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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217P2061999-10-26026 October 1999 Forwards for First Energy Nuclear Operating Co Insp Rept 50-346/99-17 on 990928-1001.Insp Was Exam of Activities Conducted Under License Re Implementation of Physical Security Program.No Violations Identified ML20217N3851999-10-20020 October 1999 Forwards RAI Re Licensee 990521 Request for License Amend to Allow Irradiated Fuel to Be Stored in Cask Pit at Davis-Besse,Unit 1.Response Requested within 60 Days from Receipt of Ltr ML20217N2321999-10-15015 October 1999 Requests NRC Approval to Use Alternative to Requirements of 10CFR50.55a(f)(4)(ii).Licensee Requests Extension to Specified Schedule for Implementing Updates to IST Program ML20217G9201999-10-14014 October 1999 Discusses Utils Request for Approval of Quality Assurance Program Changes PY-CEI-NRR-2438, Informs That DBNPS & Pnpp Staffs Have Modified or Withdrawn Several of Positions Proposed within Re Request for Approval of Qap.Revised Positions Encl1999-10-14014 October 1999 Informs That DBNPS & Pnpp Staffs Have Modified or Withdrawn Several of Positions Proposed within Re Request for Approval of Qap.Revised Positions Encl ML20217F8371999-10-0808 October 1999 Forwards Insp Rept 50-346/99-10 on 990802-0913.One Violation Occurred Being Treated as NCV ML20217A5641999-09-30030 September 1999 Informs of Completion of mid-cycle PPR of Davis-Besse on 990901.Informs That NRC Plans to Conduct Addl Insps to Address Questions Raised by Issues Re Operator Errors & Failure to Commit to JOG Topical Rept on MOV Verification ML20212L0691999-09-30030 September 1999 Forwards,For Review & Comment,Copy of Preliminary ASP Analysis of Operational Condition Discovered at Unit 1 on 981014,as Reported in LER 346/98-011 ML20216J6701999-09-24024 September 1999 Forwards Post Examination Documentation for Written Operator Initial License Examination Administered at Davis-Besse Nuclear Power Station on 990920.Without Encls ML20212D3501999-09-21021 September 1999 Forward Copy of Final Accident Sequence Precursor Analysis of Operational Event at Plant,Unit 1 on 980624,reported in LER 346/98-006 05000346/LER-1998-001, Forwards Rev 1 for LER 1998-001,which Updates Corrective Actions & Revises Completion Date Re Implementation of Changes to Plant Emergency Operating Procedure.List of Commitments Attached1999-09-0909 September 1999 Forwards Rev 1 for LER 1998-001,which Updates Corrective Actions & Revises Completion Date Re Implementation of Changes to Plant Emergency Operating Procedure.List of Commitments Attached ML20216E5961999-09-0707 September 1999 Forwards Application for Amend to License NPF-3,revising Tech Specs 3/4.3.2.1,safety Features Actuation Sys Instrumentation & Associated Bases 3/4.3.1 & 3/4.3.2,reactor Protection Sys & Safety Sys Instrumentation ML20211P3001999-09-0707 September 1999 Forwards FEMA Transmitting FEMA Evaluation Rept for 990504 Emergency Preparedness Exercise at Davis-Besse Nuclear Power Plant.No Deficiencies Identified.One Area Requiring C/A & Two Planning Issues Identified ML20211K6681999-08-30030 August 1999 Forwards Copies of Certified Personal Qualification Statement - Licensee (NRC Form 398) for Operator Candidates Listed Below.Without Encls ML20211K6611999-08-30030 August 1999 Forwards Copies of Operator License Renewal Applications for Individuals Listed.Operators Have Successfully Completed Appropriate Operator Requalification Training Program at Dbnps.Without Encls ML20211K0951999-08-30030 August 1999 Forwards Request for Addl Info Re Fire & Seismic Analyses of IPEEE for Davis-Besse Nuclear Power Station,Unit 1. Response Requested within 60 Days ML20211H0201999-08-25025 August 1999 Forwards semi-annual FFD Rept for 990101-0630 for DBNPS, Unit 1,IAW 10CFR26.71(d) ML20211D1171999-08-20020 August 1999 Forwards Insp Rept 50-346/99-09 on 990623-0802.Violations Identified & Being Treated as Noncited Violations ML20211G3911999-08-20020 August 1999 Forwards Update to Estimated Info for Licensing Action Requests Through 010930,re Administrative Ltr 99-02, Operating Reactor Licensing Action Estimates PY-CEI-NRR-2411, Informs That Firstenergy Nuclear Operating Co Has Developed Corporate QA Program Manual for Davis-Besse Nuclear Power Station & Perry Nuclear Power Plant,As Discussed on 990318 Between Util & Nrc.Revised USAR Pages,Encl1999-08-19019 August 