ML20134P061
| ML20134P061 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 11/21/1996 |
| From: | Jeffery Wood CENTERIOR ENERGY |
| To: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| 1-1111, NUDOCS 9611270219 | |
| Download: ML20134P061 (11) | |
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- ? RIM 6601 N. State Route 2 419-249 2300 John K. Wood Oak Harbor.OH 43449 FAX: 419-321-8337 Vce Presderit - Nuclear Davis-Besse t
Docket Number 50-346 License Number NPF-3' Serial ~ Number-1-1111 i
i November 21, 1996 r
i Mr. James Lieberman-l Director, Office of Enforcemen't LUnited States Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738
Subject:
Response to Notice'of Violation and Proposed Imposition of f
Civil Penalty (NRC Inspection Report Number 50-346/96008
[DRS))
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Dear Mr. Lieberman:
Toledo Edison provides the attached Response to the subject Notice of
-Violation and Proposed Imposition of Civil Penalty, issued on October
~22, 1996 (Log Number 1-3753).
Toledo Edison accepts the alleged violations.
Payment of the Civil Penalty in the full amount of
$50,000 has been'made via wire transfer to the Treasurer of the United States as of this date.
The violations involve fire protection issues identified during an inspection' conducted during June through August, 1996.
The internal resolution of the issues associated with these violations has provided i
Toledo Edison Management with valuable insights into the requirements of 10CFR50, Appendix R.
They have also served to heighten management attention to'the importance of NRC Information Notices as well as relevant information from other sources.
C E l '-l /
9611270219 961121 PDR ADOCK 05000346 G
Dockst Numbar 50-346 License Number NPF-3 Serial Number 1-1111 Page 2 Should you have any questions or require additional information, please contact Mr. James L. Freels, Manager - Regulatory Affairs, at (419) 321-8466.
Very truly yours,
(
y3 M AR fokaKW8'd GMW attachment cc:
A. B. Beach,, Regional Administrator, NRC Region III S.
Stasek, DB-1 NRC Senior Resident Inspector A. G. Hansen, NRC Project Manager USNRC Document '
crol Desk Utility Radiological Safety Board l
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- Dockst' Number 50-346 License Number NPF.
- Serial Number 1-1111
- Enclosure Page 1 RESPONSE TO NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORT NUMBER 50-346/96008 [DRS])
FOR DAVIS-BESSE NUCLEAR POWER STATION UNIT NO. 1 Attached is Toledo Edison's response to the Notice of Violation and Proposed Imposition of Civil Penalty as issued by letter dated October 22, 1996.
This Response is submitted pursuant to 10 CFR 2.201.
By:
R. E. Donnellon, Director, Engineering and Services Sworn and subscribed before me this 21st day of November, 1996.
A MM
-Notary ub\\ic, State of Ohio My Comm'ssIon expires Harch.22,1998, t
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Dockst-Numbar 50-346 License Number NPF-3 l
Serial Number 1-1111 Attachment I
Page.1 l
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- Violation I.
10 CFR Part 50, Appendix R,.Section III.G.2 requires, in.
l part, that where cables or equipment, including associated non-safety circuits that could prevent operation or.cause maloperation due to hot shorts, open circuits, or shorts to ground, of redundant trains of systems necessary to achieve and maintain hot shutdown conditions'which are located within the same fire area outside of primary containment, one of the
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following_means of ensuring that one of the redundant trains is free of fire damage shall be provided: (a) separation of cables and equipment and associated non-safety circuits of l
redundant trains by a fire barrier having a three hour j
rating; (b) separation of cables and equipment and associated i
non-safety circuits of redundant trains by a horizontal l
distance of more than 20 feet with no intervening combustible l
or fire hazards; and, fire detectors and an automatic fire i
suppression system shall be installed in the fire area; or (c) enclosure of cables and equipment and associated non-safety circuits of one. redundant train in a fire barrier having a one-hour fire rating; and fire detectors and an l
automatic fire suppression system shall be installed in the fire area.
i 10 CFR Part 50, Appendix R, Section III.G.3 requires, in i
part, that alternative or dedicated shutdown capability be provided where the protection of systems whose function is required for hot shutdown does not satisfy the requirements j'
of Section III.G.2.
l Contrary to the above, prior to March 20, 1996, the licensee f
failed to provide adequate protection to ensure operation of I
equipment for systems necessary to achieve and maintain hot shutdown conditions or provide alternate or dedicated safe j
shutdown capability, in that sixteen motor-operated valves, necessary to achieve and maintain hot shutdown conditions, i
were potentially unable to perform their post-fire safe j
shutdown function because their control circuits were susceptible to fire induced hot shorts.
