ML20133B744
Text
<
/
%e UNITED STATES O
i,4 NUCLEAR REGULATORY COMMISSION h
,h $
WASHINGTON, D. C. 20555 e
/
July 5, 1985 MEMORANDUM FOR: Chairman Palladino FROM:
William J. Dircks Executive Director for Operations
SUBJECT:
RESPONSE TO CONGRESSMAN MARKEY'S LETTER OF JUNE 17 CONCERNING DAVIS-BESSE I am forwarding revised responses to several of the questions that Congressman Markey raised in his letter of June 17, 1985 concerning the June 9,1985 incident at the Davis-Besse reactor. These changes reflect a further staff review of the question package provided to you on June 28.
It is necessary to point out to you that these responses do not factor in the facts as will finally be detemined by the Task Force.
I anticipate that the report of the task force investigating the incident will be completed and made avail-able to the Comission by July 24.
We caution use or dissemination of this infomation until a more measured review of these questions can be accomplished.
I also bring to your attention that several of the documents provided in support of the attached response are marked proprietary and should not be released outside of the Subcomittee.
I i li kI Executive Director for Operations
Attachment:
As stated cc: Comissioner Asselstine Comissioner Bernthal Comissioner Zech Jame< Cutchin, OCM SECi OGC OPE 8510070102 850717 PDR COMMS NRCC CORRESPOPOENCE PDR
O'UESTION 1.
LIST EACH FAILURE THAT OCCURRED DURING THE DAVIS-BESSE INCIDENT INCLUDING:
(A)
THE CAUSE(S) 0F EACH FAILURE, (B)
THE INTENDED FUNCTION OF THE SYSTEM OR COMPONENT THAT FAILED,
- ANSWER, THE EQUIPMENT AND SYSTEMS LISTED BELOW ARE THOSE IDENTIFIED BY THE DAVIS-BESSE NRC FACT-FINDING TEAM AS INVOLVING A FA'! UP.t,. UNEXPECTED PERFORMANCE, OR CUESTIONS ABOUT ADEQUACY OF PERFORMANCE, AS A RESULT, THESE ITEMS HAVE BEEN PLACED IN CUARANTINE AND WILL BE THOROUGHLY EXAMINED'AND TESTED TO DETERMINE CAUSE OF FAILURE OR UNEXPECTED PERFORMANCE AND THE CONTRIBUTION, IF ANY, TO THE CONSECUENCES OF THE INCIDENT, THE TEAM REPORT WILL ADDRESS THE RESULTS OF THIS EFFORT, 1.
MAIN FEEDWATER PUMP TURBINE AND CONTROLS (SUPPLIES FEEDWATER TO THE STEAM GENERATORS WHERE IT IS CONVERTED TO STEAM)
m CUESTION 1 (CONTINUED) 2.
STEAM AND FEED WATER RUPTURE CONTROL SYSTEM AND ASSOCIATED INSTRUMENTATION CHANNELS (SYSTEM IS TO DETECT POSSIBLE RUPTURES OF STEAM LINES RESULTING IN LOW STEAM GENERATOR PRESSURE OR FEEDWATER LINES RESULTING IN LOW STEAM GENERATOR LEVEL AND INITIATE APPROPRIATE CORRECTIVE ACTION) 3.
AUXILIARY FEED PUMP TURBINES AND CONTROLS (PROVIDES FEEDWATER TO STEAM GENERATORS UNDER EMERGENCY CONDITIONS) 4.
MAIN STEAMLINE ISOLATION VALVES INCLUDING CONTROLS, ACTUATING CIRCUITS, PNEUMATIC SUPPLIES (THESE VALVES ISOLATE THE STEAM GENERATORS IN CASE OF A STEAMLINE RUPTURE TO PREVENT OVERC00 LING OF THE REACTOR) 5.
STARTUP FEED VALVE SP-7A AND CONTROLS (THIS VALVE CONTROLS FLOW FROM THE STARTUP FEEDWATER' PUMP TO STEAM GENERATOR NO. 2) 6.
SOURCE RANGE INSTRUMENT CHANNELS (THIS INSTRUMEf;TATION MONITORS NEUTRONIC CONDITIONS 0F THE CORE UNDER STARTUP OR SHUTDOWN CONDITIONS) u e
.a-
A k
CbE5 TION 1.(CONTINUED) l 7.
TURBINE BYPASS VALVE SP-13A2 (THIS VALVE ALLOWS STEAM TO BYPASS OR DIVERT AROUND THE MAIN TURBINE TO THE CONDENSER.
IT IS USED DURING STARTUP OR UNDER CONDITIONS WHERE THERE IS A MISMATCH BETWEEN TURBINE LOAD AND REACTOR POWER)
J 8.
STEAM TRAPS AND DRAIN VALVES (THESE COMPONENTS PERMIT CONDENSATE TO BE ELIMINATED FROM THE MAIN STEAMLINES) 1 9.
POWER OPERATED RELIEF VALVE, CONTROLS AND ACTUATION SYSTEM (THIS VALVE ALLOWS REACTOR PRESSURE TO BE DECREASED BY VENTING OF THE VAPOR IN THE PRESSURIZER) 10.
MAIN STEAM SAFETY VALVES AND ATMOSPHERIC VENT VALVES (THESE VALVES PROVIDE OVERPRESSURE PROTECTION TO THE MAIN STEAMLINES) 11.
AF 599 AND AF 608 VALVES, ACTUATORS AND' CONTROLS (THESE VALVES SERVE AS THE CONTAINMENT ISOLATION VALVES FOR THE TWO TRAINS OF THE AUXILIARY FEEDWATER SYSTEM) 12.. VALVE MS'106 AND CONTROLS (THIS VALVE CONTROLS STEAM FLOW TO THE AUXILIARY '
FEEDWATER PUMP TURBINE NO. 1)
T .,
\\
T s-
OUE5 TION 1 (CONTINUdD) '
13.
SERVICE WATER VALVE AND CONTROLS ON AFW ALTERNATE SUPPLY (THIS VALVE ALLOWS THE AFW PUMP TO DRAW WATER FROM AN ALTERATE SUPPLY SOURCE, I.E., THE SERVICE WATER SYSTEM RATHER THAN THE CONDENSATE STORAGE TANK)
-l IN ADDITION T0,THE ABOVE EQUIPMENT UNCERTAINTIES, AN OPERATOR ERROR HAS ALS0'BEEN IDENTIFIED, WHEN THE CONTROL ROOM OPERATOR ATTEMPTED TO PANUALLY INITIATE THE STEAM FEED-WATER RU'PTURE CONTROL SYSTEM, (SFRCS), HE INCORRECTLY ACTUATED THE SFRCS ON LOW STEAM PRESSURE INSTEAD OF THE DESIRED LOW STEAM GENERATOR LEVEL.
THIS ERROR WAS PROMPTLY DETECTED AND RECOVERY ACTION WAS INITIATED.
i i
V QUESTION 2.
BASED ON PROBABILISTIC RISK ANALYSES AND PRECURSOR DATA PRIOR TO THE DAVIS-BESSE INCIDENT, WHAT WAS THE ESTIMATED PROBABILITY OF THE FOLLOWING:
A.
LOSS OF MAIN FEEDWATER; B.
LOSS OF MAIN FEEDWATER AND LOSS OF AUXILIARY FEEDWATER; C.
FAILURE OF PORV TO CLOSE; D.
EACH OTHER FAILURE THAT OCCURRED DURING THE INCIDENT; E.
THE COMBINATION OF ALL THE FAILURES THAT OCCURRED DURING THE INCIDENT.
ANSWER.
NO OVERALL PROBABILISTIC RISK ASSESSMENT OF DAVIS-BESSE HAS BEEN DONE BY, OR SUBMITTED T0, THE NRC STAFF.
THE NRC HAS RECEIVED TWO PLANT-SPECIFIC RELIABILITY ANALYSES OF THE DAVIS-BESSE AUXILIARY FEEDWATER SYSTEM, THE MOST RECENT DONE BY EDS FOR TOLEDO EDISON AND SUBMITTED TO THE NRC IN DECEMBER 1981.
AN INDEPENDENT ESTIMATE OF THE FAILURE PROBABILITY OF THE
CUESTTON 2. (CONTINUED) DhyIS-BESSEAFWSYSTEMHASBEENMADEFORTHENRCBYBROOKHAVEN NATIONAL LABORATORY, NONE OF THESE ANALYSES COVER MANY OF THE OTHER SYSTEMS OR COMPONENTS INVOLVED IN THE INCIDENT OF JUNE 9.
NONE OF THE STUDIES REFLECT PRECURSOR PLANT SPECIFIC FAILURES EXPERIENCE RELATED TO THE JUNE 9 EVENT.
BECAUSE OF THESE LIMITATIONS, THE ESTIMATES PROVIDED BELOW SHOULD BE REGARDED AS VERY ROUGH, PRELIMINARY ESTIMATES THAT MAY NOT REFLECT THE PARTICULARS OF THE DAVIS-BESSE DESIGN OR OPERATING EXPERIENCE.
A.
LOSS OF MAIN FEEDWATER:
COMPLETE INTERRUPTIONS OF MAIN CEEDWATER OCCUR ROUGHLY ONCE PER REACTOR YEAR OR LESS
- IN MOST PLANTS, A SUBSTANTIAL FRACTION OF THESE ARE RESTORABLE IN TIfiE TO AVERT A CRITICAL DEMAND FOR ALTERNATIVE COOLING.
'" AUXILIARY FEEDWATER RELIABILITY ANALYSIS - FINAL REPORT,"
SUBMITTED WITH TOLEDO EDISON CO. LETTER, DECEMBER 31, 1981: AND INTERNAL STAFF MEMORANDUM, A. THADANI TO 0. PARR, " AUXILIARY FEEDWATER SYSTEMS - CRGR PACKAGE," NOVEMBER 9, 1984, I
I
I QUESTION 2 (CONT.). B.
LOSS OF MAIN AND AUXILIARY FEEDWATER:
SUSTAINED (CRITICAL) FAILURES OF MAIN AND AUXILIARY FEED-WATER ARE ESTIMATED TO HAVE A FREQUENCY IN THE RANGE OF TWO-IN A THOUSAND TO ONE-IN-TEN-THOUSAND PER YEAR.*
BRIEF FAILURES OF THE KIND THAT OCCURRED ARE KNOWN TO BE MORE FREQUENT THAN SUSTAINED FAILURES, BUT NO ESTIMATE HAS BEEN MADE OF THE FREQUENCY OF BRIEF FAILURES.
C.
FAILURE OF PORV TO CLOSE:
THE INDUSTRY AVERAGE PROBABILITY OF A PORV TO STICK OPEN IS ROUGHLY 0.02 PER CHALLENGE.**
FOR A SEQUENCE OF EVENTS IN WHICH THE PORV LIFTS THREE TIMES, WE WOULD THUS EXPECT A SIX-PERCENT CHANCE THAT IT WOULD STICK OPEN.
D.
EACH OTHER FAILURE THAT OCCURRED DURING THE INCIDENT:
ONE CHANNEL OF THE SOURCE RANGE NUCLEAR INSTRUMENTATION AND THE SAFETY PARAMETER DISPLAY SYSTEM ARE THOUGHT TO
- MEMORANDUM A. THADANI TO 0. PARR, " ADDITIONAL INFORAMTinN FOR THE AUXILLIARY FEEDWATER SYSTEM CRGR PACKAGE," JANUARY 16, 1984.
- NUREG-0560, P. 3-14.
r-l l
l QUESTION 2 (CONT,). I HAVE BEEN INOPERABLE AT THE TIME.
THE OTHER SOURCE RANGE CHANNEL IS THOUGHT TO HAVE FAILED ON DEMAND.
PROBABILITY ESTIMATES ARE UNAVAILABLE FOR SUCH EVENTS.
IT IS NOT UNUSUAL OR UNEXPECTED THAT SOME SAFETY-RELATED COMPONENTS BE OUT OF SERVICE FOR TEST AND MAINTENANCE, S0 PERIPHERAL FAULTS OF THIS KIND ARE NOT UNLIKELY.
E.
PROBABILITY OF THE COMBINATION OF ALL THE FAILURES THAT OCCURRED DURING THE INCIDENT:
NO ESTIMATE THAT CAPTURES THE PARTICULARS OF THE INCIDENT IS AVAILABLE.
COMMISSIONER ASSELSTINE ADDS THE FOLLOWING:
THE QUESTION IS STRAIGHTFORWARD BUT THE COMMISSION, WHICH GIVES SUBSTANTIAL SIGNIFICANCE TO PROBABILISTIC PISK ASSESSMENTS, QUANTITATIVE COST-BENEFIT ANALYSES AND CUANTITATIVE SAFETY GOALS CAN NOT COME UP WITH SIMPLE FAILURE PROBABILITIES ON A FEW COMPONENTS.
FURTHER, THE COMMISSION CLAIMS TO BE ABLE TO QUANTIFY THE PROBABILITY OF A GIVEN SIZE EARTHQUAKE OCCURRING AT A GIVEN LOCATION, BUT CAN ONLY GIVE, AFTER SIX YEARS OF STUDIES OF THE DAv!S BESSE AFW SYSTEM, "VERY ROUGH, PRELIMINARY ESTIMATES" 0F THE RELIABILITY OF ONE SYSTEM IN A PLANT.
I BELIEVE A FORTHRIGHT RESPONSE TO THE QUESTION WOULD REVEAL SOME OF THE WEAKNESSES OF POLICIES AND PRACTICES THAT PLACE EMPHASIS ON QUANTIFYING THE
GilESTION2(CONT,) RELIABILITY AND RISKS OF COMPLEX PLANTS.
I WOULD ALSO POINT GUT THAT THE COMMISSION HAS MORE CAVEATS ON THE RESPONSE TO THIS STRAIGHTFORWARD QUESTION THAN IT PLACES ON THE RESPONSES TO EXTREMELY COMPLEX ISSUES INVOLVING GREAT UNCERTAINTIES, i
m CUESTION 3.
HAD THE ELECTRIC DRIVEN PUMP NOT MANUALLY STARTED DURING THE DAVIS-BESSE INCIDENT, AND HAD THE l
AUXILIARY FEEDWATER SYSTEM NOT BEEN PESTORED, WOULD
(
THERE HAVE BEEN A SEVERE CORE DAMAGE ACCIDENT.
IF YES, HOW LONG WOULD IT HAVE TAKEN BEFORE FUEL l
DAMAGE OCCURRED?
ANSWER.
IF NO FEEDWATER WERE RESTORED TO THE STEAM GENERATORS DURING THE I
DAVIS-BESSE EVENT, AND IF THE OPERATOR DID NOT TAKE ANY MIT!GATIVE ACTION, SUCH AS INITIATING FULL MAKEUP FLOW AS REQUIRED BY THE EMERGENCY PROCEDURES, FUEL DAMAGE WOULD BE EXPECTED TO OCCUR AT APPROXIMATELY ONE AND ONE-HALF (13) TO TWO (2) HOURS.
HOWEVER, IF THE OPERATOR INITIATES FULL MAKEUP FLOW, AS REQUIRED BY PROCEDURES, APPROXIMATELY 160 GPM WOULD BE PROVIDED TO THE REACTOR COOLANT SYSTEM AT THE PRESSURIZER CODE SAFETY VALVE ACTUATION SETPOINT.
FOR THIS CASE, THE CORE WOULD PROBABLY NOT HAVE EXPERIENCED FUEL DAMAGE AT DAVIS-BESSE.
THE ABOVE ESTIMATES WERE DERIVED FROM SIMPLIFIED MASS AND ENERGY BALANCE CALCULATIONS OF THE DAVIS-BESSE PLANT.
THE STAFF l
IS CURRENTLY PERFORMING MORE DETAILED ANALYSES USING ADVANCED COMPUTER CODES DEVELOPED IN NRC'S OFFICE OF NUCLEAR REGULATORY RESEARCH TO CONFIRM AND REFINE THESE ESTIMATES, AS WELL AS EXAMINE THE EFFICACY OF VARIOUS COMBINATIONS OF AVAILABLE SYSTEMS TO COOL THE CORE IN THE EVENT FEEDWATER WASN'T RESTORED IN A TIMELY MANNER.
i b
r 00EST10N 4.
ACCORDING TO PRELIMINARY INFORMATION PROVIDED BY THE NRC STAFF, THE EMERGENCY CORE COOLING SYSTEM (ECCS) AT DAVIS-BESSE IS UNABLE TO FUNCTION PROPERLY WHEN THE PRIMARY COOLING SYSTEM IS PRESSURIZED IN EXCESS OF 1,600 POUNDS PER SOUARE INCH.
(IF THIS IS TRUE, WHY DID THE OPERATORS INITIATE THE ECCS DURING THE DAVIS-BESSE INCIDENT AND WHY DID THEY TERMINATE ECCS?)
WHAT OTHER PRESSURIZED WATER REACTORS (PWR) HAVE HIGH PRESSURE INJECTION PUMPS WHOSE SHUT 0FF HEAD IS BELOW THE SET POINT OF THE CODE SAFETY VALVES?
- ANSWER, THE PRELIMINARY SEQUENCE OF EVENTS OF THE DAVIS-BESSE INCIDENT CONTAINED IN THE JUNE 19, 1985 MEMORANDUM FROM WILLIAM J. DIRCKS, EXECUTIVE DIRECTOR FOR OPERATIONS, TO THE COMMISSION NOTES THE FOLLOWING ITEM:
i l
1
COES' TION 4. (CONTINUED) JUNE 9, 1985, 01:58:
TAVE RESTORED TO NORMAL POST-TRIP TEMPERATURE.
THE C00LD0hN HAD LOWERED RCS PRESSURE TO ABOUT 1720
- PSIG, OPERATORS MANUALLY STARTED THE HPI PUMP #1 IN THE PIGGY-BACK MODE (LPI PUMP 1 SUPPLYING THE SUCTION TO THE HPI PUMP 1).
A SLIGHT AMOUNT OF WATER (ABOUT 50 GALLONS) WAS INJECTED.
THE " PIGGY-BACK MODE" REFERRED TO IN THIS EVENT MEANS ALIGNING THE LOW PRESSURE INJECTION (LPI) PUMP TO THE SUCTION OF THE HIGH PRESSURE INJECTION PUMPS.
THIS HAS THE EFFECT OF PROVIDING THE HIGH PRESSURE PUMPS WITH THE CAPABILITY TO DEVELOP A PRESSURE OF GREATER THAN 1600 POUNDS PER SOUARE INCH (PSI).
AS A CONSEQUENCE, THE ECCS IS CAPABLE OF INJECTING WATER INTO THE RCS AT PRESSURES ABOVE 1600 PSI; HOWEVER, THE TEAM IS INVESTI-GATING WHY THE OPERATORS INITIATED AND THEN TERMINATED ECCS FLOW.
THE TEAM WILL ADDRESS THE RESULTS OF THEIR REVIEW AND EVALUATION OF THIS ISSUE IN THEIR REPORT OF THE INCIDENT,
'00EST!0N 4.
(CONTINUED) OTHER PWRS WITH ECCS PUMPS NOT CAPABLE OF INJECTING AGAINST THE PRESSURIZER CODE SAFETY VALVE SET PRESSURE ARE LISTED BELOW.
HOWEVER, THESE PLANTS, LIKE DAVIS-BESSE 1, GENERALLY ALSO HAVE ADDITIONAL INJECTION PUMPS, WHICH HAVE LOWER CAPACITY, ARE NON-SAFETY GRADE, AND HAVE SHUT 0FF HEADS IN EXCESS OF THE SAFETY VALVE PRESSURE.
AS A RESULT, SOME CAPABILITY GENERALLY EXISTS AT THE FOLLOWING PLANTS TO:
PERFORM A FEED AND BLEED MODE OF COOLING.
CALVERT CLIFFS 1 & 2 GINNA MILLSTONE 2 INDIAN POINT 2 8 3 PAllSADES KEWAUNEE ST. LUCIE 1 8 2 H. B. ROBINSON YANKEE RCWE ANO-2 POINT BEACH 1 & 2 PRAIRIE ISLAND 1 8 2 TURKEY POINT 1 8 2 FT. CALHOUN
'00EST10N 4 (CONTINUED) THE PLANTS LISTED BELOW CANNOT PERFORM FEED AND BLEED COOLING AS NO PORVS ARE AVAILABLE:
PALO VERDE SAN ONOFRE 2 8 3 WATERFORD 3
QUESTION 5, ACCORDING TO PRELIMINARY INFORMATION PROVIDED BY THE NRC STAFF, DAVIS-BESSE IS NOT CAPABLE OF COOLING THE REACTOR USING THE " FEED AND BLEED" PROCESS.
WHAT IS THE TECHNICAL BASIS FOR NOT REQUIRING DAVIS-BESSE TO BE CAPABLE OF COOLING THE REACTOR USING THIS PROCESS 7 IDENTIFY ALL PWR'S FOR j
WHICH FEED AND BLEED HAS BEEN DEMONSTRATED -- USING SAFETY EVALUATIONS PERFORMED IN ACCORDANCE WITH ESTABLISH NRC REQUIREMENTS -- TO BE AN ADEQUATE i
METHOD OF CORE COOLING.
l ANSWER.