1999 Informs That Firstenergy Nuclear Operating Co Has Developed Corporate QA Program Manual for Davis-Besse Nuclear Power Station & Perry Nuclear Power Plant,As Discussed on 990318 Between Util & Nrc.Revised USAR Pages,Encl ML20211J9201999-08-13013 August 1999 Urges NRC to Find Funds for Stockpiling Radiation Pills for Residents Living Near Plant ML20211B0161999-08-13013 August 1999 Forwards SE Accepting Evaluation of Second 10-year Interval Inservice Insp Program Request for Relief Numbers RR-A16, RR-A17 & RR-B9 for Plant,Unit 1 ML20210T1061999-08-12012 August 1999 Forwards Preliminary NRC Forms 398 & 396 for Listed Candidates,Per Operator License Exam Scheduled for Week of 990913.Encl Withheld ML20210S6071999-08-11011 August 1999 Provides Final Response to NRC RAI Re GL 98-01, Y2K Readiness of Computer Systems at Npps ML20210P8051999-08-0909 August 1999 Forwards Insp Rept 50-346/99-15 on 990712-16.No Violations Noted.However,Several Deficiencies Were Identified with Implementation of Remp,Which Collectively Indicated Need for Improved Oversight of Program IR 05000346/19980211999-08-0606 August 1999 Refers to NRC Insp Rept 50-346/98-21 Conducted on 980901- 990513 & Forwards Nov.Two Violations Identified Involving Failure to Maintain Design of Valve & Inadequate C/A for Degraded Condition Cited in Encl NOV 05000346/LER-1998-009, Forwards LER 98-009-01,IAW 10CFR50.73(a)(2)(ii)(B). Commitments Made by Util Are Encl1999-08-0606 August 1999 Forwards LER 98-009-01,IAW 10CFR50.73(a)(2)(ii)(B). Commitments Made by Util Are Encl ML20210H6101999-07-30030 July 1999 Informs That Region III Received Rev 21 to Various Portions of Davis-Besse Nuclear Power Station Emergency Plan.Revision Was Submitted Under Provisions of 10CFR50.54(q) in Apr 1999 ML20210H0491999-07-28028 July 1999 Forwards Application for Amend to License NPF-3,revising TS 3/4.7.5.1, Ultimate Heat Sink, to Allow Plant Operation in Modes 1-4 with Water Temp Less than or Equal to 90 F ML20210G5521999-07-28028 July 1999 Provides Addl Response to 980923 OL Licensing Exam Rept 50-346/98-301 Re OL Exam Administered in Aug 1998.Results of Root Cause Investigation & Corrective Actions,Discussed ML20210G3831999-07-27027 July 1999 Forwards Application for Amend to NPF-3,changing TSs 6.4, Training, 6.5.2.8, Audits, 6.10, Record Retention, 6.14, Process Control Program & 6.15, Odcm ML20211P3071999-07-26026 July 1999 Forwards Final Rept for 990504 Biennial Radiological Emergency Preparedness Exercise for David-Besse Power Station.No Deficiencies Identified for Any Jurisdiction During Exercise ML20210G4391999-07-26026 July 1999 Forwards Application for Amend to License NPF-3,revising Tech Specs 3/4.3.2.1, Safety Features Actuation Sys Instrumentation, & Associated Bases 3/4.3.1 & 3/4.3.2, Reactor Protection Sys & Safety Sys Instrumentation ML20210G7151999-07-26026 July 1999 Forwards Application for Amend to License NPF-3,revising TSs 3/4.3.3.1, Radiation Monitoring Instrumentation, 3/4.3.3.2, Instrument - Incore Detectors & 3/4.3.3.9, Instrumentation - Waste Gas Sys Oxygen Monitor ML20210G5151999-07-26026 July 1999 Forwards Application for Amend to License NPF-3,revising Tech Specs for Implementation of 10CFR50,App J,Option B for Type B & C Containment Leakage Rate Testing ML20210G3211999-07-26026 July 1999 Forwards Written OL Exam & Supporting Matl for Exam to Be Administered at DBNPS During Week of 990913.Listed Encls Withheld from Public Disclosure Until After Exam Complete ML20210C4381999-07-20020 July 1999 Forwards Insp Rept 50-346/99-08 on 990513-0622.Unidentified RCS Leak Approached TS Limit of 1 Gallon Per Minute Prior to Recently Completed Maint Outage.Three Violations of NRC Requirements Identified & Being Treated as NCVs ML20209G3681999-07-15015 July 1999 Advises That Info Submitted in & 990519 Affidavit Re Design & Licensing Rept,Davis-Besse,Unit 1 Cask Pit Rack Installation Project,Holtec Intl, HI-981933,marked Proprietary,Will Be Withheld from Public Disclosure ML20207H6401999-07-0909 July 1999 Discusses Closure of TAC MA0540 Re Util Responses to RAI on GL 92-01,rev 1,suppl 1, Rv Structural Integrity. Staff Has Revised Info in Rvid & Releasing It as Rvid Version 2 ML20209D1341999-07-0808 July 1999 Forwards Notice of Withdrawal of Application for Amend to Operating License.Proposed Change Would Have Modified Facility TSs Pertaining to Allowable as-found Pressure Lift Setting Tolerance