ML20099K276

Responds to Re Violations Noted in Insp Rept 50-346/84-28.Corrective Actions:Crd Sequence Alarm Circuitry Test Incorporated Into ST 5010.03, Post-Refueling Physics Testing, on 850102

ML20099K276
Person / Time
Site:	Davis Besse
Issue date:	02/15/1985
From:	Crouse R TOLEDO EDISON CO.
To:	Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
1-499, NUDOCS 8503200224
Download: ML20099K276 (5)

Text

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pmg Docket No. 50-346 yottoo License No. NPF-3 Serial No. 1-499 N$ce

" a sSsaai February 15, 1985 Mr. C. E. Norelius, Director Division of Reactor Projects United States Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr.,

Norelius:

Toledo Edison acknowledges receipt of your January 18, 1935 letter (Log No. 1-1099), and enclosures, Appendix A, Notice of Violation, and Inspec-tion Report No. 50-346/84-28 (DRP).

Following an examination of the items of concern, Toledo Edison herein offers information regarding these items:

1. Violation: 10 CFR 50, Appendix B, Criterion XVI, Corrective Actions, states in part, " Measures shall be estab-lished to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, devia-tions, defective material and equipment, and noncon-formances are promptly identified and corrected."

The Toledo Edison QA Manual section 16.1.1 states in part, " Division Directors shall develop proce-dures to ensure that conditions adverse to quality such as equipment failures, equipment malfunctions, procedure deviations, defective material and equip-ment, and deviation to regulatory rules and require-ments are promptly identified, documented and cor-rected."

Contrary to the above, the licensee did not take prompt corrective action to establish procedures to test the computer alarms associated with control rod positions. In the response to NRC Inspection Report 82-34, the licensee stated that by April 15, 1983, the asymmetric rod fault alarm circuit test would be incorporated into the monthly rod exercise test and by startup from the 1983 refueling outage, the zero power physics test would be modified to

'I 0 THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO, OHlO 43652 8503200224 050215 PDH ADOCK 05000346

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- Docket- No. 50-346 1 ' License No. NPF-3 Serial No.z1-499 LFebruary.15,'1985

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' v includA a check of the control rod drive sequence alarm circuitry. As of December 1984, the appro-priate procedures had not been modified to include the required tests.

This is a Severity Level IV violation (Supplement 1).

? Response: (1) . Corrective action taken and results achieved.

In our letter of March 9,1983 (Serial 1-334), Toledo

-Edison committed to incorporate the asymmetric rod fault alarm circuitry test into the control rod exercise monthly test.

The bases for incorporating the alarn circuitry test

'into ST 5013.03, which is performed at each refueling outage, was submitted to 'the NRC Region III on January 3, 1985 (Serial 1-489).

.The Control Rod Drive Sequence Alarm circuitry test was incorporated into ST 5010.03, Post Refueling Physics Testing, by temporary modification T-8808 on January 2,11985.

(2) Corrective action taken to avoid further noncompliance.

' Toledo Edison has increased its' attention to commit-ments made.to the NRC since March,L1983. Procedures were developed and implemented for identifying and

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tracking commitments. Additionally, in November.

1984 Toledo Edison implemented a new computerized commitment tracking system.

With the addition of three personnel.to the Licensing staff'and the above mentioned changes, Toledo Edison believes appropriate corrective action has been taken to prevent recurrence.

(3) Date when full compliance will be achieved.

Full compliance with corrective actions was achieved on January 2,1985.

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. License No. NPF-3.

LSerial No.'l-499 February ~ 15, 1985 Page 3

2. Violation: Technical Specification Surveillance Requirement 4.7.9.3 requires a visual inspection of all fire hose stations listed in Table 3.7-4 every 31 days.

Technical Specification 4.0.3 states that " Perform-acce of a Surveillance Requirement within the speci-fied time intertal shall constitute compliance with OPERABILITY rr .irements for a Limiting Condition for Operation and Associated Action statements unless otherwise required by the specification. Technical.

Specification Limiting Condition-for Operation 3.7.9.3 requires the fire hose stations listed in Table 3.7-4 to be operable. If a fire hose station is inoperable an equivalent capacity hose must be routed to the un-protected area from an operable hose station within one hour.  !

