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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for Approval of Quality Assurance Program Changes PY-CEI-NRR-2438, Informs That DBNPS & Pnpp Staffs Have Modified or Withdrawn Several of Positions Proposed within Re Request for Approval of Qap.Revised Positions Encl1999-10-14014 October 1999 Informs That DBNPS & Pnpp Staffs Have Modified or Withdrawn Several of Positions Proposed within Re Request for Approval of Qap.Revised Positions Encl ML20217F8371999-10-0808 October 1999 Forwards Insp Rept 50-346/99-10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 UTILITY
MONTHYEARML20058H6411990-11-0909 November 1990 Forwards Final SALP Rept 50-346/90-01 Covering Mar 1989 to June 1990 ML20058E7141990-10-30030 October 1990 Forwards Exam Forms & Answer Keys,Grading Results & Individual Answer Sheets for Each Applicant ML20058D6771990-10-25025 October 1990 Forwards Exemption Request for Reactor Operators Selected for NRC Requalification Exam ML20058F4811990-10-24024 October 1990 Forwards Safety Insp Rept 50-346/90-16 on 900814-1009.No Violations Noted ML20062C6811990-10-18018 October 1990 Forwards Safeguards Insp Rept 50-346/90-19 on 900924-28.No Violations Noted ML20059N6661990-10-0909 October 1990 Forwards Correction to SER Re Request for Relief from ASME Boiler & Pressure Vessel Code,Section XI Requirements.W/O Encl IR 05000346/19900091990-09-26026 September 1990 Forwards Insp Repts 50-346/90-09,50-346/90-12 & 50-346/90-13 on 900417-0717 & Notice of Violation ML20059M2101990-09-25025 September 1990 Forwards Info Re Generic Fundamentals Exam Section of Operator Licensing Written Exams to Be Administered on 901010,including Map of Area Where Exams Will Be Taken, Preliminary Instructions for Exam & Equation Sheet ML20059L6041990-09-14014 September 1990 Confirms 901002 Meeting at Plant Site to Present Initial SALP 8 Rept for Facility ML20059J2511990-09-13013 September 1990 Forwards Safety Insp Rept 50-346/90-17 on 900827-31.No Violations Noted ML20059G1431990-09-0404 September 1990 Forwards Safety Insp Rept 50-346/90-15 on 900701-0813. Violation Noted But Not Cited.Util Implemented Corrective Actions as Result of Violation & Will Be Examined During Future NRC Insps ML20056B2701990-08-20020 August 1990 Forwards Safety Evaluation Granting 900710 Request for Relief from ASME Code for Class 3 Piping in Svc Water Sys. Request Granted Until Next Scheduled Outage Exceeding 30 Days But No Later than Dec 1991 ML20059A6821990-08-13013 August 1990 Forwards Safety Insp Rept 50-346/90-09 on 900417-0717. Violations Noted But Not Cited.Util Will Be Notified by Separate Correspondence of NRC Decision Re Enforcement Action Based on Findings of Insp ML20059A6721990-08-10010 August 1990 Forwards Safety Insp Rept 50-346/90-13 on 900605-30 & 0709. Violation Noted But Not Cited ML20059A6631990-08-10010 August 1990 Forwards Enforcement Conference Rept 50-346/90-14 on 900601 & 900717 Telcon Re Violations Noted in Insp Repts 50-346/90-09 & 50-346/90-12 ML20059A7161990-08-0808 August 1990 Provides Comments on 900105 Response to Generic Ltr 89-10 Re safety-related motor-operated Valve Testing & Surveillance. Util Should Provide Description of Methodology for Periodic Verification of motor-operated Valve Switch Settings ML20058M6141990-08-0707 August 1990 Forwards Sample Registration Ltr for 901010 Generic Fundamentals Section of Written Operator Licensing Exam. Registration Ltr Listing Names of Candidates Taking Exam Should Be Submitted to Region 30 Days Prior to Exam Date ML20055J2761990-07-24024 July 1990 Confirms 900731 Meeting in Region III Ofc to Discuss Util Response to Violation Re Instrumented Insp Techniques ML20055G6621990-07-20020 July 1990 Forwards Safety Insp Rept 50-346/90-10 on 900430-0518.No Violations Noted ML20055G3051990-07-13013 July 1990 Confirms 900718 Tour of Plant & Mgt Meeting to Discuss Sixth Refueling Outage & Other Items of Mutual Interest ML20055F2231990-07-0606 July 1990 Ack Receipt of Containing Scope & Objectives for 1990 Emergency Plan Exercise Scheduled on 900919 ML20055D9781990-06-29029 June 1990 Advises That 900614 Changes to QA Program Meet 10CFR50,App B Requirements & Acceptable.Nrc Should Be Notified of Changes to QA Commitments Existing in Docketed Correspondence Outside QA Program Description ML20055D3181990-06-29029 June 1990 Advises of Safety & Performance Improvement Program Implementation Audit Scheduled for Wk of 900716-20.Selected Samples of Technical Recommendations Encl ML20059M8631990-06-13013 June 1990 Forwards NRC Performance Indicators for First Quarter 1990. W/O Encl ML20248D8211989-09-29029 September 1989 Forwards Safety Evaluation Accepting Util 890228 & 0630 Proposed plant-specific Designs to Comply w/10CFR50.62 ATWS Rule Requirements.Proposed Date of May 1990 for Implementing ATWS Mods Also Acceptable ML20248C5691989-09-27027 September 1989 Forwards Amend 6 to Indemnity Agreement B-79,reflecting Changes in 10CFR140, Financial Protection Requirements & Indemnity Agreements, Effective 890701 ML20248A4711989-09-25025 September 1989 Requests Submission of Update Rept or Replacement Pages to Updated FSAR Submitted on 890721 to Appropriate Regional Ofc,Per 10CFR50.4(b)(6).Review of Updated QA Program Description,Section 17.2 Will Require More than 60 Days ML20247H9201989-09-0707 September 1989 Responds to Requesting Emergency Notification Sys Phone at Plant.Proposed Method for Recording Would Involve Emergency Notification Sys Phones Located in Control Room, Technical Support Ctr,Emergency Control Ctr & Inspector Ofc ML20247B4361989-09-0505 September 1989 Forwards Safety Insp Rept 50-346/89-18 on 890807-11.No Violations Noted ML20246L6571989-08-30030 August 1989 Responds to Re Annual Requalification Exam Grading Results.Based on Reviews & Consultations W/Nrc, Remedial Training,Consistent W/Identified Weaknesses, Provided & Intent of Requalification Program Met ML20246C4561989-08-17017 August 1989 Forwards Safety Insp Rept 50-346/89-16 on 890605-0716 & 24 & Notice of Violation.Violation Noted in Paragraph 7 of Rept Identified by Util Meets Criteria of 10CFR2,App C,Section V.G,Therefore Notice of Violation Will Not Be Issued ML20245J7641989-08-0909 August 1989 Forwards Insp Rept 50-346/89-20 on 890724-28.No Violations Noted ML20245F1061989-08-0303 August 1989 Confirms That Written & Oral Exams Scheduled for Wk of 891211.Ref Matl Listed on Encl & Reactor Operator License Applications Should Be Submitted at Least 60 Days Prior to Exam Date ML20247N8521989-07-28028 July 1989 Confirms 890908 Enforcement Conference in Glenn Ellyn,Il to Suppl & Clarify Info Provided by Util in 890228 Response to 880128 Insp Rept 50-346/88-04 & Notice of Violation Re Approval of Procedure AD 1805,Rev 27 ML20247C2911989-07-19019 July 1989 Forwards Addendum to Insp Rept 50-346/89-08 Transmitted by ,Consisting of Comparisons of Results of Liquid Sample Collected During Insp & Criteria for Comparing Analytical Measurements ML20247C3271989-07-19019 July 1989 Advises That 890616 Rev 7 to Physical Security Plan Consistent W/Provisions of 10CFR50.54(p) & Acceptable IR 05000346/19890121989-07-18018 July 1989 Ack Receipt of Informing NRC of Steps Taken to Correct Violation Noted in Insp Rept 50-346/89-12 Re Failure to Assemble Fire Brigade Immediately Upon Receipt of Any Unplanned Fire Alarm ML20246E7781989-07-0505 July 1989 Forwards Safety Insp Rept 50-346/89-17 on 890614-16.No Violations Noted ML20245K9891989-06-23023 June 1989 Forwards Safety Insp Rept 50-346/89-15 on 890605-09.No Violations Noted.Response to Concerns Re Use of Request for Info Forms & Document Change Requests to Correct Deficiencies Identified in Design Documents Requested ML20245G1371989-06-22022 June 1989 