of Two Pressurizer Code Safety Valves 05000346/LER-1998-012, Forwards LER 98-012-01,which Is Being Submitted to Provide Addl Info Re 981018 Occurrence.Commitment List Attached1999-07-0707 July 1999 Forwards LER 98-012-01,which Is Being Submitted to Provide Addl Info Re 981018 Occurrence.Commitment List Attached ML20209C3981999-07-0101 July 1999 Responds to NRC Re Violations Noted in Insp Rept 50-346/98-21.Corrective Actions:Developed Rev to Boric Acid Control Program & Work Process Guideline on Plant Leakage ML20209B5821999-06-24024 June 1999 Provides Justification for Rev to Completion Date for One of Insp follow-up Items Cited in Insp Rept 50-346/98-03, Designated as Inspector follow-up Item 50-346/97-201-10 ML20196G1251999-06-23023 June 1999 Responds to NRC RAI Re GL 98-01, Y2K Readiness of Computer Sys at Nuclear Power Plants ML20196E5321999-06-17017 June 1999 Forwards Addl Info Re Relief Request RR-A16 to Support NRC Approval of Relief Request ML20195K2751999-06-16016 June 1999 Forwards Safety Evaluation Re GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves ML20196A6601999-06-16016 June 1999 Forwards Master Decommissioning Trust Agreements Revised After 1990 for Ohio Edison Co,Cleveland Electric Illuminating Co,Toledo Edison Co & Pennsylvania Power Co Re Bvnps,Units 1 & 2,DBNPS,Unit 1 & Perry Unit 1 ML20195F9071999-06-10010 June 1999 Forwards Application for Amend to NPF-3,changing Tech Specs 3/4.6.4.4, Hydrogen Purge Sys, TS 3/4.6.5.1, Shield Bldg Emergency Ventilation Sys & TS 3/4.7.6.1, Crevs ML20195F8851999-06-0707 June 1999 Withdraws 950929 License Amend Application,Proposing Mod to Allowable as-found Pressure Lift Setting Tolerance of Two Pressurizer Code Safety Valves ML20207G0751999-06-0707 June 1999 Forwards Insp Rept 50-346/99-04 on 990323-0513.Violations Occurred & Being Treated as non-cited Violations,Consistent with App C of Enforcement Policy 1999-09-09
[Table view] Category:NRC TO ENGINEERING/CONSTRUCTION/CONSULTING FIRM
MONTHYEARML20235B2661987-07-0101 July 1987 Final Response to FOIA Request for Documents Re Tech Specs. Forwards App B Documents.App a & B Documents Also Available in PDR ML20213H1481987-05-14014 May 1987 Partial Response to FOIA Request for Documents Re USI A-46, Seismic Qualification of Equipment in Operating Plants. Forwards App B Documents.App a & B Documents Available in PDR IA-86-836, Final Response to FOIA Request for SECY-86-226.Forwards App a Document.App a Document Also Available in PDR1987-01-14014 January 1987 Final Response to FOIA Request for SECY-86-226.Forwards App a Document.App a Document Also Available in PDR ML20207P3061987-01-14014 January 1987 Final Response to FOIA Request for SECY-86-226.Forwards App a Document.App a Document Also Available in PDR ML20210L0841986-04-0101 April 1986 Responds to FOIA Request That Two Documents Re Davis Besse Event Be Placed in Pdr.Forwards App Document.Document Also Available in PDR 1987-07-01
[Table view] Category:OUTGOING CORRESPONDENCE
MONTHYEARML20217P2061999-10-26026 October 1999 Forwards for First Energy Nuclear Operating Co Insp Rept 50-346/99-17 on 990928-1001.Insp Was Exam of Activities Conducted Under License Re Implementation of Physical Security Program.No Violations Identified ML20217N3851999-10-20020 October 1999 Forwards RAI Re Licensee 990521 Request for License Amend to Allow Irradiated Fuel to Be Stored in Cask Pit at Davis-Besse,Unit 1.Response Requested within 60 Days from Receipt of Ltr ML20217G9201999-10-14014 October 1999 Discusses Utils Request for Approval of Quality Assurance Program Changes ML20217F8371999-10-0808 October 1999 Forwards Insp Rept 50-346/99-10 on 990802-0913.One Violation Occurred Being Treated as NCV ML20217A5641999-09-30030 September 1999 Informs of Completion of mid-cycle PPR of Davis-Besse on 990901.Informs That NRC Plans to Conduct Addl Insps to Address Questions Raised by Issues Re Operator Errors & Failure to Commit to JOG Topical Rept on MOV Verification ML20212L0691999-09-30030 September 1999 Forwards,For Review & Comment,Copy of Preliminary ASP Analysis of Operational Condition Discovered at Unit 1 on 981014,as Reported in LER 346/98-011 ML20212D3501999-09-21021 September 1999 Forward Copy of Final Accident Sequence Precursor Analysis of Operational Event at Plant,Unit 1 on 980624,reported in LER 346/98-006 ML20211P3001999-09-0707 September 1999 Forwards FEMA Transmitting FEMA Evaluation Rept