ML20137Q333
| ML20137Q333 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/04/1997 |
| From: | Jeffery Wood CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1-1122, NUDOCS 9704100222 | |
| Download: ML20137Q333 (9) | |
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CENTE~COR ENERGY 5501 N State Route 2 419-249-2300 John K. Wood Oak Harbor.OH 43449 FAX: 419-3218337 Vce Presdent. Nuclear Davis-Besse Docket Number 50-346 License Number NPF-3 l
1 Serial Number 1-1122 April 4, 1997 United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 i
Subject:
Response to Inspection Report 50-346/96014 Ladies and Gentlemen:
i Toledo Edison has received Inspection Report (IR) 50-346/96014 (Log Number 1-3793) and the enclosed Notice of Violation; the response to which is provided below. After discussion with the Senior Resident Inspector for the Nuclear Regulatory Commission (NRC) at the Davis-Besse Nuclear Power Station (DBNPS) on March 24,1997, it was agreed that this response to IR 96014 would be submitted by April 4,1997.
Reply to a Notice of Violation (50-346/96014-01)
Alleced Violation
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During an NRC inspection conducted on November 26,1996 through January 24,1997, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation; are listed below:
I.
10CFR Part 50, Appendix B, Criterion V," Instructions, Procedures, and Drawings,"
states in part that, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, cr drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished".
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Docket Number 50-346 License Number NPF-3 Serial Number 1-1122 Page 2 s
- a. Administrative procedure DB-DP-00013 (Revision 04)," Surveillance and Periodic Test Program," Section 6.3.7.h stated in part that, " Test prerequisites and procedure steps shall be performed in numerical sequence..."
Contrary to the above, on December 30,1996, an NRC inspector identified that a reactor operator who was performing surveillance DB-SP-03294 (Revision 02),
" Containment Air Cooling Unit 1 Monthly Test," completed steps 4.1.7 and 4.1.8 before finishing steps 4.1.5 and 4.1.6.
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- b. Tecimical Specification 3.6.2.2 stated that,"At least two independent containment cooling units shall be operable." The associated action statement stated,"With one of the above required containment cooling units inoperable, restore at least two units to 4
l operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />."
Administrative procedure DB-OP-00005 (Revision 05), Operator Logs and Rounds,"
Section 6.2.2.d stated in part that, "The following are entries which shall be recorded in the Unit Log:...d. Entering / Exiting a Technical Specification Action Statement."
Contrary to the above, an NRC inspector identified that no unit log entry was made on December 30,1996, to record that the action statement for Technical Specification 3.6.2.2 was entered, when containment air cooler No. I was rendered inoperable during testing activities. Containment air cooler No. I was rendered inoperable when its manual service water isolation valves were isolated.
Surveillance procedure DB-MI-03353 (Revision 01), " Channel Functional Testing of c.
Anticipatory Reactor Trip System Channel 3," step 8.2.3.e, stated, " Increase test INPUT Pressure Source to PSL-4535C until Test Gauge reads approximately 375 PSIG."
Contrary to the above, on December 3,1996, an NRC inspector observed that a technician increased the test input pressure to PSL-4535C to about 450 pounds per square inch gauge (psig), which greatly exceeded the approximately 375 psig specified by the procedure."
This is a Severity Level IV violation (Supplement I).
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i Docket Number 50-346 License Number NPF-3 Serial Number 1-1122 Page 3 Response to Alleged Violation 1.a Reason for Violation The reason for this violation is procedural deficiency and personnel error. Surveillance procedure DB-SP-03294," Containment Air Cooling Unit 1 Monthly Test," requires valve testing by a second procedure, DB-PF-03020," Service Water System Quarterly Test Train 1 Valve Testing," which when completed did not leave the system in the proper configuration to complete surveillance procedure DB-SP-03294. The Control Room operator delayed completion of the valve testing in procedure DB-PF-03020 (required by steps 4.1.5 and 4.1.6 in DB-SP-03294) until there was alignment between the two procedures. A procedural deficiency existed, and was not corrected, due to the inadequate coordination between the two procedures. The Control Room operator did not identify this situation as procedural non-compliance.
