ML19329A950

Responds to NRC 780901 Ltr Re Violations Noted in IE Insp Rept 50-346/78-19.Corrective Actions:Program Established to Assure Sys Test Procedures Keep Untested Sys & Equipment from Being Used

ML19329A950
Person / Time
Site:	Davis Besse
Issue date:	09/22/1978
From:	Williamson J TOLEDO EDISON CO.
To:	Moseley N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML19329A940	List: ML19329A950
References
1-33, NUDOCS 8001270197
Download: ML19329A950 (4)

Text

.

n

\ -

(

c :. TOLEDO

% EDISON September 22, 1978 JOHN P. WILLIAMSON

~,,,a,n

" ' " ~ " "

Docket No. 50-346 License No. NPF-3 Serial No 1-33 Mr. N.C. Moseley, Director Division of Reactor Operations Inspection Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission

. Washington, D. C. 20555

Dear Mr. Moseley:

This is in response to your letter of September 1,1978, transmitting the notice of violation resulting from the site inspections concerning defects with the sequencer logic of the Safety Feature Actuation System of our Davis-Besse Nuclear Power Station Unit No. 1.

Appendix A, enclosed, sets forth in detail the action we have taken to

\

correct the items of noncompliance and to preclude future incidents of this nature, and indicates actions we have taken relating to the specific items of noncompliance listed in Appendix A to your September 1 letter.

With respect to the concern you expressed about the effectiveness.of our

, management control over testing activities, we are modifying the appro-priate administrative procedures to ensure proper control over modifica-tion to circuitry. Our response to infraction 2(b) discribes the action we are taking in this area.

I believe our response to Item 1, of your notice of violation, describes the extensive programs we have established to ensure that system test procedures are written and reviewed to assure that facility operation is not dependent on untested systems, equipment, or components.

Finally, to emphasize the importance of management controls, we are conducting a special program which will be attended by all station employees which emphasizes the importance of adherence to er tablished procedures in the operation of Davis-Besse Station.

Yours very truly,. .

[ W r*

_ JPW/JSG/pm

Enclosure:

Appendix A 8001270h)

THE TOLEGO EOISON COMPANY EOrSON PLAZA 300 MAO!SCN AVENUE TOLEDO. OHIO 43552

THE TOLEDO EDISON COMPA*

/

_,)

• APPENDIX A

+

Docket No. 50-346 This responds to letter dated September 1, 1978, from Mr. N.C. Moseley, Director, Division of Reactor Operations Inspection. The following will detail the correc-tive steps which have been taken relative to the items of noncompliance identified in Appendix A of Mr. Moseley's letter:

Item 1 Response:

1. Toledo Edison initiated a program to establish lists of design features for the following Engineered Safety Features and Support Systems generated by an independent group:

1.1 Containment Air Cooling System 1.2 Containment Spray System 1.3 Emergency Ventilation System 1.4 Safety Features Actuation System (SFAS) 1.5 Steam and Feedwater Rupture Control System (SFRCS) 1.6 Emergency Core Cooling System 1.6.1 Core Flood System 1.6.2 Decay Heat Removal System 1.6.3 High Pressure Injection Sys :em

.((^} _j 1.7 1.8 Containment Recirculation System Reactor Protection System (RPS) 1.9 Service Water System 1.10 Component Cooling Water System 1.11 Emergency Diesel Generators 1.12 Essential Switchgear These design features were reviewed against the preoperational tests for those systems by individuals not involved with the original performance of the system preoperational tests. Where additional testing was required, the testing was accomplished by modifying Surveillance Test Procedures and performing the tests to document results. Where design features were not tested, documentation and justification were provided. Toledo Edison Company Power Engineering and our architect-engineer were involved with the development.and subsequent review and testing of these design features.

This was done to verify and ensure adequacy of procedures to determine operability.

2. Safety-related procedures, relative to on site and off-site power systems, were reviewed and modified as necessary to ensure that design features were .

not inadvertently defeated or compromised by operator action. .

3. The SFAS was retested to verify that required design features provide the required system safety function.

[s}

(,_,/

4. Safety system logic drawings, where used as specification dr wings, were reviewed and compared with scheme drawings or vendor drawings to ensure there was no conflict.

