ML20211K542
| ML20211K542 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 06/09/1986 |
| From: | Williams J TOLEDO EDISON CO. |
| To: | Paperiello C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20211K539 | List: |
| References | |
| 1-639, NUDOCS 8606300164 | |
| Download: ML20211K542 (7) | |
Text
Y TOLEDO
%m EDISON Docket No. 50-346 JOE WLUAMS JR.
Serwr Vce Presdert-Nuclear (419]249-2300 License No. NPF-3 (d* 2d"223 Serial No. 1-639 June 9, 1986 Mr. C. J. Paperiello, Director Division of Reactor Safety United States Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Dear Mr. Paperiello:
Toledo Edison acknowledges receipt of your April 30, 1986 letter (Log No. 1-1377), Notice of Violation, and Inspection Report No. 50-346/86004 Based on our discussion with Mr. I. N. Jackiw on June 3, 1986, an extension for our response was requested and granted until June 5, 1986.
In addition to the response to the violations, per the request of your April 30, 1986 letter, we will be providing a separate response to address your concern relative to abandoned drilled anchor bolts behind pipe support baseplates.
This response will be submitted by June 13, 1986.
Following an examination of the violation items of concern, Tcledo Edison herein offers information regarding these items:
Violation:
10 CFR 50, Appendix B, Criterion V, as implemented by Toledo Edison Company Nuclear Quality Assurance Manual and Nuclear Quality Assurance Procedures, requires activities affecting quality be accomplished in accordance with documented proc-edures.
Contrary to the above, the Bechtel Associates Professional Corporation (Bechtel) engineering staff failed to report to Toledo Edison Company, as required by Bechtel Procedure MGP-04 Paragraphs 6.1.a and 6.1.b, that based on stress calculation performed during December 1985 and January 1986, several piping systems and supports did not meet FSAR conditions. Consequently, Toledo Edison could not evaluate, for reportability to the NRC, the impact of the deviations on system operability. This is a repetitive finding (Reference Inspection Report No. 50-346/85035).
This is a Severity Level IV Violation (Supplement II).
(50-346/86004-01A) w g g"IOIl54"860618
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AZA 300 MADISON AVENUE TOLEDO, OHIO 43652 UN 13 E86 DR ADOCK 05000 6
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' Docket No. 50-346 License No. NPF-3 Serial No. 1-639 l
June 9, 1986 Page 2
Response
- 1) Corrective action taken and the results achieved Bechtel has provided a letter, dated February 14, 1986,'which identifies the total listing of pipe support nonconformance reports (NCR) which have been dispositioned as exceeding-FSAR allowables but meeting interim requirements. This letter also included the results of all operability evaluations conducted as of that time frame. Sper.ifically, those stress problems which had exceeded FSAR stress levels but met interim requirements and those supports which exceeded FSAR allowables as a result of the operability evaluatfons were identified. These actions are considered by Toledo Edison as bringing Bechtel into compliance with the-require-
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ments of Procedure MGP-04.
Upon completion of Toledo Edison's review of the Bechtel letter, Licensee Event Report (LER)86-013 was submitted to the NRC to document two systems (Containment Spray and Low Pressure Injection / Decay Heat) which were identified as exceeding the Safety Analysis Report (SAR) allowables, but which did meet the Davis-Besse interim requirements.
2)
Corrective action taken to avoid further violations Bechtel has issued an interoffice memorandum on March 15, 1986 from the Davis-Besse Project Engineer to_the group supervisors which discusses the reasons for the violation and the appropriate procedural actions that should have been followed. This memorandum also requests that a review of the procedure for control and reporting of interim /short-term allowable stress criteria for Seismic Category I piping systems be conducted.
Bechtel Engineering Department Instruction (EDPI) 4.6-11, Nonconformance Reports and Supplier Deviation Reports, has been revised to provide additional emphasis relative to the Bechtel responsibilities iden:ified in Procedure MGP-04.
Lastly, Bechtel issued a second interoffice memorandum j
on May 23, 1986 for all those people on the Davis-Besse Project Roster-Job 12501. This memorandum addressed the two recent procedural adherence violations related to t
Procedure MGP-04. The memorandum stressed the importance of adhering to procedural requirements in response to what i'
was identified as a repetitive finding by the NRC.
3)
Date when full compliance will be achieved
)
Full compliance was achieved with the issuance of the j
memorandum on May 23, 1986.
I
- Docket No. 50-346 License No. NPF-3 Serial No. 1-639 June 9, 1986 Page 3 Violation:
10 CFR 50,~ Appendix B, Criterion V, as implemented by Toledo Edison Company Nuclear Quality Assurance Manual and Nuclear Quality Assurance Procedures, requires activities
.affecting quality be accomplished in accordance with documented procedures.
From 1976 to 1979 there were 46 PORV lifts for which the loop seal temperature was assumed to be 130*F.
'Dtis violated the acceptance criteria specified in site Procedure PT 5164.03 which limits the number of PORV lifts to 25 times if the loop seal temperature drops
-below 400*F.
This is a Severity Level IV violation (Supplement II).
(50-346/86004-01B)
Response: 1)
Corrective action taken and the results achieved:
Procedure PT5164.03 was reviewed and determined to have incorrectly identified the Power Operated Relief Valve (PORV) acceptance criteria as 25 " lifts" when the loop seal is below 400*F.
As correctly identified in Procedure AD1840.01, Documentation of Allowable Operating Transient Cycles, and the.Teledyne Engineering Services Report TR-6388-2, Appendix G, the acceptance criteria should have been listed as either 25 " design cycles" or " analysis blowdowns".