THE NRC DOES NOT REQUIRE ANY PWR TO HAVE A FEED AND BLEED CAPABILITY.
RATHER, THE STAFF REQUIRES THAT ALL PWRS, INCLUDING DAVIS-BESSE, PROVIDE AN AUXILIARY FEEDWATER SYSTEM TO PROVIDE RESIDUAL HEAT REMOVAL.
THE AUXILIARY FEEDWATER SYSTEM AT DAVIS-BESSE 1 IS l
DESIGNED TO SAFETY RELATED REQUIREMENTS AND WAS CONSIDERED TO BE f
SUFFICIENTLY RELIABLE BY THE STAFF AT THE TIME OF ITS REVIEW.
ALTHOUGH A COMBINATION OF MALFUNCTIONS RESULTED IN A LOSS OF ALL j
FEEDWATER FOR APPROXIMATELY 12 MINUTES AT DAVIS-BESSE, THE AUXILIARY FEEDWATER SYSTEM WAS RECOVERED IN A TIMELY MANNER AND PUBLIC HEALTH AND SAFETY WAS MAINTAINED AT ALL TIMES.
ALTHOUGH FEED AND BLEED IS NOT A DESIGN REQUIREMENT, THE STAFF RECOGN!ZES THAT A FEED AND BLEED CAPABILITY EXISTS AT MOST PWRS, 1
m
OVESTION 5.
(CONTINUED) !
AS PART OF THE REQUIREMENTS DEVELOPED AFTER THE TMI-2 ACCIDENT, PLANTS WERE REQUIRED TO DEVELOP PROCEDURES FOR MANAGING EVENTS BEYOND THE DESIGN BASIS EVENTS, INCLUDING THE EFFECTS OF MULTIPLE FAILURES.
IHESE PROCEDURES UTILIZE ALL AVAILABLE EQUIPMENT, NOT JUST SAFETY-RELATED EQUIPMENT, IN ORDER TO PROVIDE MAXIMUM CORE COOLING CAPABILITY.
TO COPE WITH A LOSS OF ALL FEEDWATER EVENT, OPERATORS ARE INSTRUCTED TO OPEN ALL AVAILABLE PRESSURE RELIEF
- PATHS, E.G.,
THE PORV, AND ACTUATE ALL AVAILABLE INJECTION PUMPS, l
E.G.,
HP! AND MAKEUP.
ANALYSES HAVE BEEN PROVIDED BY THE PLANTS WHICH EXAMINE THIS MODE OF COOLING.
BASED ON THE ANALYSES RECE!VED FROM THE LICENSEES, WE HAVE CHARAC-TERIZED THE FEED AND BLEED CAPABILITY FOR THE VARIOUS PLANTS AS FOLLOWS:
TYPE 1 -
PLANTS WHICH CAN FEED AND BLEED AT THE HIGH PRESSURE SAFETY VALVE /PORV SETPO!bT.
THESE PLANTS HAVE HIGH PRESSURE HPI l
PUMPS WITH SHUT 0FF HEAD AT 2700 TO 2900 PSI
[8 PLANTS}
1 ANO-1 OCONEE 1, 2 & 3 IMI-1 CRYSTAL RIVER 3 RANCHO SECO MAINE YANKEE
00ESTf0N 5.
(CONTINUED).
l TYPE 2 -
PLANTS WHICH ARE MARGINAL FOR FEED AND BLEED AT THE SAFETY VALVE /PORV SETPOINT (HPI PUMP SHUT 0FF HEAD APPROXIMATELY l
EQUAL TO PORV/ SAFETY VALVE RELIEF PRESSURE BUT CAN DEPRESSURIZE THROUGH THE PORV AND FEED AND BLEED AT l
t LOWER PRESSURE).
I (29 PLANTS)
I BEAVER VALLEY I & 2 NORTH ANNA 1 & 2 ZION 1 & 2 0 C. COOK 1 & 2 SALEM 1 & 2 CALLAWAY FARLEY l & 2 SAN ONOFRE 1 MCGUIRE 1 & 2 HADDAM NECK TROJAN CATAWBA 1 & 2 SEQUOYAH I & 2 SURRY 1 & 2 SUMMER BYRON 1 & 2 DIABLO CANYON 1 & 2 l
TYPE 3 -
PLANTS WHICH CAf1 FEED AND BLEED IF OPERATOR DEPRESSURIZES PLANT WITH PORVS (lip! SHUT 0FF HEAD APPROXIMATELY 1600 PSI).
l (13 PLANTS)
GINNA H. B ROBINSON PRAIRIE ISLAND 1 & 2 INDIAN POINT 2 & 3 ANO-2 TURKEY POINT 1 & 2 i
KEWAUNEE POINT BEACH I & 2 FT, CALHOUN i
I m
m
OUESTION 5.
(CONTINUED) '
TYPE 4 -
PLANTS WHICH MAY OR MAY NOT BE ABLE TO SUCCESSFULLY FEED AND BLEED BY PORV DEPRESSURIZATION DUE TO LOW HPI SHUT 0FF HEAD (APPROXIMATELY 1300 PSI) AND/OR SMALL PORV CAPACITY.
(7 PLANTS}
CALVERT CLIFFS 1 & 2 ST. LUCIE 1 & 2 MILLSTONE 2 YANKEE ROWE PALISADES IN
SUMMARY
, THE NRC STAFF ONLY RECOGNIZES FEED AND BLEED AS A DEFENSE IN DEPTH MEASURE FOR COPING WITH EVENTS BEYOND THE DESIGN BASIS.
THIS MODE OF COOLING IS UTILIZED TO KEEP THE CORE COOLED WHILE MEASURES ARE TAKEN TO RESTORE FEEDWATER.
THE SPECIFIC FEED AND BLEED CAPABILITY VAPIES FROM PLANT TO PLANT, AND HAS BEEN STUDIED BY APPROPRIATE ANALYSES.
FOR DAv!S-BESSE, THE LICENSEE PROVIDED ANALYSES WHICH DEMONSTRATED THAT A LOSS OF FEEDWATER EVENT WOULD NOT RESULT IN CORE UNCOVERY IF THE OPERATOR MANUALLY INITIATED THE STARTUP FEEDWATER PUMP, ONE MAKEUP PUMP AND OPENED THE PORV WITHIN 30 MINUTES.
SOME LIMITED CAPABILITY TO PERFORM FEED AND BLEED AT DAVIS-BESSE MAY EXIST USING BOTH OF THE MAKEUP PUMPS WITHOUT THE OPERATION OF THE
OVESTION 5. (CONTINUED) >
I
'dLECTRICSTARTUPFEEDWATERPUMP.
IT IS THE STAFF'S UNDERSTANDING THAT DAVIS-BESSE HAS PROCEDURES IN PLACE TO PERFCFM FEED AND BLEED USING THE PORV, LOOP HIGH POINT VENTS, AND THE MAKEUP PUMPS (OR HPI PUMPS, AT LOWER PLANT PRESSURES).
WE DO NOT, HOWEVER, FAVE ANY SUPPORTING ANALYSES FROM THE LICENSEE FOR THIS COOLING MODE.
9
'l r
l l
b l
i r
l I
e l
l 3
i i
L
1 OVESTION 6.
DOES THE FAILURE OF THE PORV DURING THE DAVIS-BESSE INCIDENT RAISE CUESTIONS ABOUT THE ADEQUACY OF c
TESTING DONE IN ACCORDANCE WITH THE TMI ACTicN PLAN 7 l
- ANSWER, THE PORV OPERATION DURING THE INCIDENT WILL BE REPORTED BY THE NRC I
FACT-FINDING TEAM AS DISCUSSED IN THE ANSWER TO OVESTION 1. THE i
TEAM'S REPORT WILL ADDRESS THE POSSIBLE FAILURE OF THE VALVE AND THE j
PROBABLE CAUSE OF FAILURE.
FURTHER, UPON REVIEW OF THE TEAM'S i
REPORT, THE TEST PROGRAM CONDUCTED ON THIS COMPONENT WILL BE I
j REVIEWED AS TO ITS ADEQUACY.
i 1
I I
f i
i I
.i 1
I f
t
.(
f 4
I i
l I
f I
l
CUESTION 6.
(A) WAS THE SPECIFIC PORV NDEL USED AT DAVIS-BESSE TESTED AS PART OF THE TMI ACTION PLAN?
- ANSWER, IN REEPONSE TO THE REQUIREMENTS OF IMI ACTION PLAN ITEM !!,D.1 AS CLARIFIED IN NUREG-0737 "PERFORt%NCE TESTING OF BOILING WATER REACTOR AND PRESSURIZED WATER REACTOR RELIEF NO SAFETY VALVES," THE PWR OWNERS GROUP CONTRACTED W!Df EPRI TO PERFC 7 A GENERIC TEST PROGo#1 FOR FORVS AND SACETY VALVES.
TtE PORV AT DAVIS-EESSE IS A PODEL No,llPV-SN PILOT OPERATED PORV WITH A fai!NAL BCPE DIN'ETER OF 1,5 INCHES MANUFACTURED BY CROSBY VALVE NO GAGE CO.
l l
AS PART OF THE EPRI GENERIC TEST PROGANi, TWO CROSBY PORVS OF THE SME MODEL l
fuiBER, BUT WITH A Nrti!NAL BORE SIZE OF 1.3 If4CHES WERE TESTED, THE SPECIFIC i
f DESIGN TESTED WAS TO BE USED AT NORTH ANNA UNITS 3 No 2, IN ADDITION TO THE 4
Mlf0R DIFFERENCE IN BORE DINiETER, TliERE WEPE A FEW ODiER MINOR DIFFFCENCES EETWEEN THE TESTED PORVS NO THE ONE USED AT DAVIS-EESSE. ACCORDifiG TO INF0Pf%T!0fl SUPPLIED BY THE MANUFACTURER, MOST OF THESE D!FFERENCES RELATE TO CHANGES MADE TO IMPROVE EASE OF MANUFACTUPING THE VALVES. THE P9INCIPLE OF OPEPATION NO ALL SIGNIFICNiT VALVE INTERNALS FOR T}iE TESTED VALVES ARE CONSIDERED REPRESENTATIVE OF T}iE DAVIS-BESSE FORV, BASED ON NRC STAFF REVIEW OF THE EPRI TEST RESULTS. THERE WERE NO MODIFICATIONS NECESSARY ON THE IORV AS A RESULT OF THE EPRI TEST FPOGANi.
l
OUESTION 6.
(B) HOW MANY OTHER PLANTS HAVE die SAME ffDEL P0ffn
- ANSWER, CUPRENTLY THERE ARE NO OTHER PLANTS EITliER OPERATING OR UNDER CONSTRUCTION TliAT USE f0RVS MANUFACTURED BY CROSBY VALVE AND GAUGE CO, NORM ANNA 3 AND 14 WERE TO HAVE INSTALLED CROSBY PORVS, BlIT TliESE PLANTS HAVE BEEN CANCELLED, 1
i
l OUESTION 6.
(C) HOW PANY PORV FAILURES HAVE OCCURRED DURING OPEPATION OR
\\
l TESTING SINCE THE ACCIDENT AT THREE MILE ISllM)?
ANSWER.
l l
THE SOURCE OF PORV RELIEF NJD SAFETY VALVE FAILURE REPORTS IS DERIVED FRm l
ABOUT THREE YEARS OF PEPORTING REQUIREMENTS FR041980 THROUGH 1983 IN l
ACCORDN4CE Wim NUREG-0737, TMI ACTION PLAN ITEMS II.K.3.2 AND !!.K,3,3. THIS REQUIRMENT WAS SUBSEQUENTLY DELETED VIA CHANGES TO THE NRC REGULATIONS ON LICENSEE EVENT REPORT! fig REQUIREMENTS (TITLE 10 CFR 50.73) WHICH WENT INTO EFFECT IN JANUARY 1984. SCAE PLANTS, SUCH AS DAVIS BESSE, ARE STILL REQUIRED TO REPORT THESE FAILURES BECAUSE THEY HAVE NOT MODIFIED THEIR TECHNICAL SPECIFICATIONS, AS OF YET, TO REFLECT THE LESS RESTRICTIVE REQUIREMENTS OF THE NEW REGUALTIONS. BASED ON OUR REVIEW 0F LER DATA, WE STAFF IS AWARE OF ABOUT FIFTEEN (15) EVENTS SINCE DIE TMI-2 ACCIDENT WHERE A PORV FAILED TO OPEN OR CLOSE ON DEPAND, TWELVE (12) 0F WHICH WERE DISCOVERED DURING FURVEILLNICE TESTING. ONLY ONE OF THESE 15 OCCURRED AFTER JANUARY 1984 OF BESE 15, TWO RESULTED IN MODIFICATIONS TO A FIRST OF A KIND PORV DESIGN, FIVE WERE CAUSED BY IflSERVICE PECHN4! CAL DEGPADATION, NO THE BALANCE WERE CONTROL SYSTEM FAILURES, NONE OF THESE 15 EVEfRS IfNOLVED WE PORVS n DAVIS-BESSE.
[H ADDITION, THERE l
HAVE BEEN flUMEROUS INSTANCES REPORTED OF PORV SYSTEM DEGRADATION, SUCH AS EXCE551VE LEAKAGE N4D CONTROL SYSTEM MISADJUSTMENT OR MALFUNCTION.
INOCTOBER 1989 AND PARCH 1982, THE PORV AT DAVIS-BESSE WAS INSPECTED BECAUSE IT WAS j
LEAKING NO CORRECTIVE MAINTENANCE WAS PERFORMED.
1 l
\\
I
I I
OVESTich 7 DOES THE AUXILIARY FEEDWATER SYSTEM AT DAVIS-BESSE PROVIDE GPEATER, EQUAL OR SMALLER MARGIN OF SAFETY l
THAN THE AUXILIARY FEEDWATER SYSTEM AT OTHER i
PRESSURIZED WATER REACTORS?
l
- ANSWER, i
THE AUXILIARY FEEDWATER SYSTEM AT DAVIS-BESSE DOES PROVIDE A SMALLER MARGIN OF SAFETY (HIGHER UNRELIABILITY) THAN THE AUXILIARY FEEDWATER SYSTEM AT MOST OTHER PWRS, RELIABILITY STUDIES FOR THE DAVIS-BESSE TWO PUMP, NON-DIVERSE DRIVE AFWS HAVE SHCWN A HIGHER i
UNRELIABILITY THAN FOR MOST OTHER PWRS.
THE SMALLER MARGIN OF SAFETY IS BASED ON THE COMBINED CONDITIONS OF A SHORT STEAM GENERATOR DRY-0UT TIME, HAVING ONLY TWO AUXILIARY FEEDWATER PUMPS, l
AND RELIANCE CH STEAM FOR AUXILIARY FEED-WATER PUMP MOTIVE POWER l
l l
SINCE NO DIVERSE POWEPED (MOTOR-DRIVEN) AFW PUMP IS PROVIDED, THE LACK OF A THIFD DIVERSE AFW TRAIN DOES HAVE AN EFFECT ON I
I OVERAll. RELI ABILITY CF THE AFWS, THE RELIABILITY STUDY FOR j
DAVIS-EESSE GIVES NO CREDIT FOR THE INSTALLED, NON-SAFETY GRADE, j
LOWER CAPACITY, ELECTRIC DRIVEN STARTUP PUMP WHICH IS TO BE l
UPGRADED WITH A HIGHER CAPACITY PUMP, i
.l i
l i
i
1-QUESTION 8, PROVIDE A HISTORY OF ANY PREVIOUSLY NOTED DIFFICULTIES OBSERVED WITH THE MAIN OR AUXILIARY FEEDWATER SYSTEMS AT DAVIS-BESSE SINCE 1979 AND ANY ACTIONS TAKEN IN RESPONSE.
- ANSWER, AUXILIARY FEEDWATER SYSTEM i
THE TMI RELATED SHUTDOWN ORDER FOR DAVIS-BESSE REGARDING THIS SUBJECT WAS LIFTED ON JULY 6, 1979 AND THE UNIT WAS SYNCHRONIZED l
l TO THE GRID ON JULY 12, 1979.
SINCE JULY 12, 1979 THERE HAVF BEEN 48 LICENSEE EVENT REPORTS (LERS) RELATING TO PROBLEMS WITH THE I
AUXILIARY FEEDWATE9 SYSTEM AND THE STEAM FEEDWATER RUPTURE CONTROL
WITH COMMON COMPONENTS OR TO SINGULAR EVENTS WITH NO APPARENT REPETIT!VENESS.
IN EACH CASE THE LICENSEE TOOK CORRECTIVE ACTION, BUT THE REPETIT!VENESS OF CERTAIN PROBLEMS INDICATES THAT THE ROOT CAUSES WERE NOT RESOLVED.
THE FOLLOWING IS A
SUMMARY
OF THE REPETITIVE PROBLEMS AND THE MORE SIGNIFICANT SINGULAR EVENTS BASED ON THE STAFF'S LER REVIEW sREFER TO TABLE ON PAGE 6),
1 i
QUESTION 8. (CONTINUED).
AuxtLIARY FEEDWATER SYSTEM TURBINE GOVERNORS FIVE PROBLEMS WERE NOTED IN 1980, 1981, 1983 AND 1985.
THE FIRST i
FOUR, WHICH OCCURRED IN 1980, 1981, AND 1983, WERE RELATED TO A I
SPEED CONTROL MECHANISM FOR SETTING TURBINE SPEED AND INVOLVED i
e DRIVE CLUTCH WEAR AND ADJUSTMENT.
AFTER THE 1983 PROBLEM THE j
SPEED CONTROL MECHANISMS WERE SUBSEQUENTLY MODIFIED BY THE VENDOR.
FURTHER, DURING THE 1984 REFUELING OUTAGE A NEW HYDRAULIC GOVERNOR WAS INSTALLED ON AUXILIARY FEEDWATER SYSTEM TURBINE NO. 2 AS AN IMPROVED DESIGN.
ADDITIONALLY, CHANGES WERE MADE TO THE VALVE LOGIC.
DURING A REACTOR TRIP ON MARCH 23, 1985, THE NEW GOVERNOR j
1 SPEED RESPONSE WAS FOUND TO BE SLOW, REQUIRING A CHANGE TO THE SPEED BUSHING AND ELIMINATION OF CHANGES TO THE VALVE LOGIC THAT HAD BEEN INSTALLED DURING THE 1984 OUTAGE.
l AUXll!ARY FEEDWATER SYSTEM VALVES i
j PROBLEMS IDENTIFIED WITH VALVES CAN BE CLASS!FIED BOTH AS MECHANICAL AND ELECTRICAL.
DURING A 1982 REFUELING AUXILIARY FEEDWATER AND OTHER VALVES WERE FOUND MISALIGNED AND NOT PROPERLY LOCKED AND LOGGED.
RESPONSE TO NON-l COMPLIANCE RESULTED IN SIGNIFICANT TIGHTENING OF CONTROLS FOR LOCKED VALVES t
f l
QUESTION 8. (CONTINUED),
i FoUR MECHANICAL PROBLEMS IN 1979, 1983 AND 1984 INVOLVED LIMITORQUI (BRANDNAME) VALVE OPERATORS.
THE TWO 1979 PROBLEMS INVOLVED IMPROPER ASSEMBLY OF VALVE OPERATORS AND ADJUSTMENTS OF TOROUE SWITCHES.
THESE PROBLEMS WERE RESOLVED IN A REVISION TO THE MAINTENANCE PROCEDURE.
TWO OTHER PROBLEMS INVOLVED A DIRTY VALVE STEM,AND AN ADJUSTMENT TO A TORQUE SWITCH SETTING IN 1983 AND 1984 RESPECTIVELY.
THE VALVE STEM WAS CLEANED AND THE TOROUE SWITCH SETTING WAS CHANGED.
F0uR ELECTRICAL PROBLEMS IN 1979 AND 1980 INVOLVED VALVE CONTROL RELAYS AND PRESSURE SWITCHES IN THE STEAM AND AUXILIARY FEEDWATER SYSTEM PUMP SUCTION LINES.
THE DEFECTIVE COMPONENTS WERE REPLACED OR CORRECTED THROUGH MAINTENANCE ACTIVITIES.
FOUR OTHER ELECTRICAL PROBLEMS WITH VALVES HAVE BEEN IDENTIFIED.
THESE WERE SPURIOUS CLOSURES IN 1980 AND 1982, A FAILED RELAY DRIVER BOARD, A FAILURE TO ADJUST A SPEED PROBE IN 1981 AND A BLOW *l FUSE IN 1983.
THE LICENSEE INVESTIGATED EACH OCCURRENCE AND CORRECTED THE PROBLEMS.
1
~ _
i l
OVESTION 8. (CONTINUED) 14-1 i
Aux!LIARY FEEDWATEP SYSTEM TURBINE OVERSPEED TRIP i
4 j
TWO OVERSPEED TRIPS OF THE AUXILIARY FEEDWATER SYSTEM TURBINES l
WERE REPORTED IN 1983.
