ML20088A711
| ML20088A711 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 03/08/1984 |
| From: | Crouse R TOLEDO EDISON CO. |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20088A710 | List: |
| References | |
| 1-412, NUDOCS 8404130002 | |
| Download: ML20088A711 (4) | |
Text
_.
MREDO
%sm EDISON Docket No. 50-346
[, '"
naar
"" * " *22' License No. NPF-3 Serial No.~1-412 March 8, 1984 Mr. C. E. Nerelius, Director Division of Project and Resident Programs United States Nuclear Regulatory Commission Region III 799 Roosevelt Rd.
Glen Ellyn, Illinois 60137
Dear Mr. Norelius:
Toledo Edison acknowledges receipt of your February 7, 1984 letter (Log No. 1-912) and enclosures; Appendix, Notice of Violation; and report 50-346/83-24 (DPRP) referencing two apparent violations.
Following an examination of the items of concern, Toledo Edison herein offers information regarding these items:
1.
Violation: Technical Specification 6.8.1.a requires written procedures be established, implemented Lnd maintained covering the activities referenced in Appendix "A" of Regulatory Guide 1.33, November, 1972.
Regulatory Guide 1.33, November, 1972, Appendix A, Section 7.e(5) requires Radintion Protection Procedures be established, imolemented and maintained covering respiratory protection.
Health Physics Procedure HP 1605.02.11, Section 6.2.2.4, requires "Each individual certified to use respiratory protection equipment shall complete a refresher training session and be recertified annually."
Contrary to the above, a maintenance individual was authorized to use respiratory equipment by Chemistry and Health Physics Department in mid-December of 1983 even though the individual'r certification expired on October 26, 1983.
This is considered a Severity Level V violation.
gg4
' THE TOLEGO EO' SON COMPANY EOISON PLAZA 300 MADISON AVENUE TOLEDO, OHIO 43652 4130002 840404 n'
P ADOCK 05000346
_0 PDR 1
']
L
Dockat No. 50-346 g
License No. NPF-3 Serial No. 1-412 Page 2
Response
Toledo Edison does not concur with the referenced Notice of Violation. On December 20, 1983, it was necessary for a maintenance individual to perform a task requiring respiratory protection. The Health Physics Supervisor had a special training session conducted for the individual prior to performing the work. The special training session was equivalent to that given by the Nuclear Training Department for the work carried out on December 20, 1983. The individual's training records were updated to reflect the recertification.
Recognizing a deviation occurred from a strict administrative interpretation of Health Physics Procedure, HP 1604.02.11, Section 6.2.2.4 for requiring annual recertification, the full intent for providing respiratory training af ter one year was met.
Toledo Edison, therefore, requests that your office retract the item of violation in Inspection Report No. 50-346/83-24.
2.
Violation: 10 CFR 50, Appendix B, Criterion III, states in part that
" Measures shall be established to assure that applicable regulatory requirements and the design bases...are correctly translated into specifications, drawings, procedures, and instructions." Criterion also states, " Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design...."
Drawings M-190 and M-050 are shown as controlled in the licensee's drawing print index.
Contrary to the above, the licensee's design process has not ensured the information on controlled drawings is correct.
Examples:
(a) Piping Specification 602, an attachment to Drawing M-190, and the Updated Safety Analysis Report Table 6.3-2 are not in agreement. Table 6.3-2 states that the piping from the borated water storage tank to the high pressure injection suction check valves is rated at 75 psi /300*F versus 75 psi /150*F in Piping Specification 602. Table 6.3-2 states that the piping from the high pressure injection pump discharge to the discharge check valve is rated at 200 psi /300*F and then 3050 psi /300'F to the stop check valve.
Piping Specification 602 states that portions of the 3050 psi /300*F piping is 2000 psi /300*F.
L I
_a
.m
1 Dock 2t No. 50-346 g
License No. NPF-3 Serial No. 1-412 Page 3 (b) Drawing M-050, Steam Feed Rupture Control Systen logic diagram, was not annotated as requiring updating in the design work packages of FCR 80-042 and FCR 79-184 even though the logic of the system was modified by these FCRs.
This is considered a Severity Level IV violation.
Response: a.
(1) Corrective action taken and results achieved.
Bechtel has been requested to identify and resolve differences between the Updated Safety Analysis Report (USAR) and Plant Design Standard, Piping Class Summary Sheets, Drawing No. 12501-M-602, Rev. 6.
The USAR was first reviewed for areas where either design, operating or maximum pressures or temperatures for a piping system are mentioned. These pressures and/or temperatures were then compared to their corresponding values listed in drawing M-602.
Where inconsistercies were identified, a determination was made as to the correct conditions for the subject piping. A Facility Change Request (FCR) has been initiated to revise both documents.
(2) Corrective action taken to avoid further non-compliance.
A review of drawing M-602 and the Final Safety Analysis Report (FSAR) indicates that the two documents were never in agreement. As part of the FCR process, a review is conducted to determine whether the change affects the USAR and what sections are affected. The process for updating the USAR includes a review of FCR packages.
(3) Date when full compliance will be achieved.
Drawing No. 12501-M-602 will be revised by June 30, 1984. The USAR will be revised by the July 22, 1985 annual submittal in accordance with 10 CFR 50.71(e).
b.
(1) Corrective action taken and results achieved.
Drawing No. M-050, Main Steam Line and Main Feedwater Line Rupture Control System Logic, is not required for plant operations at Davis-Besse. Drawing No. M-050 has been removed from the controlled sticks and replaced with information only copies of the drawing, i
v.
?
Docket No. 50-346' License No. NPF-3 Serial No. 1-412 Page 4
~
(2) Corrective action taken to avoid further non-compliance.
See Item b. (1).
(3) Date when full compliance will be achieved.
Full compliance was achieved by December 31, 1983 when the controlled drawing was pulled and replaced with an information only copy. After the review mentioned in item 1 above is complete, Drawing No. M-050 will be updated and distributed in a controlled manner.
Very truly yours, MP h/%
RPC:SGW:lrh cc: - DB-1 NRC Resident Inepector O
=
9 8
-4; 3
- S [
1
. m.
M
.