for 990504 Emergency Preparedness Exercise at Davis-Besse Nuclear Power Plant.No Deficiencies Identified.One Area Requiring C/A & Two Planning Issues Identified ML20211K0951999-08-30030 August 1999 Forwards Request for Addl Info Re Fire & Seismic Analyses of IPEEE for Davis-Besse Nuclear Power Station,Unit 1. Response Requested within 60 Days ML20211D1171999-08-20020 August 1999 Forwards Insp Rept 50-346/99-09 on 990623-0802.Violations Identified & Being Treated as Noncited Violations ML20211B0161999-08-13013 August 1999 Forwards SE Accepting Evaluation of Second 10-year Interval Inservice Insp Program Request for Relief Numbers RR-A16, RR-A17 & RR-B9 for Plant,Unit 1 ML20210P8051999-08-0909 August 1999 Forwards Insp Rept 50-346/99-15 on 990712-16.No Violations Noted.However,Several Deficiencies Were Identified with Implementation of Remp,Which Collectively Indicated Need for Improved Oversight of Program IR 05000346/19980211999-08-0606 August 1999 Refers to NRC Insp Rept 50-346/98-21 Conducted on 980901- 990513 & Forwards Nov.Two Violations Identified Involving Failure to Maintain Design of Valve & Inadequate C/A for Degraded Condition Cited in Encl NOV ML20210H6101999-07-30030 July 1999 Informs That Region III Received Rev 21 to Various Portions of Davis-Besse Nuclear Power Station Emergency Plan.Revision Was Submitted Under Provisions of 10CFR50.54(q) in Apr 1999 ML20210C4381999-07-20020 July 1999 Forwards Insp Rept 50-346/99-08 on 990513-0622.Unidentified RCS Leak Approached TS Limit of 1 Gallon Per Minute Prior to Recently Completed Maint Outage.Three Violations of NRC Requirements Identified & Being Treated as NCVs ML20209G3681999-07-15015 July 1999 Advises That Info Submitted in & 990519 Affidavit Re Design & Licensing Rept,Davis-Besse,Unit 1 Cask Pit Rack Installation Project,Holtec Intl, HI-981933,marked Proprietary,Will Be Withheld from Public Disclosure ML20207H6401999-07-0909 July 1999 Discusses Closure of TAC MA0540 Re Util Responses to RAI on GL 92-01,rev 1,suppl 1, Rv Structural Integrity. Staff Has Revised Info in Rvid & Releasing It as Rvid Version 2 ML20209D1341999-07-0808 July 1999 Forwards Notice of Withdrawal of Application for Amend to Operating License.Proposed Change Would Have Modified Facility TSs Pertaining to Allowable as-found Pressure Lift Setting Tolerance of Two Pressurizer Code Safety Valves ML20195K2751999-06-16016 June 1999 Forwards Safety Evaluation Re GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves ML20207G0751999-06-0707 June 1999 Forwards Insp Rept 50-346/99-04 on 990323-0513.Violations Occurred & Being Treated as non-cited Violations,Consistent with App C of Enforcement Policy ML20207G0621999-06-0404 June 1999 Forwards Insp Rept 50-346/98-21 on 980901-1201 & 990425-0513.Violations Identified & Licensee Being Provided Opportunity to Either Respond to Violations within 30 Days or Inform NRC That LER Rept Already Contain Info Requested ML20207B8161999-05-25025 May 1999 Confirms Discussion Between Members of Staffs to Have Mgt Meeting on 990608 in Oak Harbor,Oh to Discuss Recent Performance at Davis-Besse as Described in Plant Performance Review ML20207B3141999-05-24024 May 1999 Informs That in September 1998,Region III Received Revision 20 to Various Portions of Davis-Besse Nuclear Power Station Emergency Plan.Rev Submitted Under Provisions of 10CFR50.54(q) ML20206T0881999-05-18018 May 1999 Confirms 990517 Telcon Between Lindsey & M Bielby Re Arrangements Made for Administration of Licensing Exam at Facility for Week of 990913 ML20206N5311999-05-11011 May 1999 Informs That NRC Office of Nuclear Reactor Regulation Reorganized Effective 990328.As Part of Reorganization,Div of Licensing Project Mgt Created.Aj Mendiola Will Be Section Chief for Davis-Besse Npp.Organization Chart Encl ML20206H2291999-05-0707 May 1999 Forwards Proposed Change to Plant,Unit 1,TS Bases Section 2.2.1, Limiting Safety Sys Settings - Reactor Protection Sys Instrumentation Setpoints - Rc Pressure - Low,High & Pressure Temp ML20206B8171999-04-27027 April 1999 Forwards Insp Rept 50-346/99-05 on 990405-09.No Violations Noted.Purpose of Insp Was to Examine on-line Maint Risk Assessment Program Recently Implemented in Response to Maint Work Control Weaknesses ML20205G5681999-03-26026 March 1999 Advises of Completion of Plant Performance Review on 990202 to Develop Integrated Understanding of Safety Performance. Overall Performance