(01013)
Acceptance or Denial of Alleged Violation Toledo Edison accepts the alleged violation.
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Dock 3t Number 50-346 License Number NPF-3 Serial Number 1-1111 Attachment Page 2 Reason for Violation The cause of this violation was a misunderstanding of the requirements of 10CFR50, Appendix R on the part of Toledo Edison personnel. Information Notice (IN) 92-18, " Potential for Loss of Remote Shutdown Capability During a Control Room Fire," was issued on February 28, 1992.
Toledo Edison's initial evaluation of this IN determined that a fire-induced hot short that could bypass the valve protective features and result in the actuator operating to the point of physical damage was considered to be a low probability scenario.
In addition, the evaluation determined that no additional acti;ns were required based on the low probability of this scenario.
Toledo Edison believed that this assessment was concistent with the available industry guidance.
Toledo Edison was not aware at the time that the industry guidance of taking no action based on the low probability of occurrence was not acceptable by the NRC.
Corrective Actions Taken and Results Achieved At 1558 hours0.018 days <br />0.433 hours <br />0.00258 weeks <br />5.92819e-4 months <br /> on March 20, 1996, after it was learned that Toledo Edison's position on MOV hot shorts was not acceptable to the NRC, Toledo Edison notified the NRC of this condition via the Emergency Notification System (ENS) in accordance with 10CFR50.72 (b) (1) (ii) (B).
Also at this time it was verified that appropriate compensatory measures were in place, which consisted of an hourly roving fire watch in the Cable Spread Room, and credit for the Control Room being continuously manned (thus meeting the requirements of a continuous fire watch).
A Licensee Event Report describing this event (LER 96-002) was submitted on April 19, 1996.
I Toledo Edison then began an additional evaluation of the effects of this scenario on MOVs needed for safe shutdown.
This evaluation considered single hot shorts in all fire areas containing circuits for safe shutdown MOVs and not just those involved in a fire in the control room as described in IN 92-18.
A total of 88 MOVs were evaluated.
It was determined that 41 of these MOVs were not susceptible to this scenario i
because they are either normally de-powered, have a unique wiring scheme, or are otherwise not subject to a single fault.
The remaining 47 MOVs
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were reviewed to determine if the actuators could be damaged by stall j
thrust or stall torque.
In all cases, calculations confirmed that j
pressure boundary damage of the valve was not possible.
Six of the 47 MOVs were determined to be not susceptible to valve operator damage and were eliminated from further consideration.
For the remaining 41 MOVs, 35 were time-line critical valves.
This means
'the MOVs are included in the time-line actions of the safe shutdown procedures, where the actions are completed within approximately 30 minutes of a fire affecting shutdown capability.
Twenty-five of these
Dock t Numbar 50-346 License Number NPF-3 Serial Number 1-1111 Attachment Page 3 time-line critical vrEves were related to reactor coolant system (RCS) letdown, reactor coolant pump (RCP) seal injection, seal cooling, or seal return. The current RCP seal design does not require these flowpaths to preserve seal integrity for non-running RCPs.
The addition of the reactor vessel head continuous vent line permits faster RCS cooldown without the RCPs operating such that the contraction volume is sufficient for boration to maintain required shutdown margin without letdown.
Therefore, these 25 valves were eliminated from further evaluation for a hot short scenario.
The remaining ten time-line critical valves, which were ten of the sixteen valves cited in the Notice of Violation, were resolved with modifications or procedure changes.
Circuit modifications were made to three valve actuators prior to restart from the tenth refueling outage and one actuator was de-powered.
Procedures were modified to use alternate valves or flowpaths for the remaining six time-line critical MOVs.
The remaining six MOVs, which are cited in the Notice of Violation and are not time-line critical (i.e.,
involve longer term actions during post fire shutdown) have been scheduled for resolution by December 31, 1996.
Appropriate compensatory measures have been established and will remain in place until resolution is complete.
A database search was conducted to find previous Davis-Besse Nuclear Power Station (DBNPS) evaluations to ins that involved other industry groups.
It was determined that for all of the ins reviewed, the industry group guidance was either endorsed by the NRC or developed in conjunction with the NRC.
