ML20153G364

Corrected Ltr Forwarding Insp Rept 50-346/83-16 on 830711-29 & Notice of Violation.Violation Noted:Alternate Shutdown Capability for Fire in Control Room or Cable Spreading Room Did Not Meet App R Requirements

ML20153G364
Person / Time
Site:	Davis Besse
Issue date:	08/31/1988
From:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Shelton D TOLEDO EDISON CO.
Shared Package
ML20153G329	List: ML20153G324 ML20153G364
References
EA-83-124, NUDOCS 8809080128
Download: ML20153G364 (4)

See also: IR 05000346/1983016

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UNITE 3 STATES

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NUCLEAR REGULATORY COMMI$slON

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OLEN ELLYN ILUNOIS 401 H

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AU6 31198S

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Docket No. 50-346

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License No. NPF-3

EA 83-124

Toledo Edison Company

ATTN: Mr. Donald Shelton

Vice President

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Nuclear

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Edison Plaza

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300 Madison Avenue

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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

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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

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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,

and of your overall fire protection program implementation. During the

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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,

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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

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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

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.

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Toledo Edison company

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AU6 311988

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During the August 16, 1983 mee'ing between your staff and the NRC staff in

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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

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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

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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

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letter to Toledo Edison, dated September 23, 1983, stated that NRC concluded

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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

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referenced inspection report was issued.

This is because the NRC has been

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developing the enforcement guidance for Appendix R based on NRC inspections

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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

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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

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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

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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

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AU6 31 1988-

Distribution

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DCD/DCB(RIDS)

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Licensing Fee Management Branch

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SECY

CA

OGPA

J. M. Taylor, DEDRO

J. Lieberman, OE

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L. Chandler, OGC

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T. Murley, NRR

RAO:RIII

PAO:RIII

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SLO:RIII

M. Stahulak, RIII

Enforcement Coordinators,

RI, RII, RIV, and RV

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A. Datta, NL/S, RES/EME

C. McCracken, NRR/ECEB

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A. Krasopoulos, RI/DRS

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G. Wiseman, RII/DRS

A. Singh, RIV/DRS

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C. Ramsey, RV, DRS

OE File

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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

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inspecti " conducted on September 7-9 and 22, 1983, and January 9, 1984,

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identi'

violations of NRC requirements.

In accordance with the "General

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Polic

ad Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C

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(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

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to 10 CFR Part 50, including, specifically, the requirements of Sections III.G,

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Fire Protection of Safe Shutdown Capability, III.J. Emergency Lighting, III.L,

Alternative and Dedicated Shutdown Capability and III.0, Oil Collection System

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for Reactor Coolant Pump.

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10 CFR 50, Appendix R, Section III.G.1 requires that fire protection

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features shall be provided for structures, systems, and components

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important to safe shutdown.

These features shall be capable of

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limiting fire damage so that:

(a) one train of systems necessary

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to achieve and maintain hot shutdown conditions from either the

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control room or emergency control station is free of fire damage.

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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:

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1.

Separation of cables and equipment and associated non-safety

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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.

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In addition, fire detectors and an automatic fire suppression

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system shalt be installed in the fire area; or

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3.

Enclosure of cable and equipment and associated non-safety circuits

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of one redundant train in a fire barrier having a 1-hour rating.

In addition, fire detectors and an automatic ;* ire rappression

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system shall be installed in the fire area.

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Notice of Violation

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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

under consideration, be provided where the protection of systems whose

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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

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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

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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

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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

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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

egress routes to the auxiliary feed pump room, condensate storage tank

1evel indicator area, and valves ICS 11A and 11B, which are needed for

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operation of safe shutdown equipment.

In addition, for areas where

emergency lighting was provided, two out of six units tested failed the

eight hour discharge test.

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E.

10 CFR 50. Appendix R, Section 111.0 requires that the reactor coolant

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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

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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

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those modifications specified in Table 1 of the SE.

