ML20101N575
| ML20101N575 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 11/29/1984 |
| From: | Crouse R TOLEDO EDISON CO. |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20101N559 | List: |
| References | |
| 1-481, NUDOCS 8501040090 | |
| Download: ML20101N575 (2) | |
Text
-
t,:
Docket No. 50-346 voteoo
%ms EDISON License No. NPF-3 Roomo P. CAOUSE Serial No. 1-481 u pm nawa
)
November 29, 1984 4
Mr. C. E. Norelius, Director Division of Reactor Projects United States Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, 1111nois 60137 l
Dear Mr. Norelius:
This letter is to revise Toledo Edison's letter of August 17, 1984 (Serial No. 1-459), responding to your July 11, 1984 letter (Log No. 1-992),
Inspection Report 84-09.
Toledo Edison has discussed with the Davis-Besse Nuclear Regulatory Commission (NRC) Resident Inspector the additional administrative burden our initial response to Violation No. 1 (84-09-02) can impose during an extended outage. This administrative burden was highlighted during our current refueling outage and discussions with the NRC Resident Inspector, have led to our revised response to this item:
1.
Violation:
10 CFR 50, Appendix b, Criterion V, as implemented by Toledo Edison Quality Assurance Program as de-scribed in Section 17.2.5, including a commitment to ANSI N18.7-1972, requires that activities affecting quality be prescribed by documented instructions and procedures. Section 5.1.5 of-ANSI 18.7-1972, and Section 1.C.6 of NUREG-0737, require independeat verification of tagging activi-ties relative to removal from and return to service of plant equipment.
Contrary to the above, no procedure or requirement existed for independent verification of tagging plant equipment out of service.
Response: (1) Corrective action taken and results achieved.
A February 11, 1982 letter (Log No. 902), from Nuclear Reactor Regulation (NBR) concluded that Toledo Edison had met the requirements of NUREG-0737, Item I.C.6_for guidance on procedures for verifying correct perform-ance of operating activities.
THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO. OHIO 43652 8501040090 841219 DEC 5 ES4 PDR ADOCK 05000346 G
____PDR
J
. ff s J,
D'ockst No. 50-346 2
I-
" License No.'.NPF-31
' Serial No. 1-481
. November 29, 1984' Page 2, t
Since initial operation of Davis-Besse, Toledo Edison.
.has used maintenance personnel for'independentiverifi-cation for. placement of tags for~ removal of equipment
- from service. The extent of verification has been governed by. Administrative Procedure AD 1803.00,
" Safety Tagging".. It is our understanding that our
. method of-independent verification as practiced in.the
. procedure does not satisfy the Region III interpreta-tion of independent' verification for all circumstances.
(2) Corrective action to'be.taken to avoid further noncom-:
pliance.
f A modification will be made to Administrative. Procedure.
AD 1803.00, " Safety Tagging", which will incorporate independent verifications ' for removal and. return to service to plant equipment by knowledgeable Operations Department personnel for systems affecting plant safety.
This modification to the procedure will specify the applicable systems.
During extended plant outages, however, Administrative Procedure AD 1803.00 will not be used to control independent verifications for equipment for systems being returned to. service.
In these conditions, independent valve lineups will be performed to. assure proper system alignment for returning the system.to service during plant startup. ' Procedure PP 1102.01,
" Pre-Startup Checklist" will be modified to require the Operations Engineer to designate when independent system lineups are to be performed. Procedure AD 1839.00, " Station Operations", will also be modified to include a new section on independent verification-requirements.
(3) Date when full compliance will be achieved.
Procedure modifications.to AD 1839.00, " Station Operations" AD 1803.00, " Safety Tagging", and PP 1101.02, " Pre-Startup Checklists", will be implemented by December 31, 1984.
e
.Very truly;yours, I
98P W y I
RPC:WTO:SGW:nif-cc: DB-1 NRC Resident Inspector' f
4..
,.--