of Plant Acceptable.Plant Issues Matrix & Insp Plan Encl ML20207G1701999-03-0505 March 1999 Forwards Insp Rept 50-346/99-01 on 990102-0212.No Violations Noted ML20207D4351999-02-25025 February 1999 Forwards Insp Rept 50-346/99-02 on 990202-05.No Violations Noted.Examples of Deficiencies with Station Procedures, Similar to Those Identified Through Staff self-assessments & in Previous NRC Insps,Were Noted IR 05000346/19960141999-02-17017 February 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-346/96-14 on 970225.Ack That Due to Plant Events,There Has Been Delay in Completion of C/As for Violation 50-346/96-14c ML20203F2541999-02-10010 February 1999 Informs That Beginning 990216,DE Hills Will Be Chief of Operations Branch Which Includes Operator Licensing Function ML20206S0811999-01-22022 January 1999 Forwards Insp Rept 50-346/98-18 on 981110-990102.No Violations Identified.Conduct of Activities at Davis-Besse Generally Characterized by Conservative Plant Operations, & Effective Engineering Involvement in Plant Issues ML20199H5821999-01-20020 January 1999 Forwards SE Re Ampacity Derating Issues Due to Application of Thermo-Lag Fire Barrier Matl at Plant ML20198E6821998-12-17017 December 1998 Forwards Insp Rept 50-346/98-20 on 981116-20.No Violations Noted.Implementation of Licensed Operator Requalification Program Was Generally Characterized by Safety Conscious Operations & Sound Evaluation of Operator Performance ML20198C9881998-12-15015 December 1998 Informs That as Part of NRC PRA Implementation Plan, Commission Assigned Two SRAs to Each Regional Ofc.Sras Will Routinely Assess Licensee Event Repts,Plant Event,Insp Findings & EAs from Risk Perspective ML20198B5391998-12-0909 December 1998 Forwards Insp Rept 50-346/98-17 on 980918-1109 & NOV Re Inadequate Maint Work Order Used by Electrician During Removal of Primary Water Storage Tank Temp Indicator ML20196G1621998-12-0303 December 1998 Submits Response to Request for TS Interpretation Re Surveillance Interval Extension Allowances ML20196H4411998-12-0303 December 1998 Confirms Plans to Hold Meeting on 981216 in Lisle,Il,To Discuss Recent Performance at Davis-Besse & Actions Being Implemented by Licensee ML20198B1511998-12-0202 December 1998 Forwards Insp Activity Plan for Next 6 Months & Plant Issues Matrix.Infor Provided to Minimize Resource Impact on Staff & to Allow for Scheduling Conflicts & Personnel Availability to Be Resolved in Advance of Inspector Arrival Onsite ML20196J5111998-12-0101 December 1998 Fowards Year 2000 Readiness Audit Rept,Which Documents Results of NRR Audit Conducted at Facility from 981027-29 ML20196D4371998-11-25025 November 1998 Discusses Concerns Re Announced Asset Transfer Between Firstenergy Corp & Duquesne Light Co ML20196C6491998-11-20020 November 1998 Forwards Insp Rept 50-346/98-19 on 981014-23.No Violations Noted.Inspectors Reviewed Circumstances Surrounding Events Leading Up to & Following Reactor Trip IR 05000346/19983011998-11-0909 November 1998 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-346/98-301OL Issued on 980923.Effectiveness of C/A Will Be Reviewed Following Submittal of Root Cause Investigation Results ML20155J1471998-11-0303 November 1998 Informs That on 981007,NRC Administered GFE Section of Written Operator Licensing Exam to Employees of Facility. Exam Answer Key for Forms a & B,Grading Results & Individual Answer Sheets Encl.Without Encl ML20155B6641998-10-28028 October 1998 Forwards Safety Evaluation Re Request for Reduction in Commitment Changes in QA Program Matl Receipt Insp Process ML20154Q6711998-10-16016 October 1998 Forwards Insp Rept 50-346/98-15 on 980914-18.No Violations Noted.Emergency Preparedness Program Effectively Implemented During 980624 Tornado Event & Station Personnel Responded Well to Event ML20154Q5891998-10-14014 October 1998 Forwards Insp Rept 50-346/98-14 on 980808-0918.No Violations Noted.Online Safety Equipment Outages Were Performed Well & IAW Established Procedures ML20154H0241998-10-0606 October 1998 Discusses Arrangements Made During 980924 Telcon for Insp of Licensed Operator Requalification Program at Davis Besse Nuclear Power Station During Wk of 981116 ML20154D1801998-09-30030 September 1998 Forwards Insp Rept 50-346/98-16 on 980831-0904.No Violations Noted 1999-09-07
[Table view] |
Text
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- ) s,( g NUCLEAR REGULATORY COMMISSION 5,,* .