Section B.14 of

Table 1 of the SE requires that the fire protection administrative

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controls be revised to follow the NRC document, "Nuclear Plant Fire

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Protection Functional Responsibilities, Administrative Controls and

Quality Assurance."

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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

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the use of organizational charts and functional descriptions of each

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positions responsibilities . . . .

2.0 Qualifications for a Fire

Protection Engineer .

These requirpents are the eligibility

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requirements as a Member in the Society of Fire Protection Engineers."

2.

Paragraph 1.0.c of Attachment No. 6 states in part that, ".

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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

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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

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No. I states in part that, "the fire brigade members qualifications

should include satisfactory completion of a physical examination

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for performing strenuous activity . . . ."

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Notice of Violation

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AU6 311988

Specifically for item (e) below, Paragraph ' .0.b(3) of Attachment

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No. 4 states in part that, "a fire watch trained and equipped to

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prevent and combat fires is present throughout any operations in

which there is potential for fire that might damage safety related

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equipment ,

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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 . . . ."

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(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

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inspection (or monthly in the case of locked-open valves) of

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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 . . . ."

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(e) Chapter 431 of NFPA 518 (1977) states in part, "Fire watchers

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

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af ter completion of cutting and welding operations . . . ."

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(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

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and testb shall be made as are necessary to assure proper

maintenance as specified." Chapter 8-4.1 of NFPA 72E states

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in part that, ". . . photoelectric smoke detectors may require

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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

consulting the manufacturer's instructions."

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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

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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; . . . ."

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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

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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

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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

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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

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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

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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

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test results for 1980, 1981, 1982, and 1983 were not compared

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to the manufacturer's certified shop test chLracteristic curve

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for the pump being tested, as specified by NFPA 20.

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Notice of Violation

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AU6 311989

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(c) Surveillance Test Procedure ST 5016.09 (Fire Protection Systems

Valve Operability) did not specify verifying fire protection

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system valve operacility as specified by NFPA 26.

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(d) Administrative Procedure AD 1828.20 (Fire Brigade) did not

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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)

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did not specify that fire watchers be trained on fire

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extinguishing equipment and that a fire watch be maintsined

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for at least a half hour after completion of cutting and

welding operations as specified by NRC requirements or by

NFPA 518.

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(f) Survo111ance Test procedure ST 5016.06 (Fire Detectors) did not

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specify measurement of detector sensitivity, periodic cleaning,

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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

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by off site fire departments.

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Periodic Test Procedure PT 5112.01 (Emergency Lighting) did not

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specify surveillance of errergency lighting snits to assure an

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8-hour battery power supply was provided as required by NRC

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requirements.

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

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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

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th9 dampers closed, until July 28, 1983 and September 8,1983 for two

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penetrations that the licensee found to be nonfunctional on May 12 and

June 7, 1993.

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Collectively, these violations have been categorized as a Severity

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Level 111 problem (dupplement I).

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Pursuant to the provisions of 10 CFR 2.201, Davls-Besse is hereby required to

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submit a written statement or explanation to the U.S. Nuclear Regulatory

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Commit,sion. ATTN: Document Control Desk, Washington, D.C. 20555, with a copy

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to the Regional Administrator

U.S. Nuclear Regulatory Commission, 799

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Roosevelt Road, Glen Ellyn, Illinois 60137, and a copy to the NRC Resident

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AU6 311989

Notice of Viclation

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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

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m1ation if admitted, (2) the correctiv:: steps that have been taken and the

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<sults achieved, (3) the corrective steps that will be taken to avoid 1arther

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violations, and (4) the date when full compliance will be achieved.

If an

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adequate reply is not received within the time specified in this Notice, an

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order may be issued to show cause why the license should not be modified,

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suspended, or revoked or why such other action as may be proper should not be

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taken. Conside.ation may be given to extending the response time for good

cause shown,

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FOR THE NUCLEAR REGULATORY COMMISSION

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A.u

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A. Bert Davis

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Regional Administrator

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Dated at Glen Ellyn Illinois

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this .3 /

day of August 1988

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