ONE WAS INADVERTENT WHEN THE TRIP LINKAGE i
hAS BUMPED DURING MAINTENANCE.
THE SECOND EVENT WAS ATTRIBUTED TO IMPROPER LATCHING OF THE MECHANICAL TRIP LINKAGE.
PARTS OF THE LINKAGE WERE CLEANED AND THE SURVEILLANCE TEST PROCEDURE FOR THE AUXILIARY FEEDWATER SYSTEM WAS REVISED TO INCREASE CYCLING FREQUENCY
)
0F THE TEST LINKAGE.
i 1
STEAM FEEDWATER RUPTURE CONTROL SYSTEM POWER SUPPLIES I,
EIGHT DC POWER SUPPLIES FAILURES OCCURRED FROM 1979 T'! ROUGH 1982.
I j
THE POWER SUPPLIES WERE RETURNED TO THE VENDOR FOR ANALYSIS AND
{
REPA!R.
I i
j AUXILIARY FEEDWATER SYSTEM STEAM GENERATOR HFADER i
l l
DURING EDDY CURRENT TESTING ON THE STEAM GENERATORS IN 1982, A DAMAGED INTERNAL RING HEADER WAS IDENTIFIED.
THIS EVENT WAS I
i l
CLASS!FIED AS A PROBLEM COMMON TO THIS B&W DESIGN.
THE INTEPNAL HARDWARE WAS STABILIZED IN PLACE AND AN EXTERNAL HEADER WAS INSTALLED.
I i
I
QUESTION 8. (CONTINUED),
aux!LIARY FEEDWATER SYSTEM PIPE RESTRAINTS EARLY MARCH 1985, THE LICENSEE IDENTIFIED DAMAGED AUXILIARY FEEDWATER SYSTEM PIPE RESTRAINTS.
THE LICENSEE ATTRIBUTED THE i
DAMAGE, IN PART, TO EXCESSIVE HYDRODYNAMIC FORCES RESULTING FROM
)
MAIN STEAM SUPPLY VALVE CONTROL LOGIC CHANGES MADE DURING THE 1984 3
i REFUELING OUTAGE.
WHEN IT WAS DETERMINED THAT THE DAMAGE PROFILE i
]
MIGHT BE MORE EXTENSIVE A CONFIRMATORY ACTION LETTER WAS ISSUED BY I
THE NRC TO ADDRESS THE LICENSEE'S ACTIONS TO IDENTIFY THE CAUSES, j
SCOPE AND CONSEQUENCES.
THE EVALUATION IS STILL IN PROGRESS.
i j
MAIN FEEDWATER SYSTEM i
i PROBLEMS RELATED TO THE MAIN FEEDWATER PUMPS ARE NOT NORMALLY REPORTED VIA THE LICENSEE EVENT REPORT SYSTEM (LER).
- HOWEVER,
)
REPETITIVE CONTROL PROBLEMS WITH THE MAIN FEEDWATER TURBINE LED i
l THE LICENSEE TO REPLACE THE TURBINE HYDRAULIC GOVERNORS WITH ELECTRONIC GOVERNORS DURING THE 1984 REFUELING OUTAGE.
SINCE THE l
INSTALLATION OF THE ELECTRONIC GOVERNORS THERE HAVE BEEN SEVERAL i
PUMP TRIPS DURING REACTOR TRIPS AND THE LICENSEE IS CONTINUING TO EVALUATE THIS PROBLEM, 1
L i
l I
00ESTTON 8. (CONTINUED)
-C-TABLE 0, 8 REVIEW OF LERS SUTMlRY DAVIS-CESSE YEAR 7.9' 80 81 82 83 84 85 AUXILTARY FEENATER SYSTEM l
TURBINE GOVERNOR 1
2 1
l'
- (PIPE RESTRAINT ISSUE IN 1985 LER).
INOPERABLE VALVE
- fiECmNICAL 2
1 1
- ER CTRICAL -- COUCH RELAYS 1
1
-- PRESSURE SWITCHES 2
-- OmER 1
2 1
1 VALVE MISALIGmENT 2
OVEPSPEED TRIP 2
STE#1 GENERATOR HEADER 1
OmERS 1
1 3
1 1
1 STEA'4 FEEDWATER RUPTURE LONTROL SYSTEM power SUPPLY 2
1 1
4 SETP0!tU DRIFT 1
COMPONENT FAILURE 2
- MSIV CLOSED 1
1 OmERS 1
1 2
- SINCE JULY 11,1979 RESTART AFTER THE TMI ORDER WAS LIFTED,
M
+
r QUESTION 9.
WHAT ARE TliE GENERIC IMPLICATIONS AND LESSONS LEARNED FROM'THE DAVIS-BESSE INCIDENT?
I
- ANSWER, THE GENERIC IMPLICATIONS AND LESSONS LEARNED FROM THE DAVIS-BESSE INCIDENT WILL BE IDENTIFIED AFTER AN INVESTIGATION OF i
THE INCIDENT IS COMPLETE.
THEN THE NRC WILL DETERMINE.WHAT APPROPRIATE CORRECTIVE ACTIONS ARE NECESSARY ON OTHER PLANTS.
i i
[ *'
g r
4 i
}
N-i l
- n w
,:--.-.L--
QUESTION 10:
IN LIGHT OF THE DAVIS-BESSE INCIDENT, IS THERE ANY INFORMATION OF WHICH THE COMMISSION IS AWARE THAT WOULD LEAD IT TO RECONSIDER ANY OF THE POSITIONS TAKEN BY THE NRC STAFF, OR IN ANY OF ITS OWN DECISIONS, IN THE TMI RESTART PROCEEDING?
FOR EXAMPLE, IN THE TMI RESTART PROCEEDING, THE NRC STAFF CONTENDED THAT A TOTAL LOSS OF FEEDWATER WAS BEYOND THE DESIGN BASIS AND, THEREFORE, CAPABILITY TO ACCOMPLISH FEED AND BLEED WAS NOT REQUIRED.
f ANSWER THERE IS NO INFORMATION AS A RESULT OF THE DAVIS-BESSE INCIDENT OF WHICH THE COMMISSION IS AWARE THAT WOULD LEAD IT TO RECONSIDER ANY OF THE POSITIONS TAKEN BY THE STAFF OR ITS OWN DECISIONS IN THE IMI RESTART PROCEEDING.
HOWEVER, THIS' POSITION COULD CHANGE WHEN THE REPORT OF THE FACT FINDING TEAM IS AVAILABLE AND THE RESULTS ARE EVALUATED.
i
., _... ~.. -,
QUESTION 11:
LIST THOSE TMI ACTION PLAN ITEMS DIRECTLY RELEVANT TO THE DAVIS-BESSE INCIDENT AND PROVIDE THE CURRENT STATUS OF COMPLIANCE.
SPECIFICALLY INCLUDED IN YOUR RESPONSE SHOULD BE A DETAILED EXPLANATION OF WHAT ACTIONS WERE TAKEN AND WHEN IN RESPONSE TO THOSE TMI ACTION PLAN ITEMS CONCERNING THE AUXILIARY FEEDWATER SYSTEM AND PILOT OPERATED RELIEF VALVE.
YOUR RESPONSE SHOULD CLEARLY IDENTIFY THOSE RELEVANT ACTION PLAN ITEMS THAT HAVE NOT BEEN FULLY IMPLEMENTED AND EXPLAIN WHEN EACH ITEM WAS ORIGINALLY SCHEDULED TO HAVE BEEN l
COMPLETED AND THE REASON IT REMAINS OUTSTANDING.
ANSWER.
THE LICENSEE HAS FULLY IMPLEMENTED ALL REQUIRED TMI ACTION PLAN ITEMS EXCEPT ITEMS 1.D.1 (CONTROL ROOM DESIGN REVIEWS) AND II.F.2 (INSTRUMENTATION FOR DETECTION OF INADEQUATE CORE COOLING).
THE STATUS OF THE IMPLEMENTATION OF THESE TWO ITEMS BY THE LICENSEE l
AND THE STAFF'S POST-IMPLEMENTATION REVIEWS ARE ADDRESSED IN TABLE O 11.
IN ADDITION, FIVE OF THE LISTED TMI ACTION ITEMS RELEVANT TO THE DAVIS-BESSE INCIDENT ARE STILL ACTIVE REGARDING THE STAFF'S POST-IMPLEMENTATION REVIEWS.
9 4
--. ~.
,.m
.mm..--.
,.,__.,,m, c
s_-_
'd OUESTION ll'.
(CONTINUED) 9 TABLE 0, 11 TMI ACTION PLAN ITEFS DIRECTLY RELEVANT TO THE DAVIS BESSE INCIDENT AND STATUS CF COMPLIANCE ACTION PLAN ITEM TITLE IMPLE4ENTATION AND REVIEW STATUS l.A.I.1 SHIFT TECHNICAL COMPLETE ADVISOR I
l.A.1.2 SHIFT SUPERVISOR COMPLETE RESPONSIBILITIES I.A.1.3 SHIFT MANNING COMPLETE I.A.2.1 ImEDIATE UPGRADING COMPLETE OF R0 8 SR0 TRAINING AND QUALIFICATIONS l.C.1 SHORT-TERM ACCIDENT CONSISTENT WITH OUR CONFIRMATORY r
8 PROCEDURES REVIEW ORDER ON SUPPLEMENT 1 TO NUREG-0737, THE LICENSEE HAS IMPLEMENTED THE EMERGENCY PROCEDURES (AT0G), STAFF REVIEW IS SCHEDULED FOR COMPLETION BY JUNE 31,1986.
q I.C.5 FEEDBACK OF OPERATING CCNPLETE EXPERIENCE i
y
+-s
-e-w
QUESTION 11.
(CONTINUED) -
4 I.D 1 CONTROL-POOM DESIGN CONSISTENT WITH OUR CONFIRMATORY REVIEWS CRDER ON SUPPLEMENT 1 TO NUREG-0737, t
THE LICENSEE SUEMITTED A SUWARY REPORT AND PRCPOSED A SCHEDULE 4
FOR IMPLEMENTATION BY THE COMPLETION OF THE 7TH REFUELING OUTAGE ABOUT 4 YEARS FRCP. NOW. THE SUBMITTALS ARE UNDER REVIEW BY THE STAFF.
I.D.2 PLANT-SAFETY-PARAMETER LI:ENSEE IMPLEMENTATION IS COMPLETE.
DISPLAY CONSOLE STAFF REVIEW SCHEDULED TO BE COMPLETED BY 9/30/85.
II.D.1 RELIEF & SAFETY-VALVE TEST 3/31/86 - LICENSEE IWLEPErfrATION IS REQUIREMENTS COMPLETE. STAFF REVIEW SCHEDULED TO BE COMPLETED BY-3/31/86.
II.D.3-VALVE POSITION INDICATION COMPLETE II.E.1.1 AUXILIARY FEEDWATER SYSTEM COMPLETE EVALUATION II.E.1.2 AUXILIARY FEEDWATER SYSTEM COMPLETE INITIATION & FLOW l
{
i i
4 F
~,---m
,e ry~,.
,4
.,y,,
,,.y.,
--m m
CUESTION 11.
(CONTINUED) 4-II.$.2 INSTRUMENTATION FOR DETECTION OF ALL ASPECTS OF THE MODIFICATION INADEQUATE CORE COOLING REQUIRED BY OUR DECEMBER 1982 CRDER ARE INSTALLED EXCEPT FOR:
CONTINU0'IS VENT FROM THE REACTOR VESSEL HEAD TO THE HOT LEG; AND REPLACEMENT OF NON-GUALIFIED ELECTRICAL CONNECTORS TO THE CORE EXIT THERMOCOUPLES WHICH ARE SCHEDULED FOR IMPLEMENTATION DURING THE 1986 REFUELING OUTAGE (SPRING OF 1986). THE STAFF'S POST-IfPLEMENTATION REVIEW IS SCHEDULED FOR COMPLETION BY 9/30/86.
II.G 1 PCWER SUPPLIES FOR COMPLETE PRESSURIZER RELIEF VALVES, BLOCK VALVES, & LEVEL INDICATORS II.K.1 IE BULLETINS COMPLETE II.K.2 ORDERS ON B&W PLANTS CmPLETE II.K.3 FINAL REC 0fHENDATIONS, BE0 LICENSEE' IMPLEMENTATION IS COMPLETE.
TASK FORCE STAFF REVIEW 0F ll K.3.30 SB LOCA METHODS SCHEDULED FOR 12/31/86 AND ll.K.3.31 COMPLIANCE WITH 10 CFR 50.46 SCHEDULED FOR 1/31/87.
W--
p q
.e weM wim eem g---.--.,q
i CUESTION 11.
(CONTINUED),
ThEACIONSTHATWERETAKENCONCERNIriGTHEAUXILIARYFEEDWATERSYSTEMANDTHE i
PILOT OPERATED RELIEF VALVE (PORV) AND WHEN THESE ACTIONS WERE COMPLETED ARE j
DISCUSSED BELOW.
PORV i
II.K.2.14 LIFT FREQUENCY OF PORV AND SAFETY VALVES.
j THE LICENSEE SUBMITTED THE ANALYSES REQUIRED TO DETERMINE THE EXPECTED FREQUENCY OF PORV ACTUATION FOR OVERPRESSURE TRANSIENTS ON JANUARY 30,1981.
THIS ITEM IS COMPLETE. THIS SUEMITTAL WAS REQUIRED UNDER ITEM II.K.3.7.
II.K.3.1 AUTO PORV ISOLATION
)
AUTOMATIC PORV ISOLATION WAS NOT SHCWN TO BE REQUIRED BASED ON ANALYSES i
j-SUBMITTED FOR II.K.3.2.
II.K 3.2 REPCRT ON OVERALL SAFETY EFFECT OF PORV ISOLATION SYSTEM l
THIS ITEM REQUIRED AN ANALYSIS OF THE PROBABILITY OF A SMALL BREAK LOCA CAUSED BY A STUCK OPEN PORV OR SAFETY VALVE AND SHOULD CONSIDER POST IMI 1
IMPROVEMENTS TO THE PORVS, THE ANALYSIS WAS SUSMITTED JANUARY 30, 1981 AND i
.l THIS ITEM IS COMPLETE. THERE WERE NO IMPROVEMENTS NEEDED ON THE PORV.
II.K.3.7 EVALUATION OF PORV OPENING PROBABILITY DURING OVERPRESSURE TRANSIENT (REFER TO ITEM II.K.2.14. AB0VE) l II.D.1 RELIEF AND SAFETY VALVE TESTING PROGRAM (REFER TO ANSWER TO QUESTION 6)
II.G.1 POWER SUPPLIES FOR PRES 5URIZER RELIEF VALVES, BLOCK VALVES, AND LEVEL INDICATOR 1
l l
i i
i I
..r
-'+-w
+-----'7
+ ---
-v-v
+-t-
+---wv-v-
-v*-
tww-
t- - ' - - -' - ' '
~w'--
v-e**
- -+-v
QUESTION 11.
(CONTINUED),
THIS ITEM REQUIRES WAT COMPONENTS ASSOCIATED WITH THE PORV AND PORV BLOCK VALVES BE CAPABLE OF BEING POWERED FROM EITHER OFFSITE POWER CR FROM THE EMERGENCY POWER SOURCE IF CFFSITE POWER IS NOT AVAILABLE. THE DAVIS BESSE LICENSEE CONFIRMED ON JANUARY 18,1980 THAT THE FORY AND BLOCK VALVE CCMPCNENTS HAVE THIS CAPABILITY.
f AUXILIARY FEEDWATER SYSTEM II.E.1.1 AUXILIARY FEEDWATER EVALUATIONS THE NRC REQUIREMENT IS THAT EACH LICENSEE EVALUATE ITS AUXILIARY FEEDWATER (AFW) SYSTEMS USING THE STANDARD REVIEW PLAN AND ASSOCIATED BRANCH a
i TECHNICAL POSITION AND PROVIDE JUSTIFICATION FOR ANY DIFFERENCES. THEY ARE ALSO REQUIRED TO PROVIDE A SIMPLIFIED AFW RELIABILITY ANALYSIS AND REEVALUATE THEIR AFW SYSTEM DESIGN FLOW RATE BASIS TO ENSURE ADEQUATE AFW FLOW UNDER VARIOUS ACCIDENT CONDITIONS. ANY AREA FOR WHICH INSUFFICIENT JUSTIFICATION EXISTS ti)ST BE UPGRADED. PRE-IMPLEMENTATION REVIEWS HAVE BEEN COMPLETED ON ALL THE PLANTS AND A POST-!MPLEMENTATION REVIEW WILL BE CONDUCTED IN ACCCFDANCE WITH NUREG-0737.
4 DAVIS-BESSE HAS SUEMITTED ITS SIMPLIFIED AFW RELIABILITY ANALYSIS, HAS EVALUATED ITS AFW SYSTEMS AGAINST THE STANDARD REVIEW PLAN AND ASSOCIATED BRANCH TECHNICAL POSITION, AND HAS REEVALUATED ITS AFW SYSTEN DESIGN FLCW RATE CRITERIA TO ENSURE ADEQUATE AFW FLOW UNDER VARIOUS ACCIDENT CONDITIONS.
THESE EVALUATIONS IDENTIFIED A huMBER OF CORRECTIVE ACTIONS.
l T
,,--t v
y 7+--
-g n
- -, - + -
QUESTION 11.
(CONTINUED),
9 DAVIS-BESSE CCFPLETED ALL PLANT MODIFICATICNS REQUIRED AS A RESULT CF THIS REVIEW IN 1980. THE ORIGINAL AFW SYSTEM AT DAVIS-BESSE WAS DESIGNED AS SAFETY GPADE, SO FEW MODIFICATIONS WEPE NECESSARY FCR THIS UNIT TO FEET THIS REGUIREMENT. HOWEVER, THREE OPEN ITEMS REMAIN IN THE NRC PEVIEW REGARDING THE CONTENTS OF THE DAVIS-BESSE TECHNICAL SPECIFICATIONS FOR THE AFW SYSTEM. THE LICENSEE HAS PROPOSED THE REQUIRED CHANGES TO THE TECHNICAL SPECIFICATIONS AND THEY ARE BEING REVIEVED.
II.E.1.2 AUXILIARY FEEDWATER SYSTEM INITIATION THE NRC REQUIREPENT IS FC'R ALL LICENSEES TO PROVIDE A CONTROL GRADE AUTCt% TIC INITIATION FEATURE FOR THEIR AFW SYSTEM AND THEN UPGRADE IT TO MEET SAFETY GRADE REQUIREMENTS. LICENSEES ARE ALSO REQUIRED TO INSTALL SAFETY GRADE INDICATION OF AUXILIARY FEEDWATER FLOW TO EACH STENi GENERATOR IN THE CONTROL ROOM.
TFE LICENSEE FOR DAVIS-BESSE, STATES THAT IT HAS INSTALLED AND TESTED THE SYSTEM MODIFICATIONS AND THAT ITS SYSTEMS ARE OPERABLE. THE LICENSEE ALSO IMPLEMENTED OPERATING PROCEDURES AND CCNPLETED OPERATCR TRAIN!hG. ALL MODIFICATIONS hEFE CCriPLETED BY AUGUST 1982.
II.K.2.8 UPGRADE OF AUXILIARY FEEDWATER SYSTEM THE LICENSEE WAS REQUIRED TO CCf4 PLY WITH CERTAIN SHORT TERM ACTIONS PRIOR TO BEING ALLOWED TO RETURN TO OPERATION FCLLOWING THE TMI-2 ACCIDENT. THE EVALUATION OF TFE LICENSEE SHORT TERM ACTIONS IS INCLUDED WITH THE 1
i
QUESTION 11. (CONTINUED) 4 JblY 6,1979 NRC LETTER SUPPLIED IN RESPONSE TO QUESTICN 12. THE LCNG TERM ITEMS WERE EVALUATED UNDER NUREG-0737 ITEMS II.E.1.1 AND II.E.1.2 AND THESE i
ITEMS ARE COMPLETE AS NOTED ABOVE.
II.K.2.19 SEQUENTIAL AUXILIARY FEEDWATER FLOW ANALYSIS THE REQUIRED ANALYSES hERE SUBMITTED FOR REVIEW FEBRUARY 5, 1980. NO I
MODIFICATKNS WERE REQUIRED AND THIS ITEM IS COMPLETE. THE ITEM ALSO REQUIRES l
E AT PRESSURIZER LEVEL INDICATION CHANNELS BE POWERED FROM W E VITAL INSTRlF.ENT BUS WHICH CAN BE POWERED FROM EITHER THE OFFSITE POWER SOURCE OR THE EMERGENCY POWER SOURCE WHEN OFFSITE POWER IS NOT AVAILABLE.
(ALSO SEE II.G.1 UNDER "PORV" ABOVE). THE DAVIS-BESSE PLANT HAS THIS CAPABILITY.