- j WASHINGTON, D. C. 20555 e...<
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Mr. Lyle Graber Licensing Engineer Licensing Information Service NUS Corporation 2536 Countryside Boulevard IN RESPONSE REFER Clearwater, FL 33575-2094 TO F01A-86-125
Dear Mr. Graber:
This is in response to your letter dated March 3,1986, in which you requested, pursuant to the Freedom of Information Act (F0IA), that two specified documents be placed in the Public Document Room (PDR).
The enclosed appendix identifies a document which is being made available for your inspection and copying at the PDR. The document will be filed in PDR folder F01A-86-125 under your name.
We have been informed by the staff that they have been unable to locate c July 24, 1985, memorandum from H. Denton to W. Dircks on the Davis-Besse event.
Sincerely,
/hw,<- // $ by Donnie H. Grimsley, Director Division of Rules and Records Office of Administration
Enclosure:
As stated l
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1 8604290170 860401 PDR FOIA GRABERB6-125 PDR
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Re: F01A-86-125 4
, APPENDIX ,
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1/ :11/26/85 Memorandum for Hirold R. Denton et.- al. from William J.
Dircks Re: Davis-Besse Event - NRC Lessons Learned .,
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Ti i MEMORANDUM FOR: Harold R. Denton, Director, NRR James M. Taylor, Director, IE Robert B. Minogue, Director, RE5 John G. Davis, Director, NMSS Clemens J. Heltemes, Director, AE00.
Thomas E. Murley, Regional Administrator, Region-I J. Nelson Grace, Regional Administrator, Region-II James G. Keppler, Regional Administrator, Region-III Robert D. Martin, Regional Administrator, Region-IV John B. Martin, Regional Administrator, Region-V l
FROM: William J. Dircks Executive Director for Operations ,
l
SUBJECT:
DAVIS-BESSE EVENT - NRC LESSONS LEARNED In my August 5,1985 memorandum on staff actions resulting from investigation of the June 9 loss of feedwater event at Davis-Besse, I assigned responsibility for a number of generic and plant-specific actions identified in the report of the NRC investigation of that event (NUREG-1154). I also directed an in-depth and searching reappraisal of NRR, IE, AE0D, RES and Region III programs in the light of the June 9 event. l i
I have reviewed the responses to that memorandum and the action plans that have l been developed by the offices for addressing those assigned actions. I also )
have met subsequently with the program directors to review progress in initiating I and implementing those action plans. I believe that the actions that are already underway or planned by the offices are a good start in addressing 4
immediate needs with respect to the specific action items assigned. I will
- continue to meet with the program directors periodically to review progress toward completion of their initiatives. I have also reviewed carefully the program reappraisals provided by the individual offices, and I believe there is ;
need for further strengthening of our agency programs beyond the improvements l indicated in the program office proposals.
The broad picture that emerges from my review of all the-assessments that have been done to date of the Davis Besse event and its implications, points to the need for improvements in the three major areas indicated below. I believe that the points discussed below reflect the major lessons learned from the Davis Besse event. To the extent that your program improvement plans do not now include explicitly specific measures to address these points, in their final forms the plans will have to be modified to do so.
- 1. More Timely Identification and Completion of Safety Issues Our safety review and inspection programs as currently structured have proven capable of identifying problems in plant design and licensee performance that could adversely affect safety (e.g., the lack of diversity /
reliability in the Davis Besse AFW system design, and the pattern of low /
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_,.de.teriorating SALP ratings for Davis Besse). However, we have not always ,
.3 2 reacted to indications of problems provided by these programs in a way that led to timely correction of the problems identifieda Although program improvements already planned by the offices, as indicated in the responses to my August 5 memorandum, should contribute substantially to correcting this weakness, the aspects of program improvement in this area that need more attention are the establishing of criteria for identifying deterior-ation of plant performance and the tracking of identified issues. Explicit provisions should be made in our improvement plans for development of an
, improved methodology for determining when facilities should be placed on an NRC required " performance improvenunt program." Likewise, we must promptly develop and implement a more-fully integrated tracking system that will maintain accurate status of the complete range of outstanding licensing actions, pending generic issues, and approved backfits that must be dealt ;
with, to better focus management attention on identified problems until necessary action is taken or completed. I have already identified some of the tracking and interoffice coordination problems that need to be addressed more effectively, in a September 5,1985 memorandum to the Directors of NRR and IE on monitoring the completion of generic issues. This beginning must be expanded upon. All offices that have a role in the identification, generation, imposition, or verification of compliance / completion of new requirements by any means share in the responsibility for development and ,
l implementation of the improved issue management system.
