ML20150B706

Ack Receipt of Informing NRC of Steps Taken to Correct Noncompliances Noted in Insp Rept 50-346/88-06. Sightglass Installed 7 Yrs Before Event W/O Detailed Drawings & Instructions

ML20150B706
Person / Time
Site:	Davis Besse
Issue date:	07/06/1988
From:	Harrison J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Shelton D TOLEDO EDISON CO.
References
NUDOCS 8807120134
Download: ML20150B706 (2)

See also: IR 05000346/1988006

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JUl. 6 '1988

Docket No.'50-346

Toledo Edison Company-

' ATTN: Mr., Donald Shelton

Vice-President

Nuclear

Edison Plaza

300 Madison Avenue

Toledo, OH 43652

Gentlemen:

Thank you for your letter dated June 9,1988, informing 'us of the steps you'

have taken to correct the noncompliances which we brought to your attention

in our letter dated April 20, 1988.

With regard to violation 88006-05, we have determined the following:

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1) The sightglass was installed (1977) seven years before the: event witho'ut'

detailed drawings and instructions;

2) No design criteria or design guides were used in the seismic qualification

calculation. Licensee's engineering calculation did not contain

appropriate acceptance criteria which were required by.the 10_CFR-50,'

Appendix B, Criterion V;

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3) At the time of the inspection, design criteria were still being developed

for the sightglass and the safety-related component modifications; and

4) The seismic qualification calculation should have been performed at the

time of installation instead of nine years (1986) later.

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Based on the above, we have concluded that_the violation was not adequately

self identified and the corrective actions taken were neither prompt, effective,

nor complete. Therefore, your request that we retract the , violation is denied.

You are requested to submit a written reply to this letter within thirty (30)

days of the dates of this letter including: (1) corrective action taken and

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the results achieved; (2) corrective action to be taken to avoid further

violations; and (3) the date when full compliance will be achieved.

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Toledo Edison Company' 2 -Jtjl'f'}ggg

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Should you have any questions .concerning this' matter, please feel free to -

contact me.

S incerely,-

0,jginal Signed by J.'J. llarricon

J. J. Harrison, Chief--

Engineering Branch'

cc: L. Storz, Plant Manager

cc w/1tr- dtd 6/9/88:

DCD/DCB (RIDS)

Licensing Fee Management Branch

Resident Inspector, Rlll

Harold W. Kohn, Ohio EPA

James W. Harris, State of Ohio

Robert M. Quillin, Ohio

Department of Health

State of Ohio', Public

Utilities Comission

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Docket No. 50-346

License No. NPF-3

Serial No. 1-806

June 9, 1988

Document Control Desk

United States Nuclear Regulatory Commission

Vashington, D. C. 20555

Subject: Response to Inspection Report 88006

Gentlemen:

Toledo Edison has received Inspection Report 08006 (Log No. 1-1783 dated April

20, 1938) and provides the following response. Based on our discussion with

Mr. F. Jablonski on June 1,1988, the response to Inspection Report 88-006 vas

extended to June 10, 1988.

Violation 88006-05:

10CFR50, Appendix B, Criterion V, requires that activities affecting quality

be prescribed by documented instruction, procedures, or dravings and be

accomplished in accordance with these instructions, procedures, or dravings.

Instructions / procedures or dravings shall include appropriate acceptance

criteria for determination that activities have been satisfactorily

accomplished.

Contrary to the above, a review of FCR 78-024 pertaining to the installation

of containment spray pump oil sightglass as.aemblies revealed the following:

a. No design drawings or detailed dravings were used during the installation

of the assemblies,

b. No instructions / procedures vere found for installation and inspection.

c. No design criteria / instructions vere utilized in the scismic qualification

evaluation.

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License No. NPF-3

Serial No. 1-806

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Response:

Acknowledgment Or Denial of the Alleged Violation

Toledo Edison does not believe the issuance of.a Notice of Violation is

varranted for the installation of the containment spray pump oil sightglass

for the following reasons.

Following the June 9, 1985 event, Toledo Edison initiated a System Reviev &

Test Program (SRTP). The SRTP was established to review the history of

systems important to the safe operation of the Davis-Besse Nuclear Power

Station (DBNPS). One of the objectives of the SRTP reviev vas to identify

problems which may impact the ability of those systems to perform the

necessary functions for safe operation of the plant and to propose corrective

actions to resolve those concerns. The Containment Spray (CS) system was one

of the systems revleved under the SRTP.

One of the concerns documented during the review of the Containment Spray

System was thnt no documentation was found that listed the vendor,

qualification, specification or appropriate installation instructions for the

oil level sight glasses added to the pumps in 1977. This concern was

documented, its safety significance determined and corrective action proposed.

Subsequent reviews confirmed there was no safety concern due to the installed

configuration. An engineering calculation, a Facility Chr.nge Request (FCR)

safety evaluation and the NRC inspection each concluded that: the calculated

stresses vere below the allovable stresses; the installation was seismically

qualified; and the sightglasses could perform their intended function during a

seismic event.

Following the June 9, 1985 event, Toledo Edison received and acknowledged

violations relating to programmatic control of modifications to the facility.

In response to those violations and as part of overall improvement efforts,

the processes for the design of modifications, control of vork, and reviews

for changes to safety related systems have been improved. Nuclear Group

Procedure NG-NE-304 requires a safety review and if applicable a safety

evaluation for proposed changes to identified systems, structures and

components important to safe operation. The Containment Spray System is one

of the systems identified in this procedure.