IN ADDITION TO ACTIONS NOTED ABOVE UNDER THE RELEVANT TMI ACTION ITEMS, THE LICENSEE HAS ALSO TAKEN THE INITIATIVE TO MAKE CHANGES TO UPGRADE THE AFW SYSTEM BASED ON THE RELIABILITY ANALYSIS SUBMITTED TO W E NRC IN DECEMBER 1981. UPGRADES ARE ONGOING WITH SOME SCHEDULED FOR THE 1986 REFUELING OUTAGE.
t 4
y
.. ___ -~
d l
i i
QUESTION 12.
IN NUREG-0667, " TRANSIENT RESPONSE OF BABC0CK 8 WILCOX-DESIGNED REACTORS" (MAY 1980). THE NRC
+
l SPECIFICALLY RECOMMENDED THAT DAVIS-BESSE IMPROVE I
SAFETY BY INSTALLING A DIVERSE DRIVE AUXILIARY FEEDWATER PUMP.
ACCORDING TO PRELIMINARY INFORMATION PROVIDED BY THE NRC STAFF, THIS RECOMMENDATION WAS SUSPENDED AND IS NOW PENDING FOR THE NEXT REFUELING OUTAGE IN 1986.
PLEASE PROVIDE A DETAILED HISTORY OF ALL ACTIONS TAKEN
,1 j
IN RESPONSE TO THIS RECOMMENDATION AND ALL ACTIONS SINCE 1979 TAKEN CONCERNING THE AUXILIARY FEEDWATER SYSTEM AT DAVIS-BESSE.
YOUR RESPONSE 4
}
SHOULD INCLUDE A LISTING OF ALL MEETINGS, COPIES 0F ALL CORRESPONDENCE BETWEEN NRC AND THE-i LICENSEE AND DOCUMENTS CONCERNING THE AUXILIARY FEEDWATER SYSTEM SINCE 1979.
ANSWER:
I EVEN BEFORE THE B&W REACTOR TRANSIENT TASK FORCE ISSUED ITS f
RECOMMENDATION FOR A DIVERSE DRIVE AUXILIARY'FEEDWATER (AFW) 4-i
. - -.. _ _ -.. ~..,
m.
- - ~ -..
3 QUESTION 12.
(CONTINUED),
I PUMP AT DAVIS-BESSE, THE STAFF HAD RECOGNIZED THAT AFW PUMP POWER DIVERSITY WOULD LIKELY IMPROVE AFW SYSTEM RELIABILITY.
THIS WOULD REDUCE THE VULNERABILITY OF THE PLANT TO LOSS OF DECAY HEAT REMOVAL CAPABILITY THROUGH LOSS OR DELAYED START OF i
THE STEAM TURBINE DRIVEN AFW PUMPS WHICH COULD RESULT IN STEAM GENERATOR DRYOUT.
THE STAFF IDENTIFIED ITS CONCERN IN THE SAFETY i
EVALUATION (SE) WHICH WAS ATTACHED WITH THE JULY 6, 1979 LETTER AUTHORIZING RESTART FOLLOWING THE TMI-2 ACCIDENT.
THE STAFF NOTED i
IN THE SE THAT A 100% CAPACITY MOTOR-DRIVEN AFW PUMP WOULD BE REQUIRED, BUT INDICATED THAT OTHER ALTERNATIVES (TO IMPROVE RELIABILITY) COULD BE ACCEPTABLE.
THE STAFF NOTED, IN ITS SE, THAT THE LICENSEE HAD AGREED TO CONTINUE TO REVIEW THE PERFORMANCE OF THE AFW SYSTEM FOR ASSURANCE OF RELIABILITY AND PERFORMANCE, AND THAT STAFF REQUIREMENTS WOULD BE HELD IN ABEYANCE CONSISTENT WITH THIS AGREEMENT, a
ON JANUARY 4, 1980,-TOLEDO EDISON SUBMITTED A RELIABILITY j
ANALYSIS AS REQUESTED BY THE NRC ON AUGUST 21, 1979.
THE i
l PRINCIPAL RESULT OF THE STUDY WAS TO IDENTIFY DOMINANT CONTRIBUTORS TO AFW SYSTEM UNRELIABILITY, HOWEVER, SPECIFIC MODIFICATIONS FOR IMPROVEMENT WERE NOT EXAMINED.
THIS RELIABILITY STUDY LATER BECAME A REQUIREMENT UNDER NUREG-0737, ITEM ll.E.1.1 AND BECAME PART OF THAT REVIEW.
l i
4 i
f I.
l
QUESTION 12.
(CONTINUED)
-U-i
\\
I UPGRADE OF THE EXISTING STARTUP FEED PUMP (SUFP).
ALSO BY JUNE 1981, THE IMPLEMENTATION PLAN FOR NUREG-0667 (MEMO D. EISENHUT TO H. DENTON, JUNE 3, 1981) REFLECTED THE DECISION TO AWAIT THE RESULTS OF A RELIABILITY STUDY WHICH THE LICENSEE HAD UNDERWAY, TO DETERMINE SYSTEM MODIFICATION REQUIREMENTS INSTEAD OF ISSUING AN ORDER TO INSTALL A DIVERSE DRIVE PUMP.
1 i
THE LICENSEE'S RELIABILITY STUDY WAS SUBMITTED DECEMBER 31, 1981, AND CONCLUDED THAT GREATER IMPROVEMENT IN RELIABILITY COULD BE ACHIEVED BY OTHER LESS COSTLY, MODIFICATIONS TO THE AFW SYSTEM THAN COULD ACHIEVED BY THE ADDITION OF A THIRD TRAIN.
THE STUDY WAS REVIEWED IN 1982 BY THE NRC AND ITS CONTRACTORS.
SOME MODIFICATIONS IDENTIFIED IN THE LICENSEE'S REPORT HAVE BEEN MADE AND ARE INCLUDED IN THE ANSWER TO ObESTION 13.
THE RESULTS OF THE STAFF / CONTRACTOR REVIEW OF THE DAVIS BESSE RELIABILITY STUDY WAS i
TRANSMITTED FROM DST TO DSI ON FEBRUARY 4, 1983, AND CONCLUDED j
THAT AN INDEPENDENT THIRD TRAIN WOULD LIKELY IMPROVE THE AFW SYSTEM RELIABILITY.
t IN 1982-1983, THE NRR STAFF WAS INVOLVED IN A GENERIC EFFORT REGARDING THE UPGRADING OF AFW SYSTEMS IN OPERATING PWRS.
THIS i
4 i
i
?
QUESTION 12.
(CONTINUED) :
l IN MAY 1980, THE B&W REACTOR TRANSIENT TASK FORCE MADE A RECOMMENDATION, IN NUREG-0667, INCLUDING:
" INSTALLATION OF A DIVERSE DRIVEN AFW PUMPS SHOULD BE EXPEDITED AT THE i
DAVIS-BESSE 1 FACILITY,"
THE RECOMMENDATIONS IN NUREG-0667 WERE REVIEWED BY THE DIVISION OF SAFETY TECHNOLOGY IN RESPONSE TO A REQUEST BY THE DIRECTOR OF NRR ON MAY 21, 1980.
DST EVALUATED THE SAFETY SIGNIFICANCE OF EACH RECOMMENDATION AND ASSIGNED i
i PRIORITIES FOR IMPLEMENTATION.
THE RECOMMENDATION FOR DIVERSE DRIVE AFW PUMPS AT DAVIS BESSE 1 WAS ASSIGNED PRIORITY l WITH 4
i THE RECOMMENDATION THAT IT SHOULD BE IMPLEMENTED BY 0RDER TO THE
- LICENSEE, (MEMO R. MATTSON TO H. DENTON OF AUGUST 8, 1980),
I i
IN 1980 TOLEDO EDISON COMPANY HAD INITIATED STUDIES RELATING TO HOW THE RELIABILITY OF THE AFW SYSTEM COULD BE IMPROVED AND, IN JANUARY OF 1981, THE LICENSEE PROPOSED TO THE NRC THAT A RISK 1
j REDUCTION COMPARISON BE USED TO EVALUATE VARIOUS ALTERNATIVES l
FOR IMPROVING RELIABILITY, THE LICENSEE ALSO INDICATED THAT j
CERTAIN DESIGN FEATURES INCLUDED !N THE DAVIS BESSE FACILITY WERE IGNORED OR NOT CONSIDERED IN THE STAFF'S PREVIOUS DETERMINATION THAT A DIVERSE DRIVE AFW TRAIN WAS REQUIRED, THE l
NRC INFORMED THE LICENSEE IN THE SPRING OF 1981 THAT THE STAFF REQUIREMENT FOR IMPROVING RELIABILITY MAY BE SATISFIED BY AN i
I L
4 1
_ _,,. ~,
QUESTION 12.
(CONTINUED).
EFFORT STEMMED FROM THE BULLETINS AND ORDERS (B&O) TASK FORCE REVIEWS AND RECOMMENDATIONS IN NUREG-0611 AND IN NUREG-0635 TO IMPROVE AFW SYSTEM RELIABILITY.
DSI DEVELOPED A DRAFT CRGR PACKAGE CONCERNING GENERIC BACKFITTING REQUIREMENTS FOR UPGRADING AUXILIARY FEEDWATER SYSTEMS IN OPERATING PLANTS (ISSUED FOR NRR STAFF COMMENT BY R. MATTSON ON AUGUST 22, 1983).
NRR STAFF REVIEW AND COMMENT ON THE PROPOSED CRGR PACKAGE CON-TINUED FOR THE REMAINDER OF 1983.
AT THIS TIME, ONLY FOUR PLANTS (DAVIS BESSE, TURKEY POINT 3 AND 4, AND HADDAM NECK) LACKED ELECTRIC DRIVEN AFW PUMPS, COMPLETION OF THE NRR STAFF ACTION ON THE PROPOSED CRGR PACKAGE WAS DELAYED PENDING RESOLUTION OF JUSTIFICATION FOR THE PROPOSED TECHNICAL POSITION.
COMPLETION OF STAFF ACTION ON THE DAVIS BESSE RELIABILITY STUDY 4
WAS HELD IN ABEYANCE THROUGHOUT 1983 WHILE STAFF CONSIDERATION OF THE CRGR PACKAGE TO BE SUBMITTED WAS IN PROGRESS.
ON APRIL 23, 1984, THE STAFF SER AND CONTRACTOR EVALUATION OF THE DAVIS BESSE RELIABILITY STUDY WAS TRANSMITTED TO TOLEDO EDISON.
THE STAFF CONCLUDED THAT THE DAVIS BESSE AFW SYSTEM IS IN THE LOW RELIABILITY RANGE COMPARED WITH AFW SYSTEMS OF OTHER PWR PLANTS, l
l l
l
00ESTION 12.
(CONTINUED) '
t j
~
ON JULY 18, 1984, DSI INDICATED THAT, SINCE PROGRESS ON THE i
PROPOSED CRGR PACKAGE WAS DELAYED, THE STAFF SHOULD RESUME
)
DISCUSSION WITH TOLEDO EDISON REGARDING THE ISSUE OF A DIVERSE j
AFW PUMP WITHOUT WAITING FOR RESOLUTION OF THE CRGR PACKAGE.
THE i
CRGR PACKAGE HAS NOT YET BEEN SUBMITTED TO CRGR FOR CONSIDERATION.
ON SEPTEMBER 19, 1984, THE STAFF MET WITH TOLEDO EDISON TO DISCUSS THE AFW PUMP UPGRADE.
AT THIS MEETING TOLED0' EDISON COMMITTED TO INSTALL A NEW STARTUP PUMP IN THE TURBINE BUILDING BASED ON OTHER SAFETY CONCERNS DESCRIBED BELOW.
.i IN MID-1984, THE LICENSEE DISCOVERED THAT UNANALYZED HIGH-ENERGY i
AND MODERATE-ENERGY PIPE LINE BREAKS RELATED TO THE USE OF THE STARTUP t
FEEDWATER PUMP COULD JEOPARDIZE THE SAFETY RELATED AFW PUMPS.
THE LICENSEE DETERMINED THAT THESE HAZARDS WOULD BE CORRECTED BY REPLACING THE ELECTRIC STARTUP PUMP WITH A NEW, ELECTRICALLY DRIVEN PUMP RELOCATED IN THE TURBINE BUILDING.
THE NEW PUMP I
WOULD BE SIZED TO PROVIDE THE FLOW OF AT LEAST ONE AFW PUMP, COULD BE SUPPLIED WITH POWER FROM THE DIESEL GENERATOR, AND l
COULD BE USED AS A 100% CAPACITY ELECTRIC MOTOR DRIVEN AFW PUMP f
TO SATISFY DIVERSITY REQUIREMENTS.
HOWEVER, THE STARTUP PUMP i
l INSTALLATION WOULD NOT BE SAFETY GRADE.
l THE NEW STARTUP FEEDWATER PUMP IS REQUIRED, BY LICENSE CONDITION i
ISSUED JANUARY 8, 1985, TO BE INSTALLED AND MADE OPERATIONAL BEFORE 4
QUESTION 12.
(CONTINUED) -
STARTUP FROM THE NEXT REFUELING OUTAGE (SCHEDULED FOR SPRING 1986).
THE ATTACHED LISTING IDENTIFIES DOCUMENTATION RELATED TO THE DIVERSE-DRIVEN AFW PUMP AT DAVIS-BESSE.
COPIES OF THE DOCUMENTS ARE PROVIDED IN ENCLOSURE 1.
I COMMISSIONER ASSELSTINE ADDS THE FOLLOWING:
THE DAVIS BESSE EVENT, THE RESPONSES TO THIS QUESTION AND TO QUESTION 13 SUGGEST THERE ARE FLAWS IN THE APPROACH BEING TAKEN 1
TO ACHIEVING AN ACCEPTABLE LEVEL OF SAFETY.
THE RESPONSES RAISE QUESTIONS REGARDING:
(A) THE USEFULNESS OF THE METHODOLOGIES FOR PERFORMING COST-BENEFIT ANALYSES, (B) WHETHER QUANTITATIVE SAFETY ANALYSES ARE REVEALING THE ACTUAL WEAK SPOTS IN SAFETY SYSTEMS, AND (C) THE NRC DECISION-MAKING PROCESS IN GENERAL.
l 4
TABLE Q. 12 DOCUMENTATION AND MEETINGS RELATED TO THE DAVIS BESSE AUXILIARY FEEDWATER SYSTEM REVIEW 1
Date Description Remarks May 16, 1979 Commission Shutdown Order NRC issued an Order requiring licensee to take various (cxternal) actions to improve the capability and reliability t
of Davis-Besse to respond to~ transients.
Includes requirements for certain improvements in the AFW System.
May 22, 1979 Letter from Toledo Edison (Mr. Poe) to Forwards plant specific analysis of small break NRR (R. Reid) Transmitting Vol. VI behavior at Davis-Besse.
of " Evaluation of Transient Behavior and Small Reactor Coolant System Breaks I
in the 177 Fuel Assembly Plants" May 23, 1979 Letter from Toledo Edison (Mr. Poe) to Transmits operating procedure matrix.
NRR (R. Reid) Transmitting Operating Procedure Matrix May 23, 1979 Letter from Toledo Edison (Mr. Poe) to Discusses overall reliability of AFW system l
NRR (R. Reid) concerning the AFW System and adequacy of AFW system capacity.
l Juns 15, 1979 Letter from Toledo Edison (Mr. Poe) to Transmits a report titled " Analysis of a Loss of H. Denton (D/NRR) concerning the AFW system Feedwater Transient for the Davis-Besse Nuclear Power Station, Unit 1".
t June 23, 1979 Letter from Toledo Edison to R.
Transmitted information demonstrating capability (external)
Reid (ORB 4/DL) transmitting of a dry steam generator to drive AFW turbine after information requested by Mazetis (NRC) loss of feedwater. Also provides analysis of capability to start AFW turbine 30 minutes after loss-of-feedwater.
July 6, 1979 Letter from NRR (H. Denton) to Toledo Letter permits resumption of operations and Edison (Mr. Roe) Transmiting Safety transmits SER on Toledo Edison responses and Evaluation on Response to NRC Shutdown actions relating to the Shutdown Order. SER l
Order of May 16, 1979 includes statements that the staff would require j
plant modification to provide the greater diversity offered by a 100% capacity motor-operated AFW pump, or an alternative acceptable to the staff.
Date Description Remarks e
August 21, 1979 Letter from D. Ross (Bulletin & Order This letter discusses organizational difficulties (external)
Task Force Director) to All B&W Operating in obtaining required long term responses to Plants except TMI-I and 2, re: IDENTIFI-Commission's May 1979 orders and sets out plan CATION AND RESOLUTION OF LONG-TERM and schedules for obtaining required submittals.
i GENERIC ISSUES RELATED TO THE COMMISSION ORDER OF MAY 1979 January 4, 1980 Letter from Toledo Edison to R. Reid Submits generic report on " Auxiliary Feedwater
'(external)
(ORB #4/DL) responding to NRC letter of Systems Reliability Analyses for B&W Plants",
August 21, 1979 BAW 1584, and draft plant specific analysis for Davis Besse. Report identifies dominant contributors to AFW system unreliability including AC dependency of motor-operated valves and system unavailability resulting from outages for preventive maintenance.
May 1980 NUREG-0667 The B&W Reactor Transient Response Task Force recommended (external)
" TRANSIENT RESPONSE OF B&W DESIGN.
that, " Installation of a diverse-driven AFW pump REACTORS" should be expedited at the Davis-Besse 1 facility."
May 21, 1980 Meno to H. Denton (NRR) to R.
Requests review, evaluation, and assignment of (internal)
Mattson (D/ DST) re: FINAL REPORT OF priorities for implementing recommendations of NUREG-0667.
THE B&W REACTOR TPANSIENT RESPONSE TASK FORCE August 8, 1980 Memorandum from R. Mattson (D/ DST) to Responds to May 21, 1980 request to review NUREG-0667 and (internal)
H. Denton (NRR) " REVIEW 0F FINAL REPORT provide evaluation of the safety significance of the OF THE B&W REACTOR TRANSIENT RESPONSE recommendations. Urges that the recommendation in TASK FORCE" (NUREG-0667)
NUREG-0667 (May 1980) that a motor-driven AFW pump should be required at Davis-Besse be implemented by issuing an order to the facility operating license.
Also recornends that the Order require an analysis of the alternate cooling scheme proposed by licensee if all feedwater is lost to show the core is adequately protected.
~
Date Description Remarks S*ptember 3, 1980 Memorandum P. Check (AD/DSI) to T. Novak Provides status of review on Item II.E.1.1 of (internal)
(AD/DL) re; DAVIS BESSE UNIT 1 AUXILIARY NUREG 0660 regarding AFW system.
Identifies FEEDWATER SYSTEM RELIABILITY.
concern with dependency of both AFW pumps on steam.
Includes a request for additional information including a request for the licensee to state plans for instal'ing a third AFWS train no depending upon steam.
November 1980 NUREG-0737 Issued to all licensees of operating plants, (external)
" CLARIFICATION OF TMI ACTION PLAN applicants for operating licenses, and holders REQUIREMENTS" construction by accompanying 650.54f letter.
S2ptember 11, 1980 Memo from D. Garner (ORB #4/DL) to Discusses reasons for delay of Toledo Edison (internal)
T. Novak (ADOR/DL) TECO's INTENTIONS response on the third AFW pump. Concludes NRC WITH RESPECT TO THE ADDITION OF A should give Toledo Edison time to complete their DIVERSE POWERED AUXILIARY FEEDWATER PUMP studies and submit proposal regarding the third AFW pump.
January 23, 1981 Letter from Toledo Edison to R. Reid Responds to NRC letter of July 5,1979 and accompanying l
(external)
(ORB #4/DL) responding to July 6, 1979 SER regarding diverse powered AFW pump.
Indicates Toledo letter and SER Edison has been studying the issue and evaluating various options to resolve the issue. Claims the staff has ignored plant features in establishing need for third pump and that this predetermines the need for diverse power capability. Proposes a risk reduction comparison to evaluate various alternatives.
i March 5, 1981 Meeting with Toledo Edison To discuss addition of third, diverse powered, AFW pumpe March 6, 1981 Memo D. Eisenhut (D/DL) to S. Hanauer Transmits the NRR preliminary plan for implementing (internal)
(D/DHFS), D. Ross (D/DSI), R. Vollmer NUREG-0667 recommendations.
Indicates that Item 3, (D/DE), and T. Murley (D/ DST) re:
Davis Besse Diverse Drive AFW, is to be implemented NUREG-0667 IMPLEMENTATION PLAN by Order.
4
,,--p
. _ ~
4
' Dato Description Remarks April 2, 1981 Letter from J. Stolz (ORB #4/DL) to Transmits request for additional information (external)
Mr. Crouse (Toledo Edison) presenting related to actions to improve AFW system Evaluation of Submittals in Response to reliability. Requests licensee to state plans NUREG-0737 Item II.E.1.1 and Comments and schedule for providing third AFW train with on AFW Pump Power Diversity diverse motive power. Suggests emphasis be placed on upgrade of the startup feedwater train to provide diversity and improve reliability. Upgrade would not have to satisfy same seismic design requirements as existing AFW system and all ESF standards.
