ML20112G532
| ML20112G532 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 03/08/1985 |
| From: | Crouse R TOLEDO EDISON CO. |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 1-505, NUDOCS 8504010149 | |
| Download: ML20112G532 (3) | |
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Docket No. 50-346 yotsoo License No. NPF-3 Serial No. 1-505
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March 8, 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 February 8, 1985 letter (Log No. 1-1112), and enclosures, Appendix A, Notice of Violation, and Inspec-tion Report No. 50-346/84-29(DRS).
Following an examination of the items of concern, Toledo Edison herein offers information regarding these items:
1.
Violation:
10 CFR 50, Appendix B, Criterion V requires that
" activities affecting quality shall be prescribed by documented instructions, procedures or drawings appropriate to the circumstances...."
Contrary to the above on December 9, 1984, the l
inspector identified that drawing M-029B was not appropriate in that it did not include a source valve for channel 3 of the Reactor Protection and Safety Features Actuation Systems. The valve was not tagged or included in tbe system procedures.
l This is a Severity Level IV violation (Supplement 1).
(346/84-29-01(DRS))
Response: (1) Corrective action taken and results achieved.
Deviation Report 84-188 was generated on December 9, 1984. The containment pressure lines for all chan-nels of the Reactor Protection and Safety Features Actuation Systems were walked down for similar source valves, none were found.
8504010149 850300 PDR ADOCK 05000346 G
PDR THE TOLEDO ED! SON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO, OHIO 43652 MAR 1 1985
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(2) Corrective action taken to avoid further noncompliance.
A temporary' modification (T-8557) was generated.to
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add - the. source ~ valve to Appendix B, Section - 3.6 of -
-ST 5061.01'= Containment Integrated Leak Rate Test.
-This modification places controls'on the source valve-for the Integrated Leak Rate Test..
A temporary modification (T-8729) was written to PP"1102.02,. Plant Startup Procedure,-to add a valve verification list to ensure critical safety system transmitters are verified in-service prior to plant heatup. This will add additional administrative controls to ensure correct line-ups of instruments.
e Facility Change Request (FCR) 84-0222 was initiated on December 10,-1984, to add the source valve (CV 74) to
' o' LP&ID Drawing M-029B.
. m (3) Date when full compliance will be achieved.
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.P&ID Drawing M-029B will be updated by a Draw.ing
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Change Notice-(DCN) by March 29, 1985.
2..
Violation:-
10 CFR Part 50, Appendix J, paragraph III.C.3 requires-that "The combined-lenkage rate for all
. penetrations and valves subject to Type B and C tests shall be less than 0.60 La."
Davis-Besse Technical Specification 3.6.1.2 paragraph b re-quires the combined leakage rate for all penetra-tions and valves subject to Type B and C tests, when pressurized to Pa be less than 0.60 La.
Contrary to the above, the licensee did not quan-tify the-leakage through various isolation valves and adequately calculate the combined leakage rate for penetrations and isolation valves during the 1980 outage. Failure to adequately calculate the combined leakage rate for penetrations and valves resulted in the licensee not knowing they had exceeded the 0.60 La limit.
This is a Severity Level V violation (Supplement 1 ) ~.
(346/84-29-03(DRS))
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IResponse: (1) Corrective: action -taken and results achieved.
Surveillance test procedure ST'5061.02, containment Vessel' Local Leak Rate Test, was modified (M-7576).
to. provide direction for measuring leakage using tije E*'
Pressure Decay Method if leakage flow rate'is'off-scale on the Local Leak Rate Test (LLRT) Panel Roto-meters.-
Local leak' rate testing conducted during the 1984 refueling outage quantified penetration leakage by
'the LLRT Panel =Rotometers or the Pressure Decay
' Method. During this testing. four containment iso-
- 1ation valves were found with leakage rates in excess of Technical Specification 3.6.1.2.b and 3.6.1.2.c.
This was reported per-10 CFR 50.72,. in Lic.casee Event
' Report 84-14.
s (2). Corrective action taken to avoid further noncompliance.
A temporary modification has been written to ST 5061.02, Containment Vessel Local Leak Rate Test, adding a step to the precautions and limitations identifying the re-quirement;to quantify the leakage rate for penetrations and valves subject to Type B and C tests.
With the procedural modification listed above and in Item 1. Toledo Edison feels sufficient controls are~in place to prevent recurrence of'the noncompliance.
(3) Date when full compliance will be achieved.
Full compliance with corrective actions has been achieved.
1
.Very truly yours, ffk=
r RPC:CER: A)M:SGW:nif '
cc:.DB-1 NRC Resident Inspector I
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