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Docket No. 50-346 TVLEDO EDISON License No. NPF-3 Acsanc P Caust Serial No. 1-211 vaamers 4
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i July 8, 1981
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Mr. James G. Keppler, Director United States Nuclear Regulatory Commission Region III l
799 Roosevelt Road Glen Ellyn. Illinois 60137
Dear Mr. Keppler:
1 This letter will confirm the discussions between your Messrs. T. Tambling, J. Smith and L. Reyes and members of my staff on July 6, 7 and 8, 1981.
l As a result of our evaluations of the inadvertent reactor trip of June 24, 1981, we have initiated the following corrective action plans on Davis-Besse Unit 1 (DB-1).
1 An overall objective is to keep the operators informed as to the true status
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of the plant.
That is, what instrumentation can be relied upon under all conditiens, and what compensatory measures are required upon the loss of I
control-grade instrumentation systems.
i There is a valid concern on the dual channel de' pendency of some control-j grade instrumentation. We are continuing to investigate the extent of this problem at DB-1 and possible similar incidents at other stations. We believe that several actions by Toledo Edison will prevent reoccurrences of this type of problem.
The May 1981 reorganization of the Nuclear Engineering and Construction (NESC) Division, which established the Facility Engineering j
Department on the DB-1 site, will help prevent similar problems in the future.
As a result of this reorganization, the Nuclear Engineering (NE) Department has assumed new responsibilities relative to conceptual / preliminary engineer-l ing and design criteria. The NE Department will continue to develop
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preliminary designs and criteria for all modifications, regardless of the organization which does the detailed engineering (such as Bechtel or B&W or l
the Facility Engineering Department).
The NE Department will provide specific, detailed channelization requirements to all design agents. We will review the detailed engineering designs for dual dependency to assure proper channel-ization of power supplied). We will increase pre-service testing of control-grade modifications as appropriate. We expect to have a further definition 1
of our engineering program plans within three months. Any required NE&C Division procedures to accomplish the above tasks will be provided and i
approved within three months.
i 8510070262 850717 i
PDR COPWW NRCC CORRESPOPOENCE PDR
, J 3 Jgg THE TOLEDO EDISON CCMPANY EDISON PLAZA 300 MAOISCN AVENUE TOLEDO, OH30 43652 b-.
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Dockst No. 50-346 Licsnes No. NPF-3 Serial No. 1-211 July 8, 1981 l
page 2 4
Prior to criticality following the current outage. the following components
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or systems will be reviewed to assure that no undesirable dual dependency
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exists:
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Reactor coolant system (RCS) saturation temperature indication.
2.
Auxiliary feedwater flow indication.
3.
Interim anticipatory reactor trip system.
4.
Make-up pump suction valve logic.
i The first three are post-TMI-2 interim, control-grade modifications. The l
fourth item was selected because of the problem which occurred during the June 24, 1981 reactor trip (i.e. cycling of suction valve which then resulted in tripping one make-up pump).
The dual power dependency problems already known and any others uncovered during this review will either be resolved or station operators will be trained and the necessary procedures provided prior to criticality.
l' The modifications which have been made to non-Class IE systems that can challenge safety systems will be reviewed for dual dependency problems before startup following the 1982 Refueling Outage. Only those modifications 3
made af ter the NNI and ICS power dependency tests conducted as a result of the 4
l Crystal River event, will be considered for review since those tests and prior plant operation indicated no existing problems.
Station operators
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will be informed of any undesirable dual dependency problems that are I
identified and any required compensatory measure.
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As a result of the 1980 Crystal River event, the primary 120 VAC power feeds j
to the DB NNI and ICS cabinets were examined.
Existing power dependency problems were identified and modifications were made or plans to make
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modifications to resolve those problems at that time. As a result of the June 24, 1981 trip, the auxiliary 120 VAC power feeds to those cabinets l
were examined to detect similar problems.
Problems uncovered by this review will be corrected or station operators will be given proper guidance j
with respect to those problems prior to criticality following the current
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outage.