Appendix G of the Teledyne Report indicates that based on a review of the PORV operating history only 21 PORV analysis blowdowns out of an allowable 25 analysis blowdowns have occurred to date. The reason for the difference between the 46 lifts and the 21 analysis blowdowns is described in Appendix G as follows:
"When the time between lifts is short (seconds and minutes) compared to the thermal response time of the piping, multiple
' analysis' blowdowns are not appropriate since the full range of stress cycles are not developed....once the loop seal blows down it will be ' cleared' from the PORV lina and it will take a comparatively long time to reform (possibly as much as a day). Therefore, for an initial blowdown followed quickly by other blowdowns:
the first lift (or blowdown) will have thermal transient stresses associated with it while subsequent blowdowns will be steam blowdowns, i.e. with no thermal transient stresses."
- Dockst Ns. 50-346 License No. NPF-3 Serial No. 1-639 June 9, 1986 Page 4 (2) Corrective action taken to avoid further violations:
Toledo Edison believes that we were correctly tracking the situation and that the procedure was misleading due to the incorrect word choice. Procedure PT5164.03, Pressurizer Relief Valve Heat Trace Test, has been deleted due to the installation of a drain upstream of the PORV under Facility
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Change Request (FCR)85-160. The documentation of the number of PORV design cycles will continue to be maintained by Procedure AD1840.01 and updates to the Teledyne Analysis as necessary.
(3) The date when full compliance will be achieved:
Full compliance was achieved with the deletion of Procedure PT5164.03 on February 12, 1986.
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Docket No. 50-346 License No. NPF-3 Serial No. 1-639 June 9, 1986 Page 5 Violation:
10 CFR Part 50, Appendix B, Criterion XVI, as implemented by Toledo Edison Company Nuclear Quality Assurance Manual and Nuclear Quality Assurance Procedures, requires that measures be established to assure that conditions adverse to quality such as deficiencies, deviations, defective material and equipment, and nonconformances, are promptly identified and corrected.
In the case of a significant condition adverse to quality, the measures must assure that the condition is determined and that corrective action is taken to preclude repetition.
Engineering Services Technical Report (TES) TR-5639-2,
" Davis-Besse Analysis and Evaluation of the Safety / Relief Valve Discharge System per NRC NUREG-0737, " Revision 0, dated January 1983 specifies that the heat trace temperature for the pilot operated relief valve (PORV) loop seal be maintained at 500*F.
Contrary to the above, site Procedure PT 5164.03 was not revised to reflect the 500*F temperature specified in TES TR-5639-2 and no attempt was made to inspect and evaluate the condition of the piping and supports.
This is a Severity Level IV violation (Supplement II).
(50-346/86004-03)
Response: 1)
Corrective actions taken and the results achieved:
i Following the June 9, 1985 event, Maintenance Work Order (MWO) 1-85-2498-00 was initiated to conduct an inspection l-for gross damage of pipe supports on the Power Operated l
Relief Valve (PORV) discharge line (8"-GCC-8). This inspection j
identified no obvious damage.
In addition, this MWO along i
with MWO 1-85-3583-00 required nondestructive examination of the piping field welds in accordance with the original inspection requirements. These examinations also resulted l
in no indications being identified.
Most recently, in response to the requirements of Confirmatory Action Letter (CAL) 85-13, Toledo Edison conducted a very detailed inspection of the entire PORV discharge line.
Quality Control (QC) personnel identified several potentially significant nonconformances as well as some minor items.
The significant conditions were reported in LER 85-019.
All nonconformances which were identified have been dispositioned and any required rework will be completed prior to Restart in order to restore the system to original FSAR commitments.
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Dockst No. 50-346 License No. NPF-3 Serial No. 1-639
= June 9, 1986 Page 6 Due to the difficulty of maintaining the 500*F minimum PORV loop seal heat trace temperature, Toledo Edison has installed a drain line upstream of the PORV. Facility Change Request (FCR)85-160 will be implemented prior to restart to eliminate the accumulation of water in the loop seal and the high loading experienced by the discharge line when the PORV is discharged. This FCR.will preclude the requirement for heat tracing the discharge line.
In order to determine if any similar problems exist in other piping systems, Toledo Edison has requested Bechtel to conduct a documented review of piping stress analyses (performed by Bechtel and any other vendors who performed analysis for them) and identify operational restraints imposed by the system designs, such as fatigue usage or similar restraints. Toledo Edison will then verify that those operational restraints which are identified have been appropriately incorporated in the plant procedures. The review of piping stress analyses by Bechtel is currently scheduled for completion by June 30, 1986. Completion of Toledo Edison's verification is expected within 30 days after Bechtel completes their review.
2)
Corrective actions to be taken to avoid further violation The apparent root cause of this condition was determined to be a failure to review and incorporate appropriate design information into plant procedures due to inadequate techneial rev :.w of the assumptions and results of the discharge piping stress analysis performed by Teledyne.
As described in the Davis-Besse Course of Action (Serial No. 1182), Toledo Edison is greatly strengthening the in-house engineering capability to ensure adequate technical review of all work. In the meantime, adequate engineering capability is being provided by seconded contractor personnel to augment Toledo Edison personnel.
Over the longer term, these seconded positions will be filled by permanent Toledo Edison personnel.
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Dock 2t No. 50-346 License No. NPF-3 Serial No.-1-639 June 9, 1986 Page 7
- 3) ~ ~ Date when full compliance will be achieved:
Full compliance will be achieved upon the completion of the Toledo Edison verification of Bechtel's review of operational restraints which is currently scheduled for July 30, 1986.
Very truly yours, g _~ ' ~. _
- TJB:plf f
cc: DB-1 NRC Resident Inspector 4
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