May 22, 1981 Letter from Toledo Edison to J. Stolz Responds to NRC letter of April 2,1981. A study (external)
(ORB #4/DL) Indicates Intent to Submit to identify dominant failure contributors is PRA on the AFW System unde rway. The study will identify dominant failure contributors to system unavailability.
Commits to upgrades of systems based on study results. Study to be submitted July 1981. Plans and schedule for AFW system and/or startup feedwater pump to be discussed when study is completed.
(This study was submitted December 31,1981.)
Juna 3, 1981 Memo D. Eisenhut (D/DL) to H. Denton Transmits the implementation plan for NUREG-U667 (internal)
(NRR) re: NUREG-0667 TRANSIENT RESPONSE recommendations.
Indicates that the issuance of an 0F B&W DESIGNED REACTORS - IMPLEMENT-Order relating to the installation of a diverse-drive ATION PLAN AFW pump at Davis Besse is postponed until a risk study is completed by the licensee. Study is due June 1981.
(The study was actually submitted December 31,1981.)
Dat7 Description Remarks June 29, 1981 Memo T. Murley (D/ DST) to H. Denton (NRR)
Proposes a revised standard' review plan for the
~
(internal) re: Use of a Reliability Criterion in the AFW system.
Standard Review Plan for the Auxiliary Feedwater System July 28, 1981 Letter J. Stolz (ORB 4/DL) to Toledo Edison Forwards request for additional information (external)
Company Requesting Additional Information relating to AFW automatic initiation and flow for Item II.E.1.1 indication.
S*.ptember 16, 1981 Letter from Toledo Edison to J. Stolz Lists some improvements made or planned for (external)
(ORBi4/DL) Responding to July 28, 1981 the AFW system. Letter was in response to Letter July 28, 1981 letter Stolz (ORB #4/DL) to Toledo Edison requesting additional infonnation.
December 31, 1981 Letter from Toledo Edison to T. Novak Identifies system modifications to improve (external)
(ADOR/DL) Submits report titled reliability. Concludes necessary reliability
" Auxiliary Feedwater System Reliability improvements can be achieved without adding third Analysis - Final Report" pump. Addition of third train AFW Would cost
$1.2 million and have a figure-of-merit of 15 vs.
the " Analysis Based" improvements cost of $300,000 for a figure-of-ment of 24.
Licensee commits to specific improvements upon receipt of NRC concurrence with the approach. States Toledo Edison Company has no plans for tne third train configuration.
Fcbruary 4, 1983 Memo A. Thadani (RRAB/ DST) to 0. Parr The memorandum transmits an evaluate based on a (internal)
(ASB/DSI) re: EVALUATION OF THE RELIABILITY Brookhaven National Laboratory review of Toledo STUDY FOR DAVIS BESSE UNIT 1 UPGRADED Edison Co. reliability study of the Davis Besse AUXILIARY FEEDWATER SYSTEM.
AFW system submitted December 31,1981). Concludes that independent third train will likely improve AFW system unavailability to acceptable range.
Elimination of comon cause and single point failures will improve AFW unreliability by factor of 2.
Davis-Besse AFWS unavailability is estimated to be in low reliability range outside the SRP numerical criteria.
March 1, 1983 Memo from F. Rowsome (AD/ DST) to 0. Parr, Comments on February 4, 1983 Thadani memo above.
(internal) et al, DAVIS BESSE EMERGENCY FEEDWATER Restates recomendation that NRR should require SYSTEM installation of a third, qualified, motor-driven AFW pump at Davis-Besse. Notes that 300 GPM of feedwater with PORV lift would save the core.
Date Description Remarks August 22, 1983 Memo from R. Mattson (D/DSI) to D. Eisenhut, Transmits Draft CRGR package for review and (internal) et al, REQUEST FOR COMMENTS ON DRAFT CRGR requests comment. Action would require compliance PACKAGE CONCERNING REQUIREMENTS FOR with diverse-drive AFW pump power and AFW system UPGRADIhG AUXILIARY FEEDWATER SYSTEMS IN unavailability criteria.
OPERATING PLANTS August 26, 1983 Handwritten memo concerning the above Requests a meetig to discuss the above August 22, f
August 22, 1983 memo 1983 memo.
August 29, 1983 Memo from L. Rubenstein (AD/DSI) to Transmits SER for NUREG-0737 Item II.E.1.1.
SER i
(internal)
G. Lainas (AD/DL) SAFETY EVALUATION concludes with implementation of recommendations l
REPORT - TAP II.E.1.1 - AUXILIARY identified the Davis-Besse AFW system reliability l
FEEDWATER SYSTEM-DAVIS-BESSE will be considerably and acceptably improved.
Diverse drive for the AFW pumps is not included l
among the recommendations. The forwarding memo i
states a CRGR package was forwarded to DL for comment.
If reviewed affirmatively will require upgrade to meet power diversity for AFW systems.
Octcber 17, 1983 Memo from A. Thadani (RRAB/ DST) to 0. Parr Presents estimates of radioactivity (internal)
(ASB/DSI) AUXILIARY FEEDWATER SYSTEM CRGR releases due to loss-of-main-feedwater l
+
PACKAGE transients, and other input data for use in CRGR package for AFW system. Submitted as a result of a meeting on September 16, 1983 re CRGR packaae.
October 25, 1983 Memo from T. Speis (D/ DST) to R. Mattson Comments on draft CRGR package as requested by (internal)
(D/DSI) COMMENTS ON DRAFT CRGR PACKAGE August 22, 1983 memo. Notes that the package, if CONCERNING REQUIREMENTS FOR UPGRADING implemented independently, will have significant 3
AUXILIARY FEEDWATER SYSTEMS IN ramifications on USI A-45 program. Suggests a more OPERATING PLANTS detailed regulatory analysis should be done to provide a good basis for deciding whether this i
issue should be done independently of A-45 issue.
Suggests deferral of the decision until then. Also conments that the statement that a 2-pump AFW system cannot demonstrate acceptable reliability is not supported by the reference. Questions if it is true that cnly a 3-pump system can satisfy the reliability criterion.
Date Description Remarks November 16, 1983 Memo L. Rubenstein (AD/DSI) to G. Lainas Transmits memorandum A. Thddani to 0. Parr dated (internal)
(AD/DL) re: AUXILIARY FEEDWATER RELIABILITY February 4,1983. No recommended action on Davis-Bess'e.
STUDY, DAVIS BESSE UNIT 1 December 7,1983 Memo D. Eisenhut (D/DL) to R. Mattson Transmits comments on the CRGR package as (internal)
(D/DSI) re: DRAFT CRGR PACKAGE CONCERNING requested by memorandum of August 22, 1983.
REQUIREMENTS FOR UPGRADING AUXILIARY FEEDWATER SYSTEMS IN OPERATING PLANTS January 16, 1984 Memo A. Thadani (RRAB/ DST) to 0. Parr Revises estimates of probability of certain i
I (internal)
(ASB;DSI) re: Additional Information events in the CRGR package.
for the Auxiliary Feedwater System CRGR Package February 21, 1984 Letter from J. Stolz (ORB #4/DL) to Toledo Transmits SER for NUREC-0737, Item II.E.1.1.
(external)
Edison Transmits SER Addressing NUREG-0737 Identifies unresolved items and indicates Item II.E.1.1 licensee can appeal imposition of the required Technical Specifications to DL.
April 9, 1984 Memo from E. Jordan (IE) to D. Eisenhut Refers to March 2,1984 steam generator dry-out l
(internal)
(D/DL) DAVIS BESSE STUCK OPEN SAFETY VALVE event at Davis-Besse and indicates 0IE support EVENT OF MARCH 2, 1984 and encouragement for the proposed CRGR effort to require diverse AFW pump power.
Indicates additional equipment failures during the event could have led to serious safety consequences.
April 17,1984 Memo from L. Rubenstein (AD/ DST) to Comparison of the EFWS at TMI-1 and other B&W (internal)
G. Lainas (AD/DL) re: ADDITIONAL INPUT FOR operating plants. Notes Davis Besse AFW THE UCS TMI-1 2.206 PETITION - COMPARIS0N system has unavailability in low range compared 0F B&W PLANTS EMERGENCY FEEDWATER to other operating plants.
SYSTEMS TO SRP SECTION 10.4.9 CRITERIA
]
April 1984 NUREG-1066, " Comparison of Implementaion Provides results of a study of eight B&W designed i
(external) of Selected TMI Action Plan Requirements nuclear power plants to determine the degree of on Operating Plants Designed by Babcock compliance with selected NUREG-0737 recuirements.
& Wilcox" I
4
-=
i -
Data Description Remarks 4
April 23, 1984 Letter from J. Stolz (ORB #4/DL) to Toledo Letter transmits SER and BNL evaluation of (external)
Edison re: AUXILIARY FEEDWATER SYSTEM of Toledo Edison Co. AFW system reliability RELIABILITY STUDY analysis December 31, 1981. Concludes Davis Besse AFW is in low reliability range and unavailability exceeds the numerical criterion in SRP. Toledo Edison Co. study differs substantially in scope and assumptions from NUREG-0611 prescribed values, therefore, meaningful comparison to licensees results can not be made.
June 20, 1984 Memo from A. DeAgazio (ORBf4/DL) to Presents brief chronology of NRC efforts to (internal)
G. Lainas (AD/DL) THIRD AFW PUMP / DIESEL get a diverse power AFW pump at Davis-Besse.
GENERATOR AT DAVIS-BESSE Notes that Toledo Edison AFW system reliability Study concluded cost benefit comparison favors
" Analysis based" configuration and not the third train of AFW. Connits to improvements upon receipt of NRC concurrence with approach.
States Toledo Edison has no plans for third train configuration.
July 18, 1984 Memo from L. Rubenstein (AD/DSI) to Memorandum indicates that CRGR package is delayed, G. Lainas (AD/DL) AUXILIARY FEEDWATER therefore, urges having discussions with Toledo Edison SYSTEM - POWER DIVERSITY REQUIREMENTS AT regarding the issue of diverse AFW pump drive without DAVIS BESSE waiting for CRGR action.
1 September 19, 1984 Meeting with Toledo Edison Company This meeting between Toledo Edison Co. and NRC (internal) was to discuss modifications to the feedwater system at Davis Besse. Toledo commits to install new startup pump with larger capacity which will meet diversity requirements.
t 4
r 4
l 8
Date Description Remarks September 28, 1984 Memo H. Denton (NRR) to W. Dircks 'ED0)-
iPresents status of NUREG-0667. The Status (internal) re: CLOSE00T OF TMI ACTION PLAN TASK Table indicated that ADB had determined that II.E.5.2 TRANSIENT RESPONSE OF B&W diverse drive was not necessary. However, DESIGNED REACTORS this memo did not accurately reflect the staff position on diverse drive which is stated in the July 18, 1984 memo, identified above.
October 9, 1984 Memo from A. DeAgazio (ORB &4/DL) to Identifies potential backfit issue at (internal)
G. Lainas P0TENTIAL BACKFIT ISSUE AT Davis Besse as a result of 'a meeting held DAVIS BESSE on 9/19/84 with Toledo Edison. At that meeting Toledo Edison agreed to install an upgraded startup feedwater pump which will meet diversity requirements and resolve Appendix R and high/ medium energy pipe break considerations. Concludes no backfit issue involved.
November 9,1984 Memo A. Thadani (RRAB/ DST) to 0. Parr Provides analysis of probability of four events (internal)
(ASB/DSI) re: Auxiliary Feedwater discussed in CRGR package.
j System CRGR Package Nsvember 20, 1984 Memo L. Rubenstein (AD/DSI) to G. Lainas Transmits SER on continued use of existing startup (internal)
(AD/DL) re: CONTINUED OPERATION OF feedwater pump. Concludes use with present pipe t
STARTUP FEEDWATER PUMP - DAVIS BESSE I arrangement is acceptable until installation of the new startup feedwater pump system.
November 21, 1984 Letter from Toledo Ediscn to J. Stolz Presents general system description of the (external)
-(0RB#4/DL) Presents Preliminary Design proposed upgraded startup feedwater pump.
for Proposed Upgraded Startup Licensee committed to installation of the feedwater Pump new pump at the Septen.ber 19, 1984 meeting.
January 8,1985 Letter from A. DeAgazio (ORB #4/DL) to License Condition added to the Davis Besse 2
(external)
Toledo Edison AMENDMENT NO. 83 TO FACILITY operating license requires the installation i
OPERATING LICENSE N0. NPF-3: LICENSE of a new startup feedwater pump before starting CONDITION RELATING TO STARTUP FEEDWATER Cycle 6 and improves operating restrictions i
PUMP OPERATION with the present pump until then.
4 i
Date Description Remarks March 12, 1985 Memo from 0. Parr (ASB/DSI) to J. Stolz
. Submits comments and recommendations on Toledo (internal)
(ORB #4/DL) re: DAVIS BESSE STARTUP Edison Co. proposed startup pump design presented FEEDWATER PUMP - TAC N0. 55581 in the November 21, 1984 letter from Toledo Edison Company. Generally, the proposed design should be acceptable for diversity considerations.
June 10, 1985 Letter J. Keppler (R:III, NRC) to Identifies the actions to be taken by the licensee (external)
Toledo Edison Co., re: CONFIRMATORY prior to obtaining approval from Region III to resume ACTION LETTER operations.
Junn 17, 1985 Meeting with Toledo Edison Co.
Toledo Edisun discussed the AFW system design and a (internal)
TRANSCRIPT OF MEETING BETWEEN THE chronolt.gf of actions taken to improve the AFW NRC STAFF AND TOLED0 EDIS0N CO.
system reliability.
CONCERNING AFW SYSTEMS 4
m
CUESTION 13:
IN TERMS OF CONFIGURATION, RELIABILITY, DIVERSITY AND CAPACITY HOW, IF AT ALL, DOES THE AUXILIARY FEEDWATER SYSTEM AT DAVIS-BESSE DIFFER FROM THE SYSTEM IN PLACE ON MARCH 28,1979?
J ANSNER:
THE DAVIS-BESSE AFWS WAS ORIGINALLY DESIGNED AS A SAFETY GRADE SYSTEM. THERE HAS BEEN NO CHANGE IN THE DAVIS-BESSE AFWS IN TERMS OF CONFIGURATION (WO PLMP TRAINS), POWER DIVERSITY FOR THE PLN S, AND PUMP CAPACITIES SINCE MARCH 28, 1979. SINCE 1979, mE PLANT HAS MODIFIED THE VALVES IN ONE AFW PUMP TRAIN FROM AC POWERED TO DC POWERED IN ORDER TO PROVIDE INDEPENDENCE FROM AC POWER.
SOME PLNP INTERLOCKS AND SPEED SWITCHES HAVE ALSO BEEN ELIMINATED. ADDITIONAL TECHNICAL SPECIFICATIONS HAVE BEEN PROPOSED (1) FOR VERIFICATION CF AFW FLOW j
FROM THE PRIMARY WATER SOURCE (CONDENSATE STORAGE TANK) TO THE STE/+1
.L GENEPATORS AND (2) FOR PUMP TESTING TO PROVIDE COPNUNICATION BETWEEN THE -
l OPERATOR IN THE CONTROL ROOM AND THE PERSONNEL PERFORMING THE TEST LOCALLY.
AS PART:0F THE TMI ACTION PLAN DAVIS-BESSE IMPROVED THE AUTOMATIC INITIATION CF THE AFW SYSTEM TO SAFETY GPADE. ADDITIONALLY UPGRADES WERE MADE IN FLOW j
INSTRtPENTATION AND OTHER INDICATORS ASSOCIATED WITH THE AFW SYSTEM.
i FUR W ERMORE THE AFW TURBINE EXHAUST LINES HAVE BEEN UPGRADED TO MEET SEISMIC j
CATEGORY l REQUIREE NTS AND THE MECHANICAL-HYDRAULIC GOVERNOR ON ONE AFW PUMP O
HAS BEEN REPLACED WITH A HYDRAULIC GOVERNOR. _ LASTLY, ALL LOCAL MANUALLY-OPERATED VALVES, AND THE HANDWHEELS AND LOCAL PUSHBUTTON STATIONS OF THE MOTOR,-0PERATED VALVES, IN BOTH AFW SUCTION AND DISCHARGE PARTS ARE NOW
' LOCKED IN THE OPEN POSITION. THESE CHANGES ARE CONSIDERED TO BE AN IMPROVEMENT 1
l TO THE OVERALL' RELIABILITY OF THE AFWS WHEN COMPARED TO THE SYSTEM IN PLACE f
BEFORE 1979.
l
QUESTION 14.
ACCORDING TO PRELIMINARY INFORMATION PROVIDED BY THE NRC STAFF, THE LICENSEE HAS RESISTED NRC RECOMMENDATIONS TO IMPPOVE THE RELIABILITY AND CAPACITY OF THE AUXILIARY FEEDKATER SYSTEM AT DAVIS-BESSE.
IS THIS TRUE AND IF S0, WHY DID NRC NOT REQUIRE THAT IMPROVEMENTS BE MADE?
ANSWER.
THE LICENSEE WAS NOT IN AGREEMENT WITH THE'NRC RECOMMENDATIONS THAT IMPROVEMENTS TO THE AFW RELIABILITY MUST BE ACHIEVED BY THE ADDITION OF A THIRD AFW PUMP.
THE LICENSEE'S STUDIES WERE CONDUCTED TO REVIEW ALTERNATIVE, MORE COST-EFFECTIVE WAYS OF IMPROVING RELIABILITY OF THE AFW SYSTEM.
AS INDICATED IN A RESPONSE TO QUESTION 12, THERE HAVE BEEN ONGOING DISCUSSIONS SINCE 1979 RELATED TO IMPROVING THE RELIABILITY OF THE AFW SYSTEM AHD. REDUCING ITS DEPENDENCY UPON MOTIVE POWER FROM STEAM ONLY.
STARTING WITH THE ISSUANCE OF THE ORIGINAL OPERATING LICENSE AT DAVIS-BESSE, THROUGH THE ISSUANCE OF THE MAY 16, 1979 ORDERS AND SUBSEQUENT ACTIONS, THROUGH THE ISSUANCE OF NUREG 0737 REQUIREMENTS, AND THROUGH THE ONGOING DISCUSSIONS RELATED TO THE DIVERSE POWER ISSUE, WHICH INCLUDED l
l
l l
0UESTION 14.
(CONTINUED) :
SEVERAL RELIABILITY ANALYSES TO IDENTIFY DOMINANT FAILURE CONTRIBUTORS, BOTH THE hhC AND THE LICENSEE HAVE IDENTIFIED SYSTEM MODIFICATIONS, AND PROCEDURAL CHANGES WHICH WOULD IMPROVE THE RELIABILITY OF THE AFW SYSTEM.
ALL OF THE MODIFICATIONS REQUIRED BY THE NRC AND MANY OF THOSE IDENTIFIED BY THE LICENSEE HAVE BEEN IMPLEMENTED, AS INDICATED IN THE RESPONSE TO QUESTION 12, A NEW STARTUP FEEDWATER PUMP IS TO BE INSTALLED, BY LICENSE CONDITION, PRIOR TO RESTART FROM THE NEXT REFUELING OUTAGE.
WE WILL REVIEW THE FINAL DESIGN OF THE NEW STARTUP FEEDWATER PUMP TO DETERMINE WHETHER THE RELIABILITY OR DIVERSITY ISSUES HAVE BEEN RESOLVED.
REGARDING THE " CAPACITY" ISSUE, THE MAY 16, 1979 COMMISSION ORDER TO TOLEDO EDISON COMPANY REQUIRED AMONG OTHER ACTIONS, THAT "THE LICENSEES WILL REVIEW AND VERIFY THE ADEQUACY OF THE AUXILIARY FEEDWATER SYSTEM CAPACITY".
THE LICENSEE PROVIDED INFORMATION WHICH SHOWED THAT THE TOTAL MINIMUM FLOW TO ONE OR BOTH STEAM GENERATORS OF 550 GPM IS REQUIRED TO SUPPORT ACCIDENT ANALYSES.
THE LICENSEE ALSO SUPPLIED DATA WHICH SHOWED THAT EVEN THE DESIGN FLOW 0F 800 GPM TO EACH STEAM GENERATOR FROM THE 1
)
-c_,
3-UESTION 114, (CONTINUED) l RESPECTIVE AFW PUMPS IS EXCEEDED (GREATER THAN 850 GPM).
THE FLOW CAPACITY.OF THE DAVIS-BESSE AFW SYSTEM IS NOT AND HAS NEVER BEEN AN ISSUE.
i i
t 1
1 a
i m-
=r 3
=
y-y rg-em---
m-y',-
- ya
-am-y mpe-m ww-y
,e-q*g 9
y yw-w w
OUESTION 15.
