ML20203G009
| ML20203G009 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 11/25/1985 |
| From: | Williams J TOLEDO EDISON CO. |
| To: | Paperiello C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20203F984 | List: |
| References | |
| 1-593, IEB-79-02, IEB-79-14, IEB-79-2, NUDOCS 8604280206 | |
| Download: ML20203G009 (8) | |
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TOLEDO Docket No. 50-346 EDISON License No. NPF-3 JOE WtuAMs JR Ser=r vce Presne t %: a p19] 249 F3CC Seria1 No. 1-593 pt9] 249 5223 November 25, 1985 Mr. C. J. Paperiello, Director Division of Reactor Safety United States Nuclear Regulatory Commission Region 111 799 Roosevelt Road Glen Ellyn, IL 60137
Dear Mr. Paperiello:
Toledo Edison acknowledges receipt of the October 18, 1985 letter (Log No. 1-1260), Notice of Violation, and Inspection Report No. 50-346/
85031(DRS).
In accordance with our discussion with Mr. I. N. Jackiw on November 18, 1985, we requested and were granted an extension of the response due date to November 22, 1985.
Following an examination of the items of concern, Toledo Edison herein offers information regarding these items:
1.
Violation:
10 CFR 50, Appendix B, Criterion III, as implemented by TECo Nuclear Quality Assurance Manual and Nuclear Quality Assurance Procedure, requires establishment of procedures among participating design organizations for review, approval, release, distribution, and revision of documents involving design interfaces.
Contrary to the above, the design interface between Bechtel Power Corporation and ITT-Grinnell Corporation during implementation of IE Bulletin No. 79-14 piping as-built activities was not established in an approved controlled interface procedure.
This is a Severity Level IV violation (Supplement II).
(50-346/85031-01)
Response: (1)
Inspection Report 50-346/85031 stated that "Upon the NRC inspector's request, Bechtel could not produce the document that controlled IE Bulletin 79-14 activities between Bechtel and ITT-Grinnell. The failure to establish a controlled design interface document to control IE Bulletin 79-14 activities between Bechtel
-nd ITT-Grinnell is considered to be a violation of pg42Sean ana@g6 NOV 291985 THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO. OHIO 43652
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Dock:t No. 50-346 License Ns. NPF-3 Serial No. 1-593 November 25, 1985 Page 2 10 CFR 50, Appendix B, Criterion III." As a result of further investigation, we have identified the following information relative to the Bechtel/ITT-Grinnell interface for the IE Bulletin 79-02 and 79-14 efforts:
a.
NRC IE Bulletin 79-02 required pipe hangers to be re-evaluated for base plate flexibility
.ind for the effects of base plate flexibility on fasteners to concrete.
IE Bulletin 79-14 required piping and hanger installations to be verified for as-built conditions versus design requirements.
b.
Pipe hangers for piping 2k inches or larger for Davis-Besse Unit I were originally designed by ITT-Grinnell, Providence, Rhode Island. Many hangers were subsequently reanalyzed by ITT-Grinnell because of the reanalysis of piping systems required for IE Bulletin 79-14 and the detailed analysis required for IE Bulletin 79-02.
The Piping systems reanalysis was performed by Bechtel. Many hangers were within the scope of both IE Bulletins 79-02 and 79-14, in which case, the hanger reanalysis, performed under IE Bulletin 79-14 incorporated the base plate flexibility criteria, dictated by IE Bulletin 79-02.
c.
For hangers within the scope of IE Bulletin 79-02 only, ITT-Grinnell furnished Bechtel with base plate forces and moments. These forces and moments were requested during conferences and by letter transmitted from Bechtel to ITT-Grinnell which listed the hanger numbers requiring the needed information. The response from ITT-Grinnell was by letter with a summary of forces and moments to base plates for each hanger.
d.
Bechtel engineering / design activities (Calcul-ations, Drawings, Vendor Documents, Drawing Change Notices, Facility Change Requests) were controlled by Project Procedures and the follow-ing procedures were prepared specifically for IE Bulletin work.
PDP-1 Inspection and Testing Procedure for Concrete Expansion Anchors
Docket Ns. 50-345 b
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Lician No. NPF-3 Serial No. 1-593 November 25, 1985 Page 3 PDP-2 Inspection Procedure for As-Built Configuration of Nuclear Safety Related Piping Components PDP-3 Evaluation Procedure for As-Built Configuration of Nuclear Safety Related Piping Components IE Bulletin 79-14.
The Bechtel/ITT-Grinnell/ Toledo Edison design interface for work performed under IE Bulletin 79-14 was as follows:
a.
Pipe stress analysis was performed by Bechtel, b.
