IR 05000346/1984009

Advises of Deletion of Violation Identified in Insp Rept 50-346/84-09 Re Independent Verification of Tagging Equipment Out of Svc,Per Hl Thompson 850606 Interpretation

ML20129B331
Person / Time
Site:	Davis Besse
Issue date:	07/08/1985
From:	Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Crouse R TOLEDO EDISON CO.
References
NUDOCS 8507150489
Download: ML20129B331 (1)

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JUL 8 1985 Docket No. 50-346 Toledo Edison Company ATTN: Mr. Richard P. Crouse Vice President Nuclear Edison Plaza 300 Madison Avenue Toledo, OH 43652 Gentlemen:

We recently received an NRC interpretation regarding independent verification of tagging equipment out of service. Even though'the interpretation, a copy of which is attached, relates to another Region III facility, it does impact the validity of a violation identified in NRC Inspection Report No. 50-346/84-09 for the Davis Besse facility. As a result, we are deleting Violation N /84-09-02 from our record Although independent verification of proper system line-up on safety-related systems and components at the time they are removed from service is not required through your comitment to ANSI N18.7-1972, we continue to believe that the verification is an important and prudent activity which should be accomplished. Accordingly, we hope that you continue your activities in this regar We regret any inconvenience this may have cause If you have any questions on this matter, please contact Mr. Frank Hawkins (312-790-5555) of my staf

Sincerely,

"Originci Sfgned by R. L. Snessard" R. L. Spessard, Director Division of Reactor Safety Attachment: As Stated cc w/ Attachment:

S. Quennoz, Plant Manager DMB/ Document Control Desk (RIOS)

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June 6, 1985 MEMORANDUM FOR: R. L. Spessard, Director Division of Reactor Safety Region III FROM: Hugh L. Thompson, Jr., Director Division of Licensing Office of Nuclear Reactor Regulation

SUBJECT: ZION 1 AND 2 -- INDEPENDENT VERIFICATION OF TAGGING EQUIPMENT OUT OF SERVICE TIA Task No. 85-17 requests our assistance in providing to Region III (1) our interpretation of requirements of NUREG-0737 Section I.C.6 relative to independent verification of tagging equipment out of service and (2) our assessment of whether Zion verification practices satisfy I.C.6. The documentation regarding this matter is composed of a February 23, 1985 memorandum from R. L. Spessard to H. L. Thompson, with enclosures. We have

' reviewed that documentation and provide below our evaluatio We note that the word "should" as used in the ANSI Standard is defined to mean a recommendation. A similar connotation applies to the word "should" as used by the NRC staff. The words "where appropriate" are undefined in the ANSI Standard and thus are vague as to their precise meanin The licensee correctly notes that the 1972 version of the ANSI Standard, to which the licensee is comitted, requires " independent verification, where appropriate, to ensure that necessary measures, such as tagging equipment, have been implemented correctly." These same words are continued in the 1976 version of the Standard (5.2.6). Thus, in our view, the licensee was not committed to provide independent verification of tag-out of equipment important to safety unless he chose to interpret the words "where

appropriate" as including such equipmen Comon sense and actual experience tell us, however, that unsafe conditions can develop when the wrong equipment is tagged out of service as well as when equipment is being put back into service. Therefore, we believe that independent verification is needed to assure that the proper equipment has been tagged out. That position is reinforced, we believe, by the 1982 version of ANSI /ANS The applicable section (5.2.6) of this version presents a significantly stronger, more positive, statement concerning this matter than did the 1972 version to which the licensee had committed. The appropriate portion is quoted belo "When a system important to safety is removed from service, independent verification shall be provided to the extent necessary to assure that the proper system was removed. This may be accomplished by checking appropriate equipment and controls, or by indirect means such as observation of indicators and status lights. This requirement may be waived if the only way of accomplishing it would result in significant radiation exposure."

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,We note that the licensee has comitted to " require independent verification of proper system line-up on safety-related systems / components at the time the equipment is removed frorr service", see the licensee's letter of February 19, 1985; Enclosure 5 to Mr. Spessard's 2/28/85 request to Mr. Thompso It appears that Commonwealth Edison Company has seen the desirability of such verificatio r- g' ; w , .

In sumary, we feel that commitment to ANSI N18.7-1972 does not commit a licensee to independent verification of equipment tag out. The wording of the Standard certainly suggests that such independent verification be performed, but it does not require it. The wording of NUREG-0737 also strongly suggests that independent verification of equipment tag out be performed, but does not require it. We, thus, conclude that the licensee is correct in his contention that the charge of noncompliance is incorrect and should be withdrawn. At the same time, however, we feel that independent verification of the correctness of tag-out of equipment important to safety is an important step that should be taken by all licensee We are pleased to note that Comonwealth Edison has committed to change the procedures at all of its nuclear stations to require such independent verification in the future, f /t??f Hugh L. Thompson,/J rector Di d ion of Licensing Office of Nuclear Reactor Regulation cc:

H. Denton D. Crutchfield G. Holahan E. Butcher S. Varga J. Norris T. Murley, RI J. N. Grace, RII J. Keppler, RIII R. Martin, RIV J. Martin, RV J. Taylor, IE L ]