THE COMMISSION WAS PROVIDED WITH A PRELIMINARY SEQUENCE OF EVENTS WHICH OCCURRED AT DAVIS-BESSE IN A JUNE 12, 1985 MEMORANDUM FROM WILLIAM J. DIRCKS, EXECUTIVE DIRECTOR FOR OPERATIONS THAT APPEARS NOT TO INCLUDE SEVERAL IMPORTANT DETAILS OF THE INCIDENT.
FOR EXAMPLE, THE PRELIMINARY CHRONOLOGY FAILS TO NOTE THAT THE PORV STUCK OPEN, THAT ECCS WAS INITIATED AND TURNED OFF, AND THAT ONE OF THE AUXILIARY FEEDWATER PUMPS COULD NOT BE RETURNED TO OPERATION FROM THE CONTROL ROOM.
WHEN DID THE j
COMMISSION FIRST BECOME AWARE OF THIS INFORMATION, AND WHY WAS IT NOT TRANSMITTED TO THE COMMISSION IN THE JUNE 12, 1985 MEMORANDUM?
ANSWER:
THE PRELIMINARY CHRONOLOGY WHICH WAS PROVIDED TO THE COMMISSION IN THE JUNE 12, 1985 MEMORANDUM, CONTAINED IN PART A PRELIMINARY SEQUENCE OF EVENTS PREPARED ON JUNE 10, 1985 BY THE LICENSEE, TOLEDO EDIS0N COMPANY.
AS SUCH IT WAS STILL UNDERGOING EXTENSIVE REVIEW AND EVALUATION BY BOTH THE UTILITY AND NRC.
n.- - --
. IN REGARD TO THE MISSING INFORMATION, ON JUNE 9, 1985, THE STAFF HAD BEEN BRIEFED ON THE ECCS MANUAL INITIATION AS WELL AS ON OTHER IMPORTANT PLANT PARAMETERS RELATED TO THE INCIDENT.
ON JUNE 11, 1985. PRELIMINARY NOTIFICATION PNO-III-85-47A WAS ISSUED PROVIDING INFORMATION REGARDING THE FAULTY OPERATION OF THE PORV AND THE SUBSEQUENT OPERATOR ACTION OF CLOSING THE BLOCK VALVE.
THIS INFORMATION WAS DETERMINED FROM A REVIEW 0F AN ALARM PRINTER BY NRC SITE INSPECTORS AND MANAGEMENT ONSITE ON JUNE 10, 1985.
lHE STAFF WAS ALSO AWARE ON JUNE 9, 1985 THAT ONE AUXILIARY FEED PUMP WAS BEING CONTROLLED LOCALLY OUTSIDE THE CONTROL ROOM.
lHE STAFF HAD ALSO CONFIRMED THAT ROTH PUMPS SUPPLIED AUXILIARY FEEDWATER TO THE STEAM GENERATORS FOLLOWING AUXILIARY FEEDWATER SYSTEM RESTORA-T!ON.
THE NRC SITE TEAMS (REGION lil AND FACT FINDING TEAMS) WERE BRIEFED, BY THE LICENSEE, ON THE SPECIFICS OF HOW THE AUXILIARY FEEDWATER CONTROLS WERE USED ON JUNE 11, 1985.
THE DAILY REPORT ON JUNE 12, 1985 INDICATED THE NATURE OF THESE ACTIVITIES.
PLEASE SEE THE ANSWER TO QUESTION 16 REGARDING THE PRELIMINARY SEQUENCE OF EVENTS.
f i
I f.
1 i
,00EST ON 16.
ACCORDING TO A JUNE 13, 1985 MEMORANDUM FROM WILLIAM J. DIRCKS, EXECUTIVE DIRECTOR FOR OPERATIONS, TO THE COMMISSION, THE LICENSEE FAILED TO PROVIDE ACCURATE INFOR-MATION TO THE NRC ABOUT THE DAVIS-BESSE
- INCIDENT, THE MEMORANDUM STATES:
"IT BECAME CLEAR THAT THE INITIAL WRITTEN DESCRIPTION OF THE EVENT WAS INCOMPLETE AND THAT A NUMBER OF POTENTIALLY IMPORTANT DETAILS WERE NOT INCLUDED."
WHAT INFORMA-TION WAS INCOMPLETE AND WHAT DETAILS WERE r
NOT INCLUDED IN THE LICENSEE'S INITIAL REPORT TO NRC7 WHAT IS THE REASON FOR THIS FAILURE AND WHAT, IF ANY, REPORTING REQUIREMENTS WERE VIOLATED?
ANSWER.
THE MEMORANDUM REFERRED TO IN THIS QUESTION NOTED THAT THE LICENSEE GAVE A BRIEFING ON THE EVENT SEQUENCE AND THAT IT BECAME CLEAR THAT THE INITIAL WRITTEN DESCRIPTION OF THE EVENT WAS INCOMPLETE, AND THAT A NUMBER OF P0TENTIALLY IMPORTANT DETAILS WERE NOT INCLUDED, THIS INCOMPLETENESS i
i 4
.~e
,.n.---..-,>---v-m 3
~
CUESTION 16, (CONTINUED) WAS NOTED BY THE TEAM BECAUSE THE LICENSEE'S ORAL BRIEFING THAT OCCURRED WHEN ThE TEAM ARRIVED GAVE DETAILS ON ITEMS THAT WERE NOT INCLUDED IN THE INITIAL LICENSEE PREPAPED SEQUENCE.
THE INITIAL TELEPHONE REPORT ON THE EVENT ON JUNE 9, 1985 ALSO DID NOT INCLUDE A NUMBER OF DETAILS NOW i
KNOWN TO THE NRC, AS AN EVENT EVALUATION PROCEEDS, THE i
EXTENT OF KNOWLEDGE ABOUT THE EVENT INCREASES, AND THE SEQUENCE OF EVENTS IS EXPANDED AND REVISED IN ORDER TO MAKE IT MORE DETAILED.
IT IS THE TEAM'S UNDERSTANDING THAT THE LICENSEE'S INITIAL SEQUENCE OF EVENTS WAS PREPARED QUICKLY AND PRIOR TO ITS COMPLETION OF THE ANALYSIS OF THE EVENT.
THUS, THE OBSERVATION OF THE TEAM WAS THAT THE LICENSEE'S SEGUENCE OF EVENTS SHOULD BE EXPANDED.
THE FACT-FINDING IS CONTINUING AND, AS A RESULT, IT IS EXPECTED THAT BOTH THE LICENSEE'S SECUENCE OF EVENTS AND THE ONE DEVELOPED BY THE NRC'S FACT-FINDING TEAM WILL CONTINUE TO BE FURTHER REVISED AND EXPANDED, AS APPROPRIATE, ON THE BASIS OF NEW INFORMATION, SINCE THIS IS AN ONGOING PROCESS, REVISIONS OF THE INITIAL SEQUENCE MAY CONTINUE TO BE IDENTIFIED, FURTHER, THE LICENSEE HAS 30 DAYS FROM THE EVENT TO SUBMIT A WRITTEN REPORT CONCERNING THE EVENT (LER AS REQUIRED BY 10 CFR 50.73),
QUESTION 17.
WHAT ACTIONS WILL NRC REQUIRE PRIOR TO RESTART OF DAVIS-BESSE.
SPECIFICALLY, WILL NRC REQUIRE THAT THE JANUARY 1985 LICENSE CONDITION COMMITTING TO AN ADDITIONAL AUXILIARY FEEDWATER PUMP BE FULFILLED PRIOR TO RESTART.
IN NOT, PLEASE 1
EXPLAIN WHY.
4 ANSWER.
PRIOR TO THE RESTART OF DAVIS-BESSE-1 THE NRC WILL REQUIRE THE LICENSEE TO UNDERSTAND THE UNDERLYING CAUSES OF THE EVENT, TAKE APPROPRIATE CORRECTIVE ACTIONS, SPECIFICALLY CORRECT THE i
FAILURES THAT OCCURRED DURING THE JUNE 9, 1985 EVENT, AND PROVIDE A WRITTEN REPORT TO THE NRC.
IN ADDITION, THE STAFF l
WILL MAKE A FINDING THAT THERE IS REASONABLE ASSURANCE THE AFW SYSTEM CAN REMOVE DECAY HEAT FROM THE DAVIS BESSE PLANT.
THIS FINDING WILL BE BASED ON THE EFFECTIVENESS OF THE CORRECTIVE ACTIONS AND OTHER IMPROVEMENTS MADE TO THE EXISTING AFW SYSTEM IN RESTORING IT TO THE SAME QUALITY STANDARDS ASSUMED IN THE f
ORIGINAL LICENSING DECISION.
A DECISION REGARDING INSTALLING THE ADDITIONAL AUXILIARY FEEDWATER PUMP PRIOR TO RESTART HAS NOT BEEN MADE. THIS DECISION IS DEPENDENT ON THE STAFF'S EVALUATION OF THE EVENT AND THE LICENSEE'S CORRECTIVE ACTIONS.
i
-,..m,.
1 QUESTION 17.
(CONTINUED) THE FACT-FINDING TEAM AT THE DAVIS-BESSE SITE WILL DEVELOP ADDITIONAL INFORMATION REGARDING THE EVENT AND AREAS NEEDING IMPROVEMENTS.
THE TEAM'S FINDINGS WILL BE CONSIDERED PRIOR Td A RESTART DECISION.
i A CONFIRMATORY ACTION LETTER WAS ISSUED JUNE 10, 1985 BY OUR REGIONAL ADMINISTRATOR, MR. KEPPLER.
THIS ACTION INSURES THE PLANT WILL REMAIN SHUTDOWN UNTIL THE NRC IS ASSURED THAT APPROPR! ATE CORRECTIVE ACTIONS HAVE BEEN TAKEN.
A COPY OF OUR CONFIRMATORY ACTION LETTER IS ATTACHED TO THE QUESTION 23 RESPONSE.
4 l
1
CUESTION 18.
LIST ALL PENDING REQUIREMENTS AND LICENSING ACTIONS RELATING TO SYSTEMS AND COMPONENTS INVOLVED IN THE DAVIS-BESSE EVENT.
AN'SWER.
THE FOLLOWING IS A LIST OF LICENSING ACTIONS OR REQUIREMENTS i
PENDING THAT ARE RELATED TO SYSTEMS OR COMPONENTS INVOLVED IN THE EVENT:
A.
RELIEF VALVE / SAFETY VALVE TESTING, NUREG 0737 ITEM ll D.I.
THERE WERE NO MODIFICATIONS NECESSARY ON THE PORV AS A RESULT OF THE EPRI TEST PROGRAM.
MODIFICATION TO THE SAFETY VALVE (RELOCATION AND LOOP-SEAL) WERE COMPLETED IN 1982.
REGARDING THE POST-IMPLEMENTATION REVIEW, THE LICENSEE HAS SUBMITTED THE REQUIRED TESTING REPORTS.
A REQUEST FOR ADDITIONAL INFORMATION HAS BEEN SENT TO THE LICENSEE.
RESPONSES ARE DUE IN MID-JULY 1985.
B.
LICENSE CONDITION 2.C.3(T) TO OPERATING LICENSE, NPF-3.
THE LICENSEE IS REQUIRED TO INSTALL A NEW, START-UP FEEDWATER PUMP BEFORE STARTUP FROM THE NEXT REFUELING OUTAGE.
'CUESTION 18.
(CONTINUED) '
C.
AFW SYSTEM TECHNICAL SPECIFICATIONS THE LICENSEE HAS SUBMITTED PROPOSED TECHNICAL SPECIFICATIONS AS REQUIRED UNDER NUREG-0737 ITEM II.E.1.1.
THESE HAVE BEEN REVIEWED AND CERTAIN CHANGES (INVOLVING THE FLOW VERIFICATION TEST AND THE TEST AND OPERATING PROCEDURES) HAVE BEEN REQUESTED BY THE STAFF.
THE LICENSEE WILL PROVIDE A REVISED PROPOSAL BY THE END OF JULY 1985.
D.
REPORT CHALLENGES TO PORV AND SAFETY VALVES NUREG 0737 ITEM ll.K.3.3 REQUIRES TECHNICAL SPECIFICATIONS TO REQUIRE REPORTING OF CHALLENGES TO PORV AND SAFETY VALVES.
THE LICENSEE HAS SUBMITTED THE REQUESTED TECHNICAL SPECIFICATION.
ISSUANCE OF THE AMENDMENT BY THE NRC IS IMMINENT.
E.
DETAILED CONTROL ROOM DESIGN REVIEW
SUMMARY
REPORT SUPPLEMENT 1 TO NUREG 0737 REQUIRED A DETAILED CONTROL ROOM DESIGN REVIEW (DCRDR)
SUMMARY
REPORT TO BE SUBMITTED.
THE
SUMMARY
REPORT HAS BEEN SUBMITTED BY THE LICENSEE AND IS CURRENTLY UNDER REVIEW BY THE NRC STAFF.
(ALSO SEE ANSWER TO QUESTION 11).
' '0VESTION 18.
(CONTINUED) !
F.
DELETION OF AFW TURBINE SYSTEM VALVE INTERLOCK THE LICENSEE HAS DETERMINE THAT DELETION OF STEAM PRESSURE INTERLOCKS ON THE AFW TURBINE VALVES WILL,
[
AMONG OTHER THINGS, IMPROVE AFW RELIABILITY AND HAS REQUESTED TECHNICAL SPECIFICATION CHANGES THAT WILL PERMIT THE DELETION AND WHICH ARE CURRENTLY-UNDER REVIEW BY NRC STAFF.
l l
i 4
i i
i i
i 1
I 1
i i
i i
i
.,.. -., -... - -. _ ~
i CUESTION 19.
ACCORDING TO A JUNE 13,1985 WMORANDUM FROM WILLIAM J.
DIRCKS, EXECUTIVE DIECTOR FOR OPERATIONS, TO THE COPfilSSION, THE NRC TASK FORE INVESTIGATING THE INCIDENT HAS ALLOWED A LAWER REPRESENTING TE LICENSEE TO E PESENT DURING INTERVIEWS WITH WDRERS AT TE PLANT. THIS PRACTIE WAS USED DURING TE INWSTIGATION OF TE ACCIDENT AT THREE MILE ISLAND WEE SCE BELIEVE IT ESULTED IN LESS TFAN CAEID TESTIMONY FROM WDRERS AND ENABLED TE COWANY TO COORDINATE TESTitt)NY PRACTIES SUCH AS THIS WEE ALSO HARSHLY CRITICIZED BY TE DEPARTENT OF JUSTI&
IN A MARCH 25,1983 LETTER. WHY IS THIS PRACTIE BEING ALLOWED AT DAVIS-BESSE WEN THE NRC HAS ALREADY NOTED THAT INF0PPATION ORIGINALLY PROVIDED WAS LESS THAN COMPLETE?
WHAT, IF ANY POLICY DOES NRC HAVE ON THIRD PARTY ATTENDANCE DURING INVESTIGATIONS?
- ANSWER, BY WAY OF BACKGPOUND IN ANSWERING THIS OUESTION, IT SHOULD BE NOTED THAT THE NRC DOES NOT HAVE TE AUTHORITY TO EXCLUDE AN ATTOREY OR OTHER EPESENTATIVE OF A WRSON'S CHOOSING FROM AN INTERVIEW, TE NRC CAN, OF COURSE, DECLIE TO CONDUCT AN INTERVIEW IF IT EREIVES THAT THE PESENCE OF A THIRD PARTY MAY CREATE A COWLICT OF INitHEST OR POTENTIAL INitetxENCE WITH THE INVESTIGATION, BUT ONLY A COURT CAN EXCLUDE THE
i OUESTION 19.
(CorrTINUFD)
REPRESENTATIVE. THIS IS CONSISTENT WITH THE VIEW PROVIDED BY THE EPAPTENT OF JUSTICE IN A FEPPUARY 16,1984 LETTER FP0M THE ASSISTAFT ATTOPNEY C{NERAL FOR THE CPIMINAL DIVISION TO CHAIRMAN PALLADINO.
A5 AN ALTERNATIVE TO A VOLUNTARY INTERVIEW OR IF A ERSON DOES NOT DESIRE TO COOPEPATE WITH THE NRC, TE NRC MAY COPPEL A KPSON'S PRESENCE TO PRO-VIDE INFORMATION BY ISSUING A SUBPOENA IN ACCORDANCE WITH SECTION 161(c) 0F TE ATOMIC ENERGY ACT OF 1954, AS ATNDED. HOWEVER, A KRSON SUBJECT TO A SUBPOEFA IS ENTITLED TO BE ACCOMPANIED, PEPPESENTED, AND ADVIED BY COUNSEL OR, IF KPPITIED BY THE AGENCY, BY OTHER QJALIFIED PEPRESENTATIVE LNDER THE ADMINISTRATIVE PPOCEDURE ACT, 5 USC 555(B). NRC MAY PE00EST THE ATTORNEY GENERAL OF THE UNITED STATES TO MAE APPLICATION BEF0PE THE DISTRICT COURT TO EhF0PCE A SLSPOENA IN ACCOPDANCE WITH SECTION 233 0F TE ATOMIC EEPGY ACT. AT THAT TIE, TE FRC COULD SEEK THE EXCLUSION OF THE KRSON'S PEPRESEPTATIVE, THE BASrS FOR THE E0 VEST WULD BE A CONFLICT OF ItF_ DEST OR INitmENCE WITH THE INVESTIGATION, THE COURTS VARY AS TO THE DEGPEE OF EVIDENCE NEEDED BY THE C#/FPfPENT TO 1
SUCCESSFULLY SUPPORT ITS RE0)EST, BUT CLEARLY SOETdiNG BOPE THAN A HYPOTHETICAL CONCERN WOULD PE NEEDED, THE NRC FACT FINDING TEAM FOLLOWED A PRACTICE OF RPMITTING INDIVIDUALS WHO VERE INTERVIEWED TO BE ACCCPPANIED AT THE INTERVIEW BY COUNSEL OR OTHER REPPESENTATIVES OF TEIR CHn0 SING. TK TEAM DID NOT ENC 00PAF INDIVIDUALS TO BPING OTHER PERSONS WITH THFP TO THE INTERVIEW, IF AN If0lVIDUAL DID BRING REPPESENTATIVES WITH HIM, THE TEAM BELIEVED THAT THE INDIVIDUAL WANTED THE PEPPESENTATIVES' ATTEh0ANCE AT THE INTERVIEW,
_3_
OUESTION 19.
(CONTINLG)
THE TEAM FOLLOWED THIS APPP0ACH AT DAVIS-BESSE BASFD ON A MlFFER OF FACTORS:
(1) THE STAFF DESIPS TO MINIMIZE TE ADVERSARY ENVIRONENT INHEPfFT IN AN NRC INVESTIGATION, THIS WAS CONSIST &lT WITH THE PPACTICE 0F THE NATIONAL SAFETY TRAtlSPORTATION BOARD WHICH WE UNDERSTAPO DES NOT PLACE LIMITATIONS ON WHO ACCOPPANIES AN INTERVIEWEE, (2) TE STAFF ADED TO PRCNTLY PPESERVE RELATIVELY FPESH ECOL-LECTICS OF INDIVIDUALS' ACTIONS IN TE PLAtIT DURING THE INCIDENT.
AN ATTEWT TO EXCLUDE THPOLG ERSUASION AN INTERVIEWEE'S REPE-SENTATIVE MAY HAVE PESULTED IN THE IFTERVIEWEE'S REFUSAL TO SPEAK TO TE TEAM VOLUNTARILY; THIS WOULD HAVE NECESSITATED TE RESORT TO C0WULSORY PROCESS WITH THE ACCCWANYING DB.AY IN CETTING INF0PPATION, (3) SUBPOENAS HAD NOT BEEN ISSUED TO THE INDIVIDUALS INTERVIEED SilCH THAT THEY WEPE PCT UNDER ANY COMPULSION Tn SPEAK WITH FPC, (4) THERE WAS NO APPARENT CONFLICT OF INTEEST. THE TEAM'S VIEW 0F TE SITUATION AS ITS IN0VIRY EVELOPED WAS TFAT TERE WAS NOT A SIG-NIFICANT DIVERSITY OF INitFta BEMEN THE LICENSEE AND THOSE IfflERVIEED AS IT RELATES TO THIS INCIDENT; MO (5) AS TE INTERVIEWS PROGESSED, TE PRESENCE OF OTHER PEPSONS AT THE INTERVIEWS DID NOT INitFttFE WITH THE INTEPVIEWS AND DID POT APPEAR TO HAVE WSULTED IN UNCANDID OR FABRICATED TESTIKit/ FP0M
OUESTION 19 (Cottr!NUED)
THE INDIVIDUALS, THE INF0PPATION DESCRIED IN THE JUNE 15m WNRANDlN AS " INCOMPLETE" REFEPRED TO THE PPELIMINARY SEQUEFE OF EVENTS DEVELOPED BY THE LICENSEE AFTER THE TPANSIENT, IT WAS PROVIDED TO THE NRC TF/M WITH THE IJNDERSTANDING THAT THE INF0PFATION WAS PPELIMINARY APO SUIUECT TO REVISION. AS STATED IN THE Jt0E 13TH f90PANDIN, THE LICENSEE WAS CONSIDEPED TO BE CANDID, FORTHCOMING AND C00PEPATIVE WITH THE TEAM.