10CFR2 Appendix C, Section V.G.2, Exercise of Discretion, allows the NRC to

refrain from issuing a Notice of Violation for violations meeting the

following criteria

a. (i) NRC has taken significant enforcement action based upon a major

safety event contributing to an extended shutdovn of an operating

reactor or a material licensee (or a work stoppage at a construction

site), or the licensee is forced into an extended shutdown or vork i

stoppage related to generally poor performance over a long period: '

(11) the licensee has developed and is aggressively implementing

during the shutdown a comprehensive program for problem

identification and corrections and (iii) NRC concurrence is needed

by the licensee prior to restart.

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b. Non-villful violations are identified by the licensee (as opposed to

the NRC) as the result of its comprehensive program, or the

violations are identified as-a result of an employee allegation to

the licensee. If NRC identifies the violation, the NRC should

determine whether enforcement action is necessary to achieve remedial

action.

c. The violations are based upon activities of the licensee prior to the

events leading to the shutdown, and

d. The non-villful violations would normally not be categorized as

higher than Severity Level III violations under the NRC's Enforcement

Policy.

The sight glass installation meets the criteria set forth in this section. In

keeping with the stated objectives accompanying the revision to this section

of the code (i.e. to encourage prompt corrections of existing violations and

adverse conditions, to deter future violations and adverse conditions, and to

encourage improved performance by the licensee, while at the same time, not

discouraging a licensee's aggressive and comprehensive implementation of a

structured program to identify and correct problems), Toledo Edison urges the

NRC to exercise its authorized discretion to refrain from issuing a violation

in this instance.

Violation 88006-10:

10CFR50, Appendix B, Criterion III, requires that measures be established to

assure that applicable regulatory requirements and the design basis, as

defined in 5 50.2 and as specified in the license application, for those

structures, systems, and components to which this appendix applies are

correctly translated into specifications, drawings, procedures, and

instructions. Design changes, including field changes, shall be subjected to

design control measures commensurate with those applied to the original design

unless the applicant designates another responsible organization.

Contrary to the above, Specifications No. 12501-E-180 vas changed

administrative 1y to include a revised load profile for the station battery

performance test without going through the Facility Change process or applying

appropriate design control.

Response:

peknowledgment or Denial of the Alleged Violation

Toledo Edison acknowledges the alleged violation.

Reason for the Violation

Nuclear Engineering Procedure (NEP)-021, Specifications, controls the

revision, review and approval of design specifications. Generically, once a

change to a specification is identified, it is evaluated by Design Engineering

to determine whether it is a significant change. Depending on the

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significance of the change required, the specification change follows 1 of 2

paths. If the change is determined to be significant, _the specification

undergoes immediate revision and the change is incorporated. When the

specification is revised a formal design review is performed. Changes to

interfacing plant procedures are identified during the formal design review

process.

If the change is determined not to be significant, a Specification Change

Notice (SCN) is issued against the specification. A SCN is a document used to

temporarily modify the specification instead of revising the specification as

described above. SCNs can be used when specification changes, not associated

with physical plant modifications, are identified such as typographical

errors, incorrect index pages or incorrect information. The SCN is attached

to the specification indicating the change to the specification. No formal

design review is required. SCNs issued against a specification are

incorporated into the specification _(by the specification revision process)

when a total of five non-plant modification related SCNs are accumulated or

one year passes. When the specification is revised the design reviev is

performed.

In the case of the ststion battery load profile change, it was determined that

this change could be processed as an editorial ("incorrect information") SCN

(SCN 12501-E-180-01-03). This SCN documented various changes to the load

profile but did not change the battery size or result in a physical change to

the facility. Therefore per NEP-021, no formal design reviews (including

changes to applicable plant procedures) were immediately required for the

issuance of SCN 12501-E-180-01-03.

Corrective Steps Taken And Results Achieved

Subsequent to this NRC inspection, a more detailed review of the battery load

profile was conducted. As a result, Calculation C-EE-002-005, Rev. 0.vas

performed to better define and document the accident scenario to which the

batteries are sized and to incorporate 5th Refueling Outage Modifications I

affecting the DC system. j

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Document Change Request (DCR) 88-0158 and USAR Change Notice (UCN)88-031 vere

issued to incorporate the new load profile into the affected design documents.

This changed the load profile for the Battery Service Test making it the same i

as that in Specification 12501-E-180 On April 16, 1988 the Battery Service l

Test was successfully completed.

Corrective Steps Vhich Vill Be Taken To Avoid Further Violation

Procedure NEP-021 vill be revised to allow the preparation of non-plant

modification related SCNs be used only in conjunction with a Document Change

Request (DCR) per NG-NE-0312, Design Document Updates and NEP-202, Processing

Document Change Request. The DCR is used for "paper work only" design

document changes. The use of the DCR process vill require a design reviev to

ensure interfacing plant procedures are reviewed for changes. Therefore

changes to specifications vill undergo the full design reviev controls imposed

by the FCR/ MOD or DCR process upon their initiation.

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Date When Full Compliance Vill Be Achieved

Full compliance vill be achieved upon issuance of EN-DP-01021 R0 (NEP-021) by

June 20, 1988.

Very truly yours,

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JCS:tlt

cc:fA.'B.: Davis,' Regional Administrator; 4

A. V. DeAgazio, DB-1 Projec t Manager

DB-1 Resident Inspector

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