Forwards Safety Insp Rept 50-346/89-14 on 890424-0604. No Response to Violations Required ML20245H1941989-06-21021 June 1989 Requests That Results of Review of Encl Allegation RIII-89-A-0081 & Disposition of Matter Be Submitted within 30 Days of Ltr Date.Encl Withheld (Ref 10CFR2.790) ML20244D7791989-06-12012 June 1989 Comments on Util 890103 Response to Generic Ltr 88-17 Re Expeditious Actions for Loss of Dhr.Expeditious Actions to Achieve Immediate Reduction in Risk Associated W/Reduced Inventory Operation Will Be Replaced by Program Enhancement ML20244B6911989-06-0606 June 1989 Forwards Safety Insp Rept 50-346/89-13 on 890315-19.No Violations Noted ML20248A0581989-06-0202 June 1989 Informs That Response to NRC Bulletin 88-004, Potential Safety-Related Pump Loss, Acceptable.Response Indicated Rev to CCW Sys Operating & Alarm Procedure Prior to Restart for Cycle 6 to Ensure That 4-hr Limit on Min Flow Not Exceeded ML20247N9471989-05-31031 May 1989 Advises of Conclusion That Allegation RIII-88-A-0057 Re Improper Work Practices for Duct Work Unsubstantiated ML20247G4041989-05-18018 May 1989 Forwards Safeguards Insp Rept 50-346/89-07 on 890221-0417.No Violations Noted.Requests That Util Retain Supporting Documentation for Investigation of Allegation for Min of 1 Yr from Date of Ltr ML20247J8181989-05-18018 May 1989 Forwards Amend 133 to License NPF-3 & Safety Evaluation. Amend Deletes from License All Remaining Sections of App B ML20247D1211989-05-12012 May 1989 Forwards Safety Insp Rept 50-346/89-11 on 890301-0423.Notice of Violation Will Not Be Issued Since Violations Identified by Licensee ML20246K7541989-05-0505 May 1989 Forwards Insp Rept 50-346/89-12 on 890313-17 & 0418 & Notice of Violation ML20246H7951989-05-0303 May 1989 Forwards Insp Rept 50-346/89-06 on 890131-0209.No Violations or Deviations Noted.Written Statement within 30 Days to Resolve Items,Including Operator Entry Into Emergency Procedure from Abnormal Procedures,Requested within 30 Days 1990-09-04
[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] |
See also: IR 05000346/1983016
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9, UNITE 3 STATES
/j6,* "84 Ig NUCLEAR REGULATORY COMMI$slON
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REolON 111
799 ROOSEVELT ROAD
/ OLEN ELLYN ILUNOIS 401 H
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Docket No. 50-346
l License No. NPF-3
EA 83-124
Toledo Edison Company
ATTN: Mr. Donald Shelton
, Vice President
l Nuclear
Edison Plaza
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300 Madison Avenue
l Toledo, OH 43652
Gentlemen:
SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-346/83-16).
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! This refers to a special inspection conducted on July 11-13 and 25-29, 1983
l and a followup inspection conducted on September 7-9 and 22, 1983 and
- January 9, 1984, at the Davis-Besse Nuclear Power Station, Unit 1, of
l activities authorized by NRC Operating License No. NPF-3. The inspection was
conducted to review steps taken by you to ensure compliance with 10 CFR 50.48
and, in particular, Sections III.G, J, and 0 of Appendix R to 10 CFR Part 50,
l and of your overall fire protection program implementation. During the ,
l inspection, violations of these requirements were identified. A copy of the
inspection report was forwarded to you on August 30, 1984. The results of
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the initial inspection were discussed with you and NRR on August 16, 1983 in
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Bethesda, Maryland. The results of this inspection and our conclusions were
also discussed on December 1, 1983, during an enforcement conference held at
the NRC Region III office between Mr. W. A. Johnson and other members of your
staff and Mr. James G. Keppler and other members of the NRC staff.