- e

. - ~ . . _. . . . - . - . -- - _ ... - _ .

t Appendix A 4 l

i Item 1 Response--contd.

Corrective steps which will be taken to avoid further noncompliance:

)

-Administrative Procedure AD 1845, " Changes, Tests, and Experiments," has been revised to ensure that post installation / modification testing shall test those safety-related design features necessary to demonstrate operability prior to r 4

.teturning the system / component to service.

, Regarding the concern over adherence to established procedures, this matter

has attention and involvement at the vice-presidential level. We have

! established a program to place greater emphasis on adherence to procedures  ;

in.our training program.

. Toledo Edison Power Engineering has established requirements for our architect- '

engineer to include post installation / modification testing in appropriate  !

engineering documents.

Date when full compliance will be achieved

Full compliance will be achieved i on September 25, 1918.

2

. Item 2(a) Response:

i

! Corrective steps which have been taken and the results achieved:

1 Surveillance. Test Procedure ST 5031.07, "SFAS 18 MJnth or Refueling Test,"

was revised to incorporate testing those safety-related design features necessary, including the feature of the SFAS designed to cope with'a loss of off-site power followed by a safety injection signal (SFAS) to fulfill the requirements to demonstrate that the structures, systems, and components

. will perform satisfactorily in service. This Surveillance Test was success-fully completed on June 21, 1978.

Corrective steps which will be taken te avoid further noncompliance:

1 Adminirtrative Procedure AD 1845, " Changes, Tests, and Experiments," has been revised to ensure that post installation / modification testing shall

!* test those safety-related design features necessary to demonstrate that structures, systems,'and components will perform satisfactorily in service j ,

assuring operability.

Date when full compliance will be achieved: Full compliance will be achieved

, by September 25, 1978.

i ' Item 2(b) Response:

. Corrective ~ steps which have been taken and the results achieved:

i The circuitry abnormalities for the emergency diesel generator were corrected,

,  ? verified, and later tested in the performance of ST 5031.07, "SFAS 18 Month for Refueling Test," on June 21, 1978.

1 O' .

4 1.

.. . . . _ _ . _ _ . _ _ _ _ _ _ , . - . _ . . .-.~. _ .. . _ _ . _- . . _ _ . .

Appendix A Item 2(b) Response--contd.

Corrective steps which will be taken to avoid further noncompliance

Scheme checks in accordance with Procedure 1-C, " Scheme Verification Procedure,"

are no longer performed, as the procedure was applicable only to the preopera-tional and startup phase. However, Administrative Procedure AD 1845, " Changes, ,

Tests, and Experiments," provides the management controls to ensure proper control over modifications of circuitry. In addition, Administrative Procedure AD 1845, " Changes, Tests, and Experiments," has been revised to improve and clarify the management controls over modifications of circuitry.

Date when full compliance will be achieved: Full compliance will be achieved on September 25, 1978.

Item 3 Response:

4

.i j Corrective steps which have been taken and the results achieved:

The jumpers installed in cabinets CDF llA-2 and CDE llc slide links, affecting valves MS 106 and MS 106A, have been removed and the slide links closed. A program was performed to visually examine and ensure that slide links were in the correct position and screws were tight in the fellowing areas:

i l.1 Q Relay Cabinets 1.2 Safety-Related Cabinets SFAS, SFRCS, RPS s

1.3 Switchgear Performing Essential Functions Corrective steps which will be taken to avoid further noncompliance:

Administrative Procedure AD 1823.00, " Jumper and Lifted Wire. Control Proceduts," ,

has been revised to more clearly define its applicability to slide links. In.

addition, a rdview of outstanding jumper and lif ted wires has been performed i to ensure that slide links are in their proper position. Station personnel

have been informed of the importance of adherence to the management control requirements of JW 1823.00, " Jumper and Lifted Wire Control Procedure."

Date when full compliance was achieved: Full compliance was achieved on June 20, 1978.

i.

i e '

,s a .

-J -

r l

h-

_ _ .. . _