License No. NPF-3 Serial No. 1-263 Page 5 of systems whose function is required for hot shutdown does not satisf y the requirements of Paragraph G-2 of Section III of Appen-dix R to 10 CFR 50, Paragraph C.3 requires that alternative shut-down capability be provided independent of the area and that fire detection and fixed fire suppression systems be installed in the area.

Contrary to the above, the licensee did not provide a fixed fire suppression system in the control room which is an area that does not satisfy the hot shutdown protection requirements of 10 CFR 50, Appendix R, Section III.G.2, nor did the licensee submit a request f or exemption f rom this requirement as permitted in 10 CFR 50.48 (c)(6).

Response: (1) Correct-ive action taken and results achieved - A request for exenption f rom the requirement as permitted in 10 CFR 50.48 (c)(6) is currently being prepared by Nuclear Licensing. This request should be submitted to the NRC by May 1,1982.

(2) Corrective action to be taken to avoid further noncompliance -

In this instance additional action cannot be taken until our request for exemption is acted on by the NRC.

(3) The date when full compliance will be achieved - In this instance a date cannot be established. The matter of compliance will de-pend on the NRC action concerning our request for exemption.

Violation: Amendment No. 18 to License No. NPF-3 issued July 26, 1979, requires that the fire protection administrative controls be upgraded to bring them into conformance with the NRC guidance documents, " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance." The inplementation date for this modification was prior to startup af ter the 1980 refueling outage (approximately November 1, 1980).

Contrary to the above, the following fire protection administrative controls procedures have not been upgraded to bring them into con-formance with the NRC guidance document:

AD 1810.00 - Fire Protection Program AD 1810.01 - Control of Combustibles AD 1844.00 - Maintenance AD 1828.20 - Fire Brigade Training Response: (1) Corrective action taken and results achieved - A comprehensive review of the referenced Administrative Procedures was per-formed. It was determined that the problem identified in the violation does exist in part, but not to the extent implied by the wording of the violation. The referenced procedures were upgraded to the NRC guidance document, but in some instances not in sufficient detail.

Docket No. 50-346 License No. NPF-3 Serial No. 1-263 Page 6 AD 1810.00: It was stated that this procedure did not meet the requirement of paragraph 1.a of Attachment No. I to the guidance document. AD 1810.00, step 4.1 reiterates paragraph 1.a essentially word for word with the exception of the ref-erence to assessment. This will be added in'the current pro-cedure modification.

AD 1810.01: It was stated that this procedure did not meet the requirements of paragraph C of Attachement No. 3 to the guidance document. AD 1810.01, Control of Combustibles, step 3.2.5 does include the requirements of paragraph c.

AD 1844.00: It was' stated that this procedure did not meet the requirenents of paragraph 2.b(3) of Attachment No. 4 to the guidance document in that there was no requirement to maintain a fire watch for thirty minutes following the com-pletion of work to check for smoldering fires. -AD 1844.00, Maintenance, step 7.14.5.7 states "After an open flame, cutting, welding, or grinding,a person must continuously monitor the area for a minimum of thirty minutes to insure no sparks or hot spots exist which could turn into a fire."

It is felt this meets the intent of the requirement and Will in f act prevent a smoldering fire from occurring.

The referenced procedures-are in the process of revision to fully incorporate all the requirements of the NRC guidance document. This effort also includes the writing of a new procedure, AD 1810.04, Fire Prevention Qualification Program, to cover training of Contractor and Station personnel in basic fire fighting and prevention and qualification of fire watchers.

(2) Corrective action to be taken to avoid further noncompliance -

Review of the procedure modifications by _ the Station Staf f and -

by QA prior. to final approval and buplementation vill prevent' recurrence of this noncompliance.

(3) The date when f ull compliance .will- be achieved --The Station -

will be in full compliance when the referenced procedures =are approved for Unplanentation. All procedure revisions'will be completed and approved by July 16. 1982.

Violation: 10 CFR 50, Appendix B, Criterion XVI, requires 'that1 conditions ad--

verse to quality be promptly corrected.

