ML20153E396

Responds to NRC Re Violations Noted in Insp Rept 50-346/85-35.Corrective Actions:Calculation A-46 for Nonconformance Rept 85-0254 Revised to Incorporate ASME Code Allowables Per Procedure MGP-04

ML20153E396
Person / Time
Site:	Davis Besse
Issue date:	02/03/1986
From:	Williams J TOLEDO EDISON CO.
To:	Paperiello C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
1-614, NUDOCS 8602250023
Download: ML20153E396 (2)

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TOLE 00 Docket No. 50-346 EDISON JOE WILLAMs. JR License No. NPF-3 w vr. p,,*  % ~

l419; 243 23]O 9 w 249 w n Serial No. 1-614 February 3, 1986 Mr. C. J. Paperiello, Director Division of Reactor Safety Unitsd States Nuclear Regulatory Comnission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Dear Mr. Paperiello:

Toledo Edison acknowledges receipt of the December 27, 1985 letter (Log No. 1-1300), Notice of Violation, and Inspection Report No. 50-346/

85035 (DRS). In accordance with our discussion with Mr. I. N. Jackiw on January 24, 1986, we requested and were granted a one week extension of the response due date to February 3, 1986. Following an examination of the item of concern, Toledo Edis'on herein offers information regarding these items:

Violation: As a result of the inspection conducted on November 12 through December 6, 1985, and in accordance with the

" General Policy and Procedures for NRC Enforcement Actions,"

10 CFR Part 2, Appendix C (1985), the following violation was identified:

10 CFR 50, Appendix B, Criterion V, as implemented by Toledo Edison Ccmpany Nuclear Quality Assurance Manual and Nuclear Quality Assurance Procedure, requires activities affecting quality be accomplished in accordance with documented procedures.

Contrary to the above, the Bechtel engineering evaluations for Toledo Edison Company site QC issued Nonconformance Reports No. 85-0254 and No. 85-0256 for pipe anchors No. A-46 and No. A-47 utilized cethods and values other than the stress allowable criteria prescribed in Bechtel Procedure MGP-04, Table 1, Section 3.3.(b).

This is a Severity Level V Violation (Supplement II).

(50-346/85035-02) 8602250023 e60203 PDR ADOCK 05000346 PDR 0 300 MAOISON AVENUE TOLEDO. OHIO 43652 g THE TOLEGO ED!SCN COMPANY EDISON PLAZA FEB 1 0 1986 v10/

7 Dockee Wo. 50-346 Licens9 No. NPF-3 S* rial No. 1-614 February 3, 1986 Page 2 Response: (1) Corrective action taken and results achieved.

Calculation A-46 for Noncenformance Report (NCR) 85-0254 and Calculation A-47 for NCR 85-0256 were reviewed for conform-ance to Procedure MGP-04, " Procedure for Control of Interim /

Short-Term Allowable Stress Criteria for Seismic Category I Piping Systems at Davis-Besse Nuclear Power Station Unit No. 1". Calculation A-46 was determined to have utilized AISC code allowables and was subsequently revised (Revision

9) to incorporate ASME code allowables as required by Procedure MGP-04. It was determined that Calculation A-47 had utilized neceptable ASME code allowables but that they were different than as required by Procedure MGP-04.

Calculation A-47 was determined to be acceptable using the appropriate ASME allowables required by Procedure MGP-04.

The NCR Log-A-Task 285378 was reviewed to determine which previously dispositioned NCRs involved attachments to pipes. Fifty-two NCRs were determined to involve attach-monts to pipes; however, only thirteen NCRs were specifically related to welds on integral attachments to pipe pressure boundaries. The thirteen NCRs were reviewed and determined to be acceptable utilizing the ASME code allowables required by Procedure MGP-04.

(2) Corrective action to be taken to avoid further violaticas.

Procedure CGP-04, " Procedure for Evaluating Nonconformance Reports Related to Pfpc Supports, Pipe Anchors, and Seismic Restraints at Davis-Fesse Nuclear Power Station Unit l,

was issued on January 28, 1986 to supplement procedure MCP-04 and provide design criteria clarification. This procedure has been issued and training has been provided to personnel performing NCR dispositions at Bechtel, Gaithernburg and at the Davis-Besse plant site.

(3) The date when full compliance will be achieved.

Full conpliance has been achieved with the issuance of Procedt re CGP-04 and the subsequent training which was comple:ed on January 31, 1986.

Very truly yours,

$& - m f ,

W:TIB:lah ec: DB-1 NRC Resident Inspector

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