Therefore, the discrepancy that existed between DBNPS's evaluation of IN 92-18 and NRC guidance was an isolated incident and no generic implications exist.
Corrective Actions to Prevent Recurrence The Information Notice review process at DBNPS was modified to utilize the existing corrective action process. This ensures prompt operability and reportability review, e
a structured timeline for resolution, e
prompt significance review, e
based on the significance, actions may receive multi-discipline review, e
independent review at close-out.
e The modified review process was in place September 25, 1996.
The expectations regarding Information Notice evaluations will be reaffirmed to appropriate DBNPS site personnel to ensure a complete technical review is performed and appropriate actions are taken.
This training will be complete by February 28, 1997.
Docket Numbsr 50-346 License Number NPF-3 j
Serial Number 1-1111 Attachment Page 4
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1 Plans are.also currently underway for an external group to perform a peer I
assessment of DBNPS's industry experience program (including both ins and.
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Operating' Experience Reports).
This peer assessment'is scheduled to be completed by December 31, 1996.
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.Date When Pull Compliance Will be Achieved-Full compliance will be achieved by December 31, 1996, when the hot short issue;for the. remaining six MOVs,.which are cited in the Notice of violation and are not-time-line critical, will be resolved as follows:
Two MOVs have been further analyzed and determined not to be required in the fire areas where the circuits may be damaged.
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Two of the MOVs have been analyzed and found that the valve actuators may be damaged, but not the valve, so the Fire Hazards Analysis Report (FRAR) will.be changed and appropriate procedural guidance given to bypass possible actuator damage by removing the damaged actuator and manually positioning the valve.
One MOV has been analyzed and found that the valve actuator may be damaged, but not the valve, so the FRAR will be changed and appropriate procedural guidance given to use an alternate source of Service Water as a-suction source for the Auxiliary Feedwater Pump in the event of actuator damage (such as Fire Suppression).
The one remaining MOV is still being analyzed.
If this analysis shows that the MOV will be susceptible to valve actuator damage, the power will be removed from the valve actuator.
Compensatory measures will remain in place until all MOVs are in full compliance.
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Docket Number 50-346 License Number NPF-3 Serial Number 1-1111 Attachment Page 5 Violation II. License Condition 2.C. (4) requires that Toledo Edison implement and maintain in effect all provisions of the approved Fire Protection Program as described in the Updated Safety Analysis Report.
Updated Safety Analysis Report Section 9.5.1,
" Fire Protection Program," states that the
" Fire Hazard Analysis Report (FRAR), which is part of the overall program, documents the analysis that ensures t
compliance with 10 CFR 50, Appendix R, Section III.G."
FRAR Section 8.1.4 requires that all fire barriers separating portions of redundant safe shutdown systems required in the event of a fire shall be operable.
FHAR Section 8.1.4.B requires with one or more of the above fire barriers inoperable in the containment or the containment annulus, then
- 1) If the fire barrier (s) is located inside containment then within one hour, establish a fire watch to inspect one side of the affected barrier at least once per eight hours or monitor the containment air temperature at least once per hour utilizing the inlet temperature of one of the operating containment air coolers, or
- 2) If the fire barrier (s) is located inside the containment annulus, then within eight hours, establish a fire watch to inspect one side of the affected barrier at least once per eight hours during Modes 3, 4,
5, or 6.
No inspection is required during Modes 1 or 2 due to ALARA concerns.
Contrary to the above, from December 15, 1992, until April 16, 1996, fire barriers (radiant energy shields utilizing Thermo-Lag) located in the containment and containment annulus were inoperable and (1) for the containment, action was not taken within one hour to establish a fire watch to inspect one side of the affected barrier at least once per eight hours or monitor the containment air temperature at least once per hour utilizing the inlet temperature of one of the operating containment air coolers; and (2) for the containment annulus, action was not taken within eight hours to establish a fire watch to inspect one side of the affected barrier at least once per eight hours during Modes 3, 4,
5, or 6.
(02014)
Acceptance or Denial of Alleged Violation Toledo Edison accepts the alleged violation.
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Dockst Number 50-346' License Number NPF-3 l
Serial Number 1-1111 i
Attachment l
Page-6 3
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.nmason for Violation ion May 18o 1990, Toledo Edison submitted an Appendix R excmption request to'the'NRC based, in part, on the existence of radiant energy shields.
f which separate redundant trains of safe shutdown circuits within the DBNPS
'l containment annulus.