While minor wiring errors within the individual instrumentation strings may exist, normal plant operations and previous testing have shown the instrument-l ation to be functionally correct. Since a detailed examination of wiring of the instrument strings could in itself create problems (broken wires, disturbed terminations, etc.), we do not feel such an examination is warranted.
TECo. has devoted much effort towards the updating of Bailey system schematic drawings and this process will continue until we have confidence that all i
changes have been incorporated into these drawings.
Our efforts will continue to ensure that proper drawing control is maintained.
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Dockst No. 50-346 Licsnsa No. NPF-3 Serial No. 1-211 l
July 8, 1981 l
page 3 J
l Certain non-Class IE instrumentation systems may require redundant power supplies to provide necessary information to plant operators.
No non-safety grade instrumentation or controls are required to go hot standby (Mode 3).
As part of our review in response to'IE Bulletin 79-27 (as indicated in our letter No. 1-129 dated May 6, 1980), we used prudent l
engineering judgment to determine those instrumentation and control strings required to achieve cold shutdown (Mode 5).
Redundant power will be supplied, and other upgrades implemented for those instrument and control 1
systems that we feel are necessary to meet these conditions. These modifi-cations will be completed by the end of the 1982 Refueling Outage.
I Redundant power supplies for the control room annunciators are considered necessary; consequently, the power supply is being modified to provide
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that redundancy as soon as possible. Additionally, the makeup and purific-j ation system will be reviewed to determine what power supply requirements j
must be satisfied to assure that makeup to, and letdown from the RCS is not jeopardized by a failure of a single power supply.
This review will be completed by the end of the 1982 Refueling Outage.
When the Bailey 855 computer is replaced, redundant power supplies to the j
replacement computer will be provided.
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Very truly yours, i
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RPC:CRD: lab cc: DB-1 NRC Recident Inspector I
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1981 01/21/81 LETTER:
V. Stello - TECo: Transmit.s Repo,rt 80-3 (PAS)
Performance Appraisal Section Report. Executive summary and report cover sheet attached.
(5 pgs.)
03/03/81 MEMO:
N. Mosely - V. Stello:
Davis-Besse PAS Inspection Transmits Assessment Report.
Evaluation of IE Program and Regional Implementation attached.
(14 pgs.)
05/01/81 MEMO:
J. Keppler - N. Moseley: Disposition of inspection findings resulting from the Davis-Besse PAS Inspection.
Report 81-03, Notice of Violation, Notices of Deviation, Memo from J. Keppler to J. Sniezek (04/22/81) attached.
(15 pgs.)
05/08/81 LETTER: TECo - J. Keppler: Response to concerns resulting from PAS Inspection. Cover sheet only attached.
(2 pgs.)
03/11/81 LETTER:
J. Keppler - TECo:
Confirms meeting scheduled for 03/17/81 at Regional Office.
(1 pg.)
03/25/81 MEMO:
E. Brach - W. Rogers:
Management visit to Davis-Besse.
Thank you for cooperation and support.
(1 pg.)
06/10/81 LETTER:
J. Keppler - TECo: Express appreciation for cooperation in meeting 05/26/81.
Comments helpful in recognizing impact of NRC initiatives.
(1 pg.)
07/08/81 LETTER: TECo - J. Keppler: Confirms discussions. Have initiated corrective action plans as a result of evaluation of inadvertent reactor trip 06/24/81.
(3 pgs.)
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1982 01/15/82 LETTER:
R. Spessard - TECo: Confirms mearing plans for 01/21/82 at Regional Office.
(1 pg.)
01/20/82 MEMO:
J. Keppler - R. Spessard:
Recent inspection findings at Davis-Besse.
Importance of borated wat'er storage overtemperature.
(1 pg.)
02/25/82 LETTER:
R. Spessard - TECo: Transmits Report 82-05 (DRP1), report of management meeting on 01/21/82 at Region III to discuss drawing control, nonconformance reports, personnel errors.
Report cover sheet only attached.
(3 pgs.)
04/30/82 LETTER: C Paperiello - TECo:
Thank you for response to items in your letter of 04/20/82.