You provided additional responses to our concerns in letters dated December 16
and 29, 1983. These letters described two audits that had been performed by
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consultants to determine the degree of compliance with Appendix R requirements,
i However, the audit reports said little about the detailed requirements of
Section III.G of Appendix R, and no mention was made of the 4equirements
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of Sections III.J., III.L. and 111.0. The root cause of your failure to
comply with Section III.G, J, L and 0 appeared to be inadequate control of
l engineering activities, including: (1) an inadequate reassessment of plant
conditions regarding the applicable Appendix R requirements and (2) lack of
supervisory reviews to assure technical adequacy of the reassessments. This
reflected a significant breakdown in the management controls used to ensure
l compliance with fire protection requirements. NRC Generic Letter 81-12, dated
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February 20, 1981, specifically emphasized the need for management to reassess
fire protection features at your facility to ensure compliance with the new
NRC requirements in this area. j
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eso9080128 080831 ;
gDR ADOCK0500g6
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Toledo Edison company 2 AU6 311988
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During the August 16, 1983 mee'ing between your staff and the NRC staff in !
Bethesda, Maryland, we stated the seriousness with which we viewed the
findings of the July 11-13 and 25-29, 1983 inspection. Toledo Edison
committed to develop short and long term programs addressing these problems f
prior to restarting the plant. Mr. Eisenhut's letter, dated August 19, 1983, '
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documented that meeting and the commitments made by Toledo Edison. Your
letters to the NRC, dated August 26, 31 and September 13, 1983, submitted your
plans for short (prior to plant restart) and long-term corrective action as
well as your evaluation of our inspection findings. We inspected your
short-term corrective actions prior to plant restart. Mr. Eisenhut, in a '
letter to Toledo Edison, dated September 23, 1983, stated that NRC concluded !
that the actions required to permit plant restart had been satisfactorily
completed.
The staff recognizes that a significant amount of time has elapsed since the !
referenced inspection report was issued. This is because the NRC has been .
developing the enforcement guidance for Appendix R based on NRC inspections I
and comments from the industry regarding the basis upon which compliance with
Appendix R would be evaluated as well as considering conducting an investigation
into the circumstances surrounding the violations. It has now been decided given :
the age of the matter not to conduct an investigation. Therefore, the NRC is
proceeding with enforcement based on the results of the referenced inspection
report.
In accordance with the "General Statement of Policy and Procedure for NRC
Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violations in the
enclosed Notice have been evaluated in the aggregate as a Severity Level III
problem. /. civil penalty is considered for a Severity Level III violation or
,
problem. However, after consultation with the Deputy Executive Director for
Regional Operatior.s and the Director of the Office of Enforcement, I have been
authorized to issue the enclosed Notice without a civil penalty. A civil
penalty is not being proposed because of the significant time that has elapsed
since the inspection occurred, the corrective actions you have taken or have
scheduled to take, and the apparent lack of clarity which existed regarding fire
protection requirements at the time. Given these factors, a civil penalty is
not considered warranted.
You are required to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing your response. In your
response, you should document the specific actions taken and any additional
actions you plan to prevent recurrence. We recognize that since the
inspection was completed you have taken actions or have scheduled actions to
correct the deficiencies and may have described these corrective actions in
previous correspondence with the NRC. For that reason, you may reference
previous submittals regarding your corrective actions when responding to this
le+ter. After reviewing your response to this Notice, including your proposed
c rective actions and the results of future inspections, the NRC will determine
wucther further NRC enforcement actions is necessary to ensure compliance with
NRC regulatory requirements.
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Toledo Edison Company 3 AU6 31 1988
In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2,
Title 10, Code of Federal Regulations, a copy of this letter and its enclosure
will be placed in the NRC Public Document Room.
The responses directed by this letter and the enclosed Notice are not subject
to the clearance procedures of the Office of Management and Budget as required
by the Paperwork Reduction Act of 1980, Pub. L., No.96-511.
