ML20150B706
| ML20150B706 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 07/06/1988 |
| From: | Harrison J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Shelton D TOLEDO EDISON CO. |
| References | |
| NUDOCS 8807120134 | |
| Download: ML20150B706 (2) | |
See also: IR 05000346/1988006
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JUl. 6 '1988
Docket No.'50-346
Toledo Edison Company-
' ATTN:
Mr., Donald Shelton
Vice-President
Nuclear
Edison Plaza
300 Madison Avenue
Toledo, OH 43652
Gentlemen:
Thank you for your letter dated June 9,1988, informing 'us of the steps you'
have taken to correct the noncompliances which we brought to your attention
in our letter dated April 20, 1988.
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With regard to violation 88006-05, we have determined the following:
1)
The sightglass was installed (1977) seven years before the: event witho'ut'
detailed drawings and instructions;
2)
No design criteria or design guides were used in the seismic qualification
calculation. Licensee's engineering calculation did not contain
appropriate acceptance criteria which were required by.the 10_CFR-50,'
Appendix B, Criterion V;
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3)
At the time of the inspection, design criteria were still being developed
for the sightglass and the safety-related component modifications; and
4)
The seismic qualification calculation should have been performed at the
time of installation instead of nine years (1986) later.
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Based on the above, we have concluded that_the violation was not adequately
self identified and the corrective actions taken were neither prompt, effective,
nor complete.
Therefore, your request that we retract the , violation is denied.
You are requested to submit a written reply to this letter within thirty (30)
days of the dates of this letter including: (1) corrective action taken and
the results achieved; (2) corrective action to be taken to avoid further
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violations; and (3) the date when full compliance will be achieved.
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Toledo Edison Company'
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Should you have any questions .concerning this' matter, please feel free to -
contact me.
incerely,-
S
0,jginal Signed by J.'J. llarricon
J. J. Harrison, Chief--
Engineering Branch'
cc:
L. Storz, Plant Manager
cc w/1tr- dtd 6/9/88:
DCD/DCB (RIDS)
Licensing Fee Management Branch
Resident Inspector, Rlll
James W. Harris, State of Ohio
Robert M. Quillin, Ohio
Department of Health
State of Ohio', Public
Utilities Comission
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Docket No. 50-346
License No. NPF-3
Serial No. 1-806
June 9, 1988
Document Control Desk
United States Nuclear Regulatory Commission
Vashington, D. C.
20555
Subject: Response to Inspection Report 88006
Gentlemen:
Toledo Edison has received Inspection Report 08006 (Log No. 1-1783 dated April
20, 1938) and provides the following response.
Based on our discussion with
Mr. F. Jablonski on June 1,1988, the response to Inspection Report 88-006 vas
extended to June 10, 1988.
Violation 88006-05:
10CFR50, Appendix B, Criterion V, requires that activities affecting quality
be prescribed by documented instruction, procedures, or dravings and be
accomplished in accordance with these instructions, procedures, or dravings.
Instructions / procedures or dravings shall include appropriate acceptance
criteria for determination that activities have been satisfactorily
accomplished.
Contrary to the above, a review of FCR 78-024 pertaining to the installation
of containment spray pump oil sightglass as.aemblies revealed the following:
No design drawings or detailed dravings were used during the installation
a.
of the assemblies,
b.
No instructions / procedures vere found for installation and inspection.
No design criteria / instructions vere utilized in the scismic qualification
c.
evaluation.
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TWE '7.ECO ED: SON CCMPANY
ED SON PLAZA
200 MAD: SON AVENUE
TOLEDO. CHO 43G52
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Dockst Ns. 50-346
License No. NPF-3
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Serial No. 1-806
Page 2
Response:
Acknowledgment Or Denial of the Alleged Violation
Toledo Edison does not believe the issuance of.a Notice of Violation is
varranted for the installation of the containment spray pump oil sightglass
for the following reasons.
Following the June 9, 1985 event, Toledo Edison initiated a System Reviev &
Test Program (SRTP). The SRTP was established to review the history of
systems important to the safe operation of the Davis-Besse Nuclear Power
Station (DBNPS). One of the objectives of the SRTP reviev vas to identify
problems which may impact the ability of those systems to perform the
necessary functions for safe operation of the plant and to propose corrective
actions to resolve those concerns. The Containment Spray (CS) system was one
of the systems revleved under the SRTP.
One of the concerns documented during the review of the Containment Spray
System was thnt no documentation was found that listed the vendor,
qualification, specification or appropriate installation instructions for the
oil level sight glasses added to the pumps in 1977.
This concern was
documented, its safety significance determined and corrective action proposed.
Subsequent reviews confirmed there was no safety concern due to the installed
configuration.
An engineering calculation, a Facility Chr.nge Request (FCR)
safety evaluation and the NRC inspection each concluded that:
the calculated
stresses vere below the allovable stresses; the installation was seismically
qualified; and the sightglasses could perform their intended function during a
seismic event.
Following the June 9, 1985 event, Toledo Edison received and acknowledged
violations relating to programmatic control of modifications to the facility.
In response to those violations and as part of overall improvement efforts,
the processes for the design of modifications, control of vork, and reviews
for changes to safety related systems have been improved. Nuclear Group
Procedure NG-NE-304 requires a safety review and if applicable a safety
evaluation for proposed changes to identified systems, structures and
components important to safe operation.
The Containment Spray System is one
of the systems identified in this procedure.