(1 pg.)
07/30/82 LETTER: TECo - J. Hind:
TECo comments on SALP Report.
acknowledges SALP, takes issue with conclusions in one area.
(2 pgs.)
09/08/82 LETTER:
J. Keppler - TECo: Confirms conversation discussing i
security matters. Region III personnel available to discuss matters.
(1 pg.)
09/23/82 LETTER:
J. Keppler - TECo: Transmits final SALP Report and l
provides overall observations on Regulatory performance (Report 1
not attached).
(3 pgs.)
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UNITED STATES h
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NUCLEAR REGULATORY COMMISSION Yk..g^/
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Docket No. 50-346 y", ",, '. jg ;
Toledo Edison Company ATTN:
Mr. W. A. Johnson President and Chief Operating Officer Edison Plaza 300 Madison Avenue Toledo, Ohio 43652 Gentlemen:
Subject:
Management Inspection 50-346/80-3 (PAS)
This refers to the management insi,4ction conducted by Messrs. L. W. Gage, A.
T. Gody, D. G. Hinckley, P. H. Johnson, W. L. Kushner, C. R. Oberg, and J. D. Woessner of the Performance Appraisal section of the Division of
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Program Development and Appraisal October 27-31, November 1, 3-7, an,d NovemberOffice of Inspection and Enforcement, on 17-21, 1980, of activities authorized by NRC Operating License No. NPF-3, for the Davis-Besse Nuclear Power Station at Oak Harbor, Chio and the Toledo Edison company corporate office at Toledo, Ohio; and to the significant observations discussed with you and others of your staff on October 31, November 7, and November 21, 1980 at the Davis-lesse Nuclear power Station and the Toledo Edison Company corpor, ate Office.
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.u The enclosed Appraisal Report No. 50-346/80-3 (PAS) identifies the areas
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examined during the inspection. Within these areas, the inspection consisted of a comprehensive examination of your management controls over licensed activities which included examination of procedures and records and interviews with management and other. personnel.
x This inspection is one of a series of management appraisal inspections being conducted by the Perfomance Appraisal Section of the Division of Program t
Development and Appraisal. Office of Inspection and Enforcement.
The results of this inspection will be used to evalusta the performance of your management j
control systems en a national perspective.
The enclosed appraisal report includes observations which may be potential enforcement findings.
These items will be followed by the IE Regional office.
The enclosed appraisal report also addresses other observations and the conclusions made by the team for this inspection.
Section 2 of the report provides further information regarding the observations and how they will be utilized.
j Appendix A te this letter is an Executive Summary of the conclusions drawn for the nine 4
functional areas inspected.
Of the nine areas inspected and evaluated, the Training Program received a highest rating of good.
Seven areas were considered to be average; however, significant weaknesses were identified in several areas which require r m-- '. -,, a u - -:
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70;eco E rson Ccmcany management attention.
The Procurement Program receivec an esai s.!an i
A survnary of the bases of these ratings is included in the attachec iw
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Summary.
The generally favorable evaluation is consicered a reflect:cr v tM I
efforts and resources applied by the Tcledo Edison Company towarc ;:rc::lems that were recognized earlier by the NRC Region III office and Toleco Ecisor management.
y As a result of the conclusions regarding Procurement, you are requested to inform this office within 30 days of receipt of this report of the actions you havi taken or plan to take to improve the management controls in the area identified as poor.
In addition you are also requested to inform this office in this same subaittal of the actions you have taken or plan to take in regard to the excessive backlog of outstanding maintenance work and facility change requests, a probles discussed in the attached Executive Summary.
Your response to this office concerning these matters, as well as your action regarding the identified weaknesses, will subsequently be followed by tne IE Regional Office.
In accordance with Section 2.790(d) of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, your facility security procedures are exempt from disclosure; therefore, the pertinent section of the Appraisal Report, Attachment
'A', will not be placed in the Public Document Room and till receive limited distribution.
In accordance with Secton 2.790 of the NRC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed appreisal report will be placed in the NRC's Public Document Rece.