Sincerely,
. 4L[
A. Bert David
Regional Administrator
Enclosures:
1. Notice of Violation
2. Inspection Report
No. 60-346/83-16(DE)
cc w/ enclosures:
L. Storz, Plant Manager
Resident Inspector, RIII
Harold W. Kohn, Ohio EPA
James W. Harris, State of Ohio
Robert M. Quillin, Ohio
Department of Health
State of Ohio, Public
Utilities Commission
See Attached Distribution
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Toledo Edison Co,i.pany 4
AU6 31 1988-
Distribution
l DCD/DCB(RIDS) ,
Licensing Fee Management Branch '
SECY
CA
OGPA
J. M. Taylor, DEDRO
J. Lieberman, OE
l L. Chandler, OGC
T. Murley, NRR
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RAO:RIII
PAO:RIII ,
SLO:RIII
M. Stahulak, RIII
Enforcement Coordinators,
RI, RII, RIV, and RV
j A. Datta, NL/S, RES/EME
l C. McCracken, NRR/ECEB
! A. Krasopoulos, RI/DRS (
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G. Wiseman, RII/DRS
A. Singh, RIV/DRS 1
C. Ramsey, RV, DRS
OE File -
EA File
JLuehman, OE
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NOTICE OF VIOLATION
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Toledo Edison Company Docket No. 50-346
Davis-Besse Nuclear Power Station License No. NPF-3
Unit 1 EA 83-124
A special fire protection inspection conducted at the Davis-Besse Nuclear
, Power Station during the period of July 11-13 and 25-29,1983, and a followup .
, inspecti " conducted on September 7-9 and 22, 1983, and January 9, 1984, !
identi' s violations of NRC requirements. In accordance with the "General
1
Polic c ad Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C
(1988), the violations are set forth below:
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, 10 CFR 50.48(b) requires that all nuclear power plants licensed to operate
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prior to January 1, 1979, satisfy the applicable requirements of Appendix R l
to 10 CFR Part 50, including, specifically, the requirements of Sections III.G, !
Fire Protection of Safe Shutdown Capability, III.J. Emergency Lighting, III.L,
Alternative and Dedicated Shutdown Capability and III.0, Oil Collection System f
4 for Reactor Coolant Pump. ;
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A. 10 CFR 50, Appendix R, Section III.G.1 requires that fire protection I
features shall be provided for structures, systems, and components '
important to safe shutdown. These features shall be capable of r
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limiting fire damage so that: (a) one train of systems necessary
to achieve and maintain hot shutdown conditions from either the ;
l control room or emergency control station is free of fire damage. 1
10 CFR 50, Appendix R, Section III.G.2 requires that where redundant
trains of systems necessary to achieve and maintain hot shutdown
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conditions are located in the same fire area outside of primary
containment, one of the following means of ensuring that one of
the redundant trains is free from fire damage be provided: ,
- 1. Separation of cables and equipment and associated non-safety
j
circuits of redundant trains by a fire barrier having a 3-hour
rating. Structural steel forming a part of or supporting such !
fire barriers shall be protected to provide fire resistance
equivalent to that required of the barrier;
2. Separation of cables and equipment and associated non-safety
circuits of redundant trains by a horizontal distance of more
. than 20 feet with no intervening combustible or fire hazards.
.
In addition, fire detectors and an automatic fire suppression
f system shalt be installed in the fire area; or
1
. 3. Enclosure of cable and equipment and associated non-safety circuits
i of one redundant train in a fire barrier having a 1-hour rating.
1
In addition, fire detectors and an automatic ;* ire rappression
l system shall be installed in the fire area.
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Notice of Violation 2
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Contrary to the above, at the time of the inspection a fire in the
auxiliary shutdown panel room could have resulted in the loss of control
and indications for both auxiliary feedwater pumps at both the auxiliary
shutdown panel room and the control room because features were not provided
to ensure that one train of the auxiliary feedwater system which is needed
to maintain hot shutdown was free of fire damage in that they were not
separated by a fire barrier having a 3-hour rating; were not separated by
a horizontal distance of more than 20 feet with no intervening combustible
fire hazards; or were not provided with 1-hour fire barriers. In addition,
numerous lengths of conduit and junction boxes in the Component Cooling
Water heat exchanger and pump room were not separated by a fire barrier
having a 3-hour rating; were not separated by a horizontal distance of
more than 20 feet with no intervening combustible fire hazards; or were
not provided with 1-hour fire barrier.
B. 10 CFR 50, Appendix R, Section III.G.3 and III.G.3(a) require that
alternative or dedicated shutdown capability and its associated circuits,
independent of cables, systems or components in the area, room or zone
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under consideration, be provided where the protection of systems whose
function is required for hot shutdown does not satisfy the requirement
,
of Paragraph G.2 of this section. 10 CFR 50, Appendix R, Section III.L
provides the requirements for alternative or dedicated shutdown
capability specifying:
1. Section III.L.1 requires that alternative or dedicated shutdown
capability provided for a specific fire area be able to achieve
cold shutdown conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
2. Section III.L.2 requires that process monitoring function for
alternative or dedicated shutdown capability shall be capable
i of providing direct readings of reactivity and reactor coolant
system heat removal funct. ions.