10CFR2 Appendix C, Section V.G.2, Exercise of Discretion, allows the NRC to
refrain from issuing a Notice of Violation for violations meeting the
following criteria
(i) NRC has taken significant enforcement action based upon a major
a.
safety event contributing to an extended shutdovn of an operating
reactor or a material licensee (or a work stoppage at a construction
site), or the licensee is forced into an extended shutdown or vork
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stoppage related to generally poor performance over a long period:
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(11) the licensee has developed and is aggressively implementing
during the shutdown a comprehensive program for problem
identification and corrections
and (iii) NRC concurrence is needed
by the licensee prior to restart.
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Dock 3t N3. 50-346
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License No. NPF-3
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Serial No. 1-806
Page 3
b.
Non-villful violations are identified by the licensee (as opposed to
the NRC) as the result of its comprehensive program, or the
violations are identified as-a result of an employee allegation to
the licensee. If NRC identifies the violation, the NRC should
determine whether enforcement action is necessary to achieve remedial
action.
The violations are based upon activities of the licensee prior to the
c.
events leading to the shutdown, and
d.
The non-villful violations would normally not be categorized as
higher than Severity Level III violations under the NRC's Enforcement
Policy.
The sight glass installation meets the criteria set forth in this section.
In
keeping with the stated objectives accompanying the revision to this section
of the code (i.e. to encourage prompt corrections of existing violations and
adverse conditions, to deter future violations and adverse conditions, and to
encourage improved performance by the licensee, while at the same time, not
discouraging a licensee's aggressive and comprehensive implementation of a
structured program to identify and correct problems), Toledo Edison urges the
NRC to exercise its authorized discretion to refrain from issuing a violation
in this instance.
Violation 88006-10:
10CFR50, Appendix B, Criterion III, requires that measures be established to
assure that applicable regulatory requirements and the design basis, as
defined in 5 50.2 and as specified in the license application, for those
structures, systems, and components to which this appendix applies are
correctly translated into specifications, drawings, procedures, and
instructions.
Design changes, including field changes, shall be subjected to
design control measures commensurate with those applied to the original design
unless the applicant designates another responsible organization.
Contrary to the above, Specifications No. 12501-E-180 vas changed
administrative 1y to include a revised load profile for the station battery
performance test without going through the Facility Change process or applying
appropriate design control.
Response:
peknowledgment or Denial of the Alleged Violation
Toledo Edison acknowledges the alleged violation.
Reason for the Violation
Nuclear Engineering Procedure (NEP)-021, Specifications, controls the
revision, review and approval of design specifications.
Generically, once a
change to a specification is identified, it is evaluated by Design Engineering
to determine whether it is a significant change.
Depending on the
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Docket No. 50-346
License No. NPF-3
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Serial No. 1-806
Page 4
significance of the change required, the specification change follows 1 of 2
paths.
If the change is determined to be significant, _the specification
undergoes immediate revision and the change is incorporated. When the
specification is revised a formal design review is performed.
Changes to
interfacing plant procedures are identified during the formal design review
process.
If the change is determined not to be significant, a Specification Change
Notice (SCN) is issued against the specification.
A SCN is a document used to
temporarily modify the specification instead of revising the specification as
described above.
SCNs can be used when specification changes, not associated
with physical plant modifications, are identified such as typographical
errors, incorrect index pages or incorrect information. The SCN is attached
to the specification indicating the change to the specification. No formal
design review is required.
SCNs issued against a specification are
incorporated into the specification _(by the specification revision process)
when a total of five non-plant modification related SCNs are accumulated or
one year passes.
When the specification is revised the design reviev is
performed.
In the case of the ststion battery load profile change, it was determined that
this change could be processed as an editorial ("incorrect information") SCN
(SCN 12501-E-180-01-03).
This SCN documented various changes to the load
profile but did not change the battery size or result in a physical change to
the facility.
Therefore per NEP-021, no formal design reviews (including
changes to applicable plant procedures) were immediately required for the
issuance of SCN 12501-E-180-01-03.
Corrective Steps Taken And Results Achieved
Subsequent to this NRC inspection, a more detailed review of the battery load
profile was conducted.
As a result, Calculation C-EE-002-005, Rev. 0.vas
performed to better define and document the accident scenario to which the
batteries are sized and to incorporate 5th Refueling Outage Modifications
affecting the DC system.
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Document Change Request (DCR) 88-0158 and USAR Change Notice (UCN)88-031 vere
issued to incorporate the new load profile into the affected design documents.
This changed the load profile for the Battery Service Test making it the same
as that in Specification 12501-E-180
On April 16, 1988 the Battery Service
Test was successfully completed.
Corrective Steps Vhich Vill Be Taken To Avoid Further Violation
Procedure NEP-021 vill be revised to allow the preparation of non-plant
modification related SCNs be used only in conjunction with a Document Change
Request (DCR) per NG-NE-0312, Design Document Updates and NEP-202, Processing
Document Change Request.
The DCR is used for "paper work only" design
document changes.
The use of the DCR process vill require a design reviev to
ensure interfacing plant procedures are reviewed for changes. Therefore
changes to specifications vill undergo the full design reviev controls imposed
by the FCR/ MOD or DCR process upon their initiation.
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License No. NPF-3
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Serial No. 1-806
Page 5
Date When Full Compliance Vill Be Achieved
Full compliance vill be achieved upon issuance of EN-DP-01021 R0 (NEP-021) by
June 20, 1988.
Very truly yours,
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JCS:tlt
cc:fA.'B.: Davis,' Regional Administrator;
4
A. V. DeAgazio, DB-1 Projec t Manager
DB-1 Resident Inspector
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