If this report contains any information that you or your contractor believe to be proprietary, it is necessary that you make a written application within five (5) days to this office to withhold such information from public disclosure.
Any such application must include a full statement of the reasons for which it is claimed that the information is proprietary, and should be prepared so that proprietary information identified in the application is contained in a separate part of the document.
If we do not hear free you in this regard within the specified period, the report will be placed in the Public Document Room.
f f you have any questions concerning this inspection, we will be glad to discuss them with you.
1 Sincerely, e
j Victor StsVlo, JC Director' /
Office of Inspection and Enforcement
Enclosures:
( See next page)
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l Appendix A Executive Sumary A team of seven NRC Inspection Specialists from the Performance Appraisal Section conducted an announced inspection at the Davis-Besse site and Toleco Edison Corporate office during October 27 - November 21, 1980.
Management controls in nine areas were inspected.
A summary of results of the inspection is given below. While taprovements were noted in most of the areas examined, a number of weaknesses were identified during the appraisal.
One' area was considered good, seven average, and one poor.
,l Trainino: Good (Section 9).
The effectiveness of the Training program l
was enhanced by active management support, a number of highly motivated
,I and qualified instructors, and continuing program development.
Improve-a !
ment was needed in the area of continuing training for maintenance J
personnel.
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Committee Activities: Averace (Section 3).
The review cosuittees were composes of capable individuals who possessed positive attitudes toward improving the adequacy and effectiveness of facility activities.
Both committees, however, needed to expand their review activities, increase their responsiveness to identified probles areas, and direct management
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attention to needed improvements.
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l Quality Assu*ence Audits: Aversee (Section 4). Audit findings were well f
researched and Involved substantial safety issues.
However, significant weaknesses were noted regarding audit guidance, checklists, audit j
folloute, and certain aspects of annagement support for the program.
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Oesien Chanens and Modifications: Averace (Section 5). While there were i
a large back' og of Facility Change llequests and an apparent lack of safety evaluat'ons in the interface between construction activities and p
i the plant during operation, the established program appeared to have been 9
implemented in a satisfactory manner.
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- .7 Maintangagg: A
($ection6).
Mest of the maintenance personnel I
were feet 11er requirements of the asintenance program, and except for same minor instances, the program was being satisfactorily 3
implemented. Two significant weaknesses were noted during the inspection.
Some routine safety related maintenance activities, which were beyond the skill of the crafts, were being performed using unreviewed asintenance instructions.
There was also an excessive backlog of outstanding maintenance work.
Review and Control of 1.leensed Activities:
Aversoe (Section 7).
The licensee had an effective operating organization.
Improvements were needed in equipment operator staffing and control of procedures.
Weak-nesses were noted in certain Control Room operations such as the tolerance of excessive numbers of alare indications.
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Corrective Action Systems: Averace (Section 8).
The licensee had not established a system to prioritize the different methods used to identify deficiencies.
Engineering activities had been redirected to reduce an existing backlog of these identified deficiencies.
Physical Protection: Aversos (Section 11). Management involvement has been increastnql to einfetze ftame of noncompliance, resolve equipment problems, and <sprove the overall effectiveness of the security program.
However, additional management attention was needed in the areas of personnel screening, search precedures, the number of persons granted access to the vita areas, and equipment problems.
u Procurement: Poor (section 10). thenerous violations of regulatory requirements were observed in the area of material storage and handling.
These are detailed in the bo4 of the report.
Precurement should be recognized as an activity which both 1spects and is affected by the full range of utility organizations: Operations, engineering, quality assurance, quality control adeinistration, security and training.
Effective procurement is dIrectly related to safety of operation as well as plant relish 111ty.:,,c g y jp g.t
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There appeared to be three root causes of the nonconforming conditions found in procurement:
(1) en indifferent attitude on the part of upper management tamard Quality Assurance in procurement activities (2) the failure of middle to control (3) the fallere. procurement actions and storeroom personnelactivity to treia procurement personnel in the hesicS of M3 ty e$eWence and M etenheds.