Bechtel prepared load summary sheets from the pipe stress analysis for the hangers. Certain hangers were selected to be reanalyzed by ITT-Grinnell. These load summary sheets were transmitted to ITT-Grinnell by letter.
c.
Hanger reanalysis for selected hangers were performed by ITT-Grinnell and upon completion, ITT-Grinnell forwarded force and moment data to Bechtel for base plate analysis under IE Bulletin 79-02. Details of any required modifications for hangers were also transmitted to Bechtel by letter.
d.
Calculations were prepared and maintained by 11T-Grinnell and Bechtel for their respective scope of work.
e.
All communications and transfer of design inform-ation was documented by letter.
f.
ITT-Grinnell engineering design and analysis work was performed under purchase order from the Toledo Edison Company (TED) to ITT-Grinnell. The TED Purchase Order required a current version of an approved ITT-Grinnell Quality Assurance Program and specifically provided that ITT-Grinnell would receive authorization related to their IE Bulletin 79-02 and 79-14 calculation efforts through written Bechtel correspondence.
I g.
Hanger drawing revisions which were required as the result of IE Bulletin analysis were prepared by Bechtel Engineering as Vendor Drawing Change j
Notices (VDCNs) to ITT-Grinnell drawings (Bechtel
)
Vendor Document Control Number 7749-M-190-H-X-X
Dock 2t No. 50-346 f
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Lic2cse No. NPF-3 S rial Ns. 1-593 November 25, 1985 Page 4 Series). VDCNs were issued in Facility Change Request (FCR) packages and sent to TED for implementation of changes to the plant. Upon completion of FCR implementation and receipt of notification that the FCR(s) implementation was completed, Bechtel incorporated the VDCNs in the drawings, issued revised drawings to reflect the as-built condition and notified TED when their actions were completed.
The engineering design interface between Bechtel and ITT-Grinnell for IE Bulletin 79-14 was clearly established and maintained by Bechtel Project Engineer-ing procedures and related actions. Procedures in effect at the time of IE Bulletin 79-14 activity were reviewed and approved by Toledo Edison Company and were implemented to effectively define and control the design interface. The manuals in effect during the IE Bulletin 79-14 effort were:
(1) The Engineering Procedures Manual (EPM), Third Edition, and (2) the Project Engineering Procedures Manual (PEPM).
Procedures related to the Bechtel/lTT-Grinnell Corpor-ation Design Interface for IE Bulletin 79-14 were included in Bechtel procedure manuals approved by TED.
Initial Bechtel/ITT-Grinnell activities were conducted when the EPM was in effect. EPM paragraph 3.0, Corres-pondence, included subparagraphs which established the Bechtel/ITT-Grinnell controlled design interface procedure.
3.2 Toledo Edison - Correspondence 3.3 Bechtel - Correspondence 3.4 Equipment Vendors - Correspondence 3.7 Conference Notes procedures required conferences to be serially numbered, the Project Engineer's signature, transmittal letters be prepared and copies distributed.
3.9 Loop Closing procedure assigned Project Engineering responsibility for review and closeout of:
- Correspondence initiated by Project Engineering (Bechtel)
- Correspondence initiated by Vendors /
Contractors (i.e., ITT-Grinnell)
Bechtel/ITT-Grinnell activities continued during the period, when the PEPM superseded the EPM and became effective (April, 1980).
Engineering
Dock:t No. 50-346
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l, Lic:0:2 No. NPF-3 Serial No. 1-593 November 25,-1985 Page 5 Department Project Instruction (EDPI) 5.1-11, Communic-ations Control, includes subparagraphs which establish the Bechtel/ITT-Grinnell controlled design interface procedure. The procedure describes handling and control of Project Engineering Communication and provides for documented closeout of action as follows:
a.
EDPI paragraph 3.0, Incoming Communications, describes the control of all incoming correspondence.
ITT-Grinnell Letter Numbers GTB-XXX Series were used to transmit IE Bulletin information to Bechtel. All letters were processed per EDPI 5.1-11, Communications Control.
b.
EDPI paragraph 4.0, Outacing Communications, describes control of all outgoing correspondence.
Bechtel Letter Numbers BV1-XXX Series were used to transmit IE Bulletin information to ITT-Grinnell. All letters were processed per EDPI 5.1-11, Communications Control.
Bechtel Letter Numbers BT-XXXX Series were used to transmit IE Bulletin information to TED. All letters were processed per EDPI 5.1-11, Communications Control, c.
EDPI paragraph 10.0, Conference Notes, describes requirements for recording formal meetings and listing action items on Exhibit I, Agreements /
Commitments form.