An important corollary to the need for keeping NRC management aware of the status of pending issues and approved-but-uncompleted licensing actions is l the need to keep licensees similarly informed. We must be explicit, as well as timely, in communicating to licensees NRC's understanding of the status of pending safety issues or approved licensing actions. This is particularly true in cases where the staff's evaluation and the final NRC decision regarding a licensee's submittal on an important issue extend for an appreciable length of time, as in the case of the Davis-Besse AFW '
system design adequacy question. Extended delay and regulatory silence on the part of NRC in such circumstances can be misinterpreted as implicit of' defacto acceptance by NRC of a position on which the staff is undecided or which the staff n.ight even regard as unacceptable. These points are
, important enough that they need to be addressed explicitly in the program improvement plans.
- 2. Broader Consideration of Positive and Potentially Negative Safety Impacts of Regulatory Actions Our current methods for assessing the safety impacts of changes to plant equipment or procedures, whether proposed by licensees or imposed by NRC, need to be improved to provide a broader and better understanding of both the positive and potentially negative effects of equipment and procedure modifications. The backfit decision which resulted in the installation of the SFRCS at Davis Besse, and other changes such as valving out the feedwater startup pump, resulted in unintended, unanticipated safety effects that contributed to and complicated the June 9 event at that l
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1~ ifacility. This was because the staff safety evaluations involved focused :
too narrowly on some specific safety concern or criterion (.e.g., seismic I qualification or protection against main steam line break) and did not I adequately take into account the other potential ramifications of such !
actions. Another example of focusing too narrowly on an innediate safety i concern or objective (not just in the Davis-Besse context) can be seen in 1 the requirement for cold-fast-start testing of diesel generators. That testing was intended as a means of demonstrating the reliability of the emergency power function on demand under stringent conditions. But, focusing too narrowly on demonstration of that capability (by harmful testing) actually resulted in degrading that capability in a number of operating plants. l l
Increased application of analysis techniques, such as PRA, that are .
specifically designed to provide a more-fully integrated treatment to the l many interrelated aspects of the complex safety issues that arise, can '
contribute significantly to the broader understanding that is needed of l both the positive and potentially negative effects of our regulatory l actions. PRA methods are inherently less likely to recognize artificial distinctions in perceived safety importance between safety-related and j nonsafety-related plant features. Such artificial distinctions reflect !
the more simplistic approach that has been taken in our safety analyses as i reflected in still-existing " deterministic" licensing criteria and i requirements. Clearly, this current approach can be seen to be a fundamental causative factor in a number of instances in the past where an intended fix of one problem has unexpectedly created or led to a more serious problem.
More emphasis needs to be given to increased application of improved analysis methods (specifically PRA) in all aspects of our regulatory 1 activity. Such increased emphasis is necessary not only to provide a I broader perspective in our assessment of the full-impact of any proposed changes in the future, but to pmvide a framework and a viable means for -
determining whether there are other examples, as yet undiscovered or unrecognized, of well intended past regulatory actions that may be having an undesired effect.
- 3. Increased Emphasis on Balance of Plant Equipment The paramount importance of proper maintenance in maintaining levels of l reliability assumed in the safety analyses that form the licensing basis ,
for operating plants has been accorded greater recognition and increased emphasis and attention by both NRC and utility management in the aftennath of the TMI accident. However, it appears from the circumstances noted in the review of the June 9 Davis-Besse event that an inappropriate, artificial distinction (alluded to in 2. above) between the importance of safety-related vs nonsafety-related plant features may have led some licensees to place inadequate emphasis on proper maintenance of all equipment necessary to assure proper facility operations. Some balance-of-plant systems may actually have equal or perhaps greater safety importance (cumulatively) than equipment classified as safety-related
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.), ._4 because their too-frequent failure can needlessly challenge the safety-related systems, and their failure can also aggravate condil. ions under which the safety-related systems must respond. We need to give increased. ,
- attention to assuring that the attention of licensee management is focused !
properly on this important aspect of plant operations and that important balance-of-plant systems and equipment receive adequate attention in the overall maintenance picture. We should also consider seriously, in the context of finalizing our improvement plans, whether this requires signifi-cantly increased connitment of regulatory attention to balance-of-plant areas within our licensing review and inspection programs.
I want to meet with you to discuss further the matter of program improvements.
! I will be scheduling a meeting within the next month or so for that purpose. I would like to receive your written reactions and connents to the above in advance of that meeting. Please provide me with your preliminary views by December 16. I have included in an enclosure to this memorandum some important general points and specific questions that I want you to consider for discus-sion at the upcoming meeting to help decide tl.ose additional internal program improvements which should be implemented.