A contributing factor to this violation is that the procedure usage requirements described in DB-DP-00013," Surveillance and Periodic Test Program," are not completely consistent with the requirements found in DB-OP-00000," Conduct of Operations". Performance of the specified surveillance tests didn't properly satisfy guidance in either of these two administrative j
procedures.
i Corrective Stens Taken and Results Achieved Although not specifically related to the alleged violation, Plant Operations management expectations regarding procedure compliance defined in DB-OP-00000 have recently been reinforced with each Plant Operations shift.
Required reading has been issued to Plant Operation: shift personnel which reviews this alleged violation and identifies that inconsistencies exist between the administrative procedures DB-OP-00000 and DB-DP-00013. This required reading also clarifies management expectations for situations that may occur until the corrective steps taken below are complete.
Corrective Stens Taken to Avoid Further Violations Surveillance procedures DB-SP-03294 and DB-PF-03020 will be revised to correct the identified procedure deficiency prior to May 30,1997.
Administrative procedures DB-DP-00000 and DB-DP-00013 will be evaluated for inconsistencies with regard to guidance on the use of procedures by May 30,1997. Procedure alterations identified by this review will be completed and personnel involved in surveillance testing will be trained on these procedure changes by July 31,1997.
Date When Full Comnliance will be Achieved Surveillance procedures DB-SP-03294 and DB-PF-03020 will be revised prior to May 30.1997.
Docket Number 50-346 License Number NPF-3 i
Scrial Number 1-1122 i
Page 4 Response to Alleged Violation 1.b Reason for Violation Surveillance procedure DB-PF-03020," Service Water System Quarterly Test Train i Valve Testing," does not contain guidance regarding the operability of Containment Air Cooler (CAC) number 1 and the need to enter the associated Technical Specification Action Statement during performance of the procedure. This example is indicative of a programmatic deficiency in that the surveillance testing program lacked sufficient scope due to omission of a necessary function in surveillance test procedures. This omission of function was that operability determinations were not adequately addressed for repositioning components during surveillance tests. Although guidance for operability determinations did exist in the Plant Operations Section procedures and policies, this guidance was not effectively or consistently implemented during surveillance testing. This was due to historical practices in which performance of surveillance testing in and ofitself would not necessarily render equipment incapable of performing its intended function.
Corrective Steos Taken and Resuus Achieved Guidance was' issued to the Control Room in the form of a Standing Order (Number 97-002) to assure that surveillance procedures are reviewed prior to performance fonhe potential to render the affected system inoperable and the need to enter a Technical Specilcation action statement.
j Procedure revisions have been initiated for surveillance procedure bd-PF-03020 and the corresponding service water train 2 surveillance procedure, D3-PF-03027, to provide explicit guidance for system operability. These revisions will be cornpleted by May 30,1997.
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I Corrective Steps Taken to Avoid Further Violations As part of the extent of condition review identified in 1.icensee Event Report (LER)96-009 submitted to the NRC on December 13,1996, Toledo Edison has initiated a program to review l
all plant procedures, including surveillance procedures, which alter plant equipment, for any condition which renders a safety system incapable of performing its intended safety function.
When such a condition is identified, if explicit guidance is not provided as to what procedural steps affect the safety system and what Technical Specification is impacted, a Potential Condition Adverse to Quality Report (PCAQR) will be generated and a revision to the procedure initiated. The results of this review are periodically updated and provided to Control Room Plant Operations personnel. The standing order guidance discussed previously was revised to assure that these periodic updates are reviewed prior to performance of a surveillance procedure. This review of procedures in response to LER 96-009 is expected to be completed by July 25,1997.