During the time this= exemption request was pending
.within.the NRC, DBNPS. personnel did not take into consideration that until j
- final disposition of the exemption request by the NRC,.the plant was not
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in; full compliance with 10CFR50 Appendix R requirements.
'IN 92-82, "Results of Thermo-Lag 330-1 Combustibility Testing," was issued j
December.15, 1992, and stated that Thermo-Lag is combustible.
This'IN' j
Ediscussed the possible use of Thermo-Lag as radiant energy shields inside Econtainment.
This-IN was inadequately reviewed, because it was merely, l
grouped with the ongoing Thermo-Lag issues that were a result of Bulletin 92-01, Supplement 1,.
" Failure of Thermo-Lag 330 Fire Barrier System To Perform Its Specified Fire Endurance Function."
However,Bulletin 92-01 only. addressed fire barriers, so the issue of combustibility for radiant energy shields was not evaluated.
i IN 95-27, "NRC Review of Nuclear Energy Institute 'Thermo-Lag 330-1 l
Combustibility Evaluation Methodology Plant Screening Guide,'" issued l
May 31,'1995,'specifically addressed the unacceptability of using Thermo-t Lag for radiant energy shields protecting safe shutdown components inside containment.
The IN was also inadequately reviewed because the significance of using Thermo-Lag for radiant energy shields was not j
recognized as an operability issue by the personnel resolving Thermo-Lag issues.
Consequentlyi operability, and corresponding compensatory measures, were not addressed until identified as an issue on April 17, 1996.
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Corrective Actions Taken and Results Achieved
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l When the condition was identified on April 16, 1996, it was verified that compensatory actions had been put in place during the shutdown for the tenth refueling outage on April 8, 1996.
These compensatory actions were in the form of. roving fire watches in both containment and the containment j
' annulus.
Because of the location of the radiant energy shields, roving fire watches!were not required by the Fire Hazards Analysis, Report before
.this time due to plant radiation levels.
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Dockat Number 50-346 License Number NPF-3 Serial Number 1-1111 Attachment Page 7 Upon startup from the tenth refueling outage, other compensatory measures were also established.
These measures included hourly monitoring of containment air temperatures, and hourly observation of the containment annulus space via a video camera installed for this purpose. These compensatory measures will continue pending achievement of a permanent resolution.
A Licensee Event Report documenting the failure to take compensatory measures for the inoperable radiant energy shields (LER 96-004) was submitted on May 17, 1996.
On February 20, 1996, Toledo Edison submitted plans to the NRC (Serial Number 2358) to replace the Thermo-Lag installed in the plant. The containment radiant energy shields will be replaced with an alternate material.
The radiant energy shields in the annulus will be replaced by installation of three-hour rated fire barriers using alternate materials, or by an alternative approach such as relocation of the affected circuits.
All of these actions will be completed by the end of the eleventh refueling outage, and may be completed sooner if a shutdown of sufficient duration occurs once the design work is complete.
Corrective Actions to Prevent Recurrence As discussed in the response to Violation I above, the Information N>tice review process at DBNPS was modified to utilize the existing correct,1ve action process. This ensures:
prompt operability and reportability review, a
a structured timeline for resolution, prompt significance review, based on the significance, actions may receive multi-discipline review, e
independent review at close-out.
e The modified review process was in place September 25, 1996.
The expectations regarding Information Notice evaluations will be reaffirmed to DBNPS site personnel to ensure a complete technical review is performed, and appropriate actions are taken.
This training will be complete by February 28, 1997.
As part of this training, literal compliance with regulations will be reaffirmed.
l Plans are also currently underway for an external group to perform a peer assessment of DBNPS's industry experience program (including both ins and Operating Experience Reports).
This peer assessment is scheduled to be
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completed by December 31, 1996.
s "Dockot. Number'50-346 License Number NPF-3:
. Serial Number 1-1111 Attachment
.Page 8 Date when Full Comoliance Will be Achieved.
Full compliance will be achieved by the completion of the eleventh
-refueling outage, scheduled for April 28, 1998.
During the eleventh refueling outage, the containment radiant energy shields will be replaced with an alternate material, and the radiant energy shields in the annulus will be eliminated by installation of three-hour rated fire barriers using alternate materials, or by.an alternative approach such as relocation of the affected circuits This work may be completed sooner if a shutdown of sufficient' duration occurs once the design work is complete. Compensatory
-measures will remain in place until full compliance is achieved.
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