3. Section III.L.3 requires that procedures be in effect to implement
the alternative shutdown capability, be independent of the specific
fire area (s) and accommodate postfire conditions where offsite power
is available and where offsite power is not available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
4. Section III.L.7 requires that safe shutdown equipment and systems
for each fire area shall be known to be isolated from associated '
non-safety circuits in the fire area so that hot shorts, open
circuits, or shorts to ground in the associated circuits will
not prevent operation of the safe shutdown equipment.
Contrary to the above, at the time of the inspection, alternative
shutdown capability for a fire in the control room or cable spreading
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room did not meet the above requirements in that:
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Notice of Violation 3 AUG 31 1988
1. The capability to achieve cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> was not
provided.
2. Alternative or dedicated shutdown system process monitoring
instrumentation was not installed outside the control room and
the cable spreading room to provide direct readings of reactivity
and the cold leg reactor coolant system temperature. In addition,
the instrument used to measure the hot leg reactor coolant system
temperature was not of adequate range.
3. Procedures were not in effect to implement the alternative shutdown
capability assuming a fire in each area, with and without offsite
power available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
4. The effect of a fire in each of these areas was not considered
including the possible effects of interaction between associated
circuits.
C. 10 CFR 50, Appendix R, Section III.G.3 requires that alternative or
dedicated shutdown capability be provided and a fixed fire suppression
system be installed in the area, room, or zone under consideration.
Contrary to the above, at the time of the inspection, a fixed fire
suppression system was not provided in the auxiliary shutdown area.
D. 10 CFR 50, Appendix R, Section III.J requires that emergency lighting
units with at least an 8-hour battery power supply shall be provided in
all areas needed for operation of safe shutdown equipment and in access
and egress routes thereto.
Contrary to the above, eme gency lighting was not provided for access and I
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egress routes to the auxiliary feed pump room, condensate storage tank l
1evel indicator area, and valves ICS 11A and 11B, which are needed for '
operation of safe shutdown equipment. In addition, for areas where
emergency lighting was provided, two out of six units tested failed the l
eight hour discharge test. l
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E. 10 CFR 50. Appendix R, Section 111.0 requires that the reactor coolant '
pump be equipped with an oil collection system. Leakage shall be
collected and drained to a vented closed container that can hold the
entire lube oil system inventory.
Contrary to the above, at the time of the inspection, the reactor coolant
pump oil collection system was inadequate in that two reactor coolant
pumps, each with a lube oil capacity of approximately 225 gallons, were
connected to drain into a single 250 gallon container.
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Notice of Violation 4 AU6 31 1989
F. Amendment No. 18 of Plant Operating License No. NPF-3 in Paragraph 2.C(4)
requires the licensee to ccmplete those modifications identified in
Section 1 of the Safety Evaluation (SE) dated July 26, 1979, including l
those modifications specified in Table 1 of the SE. Section B.14 of
Table 1 of the SE requires that the fire protection administrative ,
controls be revised to follow the NRC document, "Nuclear Plant Fire '
Protection Functional Responsibilities, Administrative Controls and
Quality Assurance."
i
As specified below the specific paragraphs of the attachments to Nuclear
Plant Fire Protection Functional Responsib111 ties, Administrative Controls
and Quality Assurance state the following:
1. Paragraph 1.0 of Attachment No. I states in part, "The organizational
responsibilities and lines of communication pertaining to fire
protection should be defined b? tween the various positions through '
the use of organizational charts and functional descriptions of each I
positions responsibilities . . . . 2.0 Qualifications for a Fire
Protection Engineer . . .. These requirpents are the eligibility
requirements as a Member in the Society of Fire Protection Engineers."
2. Paragraph 1.0.c of Attachment No. 6 states in part that, ". ..
plant modifications, including fire protection systems, are reviewed
by qualified personnel to assure inclusion of appropriate fire
protection requirements.
3. Paragraph 1.0.d of Attachment No. 6 states in part that, "A
review . . . of the adequacy of fire protection requirements . . .
is performed and documented by qualified personnel. This review
should determine tid fire protection requirements and quality
requirements are correctly stated . . . and . . . are adequate
acceptance and rejection criteria . . . ."