I Contrary to the above, the inspector found that the [

31 day surveillance requirement (ST5016.09) for visual inspection of fire hose stations was not met, including i the-25% grace period allowed for in the Technical [

Specifications.

t This is a Severity Level IV violation (Supplement I).  ;

i Response: ~(1) Corrective action taken and results achieved. I ff ~  ?

On August 21, 1984, at 0855 hours0.0099 days <br />0.238 hours <br />0.00141 weeks <br />3.253275e-4 months <br />, the Technical Speci- [

fication late date was exceeded for Surveillance Require-. i ment 4.7.9.3a, which calls for a monthly check of the ,

fire hose stations to assure all required equipment is at the hose station. The Fire Hose, Fire Hose Stations, )

and Fire System Valve Testing. ST 5016.09, was in pro- l gress at the time.- ST 5016.09 was completed at 1430 hours0.0166 days <br />0.397 hours <br />0.00236 weeks <br />5.44115e-4 months <br /> on August 21,'1985, and the results indicated that  ;

all required equipment was available at the fire hose stations. ,

(2) Corrective action taken to avoid further noncompliance.  ;

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p On October 1,1984, the Surveillance Test Schedule  !

System was converted to the Davis-Besse Maintenance Management System (DMBBS). The DBMt'3 provides exact 6 Technical Specification late date information. A Critical Surveillance Test Report lists tests which l are getting close to the Technical Specification late  ;

date and this is reviewed daily by the Technical  :

Section. ,

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d Dockst Ns. 50-346 License No. NPF-3

. Serial No. 1-499 February 15, 1985 Page 4 (3) Date when full compliance will be achieved.

Full compliance with corrective action has been completed.  ;

3. Violation: 10 CFR 50.73(a)(2)(1)(B) requires the holder of an operating license to submit a Licensee Event Report i to the NRC within 30 days after the discovery of any operation or condition prohibited by the plant's Technical Specifications.

Contrary to the above, the inoperability of the Technical Specification Table 3.7-4 fire hose stations was not reported to the NRC within 30 days.

This is a Severity Level IV violation (Supplement I).

Response: (1) Corrective action taken and results achieved.

On August 21, 1984, when the Technical Specification late date for the Table 3.7-4 hose stations was ex-ceeded by five hours, a Deviation Report (DVR 84-139) .

was written to document the occurrence. When the re-porting requirements of 10 CFR 50.73 were reviewed, the event was determined to be not reportable to the NRC.

This determination was based on comparing Technical Specification 3.7.9.3 with Technical Specifications 3.7.9.1, 3.7.9.2, and 3.7.10, which allow at least seven days to restore equipment to operable status I without initiating a Special Report to the NRC.

i Additionally, since Technical Specification 3.0.3, which would require a unit shutdown, is not applic-able to Technical Specification 3.7.9.3, the event was not considered reportable per 10 CFR 50.73(A)(2)

(i) (A) .

On November 23, 1984, during an exit with the Davis-Besse NRC Resident Inspector, it was brought to Toledo Edison's attention that the event was reportable. This is based l upon NRC interpretation of 10 CFR 50.73(a)(2)(1)(B), that

[ failure to be able to comply with any individual Technical Specification Limiting Condition for Operation is report-able.

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, DockSt.Ns.'50-3'46 License.No. NPF-3

. Serial No.-1-499 February 15, 1985

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A Deviation Report (DVR 84-177) was initiated identi-fying reportability of the. event, which was due'at the NRC by December 23 1984, to meet the-requirements of 10 CFR 50.73. Licensee Event Report (LER) 84-17 was not mailed until December 26, 1984.

In an NRC inspection exit on February 1,~1985, the Resident Inspector identified four additional LER's during.this same time frame that exceeded the 30 day requirement of 10 CFR 50.73.- The 1984 Refueling Out-age was nearing completion during this time frame and consequently the 30 day requirement did not receive the highest priority, resulting in late submittals.

(2) Corrective action taken to avoid further noncompliance.

Toledo Edison has placed increased emphasis on assigning due dates for activities in the LER reporting process to allow adequate time for review and approval by .

' Davis-Besse personnel and ensure the 30 day reporting criteria is met.

-(3) Date when full compliance will be achieved.

Full compliance with corrective actions has been achieved.

Very.truly yours, p__

RPC:SCW:nif

-cc: DB-1 NRC Resident Inspector J