Date When Full Comoliance will be Achieved
- Full compliance was achieved upon issuance of enhanced guidance for operability determinations to Plant Operations in response to LER 96-009.
Docket Number 50-346 License Number NPF-3 Serial Number 1-1122 1
Page 5 Response to Alleged Violation 1 c Reason for Violation The reason for this violation is programmatic deficiency in that some Electrical and Control (E&C) procedures are insufficient with regard to providing appropriately bounded limits.
During the performance of surveillance procedure DB-MI-03353, " Channel Functional Test of PSL-4533C,4534C, and 4535C Main Feed Pump 1 and 2 Turbine Hydraulic Oil Trip and Main Turbine Oil Trip ARTS Channel 3," step 8.2.3.e directed increasing the test input pressure to PSL-4535C until the test gauge reads approximately 375 psig. When the expected result, resetting of the ARTS bistable, was not observed, the test leader directed that the test input j
pressure be increased to approximately 450 psig. In thejudgment of the test leader, based on a normal operating pressure of 1600 psig, the increase to 450 psig was within the procedure guideline since the required value was preceded by " approximate." Surveillance procedure DB-MI-03353 was deficient in that no allowable absolute value was provided to limit the test input pressure.
Corrective Stens Taken and Results Achieved On February 13,1997, Procedure Change Requests (PCR) 97-0380,97-0381,97-0382, and 97-0383 were initiated to provide for the resetting of the ARTS bistable. Surveillance procedure DB-MI-03353 and the associated surveillance procedures for the Anticipatory Reactor Trip l
System (ARTS) channels 1,2, and 4 (DB-MI-03351, DB-MI-03352, ami DB-MI-03354) will be revised to provide an upper bounding value of 400 psig for the test input pressure. These revisions will be completed and made etTective by May 9,1997.
Corrective Stens Taken to Avoid Further Violations It is recognized that other E&C procedures exist that also use " approximate" or unbounded values. A review for the use of approximate or unbounded limits within E&C procedures has been initiated to identify those procedures. This review will be conducted in conjunction with routine E&Cjob activities through the next refueling outage. Each procedure identified will then be evaluated to ensure appropriate limits are specified. Procedure changes will be initiated for those procedures that are evaluated to need additional guidance. All E&C personnel will be made aware of this violation and the presence of approximate values in procedures by issuance of a memorandum to all E&C personnel in conjunction with tailgate training sessions. These actions will sensitize E&C personnel to the concern over approximate values and identify those cases where more specific guidance is appropriate.
Date When Full Comnliance will be Achieved Surveillance procedure DB-MI-03353 and the associated surveillance procedures for the Anticipatory Reactor Trip System (ARTS) channels 1,2, and 4 (DB-MI-03351, DB-MI-03352, and DB-MI-03354) will be revised and made effective by May 9,1997. The review of E&C procedures for the use of approximate or unbounded values will be completed by July 31,1998 which should include the next RFO.
O Docket Number 50-346 License Number NPF-3 e
Serial Number 1-1122 l
Page 6 l
Reolv to a Notice of Violation (50-346/96014-02)
Alleged Violation k
II.
Section 70.24(a) of Title 10 of the Code of Federal Regulations, requires, in part, each licensee authorized to possess special nuclear material (SNM) in a quantity exceeding those identified, to maintain a radiation monitoring system in each area where SNM is handled, used or stored that will alarm if accidental criticality occurs. Furthermore, applicable emergency procedures must be maintained to ensure personnel are withdrawn to an area of safety when the alarm sounds.
Contrary to the above, as of January 24,1997, the licensee never installed a radiation monitoring system in the Davis-Besse new fuel storage areas capable of alarming should an accidental criticality occur. Furthermore, the licensee's initial exemption from the requirements of 10CFR70.24(a) (contained as part ofits original NRC Materials License for possessing SNM) expired when the Davis-Besse construction permit was converted to an operating license in 1977. At that time, the licensee failed to install a radiation h
monitoring system and implement appropriate emergency procedures, or renew its
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i exempt on. Since then, new fuel storage areas have been used to handle, use and store new fuel assemblies on a regular basis prior to each unit refueling outage.