4. Paragraph 2.0.b of Attachment No. 6 states in part that, "Activities
such as . . . test . . . of fire protection systems are prescribed
and accomplished in accordance with documented . . . procedures
. . . ." Paragraph 1.0.6 of Attachment No. 6 states in part that,
"Quality standards are specified f n the design documents such as ;
appropriate fire protection codes and standards . . . .
(c) . . . designs . . . including fire protection systems, are
reviewed . . . to assure inclusion of appropriate fire protection
requirements."
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Specifically for item (d) below, Paragraph 2.0.b of Attachment i
No. I states in part that, "the fire brigade members qualifications I
should include satisfactory completion of a physical examination i
for performing strenuous activity . . . ." i
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Notice of Violation 5 AU6 311988
Specifically for item (e) below, Paragraph ' c.0.b(3) of Attachment i
No. 4 states in part that, "a fire watch trained and equipped to '
prevent and combat fires is present throughout any operations in
which there is potential
"
for fire that might damage safety related
equipment , ...
Section 9.5.1.1 of the Davis-Besse Final Safety Analysis Report (FSAR)
references a number of the applicable design documents for the fire
protection system stating that, "The fire protection systems are
designed, installed and tested to satisfy the intent of the National
, Fire Protection Association (NFPA) codes . . . ."
(a) Chapter 2-7.2.1 of NFPA 13A (1978) states, "Test alarms by
opening the inspector's test connection and/or the by pass test
connection, in conjunction with making a water-flow test when
facilities and conditions permit."
(b) Chapter 12-1.2 of NFPA 20 states that, "The field acceptance
test results shall be as good as the manufacturer's certified
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shop test characteristic curve for the pump being tested."
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' (c) Chapter 3.1 of NFPA 26 (1976) states that, "A systematic weekly ,
inspection (or monthly in the case of locked-open valves) of
each valve should be made and a report form used to record the
condition of each valve."
(d) Chapter 33 of NFPA 77 (1975) states in part that, "minimum
physical requirements should be established . . . ." ,
(e) Chapter 431 of NFPA 518 (1977) states in part, "Fire watchers
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shall have firt extinguishing equipment readily available and
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be trained in its use, including practice on test fires . . . . ,
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434. A fire watch shall be maintained for at least a half hour
af ter completion of cutting and welding operations . . . ." )
(f) Chapter 8-1.1 of NFPA 72E (1978) states in part that, "Each
automatic detector shall be :ontinuously maintained in reliable
operating condition at all times, and such periodic inspections
i and testb shall be made as are necessary to assure proper
- maintenance as specified." Chapter 8-4.1 of NFPA 72E states
in part that, ". . . photoelectric smoke detectors may require
1
j periodic cleaning to remove dust or dirt which has accumulated
. . . for each detector, the cleaning, checking, operation
and sensitivity adjustment, shall be attempted only after
3
consulting the manufacturer's instructions."
5. Attachment No. 5 states in part that, "Firefighting procedures
should be established to cover such items as . . . coordination
of firefighting activities with offsite fire departments. The
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Notice of Violation 6
AU6 31198S
firefighting procedures should identify . . . : g. Actions to
be taken that will coordinate firefighting activities with
offsite fire departments, including: . . . identification of
individual who will direct firefighting activities when aided '
by offsite firefighting assistance; . . . ."
6. Paragraph 5.0 of Attachment No. 6 states in part that,
". . . b. Periodic testing . . . emergency lighting equipment
is tested periodically to assure that the equipment will properly
function and continue to meet the design criteria."Section III.J
of Appendix R to 10 CFR Part 50 requires emergency lighting units
with at least an eight hour battery power supply be provided.
Contrary to the above, the licensee failed to develop and implement i
adequate inspection, surveillance test procedures, administrati,ve
controls and quality assurance in that:
1. The implementation of the staffing qualifications for the fire
protection program was inadequate in that: the fire protection
coordinator was the only individual who had direct responsibility
for the fire protection program; the licensee's Administrative
Procedure 1810.00 inadequately described the number of individuals '
involved in implementing the fice protection program; and the
licensee's fire protection engineer had not had his qualifications
evaluated to determine acceptability to NRC criteria.
2. No procedure was in effect to ensure that modifications that may <
change the fire resistive rating of fire doors were reviewed by
qualified personnel.
