ML20115J707

Responds to NRC NOV Re Violations Noted in Integrated Insp Rept 50-346/96-02 on 960209-0410.C/A:emergency License Amend Requested Per 10CFR50.91(a) & Amend 208 to FOL Allowed Compliance W/Sr 4.5.2.b

ML20115J707
Person / Time
Site:	Davis Besse
Issue date:	07/15/1996
From:	Stetz J CENTERIOR ENERGY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
1-1103, NUDOCS 9607250015
Download: ML20115J707 (4)

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I CENTERf0R

% ENERGY 300 h h us John P. Slett 104edo, OH 43652-0001 Vice President - Nuclear 419-249-2300 mm Docket Number 50-346 License Number NPF-3 Serial Number 1-1103 July 15, 1996 United States Nuclear Regulatory Commission Document. Control Desk 1 l

Washington, D. C. 20555

Subject:

Response to Integrated Inspection Report 50-346/96002 Ladies and Gentlemen:

Toledo Edison has received the Notice of Violation (Log Number 1-3707) for the failure to satisfy the Davis-Besse Nuclear Power Station (DBNPS), Operating License, Appendix A, Technical Specification (TS) Surveillance requirement for venting High Pressure Injection (HPI) system piping which was discussed in Inspection Report 50-346/96002 (Log Number 1-3694). The response to this Notice of Violation is provided below.

Reply to a Notice of Violation (346/96002)

Alleced Violation During the Nuclear Regulatory Commission (NRC) inspection conducted from February 9 through April 10, 1996, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

A. 10 CFR 50.59(a) permits a licensee to make changes in the facility as  !

described in the safety analysis report, without prior Commission approval, unless the proposed change involves a change in the technical specifications incorporated in the license or an unreviewed safety l0 l

question.

[y]li 3 j 10 CFR 50.59 (b) (1) requires that a licensee maintain records of changes in I the facility made pursuant to this section, to the extent that these changes constitute changes in the facility as described in the safety analysis report. The records must include a written safety evaluation which provides the bases for the determination that the change does not  !

involve an unreviewed safety question. .

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Operating Componies Clevelond Electne liluminating Toledo Edison

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Docket Number 50-346 License Number NPF-3 Serial Number 1-1103 Page 2 The HPI System functional drawing is provided in Updated Safety Analysis Report (USAR) Figure 6.3-2.

Contrary to the above, on December 5, 1989, the licensee completed Safety Evaluation SE89-0245, for modification 99-066 (to re-route the normal HPI makeup discharge from HPI line 2A to HPt line 2B during the sixth refueling outage in 1990), and failed tc determine that the change )

involved a change in TS 4.5.2.b or an unreviewed safety question. (01013)

B. TS 3.5.2 requires that two independent Emergency Core Cooling System .

(ECCS) subsystems shall be operable in Modes 1, 2, and 3. TS 3.5.2.a I requires that with one ECCS subsystem inoperable, restore the inoperable subsystem to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> er be in Hot Shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

TS surveillance requirement 4.5.2.b requires that each ECCS subsystem j shall be demonecrated operable at least once per 18 months, or prior to operation after ECCS piping has been drained, by verifying that the ECCS  ;

piping is full of water by venting the discharge piping high points.

Contrary to the above from June 16, 1990, until March 4, 1996, while in l Modes 1, 2, and 3, HPI Train 2 (an ECCS subsystem) was inoperable because not all HPI Train 2 piping was verified to be full of water by venting the high points as required by TS 4.5.2.b, and action was not taken to restore the inoperable subsystem to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or to be in Hot Shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. (01023)

This is a Severity Level III problem (Supplement I).

Toledo Edison Resoonse

1. Reason for the Violation The reasons for these violations were reported in Licensee Event Report (LER) 346/96-001 (NP-33-96-001) dated April 3, 1996. Further discussion of the apparent causes for these violations occurred at a predecisional enforcement conference on May 23, 1996 which is documented in the NRC Predecisional Enforcement Conference Report Number 50-346/96004 (Log 1-3708) dated June 11, 1996,

2. Corrective Actions Taken and Results Achieved Corrective actions taken and results achieved were discussed in LER 346/96-001 and during the predecisional enforcement conference. In summary, an emergency license amendment was requested pursuant to 10 CFR 50. 91 (a) and Amendment 208 to the Facility Operating License was issued by the NRC on March 7, 1996, which allowed the facility to

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Docket Number 50-346 License Number NPF-3 Serial Number 1-1103 Page 3 be in compliance with Surveillance Requirement (S:R) 4.5.2.b. A plant modification to install a manual vent valve on the high point of HPI Line 2A down stream of valve HP2A outside of containment was implemented during the Tenth Refueling Outage (10RFO) which ended on June 2, 1996. Venting of the line was completed in accordance with the revised procedure, Venting of ECCS Piping (DB-SP-03212) prior to startup from the 10RFO.

3. Corrective Actions to Prevent Reccurrence As discussed in the LER and at the predecisional enforcement conference, several changes have occurred in the procedures and culture at the DBNPS since 1989, which should contribute to the prevention of this type of occurrence in the future. These include enhancements to the modification process and safety review / evaluation process along with greater experience and maturity within the engineering staff in the area of 10CFR50.59 evaluations.

This event has served to further raise the sensitivity of station personnel to the heightened focus regarding issues of compliance.

Subsequent Station Review Board determinations on a similar condition of compliance with regard to TS required testing of charcoal filters, described in Amendment 209 to the facility operating license, serves as an example of appropriate and conservative determinations with

regard to issues of compliance. During the conduct of the predecisional enforcement conference on May 23, 1996, Toledo Edison representatives stated their intent to further improve the station's sensitivity to compliance. This improvement will be fostered by providing training on compliance that provides a heightened sensitivity to recognize and implement requirements of the facility operating license and the station's licensing basis. Specific groups that will be targeted for this training are Operations, Plant Engineering, Design Basis Engineering, the Station Review Board, the Company Nuclear Review Board and Independent Safety Engineering.

Training of these targeted groups will be completed by October 18, 1996.

Also discussed at the predecisional enforcement conference was Toledo Edison's intent to further enhance the USAR, which is the cornerstone of the safety review and evaluation process. This enhancement will assist qualified personnel in preparing safety reviews and evaluations that address in a more complete manner the appropriate bases for changes made pursuant to 10 CFR 50.59. During the course of the required periodic update of the USAR, emphasis will be placed on identification and revision of USAR passages in which clarification or additional information will serve to more accurately reflect the DBNPS licensing basis. In accordance with 10CFR50.71(e) the next periodic update is required to be submitted no later than December 2, 1996.

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i Docket Number 50-346 i License Number NPF-3  ;

Serial Number 1-1103 i Page 4 .[

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4. Date When Full Compliance Will Be Achieved  !

Full compliance was achieved upon issuance of Amendment 208 to the  !

facility operating license on March 7, 1996. Continued compliance j was facilitated by addition of the manual vent valve to the HPI Line

• 2A and completion of the revised surveillance test prior to startup  !

from 10RFO. i Should you have any questions or re* quire additional information, please contact Mr. James L. Freels, Manager - Regulatory Affairs, at (419) 321-8466.

i Very truly yours, i

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cc: L. L. Gundrum, NRC Project Manager l H. J. Miller, Regional Administrator, NRC Region III  !

S, Stasek, DB-1 NRC Senior Resident Inspector Utility Radiological Safety Board i

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