This is a Severity Level IV violation (Supplement I).
Response to Alleged Violation Reason for Violation An exemption from the requirements of 10CFR70.24(a) for a criticality alarm system in the new and spent fuel pool area was granted by the NRC as part of the Materials License No. SNM-1601 when it was approved on June 16,1976, for the DBNPS. License SNM-1601 expired when the DBNPS Construction Permit No. CPPR-80 was converted to 10CFR Part 50 Operating License NPF-3 on April 22,1977. The exemption to 10CFR70.24(a) was not explicitly incorporated into the Operating License by the NRC at that time.
A criticality alarm system was not addressed in the DBNPS Final Safety Analysis Report (FSAR) or the NRC Operating License Safety Evaluation Report and its supplement (NUREG-9136) during the licensing of the DBNPS, even though NRC Regulatory Guide 8.12, Criticality Accident Alarm Systems, dated December 1974, Section C - Regulatory Position existed at that time and described the requirements for a criticality alarm system. The Standard Technical Specifications for B&W Type Plants, NUREG-0103, Revisions 0 (1976) through 4 (1980) listed fuel storage pool area criticality monitors in Table 3.3-6, Radiation Monitoring Instrumentation.
However, Toledo Edison in its letter to the NRC dated August 15,1975, " lined out" this item from the Operating License Technical Specifications being proposed for the DBNPS.
Accordingly, the NRC apparently accepted this proposal (consistent with the exemption) and did not issue any requirements for criticality accident monitors in the Operating License Technical Specifications, dated April 22,1977.
Docket Number 50-346 License Number NPF-3 e
Serial Number 1-1122 Page 7 s
Operating License NPF-3, Section 2.B.3 states that Toledo Edison is licensed pursuant 10CFR70 to receive, possess and use at any time special nuclear material as reactor fuel "in accordance with the limitations for storage and amounts required for reactor operation, as described in the FSAR." Since no criticality alarm system is described in the FSAR or other DBNPS/NRC licensing bases documentation, Toledo Edison believed that this provision served the purpose of the previous exemption. This, coupled with the initial exemption, led Toledo Edison to conclude that the requirements of 10CFR70.24 were not applicable for the life of the DBNPS.
Toledo Edison had also obtained a copy of a May 11,1988, letter from the NRC to the Tennessee Valley Authority (TVA) regarding the 10CFR70.24 exemptions for Browns Ferry Units 1 through 3. These units had also received exemptions from 10CFR70.24 in their Special Nuclear Material Licenses, but the exemptions had not been incorporated into the subsequently issued Operating Licenses, and TVA was requesting new exemptions. This NRC letter stated that the NRC "... staff considers that the previously issued exemptions are still in effect even though the specific provisions of the Part 70 licenses were not incorporated into the Part 50 license."
4 "Section 2.B(2) of the... licenses state TVA is authorized to receive, possess and use special nuclear material as reactor fuel in accordance with Part 70. In view of this provision, the previously issued exemptions should not be considered to have expired and you are hereby advised that the staff does not consider a further exemption necessary." As the DBNPS was similarly situated like Browns Ferry with regards to the 10CFR70.24 exemptions, Toledo Edison concluded that this further confirmed that the previously issued exemption under license SNM-1601 had not expired.
This situation of not explicitly including the exemption in the Operating License or issuing a separate exemption occurred nearly 20 years ago and the involved personnel from the NRC and Toledo Edison are unavailable. Thus, reconstructing their reasoning is not possible.
Current Davis-Besse Design The DBNPS Updated Safety Analysis Report (USAR) Section 3D.I.53, " Criterion 62 -
Prevention of Criticality in Fuel Storage and Handling," describes the features utilized to prevent criticality in fuel storage and handling. New fuel assemblies are stored in a dry protected area.