Based on the foregoing, we believe Toledo Edison was in full compliance with regards to the design interface requirements specified by 10 CFR 50, Appendix B, Criterion III.
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Docket ~Na, 50-346 b b
Lic:nsa Ns. NPF-3 Serial No. 1-593 No'vember 25, 1985 Page 6 2.
Violation:
10 CFR 50, Appendix B, Criterion XVI, as implemented by TECo Nuclear Quality Assurance Manual andluclear Quality Assurance Procedure, requires that coaditions adverse to quality such as deficiencies, deviations, and nonconformances be promptly identified and cor-rected.
Contrary to the above, the licensde did not effectively implement its Facility Change Request system in that a number of safety-related supports were not restored to their FSAR design condition in a timely manner. These supports were left in a short-term operable status for three to five years.
This is a Severity Level IV violation (Supplement II).
(50-346/85031-02)
Response: (1) Corrective action taken and results achieved.
l Inspection Report 50-346/85031 stated that " Based on
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the above findings, the inspector concluded that the present TEco FCR system is ineffective. Continually adding supplements to some FCRs (changing the scope of work) partially contributed to some nonconforming or deficient conditions not being corrected in a timely manner (FCR No.80-087 has 11 supplements up to March 29, 1985; FCR No.80-125 has 12 supplements up to September 10,1985). Some FCRs became so large and were contingent upon so many other conditions (such as drainage and support as-built evaluations),
that final closeout was difficult, if not impossible.
It is estimated that there are numerous FCRs that fall into this category."
Major revisions to Engineering Department Procedures have been completed since 1981. These revisions established more stringent controls on the Facility Change Request (FCR) process, specifically within the conceptual design area. The development of the l
conceptual design portion of the FCR will be utilized s the basis for determining the limits and the scope of the FCR as well as for confirming the technical feasibility and the validity of the FCR. Please note that procedural requirements dictate that the scope of an FCR may not be changed by a supplement.
Scope changes can only be changed by a revision to the FCR which entails a complete review of the FCR package.
Docket No. 50-346 f
f Licera N3. NPF-3 Serial No. 1-593 November 25, 1985 Page 7 Since the 1981 timeframe there have been very few FCRs generated with a significant number of supplements. A review of the FCR Log provided the following status as of November 11, 1985:
1.
Number of FCRs Issued Since 2984 Startup - 1977 2.
Number of FCRs with More than 106 Six Supplements 1
3.
Number of FCRs with More than 42 Ten Supplements 4.
Number of FCRs with More than 17 15 Supplements (Both Nos. 3 and 4 are subsets of 2) 5.
Number of FCRs since 1981 with 5
More than Six Supplements Those FCRs (80-079 through 80-094,80-125,80-131) which were identified during the IE Bulletin 79-02 and 79-14 walkdowns as requiring restoration of the supports / hangers to their FSAR design condition, have been closed out with the exception of FCR 80-091. This FCR has been implemented in the field and the remaining actions to be completed include drawing update and final Toledo Edison engineering closeout.
It should be noted that there was no impact on piping system operability as a result of those supports / hangers which were allowed to remain within interim allowable requirements (short-term operable status). These interim allowables were developed in conjunction with the IE Bulletin 79-14 program.
Additionally, Nuclear Facility Engineering Procedure NFEP-060, Processing Nonconformance Reports, Deviation Reports, and Supplier Deviation Disposition Requests, was modified on October 1, 1985 to provide specific time limits for ensuring that piping systems are restored to FSAR requirements if they are determined to be within interim allowable require-ments. This is part of the Operibility Evaluation Program which was reviewed and accepted by Region III in Inspection Report 50-346/85031.
(2) Corrective action to be taken to avoid further violation.
Of the 106 FCRs iseded with more than six supplements, approximately 507,are still open. This fact, coupled with the current backlog of FCRs has led the Engineering Services Department to develop an FCR Closcout Action Plan. The plan establishes the support requirements, responsibilities, interfaces, tasks and activities which are necessary to closeout the backlog of FCRs as well as the FCRs which will have been implemented by the end of the current outage.
Docket Ns. 50-346' f f
- LicIcs2 No. NPF-3 Serial No. 1-593 l
No'vember 25, 1985 Page 8 Additionally, one of the secondary objectives of the FCR closeout Action Plan is to ensure compliance with procedures and expedite the FCR closcout process.
(3) The date when full compliance will be achieved.
Full compliance will be achieved upon completion of the FCR Closeout Action Plan which is scheduled for the end of the fifth refueling outage.
Very truly yours, D M2 7
- TJB:lah cc: DB-1 NRC Resident Inspector i
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