ML20054G282

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Responds to NRC Re Violations Noted in IE Insp Rept 50-346/82-02.Corrective Actions:Procedure Mod Completed 811222 & Personnel Counseled Re Minimizing Delays in Revision Process
ML20054G282
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 05/03/1982
From: Crouse R
TOLEDO EDISON CO.
To: Spessard R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20054G272 List:
References
1-266, NUDOCS 8206210368
Download: ML20054G282 (2)


Text

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TOLEDO

%mm EDISON Docket No. 50-346 Acau o p. cname Sce Pres dent License No. NPF-3

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Serial No. 1-266 May 3, 1982 Mr. R. L. Spessard, Director Division of Resident and Project Inspection U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Spessard:

Toledo Edison acknowledges receipt of your April 8, 1982 letter (Log 1-612) and enclosures and report 50-346/82-02-01, referencing the violation of Technical Specification 4.0.5.

This violation is listed as Severity Level IV (Supple-ment I).

Violation: Technical Specification 4.0.5 requires Inservice Testing of ASME Code Class 1, 2, and 3 components be conducted as per the require-ments of Section XI of the ASNI Boiler and Pressure Vessel Code and applicable Addenda.Section XI, Article IWV-3410(b)(1) of the ASME Boiler and Pressure Vessel Code requires exercising valves to the position required to fulfill their function at least at quarterly intervals or the next cold shutdown for inaccessible valves.

Contrary to the above, containment isolation check valves CV 124, CV 125, SA 502, IA 501, and NN 38 which had been last tested August 12, 1981, were not exercised during the cold shutdewn on November 16-30, 1981.

Response

(1) Corrective action taken and results achieved:

Following a similar occurrence on August 20, 1981, a major modification to Surveillance Test ST 5099.08, Miscellaneous Valves Quarterly Test was written and reviewed by the Station Review Board in a timely manner. The major modification was delayed during the typing and proofing stage and, therefore, had not been distributed for use.

This led to the second 8206210368 820615 PDR ADOCK 05000346 G

PDR THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO. OHlO 43652 W 10 882

F 1

Docket No. 50-346 License No. NPF-3 Serial No. 1-266 Page 2 occurrence of a missed test on December 15, 1981. The new revision to procedure ST 5099.08, which incorporated the major modification that grouped the five valves into one section, received final approval and was distributed for use on December 22, 1981. The surveillance testing computer schedule was also changed to incorporate the new section.

A modification was made to the Startup Checklist Procedure PP 1102.01 to reference this new section of ST 5099.08 in the Mode 4 Startup Checklist.

(2) Corrective action to be taken to avoid further non-compliance The delay in issuing the new revision of ST 5099.08 was the cause of the second occurrence. This delay is not typical and can be traced to a lack of prioritizing rather than a procedure methods problem. The individual responsible for maintaining priority and minimizing delays in the revision process of this procedure did not remain cognizant of the major modification status or expedite its processing. This lack of cognizance has been discussed with the responsible individual, emphasizing the consequences.

(3) The date when full compliance is achieved.

Full compliance was achieved when the major modification to ST 5099.08 was incorporated, and the new revision of this procedure was distributed for use on December 22, 1981.

Very truly yours, ff Pw RPC:JRL:ECC:ljk Attachment 1

cc: DB-1 NRC Resident Inspector