ML20133K854

Confirmatory Action Ltr CAL-RIII-85-13 Re Piping Sys Support Insps/Walkdowns,Resulting Engineering Evaluations & Corrective Actions.Notification Requested If Plans Differ from Listed Corrective Actions

ML20133K854
Person / Time
Site:	Davis Besse
Issue date:	10/17/1985
From:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Williams J TOLEDO EDISON CO.
References
CAL-RIII-85-13, CAL-RIIII-85-13, IEB-79-14, NUDOCS 8510220323
Download: ML20133K854 (3)

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OCT 171985 CONFIRMATORY ACTION LETTER Docket No. 50-346 CAL RIII-85-13 Toledo Edison Company ATTN: Mr. Joe Williams, Jr.

Senior Vice President Nuclear Edison Plaza 300 Madison Avenue Toledo, OH 43652 Gentlemen:

This letter confirms the matters discussed during a meeting at the Davis-Besse site on October 9, 1985, between Mr. Carl J. Paperiello and others of this office and you and others of your staff and a subsequent telephone discussion between Mr. J. Harrison of my staff and Mr. D. Wuokko of your staff on October 16, 1985, relating to piping systems support '.ispections/walkdowns and resulting engineering evaluations and corrective actions. The supports covered under this effort are those located on nuclear safety-related and seismic Category 1 piping systems within the scope of IE Bulletin 79-14.

With regard to the matters discussed, we understand that you plan to accomplish the following:

1. Phase ! - Prior to Restart

a. Ac t ion _s_

(1) Complete inspections /walkdowns utilizing Toledo Edison Company (TED) procedures on the piping system supports identified in item 1.b and all other safety-related piping system supports inside containment not listed in Item 1.b. and issue nonconformance reports (NCRs) as appropriate.

(2) Rescive any resulting NCRs for those piping system supports listed in Item 1.b including the completion of any necessary corrective actions to achieve piping system operability based on FSAR corrmitments/IE Bulletin 79-14 interim allowable stresses.

(3) Screen any resulting NCRs for safety-related piping system supports inside containment not listed in Item 1.b and resolve those NCRs that are determined to be significant relative to system operability.

(4) Complete and close engineering evaluations for all open Facility '

Change Requests (FCRs) that relate to completed modificaticns which could impact piping system operability listed in Item 1.b.

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Toledo Edison Company 2 OCT 171985 l

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i (5) From the results obtained from actions delineated in  ;

j Items 1.a.(2) and 1.a.(3), provide a basis for not performing i

inspections /walkdowns and resolution of resulting NCRs for all [

safety-related piping system supports not listed in Item 1.b.

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i b. Systems A

(1) Outside Containment: t

) - High Pressure injection j

- Low Pressure Injection / Decay Heat Removal 3

- Auxiliary Feedwater* l i

- Auxiliary Feedwater Turbine Steam Supply

• t j (2) Inside Containment-

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High Pressure Injection

- Low Pressure Injection / Decay Heat Removal  ;

1 Auxiliary Feedwater* i

- Containment Spray (accessible portion)

Core Flood  ;

Hydrogen Dilution L Pressurizer Relief I

• The results of reviews and engineering evaluations for these l systems do not have to be considered when deternining the  ;

, operability basis (see Item 1.a.(5)) of safety-related piping i systems not listed in 1.b.(1)and 1.b.(2) above.

2. Phase II - After Restart

a. Complete inspections /walkdowns utilizing TED procedures on all safety-related piping system supports outside containment not listed in Item 1.b and issue NCRs as appropriate.

l b. Resolve all outstanding NCRs issued as a result of the inspections / l walkdowns on all safety-related piping system supports including any '

necessary corrective actions relating to system operability based on i j FSAR commitments /IE Bulletin 79-14 interim allowable stresses. All  ;

NCR evaluations and corrective actions will be completed as soon as '

i reasonably possible and comply with applicable action statements i j in the Technical Specifications, including prompt reporting.

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c. Complete and close engineering evaluations for all open FCRs '

! that are related to piping system modifications completed as of

the date of this letter, which impact the operability of all j safety-related piping systems.

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Toledo Edison Company 3 OCT I 71985

3. Phase III - By The End Of The Next Refueling Outage Restore all safety-related piping systems to FSAR comitments.

If TED determines that specific supports should be exempted from inspection / evaluation based on adverse location; e.g., high radiation areas, inaccessability, etc., TED shall request such exemptions for these supports from Region III and provide the bases for the exemptions.

Please advise us immediately if your understanding of these items differs from that set forth above.

Sincerely, James G. Keppler Regional Administrator cc: L. Storz, Plant Manager DCS/RSB (RIDS)

Licensing Fee Management Branch Resident Inspector, RIII Harold W. Kohn, Ohio EPA James W. Harris, State of Ohio Robert H. Quillin, Ohio Department of Health E. L. Jordan, IE A. W. DeAgazio, NRR II R1 RIII RIII R ~T 6 Ik !

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