ML19274E237

Responds to NRC 790125 Ltr Re Violation Noted in IE Insp Rept 50-346/78-29.Corrective Actions:Preparation of Repts Re Water Sys Loss of Redundancy & Operating in Degraded Mode

ML19274E237
Person / Time
Site:	Davis Besse
Issue date:	02/16/1979
From:	Jeffery Grant TOLEDO EDISON CO.
To:	Fiorelli G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19274E234	List: ML19274E237
References
NUDOCS 7903210014
Download: ML19274E237 (5)

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TOLEDO February 16, 1979 l3()l6l()Id Docket No. 50-346 JAMES S GRANT v.c. p .e License No. NPF-3 e e. s, s.w, (419) 25 9-EP32 Serial No. 1-49 Mr. Gaston Fiorelli, Chief Reactor Operations and Nuclear Support Branch, Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Fiorelli:

Toledo Edison acknowledges receipt of your January 25, 1979 letter and report enclosures 78-29, referencing apparent deviations from Davis-Besse Nuclear Power Station Unit No. I commitments to the NRC listed as " Infraction" and

" Deficiencies" under the heading " Notice of Violation".

Following a thorough examination of the items of concern, Toledo Edison herein offers information regarding the items of noncompliance.

Item 1, Infraction: Section 3.7.9.1 of the Technical Specifications require that with one pump and/or one fire suppression water supply inoperable, restore the inoperable equipment to operable status within seven days or, in lieu of any other report required by Specification 6.9.1, prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within the next thirty days out-lining the plans and procedures to be used to provide for the loss of redundancy in the fire suppression water system.

Contrary to the above, during May 1978, with the diesel fire pump inoperable for more than seven days on two occasions, a Special Report was not prepared and sub-mitted to the NRC.

Response: 1. A special report is being prepared for submission to the Commission pursuant to Technical Specifica-tion 6.9.2, outlining the plans and procedures to be used to provide for the loss of redundancy in the fire suppression water system.

THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO. OHIO 43652

-EB 2 01979 7 903 2100d

~

Mr. Gaston Fiore11i Docket No. 50-346 Serial No. 1-49 February 16, 1979 Page 2

2. The primary cause of the inspector's concern was that personnel who documented test results were not clear and explicit in their documentation.

The Station is establishing a program for per-sonnel who document tests results to be more explicit in the noting of any test deficiencies and to document these deficiencies correctly.

3. Full compliance will be achieved by March 30, 1979.

Item 2, Deficiency Section 6.9.1.9.b of the Technical Specifications requires a thirty day written report for conditions leading to operations in a degraded mode permitted a limiting condition for operation.

Contrary to the above, a thirty day written report was not submitted to the NRC to report the drift in the setpoints of the main steam line code safety valves discovered as the result of surveillance testing on July 21, 1978.

Response: 1. A thirty day written report is being prepared in accordance with Technical Specification 6.9.1.9.b for conditions leading to operations in a degraded mode permitted a limiting condition for operation.

2. Personnel involved with maintenance of main steam safety valves have been made aware of the require-ments of Technical Specification 6.9.1.9.b.

3. Full compliance will be achieved by February 28, 1979.

Item 3, Dcficiency Section 6.8.1 of the Technical Specifications requires that written procedures shall be established, imple-mented and maintained covering surveillance and test activities of safety related equipment and fire pro-tection program implementation.

Contrary to the above, established written procedures were not implemented and maintained in the following areas:

e Mr. Gaston Fiore11i Docket No. 50-346 Serial No. 1-49 February 16, 1979 Page 3

a. Unit log entries were not made on May 4, 1978 on the performance of surveillance test ST 5016.01 as required by Administrative Procedure AD 1839.

00, Section 5.4.1.

Response: 1. The log entry at 0634 on 5/4/78 in the Reactor Operator Log was for the performance of a periodic test (PT) which this test had been.

A note was added to the Reactor Operator log entry of 5/4/78 on 2/8/79 clarifying this en-try.

2. There is no corrective action required to avoid further noncompliance as the operators are now aware that test is performed as a surveillance test.

3. Full compliance was achieved on February 8, 1979.

b. Surveillance Test 5016.01, Step 7.1.2 was not re-scheduled after an incomplete test was performed on May 4, 1978 and/or as soon as possible after completion of repair work, as required by Admin-istrative Procedure AD 1838.02.3, Section 4.6.

Response: 1. The surveillance test procedure was revised on June 2, 1978.

2. The designated reviewer in this case was the cognizant engineer for the fire protection sys-tem and was qualified to make the determination that no retest was required. However, desig-nated reviewers shall be informed that test deficiencies involving a change in acceptance criteria should not be signed off as acceptable until a Major Modification changing acceptance criteria has a spproved.

3. Full compliance was achieved on February 16, 1979.

Mr. Gaston Fiore11i Docket No. 50-346 Serial No. 1-49 February 16, 1979 Page 4

c. Surveillance Test ST 5016.01 was not suspended on May 11, 1978 and the diesel fire pump declared in-op_erable due to a bad coolant system hose, as re-quired by Administrative Procedure AD 1838.02.3, Section 4.2 and 4.3.

Response: 1. The Shift Foreman determined that the coolant leak was not significant enough to declare the Diesel Fire Pump inoperabic. However, a test deficiency and work request should have been submitted with the May 11, 1978 test.

This was corrected by the submission of a work request on May 16, 1978.

2. Station personnel will be reminded that a deficiency and a work request if required must be filled out even if the Shift Foreman has ap-proved the test.

3. Full compliance will be achieved by February 17, 1979,

d. A reading of 115 degrees F. was approved on May 26, 1978 as an acceptable temperature to surveillance test 5016.01, Step 7.1.2, (acceptance test limit for engine coolant temperature should not be less than 120 degrees F.), without making approved changes to acceptance criteria as required by Administrative Procedure AD 1838.02.3, Section 4.1.

Response: 1. The surveillance test procedure was revised to remove this requirement.

2. The designated reviewer in this case was the cognizant engineer for the Fire Protection System and was qualified to make this deter-mination. However, designated reviewers shall be informed that test deficiencies involving a change in acceptance criteria should not be signed off as acceptable until a Major Modifica-

, tion changing acceptance criteria has been ap-proved.

3. Full compliance was achieved on February 16, 1979.

Mr. Gaston Fiore11i Docket No. 50-346 Serial No. 1-49 February 16, 1979 Page 5

e. An auxiliary operator did not follow approved procedures while performing surveillance test ST 5016.01 on May 23, 1978 as required by Administra-tive Procedure AD 1838.02.3, Section 4.1 and AD 1839.00, Section 5.4.

Response: 1. The individual involved is no longer a member of the Operations Section.

2. All Station personnel were informed of the requirements for procedure adherence.

3. Full compliance was achieved on July 16, 1978.

Yours very truly, Iro 5 James S. Grant Vice President, Energy Supply TDM/hllG/ daw h