ITS ACTIONS WERE NOT j
VIEWED AS AN ATTEWT TO WITHHOLD OR CONCEAL INFORMATION FROM THE TEAM, 00WANY COUNSEL WAS NOT, IN FACT, IN ATTENDANCE AT ALL OF THE INTERVIEWS, FOR EXAMPLE, THE SHIFT SUPERVISOR ON DUTY ON TE NIGHT OF THE INCIDENT INITIALLY SPOE TO TE TEAM ALCNE: TM) REACTOR OPERATOPS WHO WEE ON DlfiY ASED FOR TFE PESENT OF TEIR OPERATIONS SUPERVISOR DUPING TFEIR INTERVIEWS, IN ANSWER TO TE PORTION OF THE OL!ESTION CONCEPNING EXISTING CCPNISSION GUIDANE ON THIPD PARTY ATTENDANCE AT INTERVIEWS, THE CCINISSION APPPOVED ON MAY 21, 1985, THE FOLLOWING POLICY APPLICABLE TO INVESTIGATIONS INVOLVING POTENTIAL WRONGD0ING BY THE COPNISSION'S OFFICE OF INVESTIGATIONS:
INDIVIDUALS BEING INTERVIEWED WILL NDRfALLY BE NRMITTED TO HAVE A PERSONAL ATTOPJEY OR OlFER PEPSONAL PEPRESENTATIVE PRESENT DURING ifffERVIEWS. HOWEVER, IF THE PERSONAL ATTORNEY OR PEPPESENTATIVE ALSO REPRESENTS ANOTEP POTENTIAL INTERVIEWEE, OR THE COWANY BEING INVESTIGATED, THEN TE INVFSTIGATOR WILL CONTACT HEADCCARTERS AND A CASE-BY-CASE DETERMINATION SHALL PE MADE WHETER TO EXCLUDE TE PERSONAL ATT0PNEY ON CONFLICT OF INTEREST GPalNDS, E0 VESTS FOR OTER THAN WRSONAL COUNSEL SHALL BE HANDLED ON A CASE-BY-CASE BASIS AFTER CONSULTATION WITH OGC,
.i 5-i 1
i CUESTION 19.
(CONTINUFD)
THE COMISSION HAS NOT AD0PTED A POLICY ON THIRD PARTY ATTENDANCE FOR i
l STAFF INVESTIGATIONS SUCH AS THE TEAM IhNESTIGATI(fl AT DAVIS-BESSE. THIS ISSUE WILL BE CONSIDERED IN DEVELOPING THE INCIDENT IPNESTIGATION TEAM
- PROGPAM, Y
a 1
i i
i.
3 l
4 i
l c
l
~
b t
i I
i i
i
}
i n
y--,,-r
-vem-
-e-c-----
c - - -, -, -
--,-w
--r-
+ - - - - -
p---
w
-w--
s*
?
=
-r w-
>=v--
4 0UESTION 20.
PLEASE PROVIDE THE FOLLOWING INFORMATION FOR EACH YEAR SINCE 1980:
(A)
THE NUMBER OF 10 CFR 50.72 REPORTS.
ANSWER.
NUMBER OF 10 CFR 50.72 REPORTS YEAR FROM DAVIS-BESSE 1980 12 1981 14 1982 7
1983 18 1984 14 1985 (TO JUNE 19) 11 i
9
OVESTION 20, (B)
THE TOTAL NUMBER OF LICENSEE EVENT REPORTS, SPECIFYING THE NUMBER ATTRIBUTABLE TO PERSONNEL ERROR, EQUIPMENT FAILURES, AND DESIGN OR FABRICATION ERRORS.
- ANSWER,
SUMMARY
OF LERS FRCM DAVIS BESSE FOR 1981-1984 CAUSE STATED IN LER ABSTRACT NO. OF DESIGN /
YEAR
- LERS PERSONNEL EQUIPMENT FABRICATION OTHER 1981 79 33 37 8
1 1982 68 28 23 13 4
1983 74 19 38 10 7
1984 22
_8 7
6 1
TOTALS 243 88 105 37 13 t
i
OVESTION 20.
(C)
THE NUMBER OF UNUSUAL EVENTS, ALERTS AND ABNORMAL OCCURRENCES.
- ANSWER, THE FIFTEEN (15) DAVIS-BESSE UNUSUAL EVENTS ARE AS FOLLOWS:
DATE DESCRIPTION 04/13/80 FLOOD WATCH 06/25/80 MINOR FIRE IN CONTROL ROOM 07/29/80 EYE INJURY NON-NUCLEAR RELATED 02/04/81 LOSS OF METEOROLOGICAL. INDICATION 02/19/81 LOSS OF METEOROLOGICAL INDICATION 12/16/82 OVERTURNED GASOLINE TRUCK IN AREA 01/18/83 LOSS OF CONTAINMENT INTEGRITY (NO, 2 MSIV LEAKING) 12/17/83 REACTOR COOLANT LEAK (LETDOWN SYSTEM ISOLATION VALVE PACKING LEAK) 01/17/84 LOSS OF METEOROLOGICAL INDICATION 02/21/84 LOSS OF METEOROLOGICAL INDICATION 03/02/84 MAIN STEAM LINE SAFETY VALVE STUCK OPEN 05/02/84 LOSS OF METEOROLOGICAL' INDICATION 05/06/85 LOSS-OF METEOROLOGICAL INDICATION 05/16/85 RCS LEAK / PRESSURIZER SPRAY VALVE PACKING 06/09/85 REACTOR TRIP / LOSS OF MAIN FEEDWATER/ aux!LIARY FEEDWATER MALFUNCTION l
i 2-QUESTION 20C. (CONTINUED)
THE DAVIS-BESSE ALERTS ARE AS FOLLOWS:
1 l
NONE.
1 i
THE DAVIS-BESSE ABNORMAL OCCURRENCES ARE AS FOLLOWS:
1981 -
NO REPORTS.
1982 -
IN NUREG-0090, VOL. 5, N0. 2, INFORMATION WAS REPORTED ON DAMAGE THAT OCCURRED TO THE STEAM GENERATOR AUXILIARY FEED-WATER HEADER IN NO. 1 AND NO. 2 STEAM GENERATORS.
THIS INFORMATION APPEARED IN THE UPDATE SECTION OF THE REPORT UNDER ABNORMAL OCCURRENCE 76-11, STEAM GENERATOR PROBLEMS.
1983 -
NO REPORTS.
1984 -
NO REPORTS.
i l
i I
l l
6
,_.._v,-.
..--,,r g,_.
.e, y
___.-,,._~,.-.n
.. = _-...
QUESTION 20.
(D)
THE NUMBER AND CAUSE OF REACTOR TRIPS.
ANSWER.
1 OVER THIS PERIOD OF FIVE AND ONE-HALF YEARS, FORTY (40) REACTOR TRIPS OCCURRED.
THE CAUSE OF EACH TRIP AND ITS DATE ARE SHOWN IN THE FOLLOWING TABLE.
A LIST OF CAUSE DEFINITIONS IS PROVIDED AT THE END OF THIS TABLE.
FOR 1984 AND 1985, REACTOR TRIPS WERE ANALYZED TO DETERMINE IF AUXILIARY FEEDWATER PROBLEMS OCCURRED i
AFTER THE TRIP; THOSE ARE MARKED WITH AN ASTERISK, "*".
THIS ANALYSIS WAS NOT DONE FOR OTHER YEARS.
DATE CAUSE i
02/05/80 HARDWARE BELIEVED CAUSED BY MAIN STEAM ISOLATION q
t VALVE CLOSURE.
03/27/80 HARDWARE ELECTRICAL FAILURE IN THE ROD CONTROL SYSTEM.
i
)
04/07/80 HARDWARE HIGH FLUX DURING MAINTENANCE ON
& HUMAN ERROR FEEDWATER HEATER CAUSED PRESSURE j
INCREASE IN CONDENSER AND THE AUTOMATIC INTEGRATED CONTROL l
SYSTEM (ICS) ATTEMPTED TO CORRECT.
4 1
,,, _ -.,. - - ~ _,. -
n..,,
_.n
,,a y
-,.---,m.m,,.
m
1 QUESTION 20D. (CONTINUED) !
DATE CAUSE i
11/06/80 NOT PROVIDED BELIEVED TO BE DUE TO ELECTRICAL PROBLEM IN SWITCH YARD.
1 11/07/80 HUMAN ERROR PERSONNEL ERROR COMPLICATED BY ICS 1
CONTROL.
l 11/12/80 HARDWARE ELECTRICAL FAILURE.
1 03/11/81 HUMAN ERROR ELECTRICIAN ERROR LED TO MAIN STEAM ISOLATION VALVE CLOSURE.
04/25/81 HUMAN ERROR DURING STARTUP, TRIPPED ON LOW STEAM l
GENERATOR LEVEL DURING TEST OF MAIN FEEDWATER BLOCK VALVE.
STARTUP FEED f
PUMP DID NOT RESPOND QUICKLY ENOUGH.
[
05/12/81 HARDWARE ELECTRICAL FAILURE.
06/24/81 HARDWARE LOSS OF DC RESULTED IN LOSS OF NON-i NUCLEAR INSTRUMENTATION.
4 i
l
..,m,--
-u r
c n.-m
-- ---. - -, - - - - - - -. + -,,., - - -
-y,---~-v-ye
-,-,,-.m_w 9
-n-.,,-w w w-w~,,,-<
1 t
{
OVESTION 20D. (CONTINUED) f i
DATE CAUSE I
t l
07/30/81 NOT PROVIDED 1
09/02/81 NOT PROVIDED MANUAL TRIP.
i 10/22/81 PROCEDURE TRIP DURING USE OF SURVEILLANCE TEST f
i
{
PROCEDURE, t
1 1
i l
12/28/81 NOT PROVIDED HIGH FLUX TRIP (POSSIBLY SPURIOUS)
WHILE EXERCISING RODS.
i 10/28/82 PROCEDURE CONTROL VALVE TESTING.
i 10/29/82 NOT PROVIDED MAIN FEED PUMP TRIP DURING 1
i i
SURVEILLANCE TESTING.
i i
1 11/08/82 HARDWARE FAULTY MOISTURE SEPARATOR-REHEATER ll' LEVEL SWITCH.
i l
01/15/83 HUMAN ERROR UNTIMELY CORRECTION OF AXIAL FLUX i
i IMBALANCE.
r i
I t
i
QUESTION 20D. (CONTINUED) DATE CAUSE i
01/18/83
' HARDWARE ELECTRICAL FAILURE, BLOWN NON-NUCLEAR INSTRUMENTATION FUSE CAUSED HIGH PRESSURE TRIP.
4 01/31/83 HUMAN ERROR DUE TO FEEDWATER FLOW REGULATINi VALVE BEING CYCLED.
04/10/83 HUMAN ERROR NEGATIVE AXIAL FLUX IMBALANCE.
j 05/10/83 HARDWARE ELECTRICAL FAILURE OF AN INVERTER.
i 07/25/83 NOT PROVIDED ACTUATION OF STEAM AND FEEDWATER RUPTURE CONTROL SYSTEM FOR UNKNOWN 1
REASON.
I 10/02/83 S/G LEVEL TRIP DUE TO MANUAL FEEDWATER CONTROL.
L 10/02/83 HARDWARE ELECTRICAL FAILURE IN INTEGRATED CONTROL SYSTEM (ICS).
10/03/83 HUMAN ERROR ICS IN COMBINATION WITH HUMAN ERROR.
i QUESTION 20D. (CONTINUED) i DATE CAUSE i
10/15/83 HARDWARE CONTROL PROBLEN WITH MAIN FEED PUMP.
11/09/83 HARDWARE ELECTRICAL FAILURE IN CONTROL ROD DRIVE SYSTEM.
11/14/83 HARDWARE ELECTRICAL FAILURE IN CONTROL ROD DRIVE MODULE.
j 12/17/83 HARDWARE ELECTRICAL FAILURE IN REACTOR PROTECTION SYSTEM ANTICIPATORY TRIP CHANNEL.
01/09/84 HARDWARE ELECTRICAL FAILURE IN THE CONTROL ROD DRIVE SYSTEM.
03/02/84*
HARDWARE MAIN STEAM ISOLATION VALVE CLOSURE.
06/24/84 HUMAN ERROR OPENED WRONG TRIP BREAKER DURING SURVEILLANCE TESTING.
i
...._,-.m,,_.
-m.
i QUESTION 20D. (CONTINUED) i
(
DATE CAUSE-09/11/84 HUMAN ERROR FEEDWATER MOISTURE SEPARATOR-REHEATER LEVEL SWITCH BUMPED.
09/12/84 HARDWARE STEAM AND FEEDWATER CONTROL SYSTEM ELECTRICAL FAILURE.
d
]
01/15/85*
S/G LEVEL FEEDWATER FLOW CONTROL VALVES WERE IN MANUAL AT ZERO POWER.
03/21/85 HARDWARE OSCILLATIONS IN FEEDWATER CAUSED BY MAIN FEED PUMP.
J 1
04/24/85 HARDWARE FLUX TO FLOW IMBALANCE SIGNAL.
l 06/02/85 HARDWARE TURBINE TRIP ON HIGH VIBRATION DURING i
TESTING.
06/09/85*
HARDWARE LOSS OF MAIN FEED PUMP.
i 4
r
-7m---
-~-r--
- --,-- +--
A f
m QUESTION 20D.-(CONTINUED),
4
SUMMARY
THE OVERALL TRIP
SUMMARY
BY CAUSE FOR THOSE REACTOR TRIP l
SINCE 1980 IS AS FOLLOWS.
HARDWARE..................
20 HUMAN ERR 0R...............
9 STEAM GENERATOR...........
2 PROCEDURE.................
2 HARDWARE AND HUMAN ERROR... 1 0THER.....................
6 i
TOTAL.....................
40 4
i k
N11
\\
4 QUESTION 20D. (CONTINUED) CAUSE DEFINITIONS HARDWARE THE SCRAM WAS A DIRECT RESULT OF A SYSTEM, SUBSYSTEM, MAJOR SYSTEM COMPONENT, OR COMPONENT FAILURE OR FAULT.
HUMAN ERROR THE SCRAM WAS THE DIRECT RESULT OF AN INCORRECT PERSONNEL ACTION.
BOTH ANY COMBINATION OF HARDWARE AND HUMAN ERROR THAT (HARDWARE &
CAUSE A REACTOR SCRAM.
NOTE THAT THE ONLY REQUIRE-HUMAN ERROR)
MENT IS THAT THE SCRAM WOULD NOT HAVE OCCURRED WITHOUT BOTH ACTIONS.
PROCEDURE REACTOR SCRAMS THAT ARE A DIRECT RESULT OF PROTEDURAL DEFICIENCIES.
S/G LEVEL REACTOR SCRAMS THAT OCCUR WHILE THE STEAM GENERATOR LEVEL CONTROL SYSTEM IS IN MANUAL CONTROL.
UNKNOWN REACTOR SCRAMS FOR WHICH NO CAUSE CAN BE DEFINED, I.E., WHEN THE SYSTEM INITIATING THE SCRAM IS TESTED AFTER THE PLANT HAS BEEN STABILIZED NO FAILURE OR FAULT CAN BE FOUND.
QUESTION 20D. (CONTINUED) 4 CAUSE DEFINITIONS NOT PROVIDED THE SCRAM CAUSE COULD NOT BE DETERMINED BASED ON INFORMATION PROVIDED IN THE LICENSEE's LER, i
u J4, f
1 i
T
-4
CUESTION 20.
(E)
THE NUMBER OF ALL ENFORCEMENT ACTIONS INCLUDING A BRIEF DESCRIPfl0N OF THE ISSUE, THE SEVERITY CLASSIFICATION AND ANY FINE LEVIED.
ANSWER.
TWO ESCALATED ENFORCEMENT ACTIONS HAVE BEEN TAKEN AND COPIES OF THE ACTIONS ARE ATTACHED.
A COMPUTER PRINTOUT OF ALL CITATIONS, INCLUDING NON-ESCALATED ACTIONS, HAS BEEN PROVIDED IN ENCLOSURE 2 AS WELL AS A COPY OF TWO NOTICES OF VIOLATIONS AND PROPOSED IMPOSITION OF CIVIL PENALTIES.
A.
A NOTICE OF VIOLATION AND DROPOSED.lMPOSITION OF CIVIL PENALTIES IN THE AMOUNT OF $90,000 WAS ISSUED ON NOVEMBER 21, 1984 AND INVOLVED SEVERAL SEVERITY LEVEL 111 VIOLATIONS.
BOTH TRAINS OF THE CONTROL ROOM EMERGENCY VENTILATION SYSTEM (CREVS) WERE REMOVED ON APRIL 23, 1984 THROUGH MAY 7, 1984 WITHOUT VERIFYING THE OPERABILITY OF REDUNDANT EQUIPMENT.
THIS RENDERED THE CREVS INOPERABLE IN VIOLATION OF TECHNICAL SPECIFICATION REQUIREMENTS.
SEVERAL EXAMPLES OF FAILURES TO FOLLOW PROCEDURES REGARDING THE OPERATION OF THE STARTUP FEED PUMP WERE ALSO IDENTIFIED.
IN ADDITION, THREE EXAMPLES INVOLVING CHANGES IN THE FACILITY AS DESCRIBED IN THE SAFETY ANALYSIS REPORT WERE IDENTIFIED.
NO WRITTEN SAFETY EVALUATION OF WHETHER THE CHANGE INVOLVED
QUESTION 20E. (CONTINUED) A CHANGE IN THE TECHNICAL SPECIFICATIONS OR AN UNREVIEWED SAFETY QUESTION WAS PREPARED AS REQUIRED BY 10 CFR 50.59.
THE CIVIL PENALTY WAS PAID ON JANUARY 14, 1985.
B.
A NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES IN THE AMOUNT OF $13,000 WAS ISSUED ON JUNE 20, 1980 AND INVOLVED THREE ITEMS OF NONCOMPLIANCE INCLUDING AN OVEREXPOSURE TO RADIATION DUE TO INADEQUATE CONTROL OF ACCESS TO A HIGH RADIATION AREA NEAR THE REACTOR CAVITY.
THE VIOLATIONS WERE NOT CATEGORIZED ACCORDING TO SEVERITY LEVEL BECAUSE THEY PREDATED THE EXISTING ENFORCEMENT POLICY.
THE CIVIL PENALTY WAS PAID ON JULY 10, 1980.
OUESTION 21:
NRC'S MOST RECENT SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE REPORT ON DAVIS-BESSE NOTED THAT IMPROVEMENT WAS NEEDED IN 5 0F 11 AREAS.
THE REPORT CONCLUDED THAT " STRONG STEPS ARE NEEDED TO RAISE THE PERFORMANCE LEVEL AT THE DAVIS-BESSE FACILITY."
SPECIFICALLY WHAT ACTIONS HAS NRC TAKEN?
ANSWER:
THE FOLLOWING ACTIONS HAVE BEEN TAKEN SINCE DECEMBER 1984 TO IMPROVE THE LICENSEE'S PERFORMANCE.
1.
INSPECTION ACTIVITIES HAVE BEEN INCREASED AND FOCUSED ON SYSTEMATIC ASSESSMENT OF LICENSEE PERF0PMANCE (SALP) CATEGORY 3 FUNCTIONAL AREAS AND OTHER FUNCTIONAL AREAS WHERE PERFORMANCE LEVEL WAS PERCEIVED AS DECLINING.
THE PUPPOSE OF THESE INSPECTIONS IS TO DETERMINE THE ROOT CAUSE(S) 0F POOR PERFORMANCE AND DETERMINE IF PLANNED LICENSEE CORRECTIVE ACTIONS ADDRESS THE ROOT CAUSES, ARE LIKELY TO BE EFFECTIVE, AND ARE APPROPRIATELY SCHEDULED.
, 2.
THE REGIONAL ADMINISTPATOR ME7 WITH THE CHIEF EXECUTIVE OFFICER ON DECEMBER 28, 1984 TO DISCUSS WEAKNESSES IN LICENSEE'S PERFORMANCE.
THE REGIONAL ADMINISTRATOR URGED THE CHIEF
. EXECUTIVE OFFICER TO OBTAIN EXPERIENCED SUPPORT FROM OUTSIDE THE TOLEDO EDISON COMPANY IN ORDER TO ACHIEVE NEEDED IMPROVEMENT.
3.
COMMISSIONER ASSELSTINE VISITED THE DAVIS-BESSE FACILITY ON JANUARY 11, 1985, TO MAKE FIRST HAND OBSERVATIONS AND SUPPORT NRC EFFORTS TO IMPROVE LICENSEE'S PERFORMANCE.
4.