3. Test procedure ST 5016.11.1 was inadequate in that this procedure
failed to indicate that only one attempt was allowed to close the
damper in determining operability. Therefore, the test procedure ,
acceptance criteria for this test procedure was not satisfactory.
Additionally, the procedure specified that the damper and ductwork
shall be cleaned prior to testing. This could have affected the
fire damper test results.
4. (a) Surveillance Test Procedure ST 5016.07 (Automatic Sprinkler
Systems) was not followed it. 1980, 1981, 1982 and 1983 in ,
that alarms were not tested by opening the inspector's test
connection and/or the by pass test connection in conjunction
with making a water flow test on the wet pipe sprinkler systems
as specified by NFPA 13A.
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(b) Surveillance Test Procedures ST 5016.03 and ST 5016.12 (Fire
Pump Testing) were inadequate in that the diesel fire pump ,
test results for 1980, 1981, 1982, and 1983 were not compared '
to the manufacturer's certified shop test chLracteristic curve l
for the pump being tested, as specified by NFPA 20.
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Notice of Violation 7 AU6 311989 .
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(c) Surveillance Test Procedure ST 5016.09 (Fire Protection Systems
Valve Operability) did not specify verifying fire protection ,
system valve operacility as specified by NFPA 26. '
'
(d) Administrative Procedure AD 1828.20 (Fire Brigade) did not
specify minimum physical requirements for fire brigade
members as specified by NRC requirements or NFPA 27.
(e) Administrative Procedure AD 1810.01 (Fire Protection Program) .
i did not specify that fire watchers be trained on fire f
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extinguishing equipment and that a fire watch be maintsined
for at least a half hour after completion of cutting and
welding operations as specified by NRC requirements or by
NFPA 518. t
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(f) Survo111ance Test procedure ST 5016.06 (Fire Detectors) did not l
] specify measurement of detector sensitivity, periodic cleaning, i
maintenance and adjustment of photoelectric fire detectors as
specified by NFPA 72E.
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5. Administrative Procedures AD 1810.00 and 1828.20 did not specify the
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actions to be taken by offsite fire departments with respect to who
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would direct firefighting activities when the fire brigade was aided >
by off site fire departments. ;
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- 6. Periodic Test Procedure PT 5112.01 (Emergency Lighting) did not f
j specify surveillance of errergency lighting snits to assure an -
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8-hour battery power supply was provided as required by NRC
j requirements.
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G. Technical Specification 3.7.10 requires that with one or more of the
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required penetration fire barr ters nonfunctional, a continuous fire
watch on at least one side of the affected penetration be established
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within one hour,
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Contrary to the above, a continuous fire watch was not established, or '
th9 dampers closed, until July 28, 1983 and September 8,1983 for two i
penetrations that the licensee found to be nonfunctional on May 12 and
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June 7, 1993.
Collectively, these violations have been categorized as a Severity !
3 Level 111 problem (dupplement I). .
i Pursuant to the provisions of 10 CFR 2.201, Davls-Besse is hereby required to l
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submit a written statement or explanation to the U.S. Nuclear Regulatory '
Commit,sion. ATTN: Document Control Desk, Washington, D.C. 20555, with a copy '
, to the Regional Administrator U.S. Nuclear Regulatory Commission, 799 :
j Roosevelt Road, Glen Ellyn, Illinois 60137, and a copy to the NRC Resident
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AU6 311989
Notice of Viclation 8 t
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Inspector at Davis-Besse within 30 days of the date of the letter transmitting
this Notice. This reply should be clearly marked as a "Reply to a Notice of ,
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Violation" and should include for each violation: (1) the reason for the !
m1ation if admitted, (2) the correctiv:: steps that have been taken and the :
) ;<sults achieved, (3) the corrective steps that will be taken to avoid 1arther l
l violations, and (4) the date when full compliance will be achieved. If an
adequate reply is not received within the time specified in this Notice, an
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a order may be issued to show cause why the license should not be modified, l
suspended, or revoked or why such other action as may be proper should not be i
taken. Conside.ation may be given to extending the response time for good
cause shown,
7 FOR THE NUCLEAR REGULATORY COMMISSION I
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$ A.u
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) A. Bert Davis !
Regional Administrator ;
Dated at Glen Ellyn Illinois .
1 this .3 / day of August 1988 i
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