ML20071B542
| ML20071B542 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 01/31/1983 |
| From: | Crouse R TOLEDO EDISON CO. |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20071B537 | List: |
| References | |
| 1-323, NUDOCS 8302280396 | |
| Download: ML20071B542 (3) | |
Text
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T Docket No. 50-346 79tgoo License No. NPF-3 Rmno P. CROUSE Serial No. 1-323 U. 7 N S422' January 31, 1983 Mr. C. E. Norelius, Director Division of Engineering & Technical Programs United States Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Norelius:
On December 10, 1982, Toledo Edison provided a response to your letter of November 3, 1982 (Log No. 1-702) and enclosures, Appendix, Notice of Violation and Report 50-346/82-21. This report referenced five apparent violations on the Davis-Besse Nuclear Power Station, Unit No. 1.
On January 5,1983, Toledo Edison received a phone call from your Mr.
Cordell Williams requesting a clarification of Toledo Edison's response to two of the five items. Following is our response, as per that request:
2b. Violation: Toledo Edison Nuclear Construction Department Procedure (NCDP) 6080.01, Revision 2, states in part, "Whenever an item is separated from its identification, such as...
Etting off a piece of cable from a reel, the identifi-cation such as a purchase order number...shall be j
transferred to each marked piece. Material not identified to the purchase order shall not be permitted to be used."
l Contrary to the above:
The licensee failed to take corrective action or establish measures to determine whether cables already cut from their reels, and issued under FCR numbers before March, 1982, could be identified or determine what impact this lack of identification could have on safety. The following cables were determined not to have traceability to a unique and specific document attesting to its quality: 2CINCRTMA, 2CINCRTMG, 2LPT4587A, ILPT4587B, 2LPT4586A, 2LPT4588B, 2CBF1285J, 2CBF1285M, ICV 40608AA, 2LTRC3A6B, 2LTRC3B6B 2LF4631M, 2LCT4594B, 2LLE4617C, ILLT4595A, and ILLI4595C.
This is a Severity Level IV violation (Supplement II).
THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO, OHIO 43652 8302280396 830224
'$ N PDR ADOCK 05000346
'96 o
'o Docket No. 50-346 License No. NPF-3 Serial No. 1-323 January 31, 1983 Page 2
Response
Toledo Edison ~ recognized the inherent weaknesses in our cable tra'ceability procedures and,'because of that, upgraded the procedures to assure complete traceability in March.-1982.
Although-the traceability of cables cut and issued prior to March, 1982, is difficult, there is sufficient traceability to assure appropriate quality..Therefore, Toledo Edison'does not feel any corrective' action is required.
- 3. Violation:
10 CFR 50, Appendix B, Criterion III, states in part,
" Measures shall be established to assure that applicable regulatory requirements and the design basis...for those structures, systems and components to which this appendix applies are correctly translated into specifications...
and instructions. These measures shall include provisions i
to assure that appropriate standards are specified and included in design documents and that deviations from 7
such standards are controlled."
Contrary to the above:
The licensee failed to implement measures to assure that applicable regulatory and design basis requirements were specified and that deviations from such standards were documented and controlled for certain Post-Three-Mile Island (TMI) modifications.
Removal of the seismic specifications from the procure -
l-ment documents for FCR's79-409, 79-425, and 79-430 were not accomplished in accordance with documented and
' approved procedures or instructions. Consequently, failure to document the design changes resulted in QA inspectors approving the instrumentation without the seismic qualifications, as required by NUREG-0737. The licensee failed to control design changes for the following instrumentation:
a.
Containment Wide Range Water Level Indication (FCR-79-409).
b.-
Containment Wide Range Pressure Indication (FCR-79-425).
c.
Safety Grade AFW Flow Indication (FCR-79-430).
This is a Severity Level IV Violation (Supplement II).
Docket No. 50-346 License No. NPF-3 Serial No. 1-323 January 31, 1983 Page 3 Response: (1) Corrective action taken and results achieved.
This situation was reported to Toledo Edison's Quality Assurance Department by NCR 82-464, thus documenting the lack of seismic specifications. Since there are no manufacturers who presently furnish seismically qualified instruments of the type required to meet Toledo Edison's commitment, an engineering evaluation was performed allowing the interim use of the instruments pending the completion of the manufacturers seismic qualification program. When seismic qualification documentation is received from the manufacturer.. NCR 82-464 will be closed out.
(2) Corrective action taken to avoid further non-compliance.
Supplier deviations, which are required for acceptance of an order, but which must be resolved prior to equipment / material operation, will be tracked using Toledo Edison's Supplier Deviation Report System. Appropriate procedures will be revised to address this situation.
(3) Date when full compliance will be achieved.
Procedure revisions will be accomplished prior to March 4, 1983.
L Very truly yours,
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l RPC:RFP:nif cc: DB-1 NRC Resident I spL tor l
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