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(Signed) William J.Dirchs l
William J. Dircks Executive Director for Operations l Enclosure Important General Points and Specific Questions for Discussion ,
1 Distribution:
WJDircks VStello l JHSniezek '
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l l NAME :JConran :J l k :VSt 11o :WJDfrcks : : :
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DATE :10/17/85 :19/W/85 :1//F/85 :W/ #85 : : :
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1 Enclosure II i 3 '
DISCUSSION POINTS A. Important Points for Consideration Regarding Program Improvment Identification
- 1. There is much about our existing regulatory programs and processes 1 that work, and work well. Those aspects of our current programs that I do work, demonstrably and effectively, should for the most part be left alone now. We should concentrate our improvement efforts on program aspects that clearly need to work more effectively. With regard to the SALP process specifically, for example, in its existing form that program effectively identified before the June 9 event the !
! need for improvement in licensee performance in areas highlighted subsequently in the NRC investigation following that event. The problem, therefore, was not that the SALP process failed to identify ;
problems. The need for further improvement in the SALP process !
(beyond changes already planned in the imminent SALP Manual Chapter revision) would appear to lie principally in the program managers' recognizing and reacting somewhat sooner to SALP trends indicating poor or deteriorating licensee performance.
Similarly, the safety review process, as it is currently conducted within NRC, did identify basic questions regarding the adequacy and reliability of the Davis-Besse AFW systems configuration, and resulted in a continuing pressure to upgrade its design and improve l its reliability over a longer period of time. The problem is that I the period of time involved was too long. In retrospect, it does l seem likely that the perspectives provided by a more-fully integrated '
treatment of that system's less desirable features (such as the SFRCS, and the locking out of the standby feedwater startup pump) had they been available earlier, would have brought things to a head with regard to final disposition of that issue before the occurrence of the June 9 Davis Besse event. It is also likely that the existence of the improved issue mangagement system referred to above, might have kept management attention focused more effectively on that situation and brought about earlier resolution of that issue. The message, again, from all this is: we must avoid change for change sake in the heat of this particular moment. I see no need for funda-mental or wholesale change in our programs. What is needed are judicious improvements on what are, for the most part, well-working programs. We need to concentrate our efforts in those areas where the need for improvement is strongly and broadly indicated, j
- 2. There has been criticism directed at the use of PRA in our regulatory activities, to the effect that reliance on PRA in determining the priority of a safety issue contributes to inordinate delay in dealing effectively and promptly with issues that are identified; e.g., the fJW 3afety issues that had been identified at Davis-Besse. It is
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Ti i likely true that, if our licensing decisions regarNng' Davis-Besse had been made solely on the basis of deteministic-type criteria and judgments to the exclusion of any probabilistic analysis input, NRC would long ago have required Davis-Besse to provide a diverse AFW system design. The balancing consideration is that we would likely also have required that utility and other utilities to do many other things, a number of which would now be seen as unnecessary for safety in the light of insights provided by PRA. As we learned in the after-math of TMI, the undisciplined proliferation of requirements that can ,
result when we restrict ourselves solely to use of deteministic- 1 type criteria and engineering judgment can adversely affect safety. I Equally important, the improved, more-fully integrated treatment of i safety issues (the need for which I have previously emphasized) can only practicably be achieved at this time by systematic analyses !
within the framework provided by PRA methodology. So keeping in mind l the uncertainties and limitations of PRA methods as they have evolved !
to this point, and appropriately taking into account such uncertainties and limitations in our decisionmaking, we must continue to apply and even broaden our application of those powerful integrating methods to achieve important program improvements that can be demonstrated to be j necessary. I would expect to see, therefore, in the comprehensive plans for program improvements that result finally from our upcoming discussions, proposals for increased use of PRA in determining safety importance of issues identified for regulatory action, in detemining ,
inspection methods and focus, in prioritizing operational experience l review efforts, detemining research programs, etc; in short, in every l phase of our activities. ,
B. Specific Questions To Be Considered in Determining Additional Program Improvements Questions
- 1. Should NRC as a matter of policy concentrate more heavily on balance-of-plant systems in our full range of regulatory activities?
- 2. What is the most efficient and effective means of examining retrospectively whether, in the absence of a more-fully integrated evaluation of safety issues in the past, we have prescribed actions (such as locking out valves / pumps / breakers) or approved installation of systems (such as SFRCS) in licensing contexts other than Davis-Besse that could have' unintended, adverse effects on safety?
- 3. Are administrative control measures like locking or chaining valves driven principally by security or safety concerns? If safety is the driving concern, wouldn't use of more easily broken seals or other such " flags" satisfy the safety purpose involved (i.e., inadvertent operation) in many areas? If security was the driving concern in implementing such measures, has adequate consideration been given to alternative measures th t could be more easily overridden in the event of an emergency?
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- 4. Should serious consideration be given to moving away from testing of individual components of safety systems during normal operation as a means of verifying or assuring operability, to more integrated testing of systems during outages?
- 5. Should we develop criteria which mandate when a licensee is to be required to implement a " Performance Improvement Program"?
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