THE REGIONAL ADMINISTPATOR BRIEFED THE COMMISSIONERS ON THE PERFORMANCE PROBLEMS AT DAVIS-BESSE DURING A COMMISSION MEETING WITH THE OFFICE DIRECTORS AND REGIONAL ADMINISTRATORS ON JANUARY 29, 1985.
5.
THE CHIEF EXECUTIVE OFFICER AND MEMBERS OF HIS STAFF MET WITH THE REGIONAL ADMINISTRATOR AND MEMBEPS OF HIS STAFF ON MARCH 6, 1985.
THE LICENSEE PRESENTED ITS ACTION PLAN TO ADDRESS THE SALP FINDINGS AND TO IMPROVE PERFORMANCE.
THE ACTION PLAN ADDRESSED MANAGEMENT INITIATIVES TO IMPROVE PERFORMANCE IN THE APEAS OF PLANT OPERATIONS, MAINTENANCE, TRAINING, QUALITY ASSURANCE AND ADMINISTRATIVE CONTROLS, FIRE PROTECTION AND EMERGENCY PLANNING.
, 6.
THE CHIEF EXECUTIVE OFFICER AND MEMBERS OF HIS STAFF MET WITH THE EXECUTIVE DIRECTOR FOR OPERATIONS, INVOLVED OFFICE DIRECTORS AND THE REGIONAL ADMINISTRATOR ON MAY 17, 1985.
.THE LICENSEE DISCUSSED HIS DETERMINATION AND PLAN TO IMPROVE PERFORMANCE.
7.
AN ENFORCEMENT CONFERENCE WAS HELD BY REGION lli WITH THE LICENSEE ON MAY 24, 1985, TO DISCUSS THREE RECENT OPERATIONAL EVENTS WHICH CONTINUED TO SHOW WEAK LICENSEE PERFORMAN'CE.
AN ESCALATED ENFORCEMENT ACTION IS BEING PROCESSED AT THIS TIME, 8.
MONTHLY MEETINGS ARE BEING HELD WITH THE LICENSEE TO MONIT00 ITS PROGRESS IN IMPLEMENTING THE PERFORMANCE ENHANCEMENT PROGRAM (PEP).
THE PEP IS A FROGRAM INITIATED BY THE LICENSEE IN LATE 1983 TO IMPROVE REGULATORY PERFORMANCE AT THE DAVIS-BESSE FACILITY.
AS A RESULT OF THESE EFFORTS, IMPROVEMENTS IN LICENSEE PERFORMANCE HAVE BEEN NOTED, BUT OVEPALL PROGRESS HAS BEEN SLOW.
REGION lll IS CLOSELY FOLLOWING THE LICENSEE'S ACTIONS THROUGH AN AUGMENTED INSPECTION PROGRAM AND THE MONTHLY MEETINGS.
FURTHER, THE TOLEDO EDISON COMPANY ANNOUNCED ON JUNE 18, 1985, THE APPOINTMENT OF A NEW COMPANY PRESIDENT AND SENIOR VICE PRESIDENT, NUCLEAR.
THIS CHANGE WAS OBVIOUSLY DESIGNED, IN PART, TO STPENGTHEN PERFORMANCE.
4 QUESTION 22:
WHAT ARE THE ROOT CAUSES OF MANAGEMENT PROBLEMS NOTED BY NRC AT DAVIS-BESSE?
WHAT STEPS SHOULD BE 4
TAKEN TO CCRRECT THESE PROBLEMS?
PROVIDE ANY DOCUMENTS INCLUDING INTERNAL MEMORANDA THAT RELATE TO NRC CONCERNS ABOUT DAVIS-BESSE'S REGULATORY PERFORMANCE.
ANSWER:
WE ARE NOT SURE THAT WE HAVE IDENTIFIED ALL ROOT CAUSES OF THE MANAGEMENT PROBLEMS AT DAVIS-BESSE.
THE FOLLOWING ARE OUR CURRENT VIEWS:
1 1.
THE CHIEF EXECUTIVE OFFICER, THE PRESIDENT, THE VICE PRESIDENT, NUCLEAR, THE ASSISTANT VICE PRESIDENT, NUCLEAR AND THE PLANT MANAGER WERE NOT AN EFFECTIVE TEAM IN IDENTIFYING PROBLEMS OR IN S0LVING PROBLEMS AT DAVIS-BESSE ONCE THEY HAD BEEN IDENTIFIED.
2.
THERE ARE SOME INDICATIONS THAT THE COMPANY'S FINANCIAL INVOLVEMENT IN OTHER NUCLEAR PROJECTS NECESSITATED BUDGET RESTRAINTS AT DAVIS-BESSE.
i 3.
THE CHIEF EXECUTIVE OFFICER WAS NOT SUFFICIENTLY INVOLVED IN THE DAVIS-BESSE OPERATION PRIOR TO THE SALP REPORT OF DECEMBER 1984, r
i
QUESTION 22. (CONTINUED).'
1 4.
ALTH0dGH THE COMPANY AND ITS CONSULTANTS WERE CAPABLE OF DEVELOPING ELABORATE PROGRAMS FOR RESOLVING PERFORMANCE DEFICIENCIES ONCE PROBLEMS WERE IDENTIFIED, MANAGEMENT WAS INEFFECTIVE IN IMPLEMENTING SUCH PROGRAMS, 5.
THERE IS A LACK OF CORPORATE SUPPORT TO THE NUCLEAR MISSION
.IN SUCH AREAS AS PROCUREMENT AND PERSONNEL.
STEPS ARE CURRENTLY IN PROGRESS TO ADDRESS THESE PROBLEMS.
THE CHIEF EXECUTIVE OrFICER IS NOW DEEPLY INVOLVED IN THEIR RESOLUTION AND HAS PLEDGED HIS PERSONAL ATTENTION AND COMPANY RESOURCES TO RESOLVE THEM.
SIGNIFICANT MANAGEMENT CHANGES HAVE BEEN MADE BY APPOINTING A NEW PRESIDENT AND SENIOR VICE PRESIDENT, NUCLEAR.
SIGNIFICANT NRC EFFORT IS BEING FOCUSED ON IDENTIFICATION OF ROOT CAUSES OF THOSE FUNCTIONAL AREAS WITH SALP 3 PERFORMANCE RATINGS AND ON CLOSELY FOLLOWING THE PROGRESS OF CORRECTIVE ACTION PROGRAMS, TO ASSURE THAT ACTIONS ARE SUFFICIENT.
DOCUMENTS, INCLUDING INTERNAL MEMORANDA THAT RELATE TO NRC CONCERNS ABOUT DAVIS-BESSE'S REGULATORY PERFORMANCE ARE CONTAINED IN ENCLOSURE 4.
INSPECTION REPORTS HAVE NOT BEEN PROVIDED SINCE THEY ARE VOLUMINOUS AND ARE A MATTER OF PUBLIC RECORD.
i i
OUESTION 23:
PLEASE PROVIDE ALL DOCUMENTS INCLUDING INTERNAL NRC STAFF MEMORANDUM WHICH RELATE TO THE DAVIS-BESSE INCIDENT. YOUR RESPONSE SHOULD PROVIDE ALL DOClMENTS GENERATED BY THE NRC TASK FORCE INVESTIGATING THIS MATTER INCLUDING TRANSCRIPTS OF INTERVIEWS WITH EMPLOYEES OF TOLEDO EDISION.
ANSWER:
DOCUMENTS IN THE POSSESSION OF THE NRC FACT-FINDING TEAM ARE NOT BEING FORWARDED AT THIS TIME. THIS INFORMATION IS BEING EVALUATED AND CONSIDERED AS AN INTEGRAL PART OF THE NRC FACT-FINDING TEAM, AND ALL PERTINENT BACK-GROUND DOCUMENTS, INCLUDING THE TRANSCRIPTS OF INTERVIEWS, WILL BE RELEASED AT THE TIME THE TEM'S REPORT IS PUBLICLY ISSUED. THE TEM'S REPORT IS CURREffTLY SCHEDULED TO BE ISSUED TO THE CCMISSION AND THE ED0 ON JULY 24, 1985.
?
ENCLOSURE 3 CONTAINS THE FOLLOWING DOCUMENTS RELATING TO THE DAVIS-BESSE IfiCIDEfiT:
t QUESTION 23.
(CONTINUED) 1.
DAILY HIGHLIGHT - DAVIS BESSE UNIT NO, 1 6/11/85 2.
PRELIMINARY NOTIFICATION OF EVENT OR UNUSUAL OCCURRENCE, 6/10/85 DAVIS BESSE - LOSS OF FEEDWATER TO STEAM GENERATORS (PND-III-85-47) 3.
PRELIMINARY NOTIFICATION OF EVENT OR UNUSUAL OCCURRENCE, 6/11/85 DAVIS BESSE - LOSS OF FEEDWATER TO STEAM GENERATORS -
UPDATE (PNO-III-85.-47A) 4.
PRELIMINARY NOTIFICATION OF EVENT OR UNUSUAL OCCURRENCE 6/13/85 DAVIS BESSE - LOSS OF FEEDWATER TO STEAM GENERATORS (PNO-III-85-47B) 5.
EVENT DESCRIPTION - REPORTABLE EVENT NUMBER 01084 (01:33) 6/9/85 6.
EVENT DESCRIPTION - REPORTABLE EVENT NUPSER 01087 (14:15) 6/9/85 7.
RIII - DAILY REPORT - DAVIS BESSE 6/10/85 8.
RIII - DAILY REPORT - DAVIS BESSE 6/11/85 9.
RIII - DAILY REPORT - DAVIS BESSE 6/12/85
- 10. RIII - DAILY REPORT - DAVIS BESSE 6/13/85
- 11. RIII - DAILY REPORT - DAVIS BESSE 6/14/85
- 12. RIII - DAILY REPORT - DAVIS BESSE 6/17/85
- 13. RIII - DAILY REPORT - DAVIS BESSE 6/18/85
- 14. RIII - DAILY REPORT - DAVIS BESSE 6/19/85
- 15. RIII - DAILY REPORT - DAVIS BESSE 6/21/85 16, CONFIRMATORY ACTION LETTER TO TECO FROM KEPPLER 6/10/85
- 17. SLIDE PRESENTED AT NRR/0R EVENTS BRIEFING 6/12/85 (DAVIS BESSE - LOSS OF ALL PAIN FEEDWATER AND AUXILIARY FEEDWATER)
\\
'00ESTION 23.
(CONTINUED) '
- 18. ftETING TRANSCRIPT - MEETING BETWEEN NRC STAFF AND TECO 6/17/85 CONCERNING AFW SYSTEMS
- 19. MEMO:
L. G. HULMAN TO W. MINNERS 6/18/85
SUBJECT:
POTENTIAL PERSON - REMS FRCN A CORE PtLT CAUSED BY LOSS-OF-FEEDWATER AT DAVIS BESSE
- 20. MEMO:
L. RUBENSTEIN TO G. LAINAS 6/18/85
SUBJECT:
DAVIS BESSE 1 - CHRONOLOGY RELATING TO THIRD, DIVERSE POWERED AFW PLNP
- 21. MEMO:
H. THOMPSON, JR. To J. KEPPLER, ET. AL.
6/19/85
SUBJECT:
CONGRESSIONAL INQUIRIES CONCERNING THE DAVIS BESSE INCIDENT
- 22. ftMo:
H. THOMPSON, JR. T0 H. DENTON 6/20/85 I
SUBJECT:
DEGREE OF COMPLIANCE OF DAVIS BESSE 1 WITH TMI ITEMS
- 23..RIII -
DAILY REPORT - DAVIS BESSE 6/24/85
- 24. RIII -
DAILY REPORT - DAVIS BESSE 6/20/85
- 25. GENERAL INSPECTION GUIDELINES 6/15/85
- 26. MEMO:
JAMS G. KEPPLER, REGIONAL ADMINISTRATOR 6/12/85 FOR A. BERT DAVIS, DEPtHY REGIONAL ADMINISTRATOR DATED JUNE 17, 1985 "TELECON" WITH RICHARD UDELL.
- 27. ftM0:-
J. G. KEPPLER FROM C. E. NORELIUS DATED 6/21/85 4
JUNE 21, 1985 " REGION III STUDY GROUP."
i
J 0UESTION 23.
(CONTINUED) 28. SEQUENCE OF EVENTS REGION lli SEQUENCE OF EVENTS: TWO SEQUENCES; DATED JUNE 9 AND JUNE 12,1%5. LICENSEE SEQUENCE OF EVENTS: TWO SEQUENCES; DATED JUNE 9 AND JUNE 13,1985.
' DAVIS-BESSE SYSTEMS COMPOSITE SIMPLIFIED SEQUENCE OF MAJ0P EVENTS DAVIS-BESSE REGULATORY PERFORMANCE HISTORY FFT SEQUENCE OF EVENTS PNO-III-85-45 TMI AUXILIARY FEEDWATER SYSTEM STATUS DAVIS-BESSE REVIEW 0F LER'S
SUMMARY
DAVIS-BESSE AUXILIARY FEEDWATER SYSTEM OPERATING EXPERIENCE MGMNT. SEQUENCE OF EVEffrS
- 29. LOGBOOK ENTRY SHEET (TECO) NO E85-152A RECORDS RESULTS 6/13/85 0F PIPING WALKDCWN ON 06/13/85 a 0930 HRS (1 PG.)
- 30. UPDATED SEQUENCE OF EVENTS FOR 06/09/85 TRIP (SOURCE 6/14/85 UNKNOWN) (6 PGS.)
- 31. ATTACHMENT 1 TO REV1SION 1 (SOURCE DOCLNENT UNKNOWN) 6/15/85 TITLED " EQUIPMENT FREEZE;" DISCUSSES EQUIPMENT IN QUARANTINE (2 PGS.)
32.
INTRA-COMPANY ftMo (REV. 1) (TECO) J. WOOD - ACTION ITEM 6/15/85 LEAD INDIVIDUALS; PROVIDES GUIDELINES WhEN TROUBLESHOOTING OR INVESTIGATING 06/09/85 REACTOR TRIP (3 PGS.)
33.
INTRA-COMPANY MEMD (REV. 2) (TECO) J. WOOD - ACTION ITEM 6/15/85 INDIVIDUALS: REVISES REV.10F SAME ftM0 (ITEM JUST MENTIONED)
(5 PGS.)
OUESTION 23.
(CONTINUED) 34. REPORT: J. LONG (AUm0R): " AUXILIARY FEEDWATER SYSTEM 6/16/85 VALVE PROBLEM ANALYSIS (AF 599 & AF 608)" (5 PGS.)
- 35. TYPED NOTES NRC GEt'ERATED - (AUTHOR UNKNOWN): FAILURE UPDATED EVALUATION FOR AUXILIARY FEEDWATER VALVES AF-599 AND
' AF-608 (3 PGS.)
- 36. REPORT: J. DESANDO (AurHOR): "NI-2 COUNT RATE LEVEL 6/17/85 INDICATION FAILURE ANALYSIS" (5 PGS.)
- 37. REPORT: M. BORYSIAK (AUTHOR): " ACTION PLAN REPORT FOR 6/17/85 NI-1 SOURCE PANGE CHANNEL" (6 PGS.)
- 38. SEQUENCE OF EVENTS (REv. 0) NRC FACT FINDING TEAM: GIVES 6/18/85 SEQUENCE OF EVEffrS AS OF 3:00 P.M. ON 06/18/85 (6 PGS.)
- 39. REPORT: M. RAYNES (AUTHOR): " TURBINE BYPASS VALVE 2-2 6/18/85 (SP 13A2) PROBLEM ANALYSIS" (4 PGS.)
- 10. REPORT: D. WILCZYNSKI, ET g.(AUTHOR): " AUXILIARY FEED 6/20/85 PureS OvERSPEED TRIPS" (13 PGS.)
- 41. MEMO:
W. DIRCKS, EDO, To THE CorHISSION CONCERNING 6/12/85 THE SEQUENCE OF EVENTS AT DAVIS-BESSE
~
/
AT THE SUBCOMMIT,TGE'S APRIL 17, 1985, BUDGET QUESTION 24.
AUTHORIZATION 4'[ EARING, THE COMMISSION TESTIFIED j
THAT SOME Rt' ANTS DOMINATE THE PROBABILITY OF A SEVEREAC'b!DENTASREPORTEDINTHECOMMISSION'S 45PEKbENTESTIMATEOFACOREMELTDOWNATAU.S.
4 REA'bTOR IN THE NEXT 20 YEARS.
IS DAVIS-BESSE ONE
,-bFTHOSEPLANTS?
WHAT FACTORS ARE IMPORTANT IN IDENTIFYING THOSE PLANTS MOST LIKELY TO HAVE A SEVERE ACCIDENT?
WHAT FACILITIES HAS THE COMMISSION IDENTIFIED AS MOST LIKELY TO HAVE A SEVERE ACCIDENT AND WHAT ACTIONS HAS THE COMMISSION TAKEN AT EACH?
4 l
ANSWER.
4 THE ESTIMATE OF A 45 PERCENT CHANCE OF SEVERE CORE DAMAGE OR MELTDOWN WITHIN A POPULATION OF 100 PLANTS OVER A 20 YEAR PERIOD WAS BASED UPON THE SIX MOST RECENT AND THOROUGH PRAS TO BE SUBMITTED BY THE LICENSEES TO THE NRC.
THESE PLANTS ARE NOT THOUGHT TO BE MORE LIKELY THAN AVERAGE TO HAVE CORE DAMAGE.
~
DAVIS-BESSE WAS NOT AMONG THEM.
e THE VARIATIONS IN PROJECTED CORE MELT FREQUENCY AMONG PRAS y
,.r
, CUESTION 24 (CONT.).
SUGGEST THAT SOME PLANTS ARE MORE LIKELY THAN OTHERS TO INCUR SEVERE CORE DAMAGE OR MELTDOWN.
THE CAUSES OF THE DIFFERENCES IN ESTIMATED ACCIDENT FREQUENCY LIE IN THE DETAILS OF PLANT DESIGN, EQUIPMENT RELIABILITY IN SERVICE, AND OPERATIONS, SUCH AS PROCEDURES, MAINTENANCE AND OPERATOR PERFORMANCE.
THE DIFFERENCES DO NOT CORRELATE STRONGLY WITH EASILY IDENTIFIED j
FEATURES SUCH AS MAKE OF THE REACTOR, ARCHITECT-ENGINEER, DATE OF LICENSING, OR UTILITY.
PERFORMANCE OF A PLANT-SPECIFIC PRA APPEARS TO BE THE MOST RELIABLE MEANS OF IDENTIFYING THE PLANTS WITH THE GREATEST SUSCEPTIBILITY.
THE NRC HAS NOT YET SYSTEM-ATICALLY SCREENED ALL OPERATING PLANTS TO IDENTIFY AND CORRECT OUTLIERS (THOSE WITH UNUSUALLY HIGH SUSCEPTIBILITY) BUT INTENDS TO DO SO IN THE IMPLEMENTATION OF THE SEVERE ACCIDENT POLICY.
l THE NRC HAS ORDERED PRAS OF PLANTS AT THE SITES OF HIGHEST POPULATION DENSITY.
IN EACH CASE THE OWNERS OF THE PLANTS HAVE VOLUNTEERED IMPROVEMENTS FOR THE MORE PROMINANT CONTRIBUTORS TO RISK.
FOR EXAMPLE, INDIAN POINT UNIT 2 MADE ALTERATIONS TO DIMINISH THE VULNERABILITY OF THE CONTROL BUILDING TO EARTHQUAKE DAMAGE AND TO FIRE, AND A PROCEDURE TO SHUT THE 1
t
CUESTION 24 (CONT.l PLANT DOWN WAS INSTITUTED IN THE EVENT EAT A HURRICANE l
THE NRC HAS FOUND IT UNNECESSARY TO ORDER IMPROVEMENTS SITE.
THOSE VOLUNTEERED BY THE LICENSEES ONCE A PRA REVEALED WE DO NOT YET KNOW WHETHER DAVIS-SESSE IS AN OUTLIER, AND IT WILL BE EVALUATED AS PART OF OUR SYSTEMATIC ASSESSMENT OF
.WITH W E SEVERE ACCIDENT POLICY. THERE ARE PRELIMINA THERE ARE ITS CORE DAMAGE OR MELT FREQUENCY MAY WELL BE ABOVE AVERA NO INDICATIONS THAT THE FREQUENCY OF SEVERE RELEASE RADIOLOGICAL RISK - IS ABOVE AVERAGE.
C0fHISS10NER ASSELSTINE ADDS THE FOLLOWING:
WITH REGARD TO WHICH PLANTS ARE MOST LIKELY TO HAVE A SEVERE ACCIDE I BELIEVE THAT THERE ARE AT LEAST TWO CONTRIBUTORS THA MOST IMPORTANT; NAMELY, POOR DESIGN AND POOR MAINTENANCE AND OPER THEY ARE BROUGHT TOGETHER AT DAVIS BESSE. THERFORE, MY PRELIMINA IS THAT DAVIS BESSE IS ONE OF THOSE PLANTS THAT DOMIN OF A SEVERE ACCIDENT.
w