The spacing requirements for storage, combined with the blocking of rows C and F for new fuel assemblies, is adequate to maintain a k,g ofless than 0.95 for an enrichment of 5.0 percent even if flooded with unborated water, and is adequate to maintain a k,g ofless than 0.98 even if immersed in a hydrogenous " mist" that produces optimum moderation. For spent fuel storage the spacing and " flux" trap construction, whereby the fuel assemblies are inserted into neutron absorbing stainless steel cans, is sufficient to maintain a k gofless than 0.95 for spent fuel of e
initial enrichment of 3.56 wt% U-235 or less. However, as higher enrichment spent fuel assemblies are stored in the spent fuel pool they must be stored in a checkerboard pattern taking into account fuel burn-up to maintain a k,n fless than 0.95. Further, Technical Specification o
3.9.13, Spent Fuel Pool Fuel Assembly Storage, restricts the placement of fuel assemblies within the spent fuel pool to ensure that k,gwill always remain less than 0.95 assuming the pool to be flooded with non-borated water.
Docket Number 5b-346 License Number NPF-3 e
Serial Numbcr 1-1122 Page 8 j
4 Area radiation monitors are installed for station personnel protection in the Spent Fuel Pool and New Fuel Storage areas. Two area radiation monitors (RE8417 and 8418) are installed in the Fuel Handling Area and two area radiation monitors (RE8426 and 8427) are installed in the Spent Fuel Pool Area. These area radiation monitors provide station personnel with continuous monitoring of gamma emitting radioactivity, and alarm on high radiation. The station's response to high radiation alarms is directed by procedures DB-OP-02009, Plant Services Alarm Panel 9 3
Annunciators, DB-OP-06412, Process and Radiation Monitor, and as applicable, RA-EP-02861, RadiologicalIncidents.
Corrective Steos Taken and Results Achieved Toledo Edison was initially contacted by the NRC Office of Nuclear Reactor Regulation on August 5,1996, regarding an NRC survey as to whether or not the DBNPS had an explicit exemption ;o 10CFR70.24 and how the exemption was approved and maintained. Information regarding the status of the DBNPS exemption was presented verbally and by facsimile by Toledo Edison to the Office of Nuclear Reactor Regulation. A Potential Condition Adverse to Quality Report (PCAQR 96-1087) was self-initiated by Toledo Edison on August 6,1996, to identify the status of the criticality monitor exemption at the DBNPS as an item of potential regulatory non-
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compliance.
4 Corrective Steos Taken to Avoid Further Violation On January 30,1997, Toledo Edison submitted a request for an explicit exemption from 10CFR70.24, " Criticality Accident Monitoring Requirements," (Letter Serial Number 2440).
Toledo Edison believes the exemption is technically appropriate for similar reasons the NRC granted an exemption in connection with the Materials License No. SNM-1601, and issued the 4
DBNPS Operating License Technical Specifications in 1977 without standard criticality monitoring instrumentation requirements. Until the NRC approves the exemption request (or 10CFR70.24 is met without reliance on an exemption), Toledo Edison does not plan to receive new nuclear fuel. Movement of spent fuel will first be evaluated against the requirements of 10CFR70.24.
Date When Full Comnliance Will be Achieved Full compliance will be achieved upon NRC approval of the exemption request submitted by Toledo Edison.
DockctNumber 50-346 License Number NPF-3 Scrial Number 1-1122 Page 9 Should you have any questions or require additiond information, please contact Mr. James L.
Freels, Manager - Regulatory Affairs, at (419) 321-8466.
l Very truly yours, DL dic cc: A. B. Beach, Regional Administrator, NRC Region III A. G. Hansen, NRC/NRR Project Manager S. Stasek, NRC Region III, DB-1 Senior Resident inspector Utility Radiological Safety Board 9
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