As h ated is provie{ws IEC co) e @ N y b y.,
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the past regulatory and operatinilperformanceoftheDesie-tesseBucI"eerpowerplanthadbeenless then des' red. Ileusver, it was the Performance Appraisal Section's judgment that actions initiated by Telede Edison Ceepent since late 1979 response to the inspection and esforcesamt efforts of Segion III, partly in have been responsive to identified concerns and should proeide for improved future performance.
These actione' included e corporate a mitattet. 4.ict. i s increased emphasis'en actietties effecting the Devis se plant.
pf m'eg3. n, 4 :, y m:4y 3 a The Performance Appraisal Section'did seacleds that management emphasis was weighted tee base 11y to esuplete estivities.dich tenediately affected on-Ifne operation of the facility or dich were specific Itcense requirements. As a result, other outstandtag plant-effecting wer's has accumulated as evidenced by ev:r 1100 outstanding Facilit Maintenance teork Orders (Ite'y)., Ouring his plant tour the Directer. IE, Change Rogu s
personally witnessed the resulta of a deferred asintenance item involving clogged lines in a level indicating f astrument en a radioactive weste co' lec-ting tank; the absence of this level indication contributed to the tank rupture disc parting and a resultino spill of contaminated water.
should ensure that work, as identif' ed in the outstanding FCA's and MW s, isMana p nt carefully reviewed for any potential to disrupt safe, continued operation of the facility.
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I U. S. NUCLEAR REGULATORY CCHMISSION OFFICE OF INSPECTION AND ENFORCEMEN' 0! VISION OF PROGRAM DEVELOPMENT AND APPRAI$4 PERFORMANCE APPRAISAL SECTION Report No.
50-346/80-3 (PAS)
Docket No.
50-346 License No. NPF-3 Licensee:
Toledo Edison Company Edison Plaza, 300 Madison Ave.
Toledo, Ohio 43652 Facility Name:
Davis-8 esse Nuclear Power Station Inspection At:
Davis-Besse Site, Oak Harbor, Ohio and Toledo Edison Company, Toledo, Ohio Inspection Conducted:
October 27 31, November 1, 3-7 and November 17-21, 1980 Inspectors:
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/E//S /80 A. T. Gody, Inis i;tio talist (Team Leader)
Date Signed
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Gage,/Inspectflon Specialist Date Signed A
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/S//f/ TO 0.G.Hinckley,inspectip @ecialist Date Signed
@&W r:/t s/w P. H.f' nnson, Inspection Specialist Date Signed
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W. L. Kushner Inspeption Specialist Date Signed W
/Y) ? $0 C.A.Oberg,Insgionspecialist Oate Signed
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// N G. D. Woessner, Inspection Specialist OM.e 5(gned Accompanying Personnel:
L. Reyes, $enfor Resident Inspector
+* V. Stallo, Of rector, Of fice of Inspection & Enforcement
- J. M. Taylor, Deputy Director, Division of Program Development and Appraisal
- J. G. Keppler, Director, Region !!!
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l Docket No. 50-346 s
'N Toledo Edison Coepany ATTN:
Mr. Richard P. Crouse h
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Vice President g".
Nuclesr 5), '
Edison Plass
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300 Madison Avenue A
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Toledo, OH 43652
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Gentlemen:
This confirme our plane, se discussed on January 12, 1982, between Mr. Murray of your staff and Mr. McCregor of this of fice, to meet with
'l you and members of your staff at 10:00 a.m. CST on January 21, 1982, at our Regional Office in Glen tilyn, Illinois.
The purpose of this management meeting is to discuse our concerne in the i
following areas 1.
Drawing Control 2.
Nonconformance Reports i
3.
Personnel Errore We will gladly discuse any questiona you have concerning this meetina, e
, Sincerely,,
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, R. L. Spessard, Direetc.r
, Division of Resident &
Project Inspection ace Mr. T. D. Murray, Station Superintandent DMB/ Document Control Desk e
(RIDS)
Raeident Inspector, RIII Rarold W. Eohn, Power Siting Constission Belen W. Evens, State of Ohio
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