Contrary to che above, the fire fighting practice-training for-the fire brigade was documented as being deficient in Toledo Edison Audit No. 729, dated August 20-22, 1980, and in Toledo Edison Audit No. 781, dated July 20-22, 1981, but the necessary corrective action had not

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Docket No. 50-346 License No. NPF-3 Serial No. 1-263 Page 7 been taken at the time of this inspection to upgrade the first fight-ing practice training program to satisfy the requiremants in Paragraph 2.0 of Attachment No. 2 to " Nuclear Plant Fire Protection Functional Responsibilities, Administrative Controls and Quality Assurance."

Response: (1) Corrective action taken and the results achieved - Within the past couple of months a trailer has been prcvided on site to construct an enclosed area with heat and smoke to simulate fighting fires under strenuous conditions.

Work request 82-1013-13 was issued on April 19, 1982 to modify the inside of the trailer provided. The modifications are to be done eccording to the guidelines provided by the Ohio Fire Academy in their booklet "The Situation Maze."

When complete this facility will be used to provide training with the use of self-contained breathing apparatus (SCBA), and in an enclosed environment.

(2) Corrective action to be taken to avoid further noncompliance -

The corrective action being taken will prevent further non-compliance as this action will satisfy the fire brigade train-ing requirement.

(3) The date when full compliance will be achieved - The Station will be in full compliance of upgrading the fire brigade practice training program by June 30, 1982 when the actions outlined in (1) abcve will be completed.

Violation: 10 CFR 50, Appendix B, Criterion XVIII, requires that a comrrehensive system of planned and periodic audits be carried out to verify com-pliance with all aspects of the quality assurance program.

Toledo Edison Company Nuclear Quality Assurance Procedure QAP 2180,

" Audits," states in part, "A comprehensive system of planned periodic audits to verify compliance with QA program requirements and to deter-mine QA program effectiveness shall be conducted. . . The goals of the audit system are. . . to provide an objective assessment of com-pliance with established requirements."

Docket No. 50-346 License No. NPF-3 Serial No. 1-263 Page 8 Toledo Edison Company Nuclear Quality Assurance Manual, Volume 1, Section 1.2.8, defines Audit Activity as " Documented QA/QC activities to determine, through investigation, the adequacy of, and adherence to... licensing requirements."

Contrary to the above, the quality assurance audits of the fire pro-tection program performed in June 19-26, 1979 (Audit No. 598) , April 21 - May 30, 1980 (Audit No. 666) and March _23-25, 1981 (Audit No.

744), only reviewed the adequacy of implementation of the existing plant procedures. Assessments were not made concerning the adequacy '

of those procedures utilizing the fire protection licensing require-ments as inspection guidance. This narrow. scope for the quality.

assurance audits permitted deficiencies in fire protection pro- ,

cedures to go undetected.

Response: (1) Corrective action taken and the results achieved . Toledo Edison utilizes a QA review of Station Administrative Procedures to '

verify that procedures satisfy the QA requirements ~npplicable to the particular Nuclear Safety Related activity. Audits are then utilized to verify that these procedures are being implemented. QA personnel have been-instructed to exercise greater care when reviewing Station Administrative Procedures-to ensure that QA requirements have been incorporated into the-appropriate procedure. ,

(2) Corrective action taken to avoid further noncompliance - The QA Director is preparing a memo to QA personnel reiterating the instructions referenced in (1) above to be more cognizant i'

of the QA requirements that should be covered when reviewing Station procedures. This memo will be distributed by April 30, ,

1982.

(3) The date when full compliance is achieved - The QA Department' ,

is presently in full compliance with the requirements of '

10 CFR 50, Appendix B, Criterion XVIII.-

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Very truly yours, .

YAf RPC/TDM/BJW/ daw m . .

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cc: DB-1 NRC Resident Inspector ,

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ATOMIC ENERGY ACT OF 1954 SECTION 182 SUBMITTAL IN RESPONSE FOR THE DAVIS-BESSE FUCLEAR POWER STATION UNIT 1 FACILITY OPERATING LICENSE NPF-3 This response is submitted in conformance with Atomic Energy Act of 1954, Section 182 relating to Mr. C. E. Norelius's letter of April 1, 1982.

This deals'with routine safety inspection (82-03) conducted by Messrs. J. A.

Crobe and R. Mendez.

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"Y 1 C. T. Daft, (uality Assurance Director Acting'on behalf of R. P. Crouse,

' Vice President, Nuclear h

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! Sworn to and subscribed before me this thirtieth: day of-Apr11; 1982. ' f -

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