ML20247K139
| ML20247K139 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 05/19/1989 |
| From: | Shelton D TOLEDO EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8906010226 | |
| Download: ML20247K139 (4) | |
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i A Canum Ensw Company FILE DONALD C. SHELTON Vu.e Presdent -Nuclear (419) P49-2300 l
May 19, 1989 Mr.
A.'B.
Davis, Regional Administrator U. S. Nuclear Regulatory Commission Region III l
~'l 799 Roocevelt Road
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Glen Ellyn, IL 60137 r
Dear Bert j
i Af ter our meeting of May 1,1989, I had members of my staf f follow up on the items we discussed concerning the rating that Davis Besse received in the Radiological Controls area.
i Specifically, I had them compare the SALP 7 Report to the SALP 6 Report and address each apparent weakness identified h
in the SALP 7 Report.
The results, which are attached, l
indicate that changes in this area cince SALP 6 have been l
in the direction of. improvement rather than decline.
\\
Sincerely, i
i DCS/dm 4,
.- 1
.1 Attachment 1
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TOLEDO EDISON COMMENTS ON SPECIFIC STATEMENTS MADE IN THE SALP 7 REPORT CONCERNING THE RADIOLOGICAL CONTROLS FUNCTIONAL AREA Excerpt From Section II.A, page 3:
" Radiological Controls decreased from Category 1 to Category 2.
This decrease was exemplified by:
failure to fully implement a post-accident sampling system; higher than normal (for Davis-Besse) yearly doses; and frequent inoperability of effluent monitors."
TE Comments This statement is not supported by the analysis provided for the Radiological Controls functional area.
For example, TE implemented a post-accident sampling system to meet NUREG-0737 requirements during the 4th Refueling Ootage. The actual concern was the timeliness of implementing modifications to enhance rather than complete the system.
Excerpt From Section III.B.1, page 11:
"Three events which attributed to eetivities in this functisnal area required the submittal of LERs during this essessment period; each had a different causal factor."
TE Comments Follow up discussion with the Davis-Besse's Senior Resident Inspector indicated that LERs are categorized to a specific functional area based on cause. An independent review performed by TE using this philosophy indicates one LER could be attributed to activities in this functional area.
- However, the assignment of this LER [(LER 88-006, Software Problems with Kaman Radiation honitor (10CFR21)] was attributable to a design deficiency identified by the vendor, over which TE had no control, and is therefore unrelated to evaluation of the licensee's performance in the radiological controls area.
Excerpt From Section III.B.1, page 11:
" Staffing in this functional area was ample.
No significant adverse long-term affects appear to have resulted from the major staffing and organization chnnges discussed in the previous SALP report."
TE Comments Major staffing and organizational changes were made in 1987 in response to recommendations from INPO and General Dynamics (independent audit) to bring the organizational structure in line with the rest of the industry. The SALP report is worded in such a way that one would believe the NRC expected the organizational and staffing changes to have a negative rather than positive effect on this area.
As expected, these changes have resulted in an Improvement in the overall control of activities conducted in this functional 3 gg area.
~
Excerpt From Section III.B.1, page 11:
" Management involvement in assuring quality was generally good with some exceptions.
....However, the licensee's management controls with regard to effluent monitors were weak. The effluent monitors were frequently inoperable due in part to unreliable equipment, poorly defined and understood interdepartmental interactions, and failure to aggressively pursue and resolve problems identified with the radiation monitoring system."
TE Comments TE reviewed Maintenance Work Orders (MV0s) performed during the SALP 7 period to ascertain the validity of this statement.
Frequent maintenance was performed on effluent monitoring equipment.
Notwithstanding this level of c~entenance, the effluent monitors (19) on the average were available 97% of 6:e time compared to about 93% during SALP 6.
The operability of associated non Tech Spec strip charts was 74% during SALP 7 compared to 78% during SALP 6.
The effluent monitors had less availability during the SALP 6 period than SALP 7 yet there were no related concerns noted in the SALP 6 report.
Excerpt From Section III.B.1, page 11:
"The licensee's responsiveness to NRC initiatives has generally been good with the exctption of slow progress regarding needed modifications to the post accident noble gas high range detector system."
TE Comments The "needed" modifications mentioned in the SALP report were two enhancements which evolved from NUREG 0737 Task Items.
Neither modification, tracked as an NRC Open Item, was an actual NRC requirement. Toledo Edison's response to these open items indicated that modifications would be made to snhance the Kaman rediation monitoring system. One of these modifications enhanced the noble gas monitor's response to high energy short-lived isotopes that would occur post accident.
(Note: Actions taken in the interim were more conservative and would have resulted in higher estimates of activity.) The other modification re-routed the station vent sample line.
The need to 1.
re-route this sample line had previously been in question and referred to NRR for resolution.
Since the decision made to proceed with implementation removed the need for NRR resolution, it was not pursued further by TE.
The FCR for these modifications, which was initiated in October 1986, was
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initially approved through the D-B Vork Scope Committee in April 1987 to be worked during Cycle 5.
In October 1987 the Work Scope Committee deferred this FCR to Cycle 6.
This deferral was necessary to allow the performance of higher priority work. An attempt was made to re-prioritize the modification so that it could be worked in Cycle 5 in late 1037 but other more J
safety significant work took precedence.
The 5th Refueling Ontage was extended approximately three months, which served to further defer implementation of the modifications.
Problems encountered during implementation with vendor supplied equipment further delayed completion. The modifications had significantly less priority from a safety standpoint than j
the majority of modifications performed since 1985.
Both modifications are
i now complete. The above demonstrates. management's active involvement in the resolution of these concerns.
J I
Excerpt From Section III.B.1, page 12:
" Total station dose for 1988 was about 308 person-rem, significa.itly above the 1986 total dose of 124 person-rem and 47 person-rem in 1987. The total dose, l
1 vhich resulted from an e % c:h' extended outage and unplanned work on high pressure injection nozzle:
.uned well below the average for pressurized water reactors (PVRs).
l TE Comments As noted in Davis-Besse's SALP 7 report, the total station dose of 308 person-rem was well below the average for pressurized water reactors (PWRs) that experience two to three months of outage per year. This was accomplished even though Davis-Besse was in a refueling and modification outage for 9 months and unplanned work on the high pressure injection (HPI) nozzles was required. Therefore, a numerical cemparison of the total station dose for 1988 to previous years without regard to the scope of work and estimated dose for that work is not valid for purposes of performance evaluation.
Excerpt From Section III.B.1, page 17:
"Although total volume of solid radioactive vaste is relatively low, it is higher than what would be expected by current industry standards."
TE Comments Davis-Besse's total volume of 172.8 cubic meters during 1988 was slightly above the industry average for PVRs of 169 cubic meters. This was accomplished even though Davis-Besse was in an extended outage for nine months and unplanned work on the HPI nozzles was required.
A numerical comparison to previous years at Davis-Besse or to other plants without regard to the scope of work is not valid fo* the purposes of performance evaluation.
(Note:
Davis-Besse total voluacs
- r 1986 and 1987 vere 141.5 cubic meters and 84.8 cubic meters, respectively.
Industry average for these years were 211 cubic meters and 194 cubic meters, respective 1').
J
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