ML20113E271
| ML20113E271 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 01/18/1985 |
| From: | Crouse R TOLEDO EDISON CO. |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| References | |
| 1114, GL-83-28, NUDOCS 8501230387 | |
| Download: ML20113E271 (4) | |
Text
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Docket No. 50-346 TOLE"10 EDISON License No. NPF-3 Ro.uo p Cww Serial No. 1114 CU" January 18, 1985 a wa Director of Nuclear Reactor Regulation Attn.:
Mr. John F. Stolz Operating Reactor Branch No. 4 Division of Licensing United States Nuclear Regulatory Co= mission Washington, D.C.
20555
Dear Mr. Stolz:
By letter dated July 31, 1984, Toledo Edison Company (TED) submitted an overview of preliminary activites being pursued '~ response to the con-cerns of Sections 2.2.2 and 3.2 of Generic Lett 3-28 (Log No. 1322), at the Davis-Besse Nuclear Power Station, Unit No. 1.
Generic Letter 83-28, dated July 8, 1983, is entitled " Required Actions Based on Generic Impli-cations of Salem AWS Events".
Since that time, Toledo Edison has continued to make progress in its review and understanding of the concerns of the Generic Letter (GL), as well as implementation of actions in response to those concerns.
This letter is provided to update the current status and long range plans and schedules for the implementation of actions to respond to the CL, Sec-tions 2.2.2 and 3.2 The Toledo Edison ATUS/ Salem Program Management Group (PMG) is ensuring that proper management attention is given to these issues. The PMG itself has been chartered to:
Interpret the requirements of the Generic Letter and concerns of NUREG 1000.
Identify actions necessary to address AWS/ Salem issues at the Davis-Besse Nuclear Power Station. Unit No. 1 (DB-1).
Develop plans and schedules to implement the necessary program upgrades responsive to ATWS/ Salem issues.
Ensure necessary resources are identified and available to meet those schedules.
THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO. OHIO 43652 050123Q70 0 03 6 PDR AD PDR f
Dockst No. 50-346 Licence No. NPF-3 Serial No. 1114 January 18, 1985 Page 2 The status of the Group's activites, to date, with regard to the Vendor Equipment Technical Infornation Program and Post-Maintenance Testing are l
discussed below.
Vendor Equipment Technical Information Program The Program Management Group has reviewed the Nuclear Utility Task Action Committee (NUTAC) report concerning the " Vendor Equipment Technical Information Program" (VETIP). A program built upon the NUTAC program format is being studied at Toledo Edison.
A Program procedures needing development to control vendor related informa-tion available to Davis-Besse will be identified. The sources of informa-tion include:
Vendor Technical Bulletins
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SEE-IN Program Information Nuclear Plant Rcliability Data System (NPRDS) Program Implementation 7
B&W Geners Information (Preliminary Safety Concerns (PSC's),
and Owner Activites) 10 CrR 21 Reports 10 CFR 55(c) Reports Licensee Event Reports (LER's) from Other Plants Office of Inspection & Enforcement (I&E) Information Notices Vendor Representative Contacts Vendor Manual Updates, Revisions The plan for implementation of a Vendor Equipment Technical Information Program is as follows:
1.
A survey will be conducted to ascertain all mechanisms through which equipment information enters the Davis-Besse Nuclear Power Station, Unit No. 1 (DB-1). The survey will result in documen-
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tation of the types of information, the processes for dissemina-tion of that information, and the administrative controls pre-sently in place to ensure adequate evaluation is given to appro-
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priate information, i
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A review of the survey results will be performed against the vendor interface program guidance provided in the Generic Letter 83-28 NUREG 1000, and the NUTAC VETIP, as proposed.
3.
Specific deficiencies, redundancies, and conflicts regarding this information will be identified and analyzed.
4 Program enhancements will be identified.
Dockat No. 50-346 Licens2 No. NPI'-3 Serial No. 1114 o
January 18, 1985 Page 3 i
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The program enhancements will then be developed and implemented in accordance with the Integrated Living Schedule Program (ILSP).
1 Post-Maintenance Testing As discussed in the Toledo Edison response to GL 83-28 (Serial No. 1000, l
dated November 7,1983), all maintenance performed at DB-1 is controlled by a Maintenance Work Order (HWO) as delineated in Administrative Procedure AD 1844.00, " Maintenance". This procedure was established to ensure that maintenance is performed, planned and documented in accordance with the requirements of the Toledo Edison Nuclear Quality Assurance Manual, and all applicable regulatory requirements.
Since issuance of the Toledo Edison GL 83-28-response, specific enhancements have been made to the AD 1844.00 procedure to ensure its responsiveness to GL 83-28 sections 2.2 and 3.2.
These enhancements are discussed herein.
Within the MWO process, any required procedural guidance for nuclear safety related work shall be acceeplished through the use of appropriate procedures, reviewed by the Station Review Board (SRB), and approved by the Plant Manager.
Testing requirements are established by the MWO originator and are reviewed for adequacy by an Operations Department staff person, who presently holds or has held a Senior Operating License. The Shif t Supervisor, who holds a Senior Operating License, also reviews testing requirements upon completion of maintenance, prior to returning equipment to service. These reviews ensure that post maintenance testing of safety related components demon-strates that the equipment is capable of performing its safety functions.
All nuclear safety related MWO's have the testing requirements identified and reviewed, as discussed above. Equipment for which operability is mandated per the Technical Specifications requires an Enclosure 13 to the MWO. The Enclo6ure 13. " Tech Spec Equipment Operability Checkoff List",
ensures that the necessary redundant equipment is available prior to removing the component f rom service. Additionally, the post-maintenance testing re-quirements are specified on this enclosure. Nuclear safety related HWO's are approved by the Lead Support Engineer or his designee, and reviewed by the Quality Control Department to determine any inspection requirements.
In response to the GL 83-28 Sections 2.1 and 3.1. Toledo Edison is performing a review of the appropriate Reactor Trip System procedures. The intent of this review is to assess the adequacy of vendor manual information incorpora-tion. Additionally, the procedure review will assess the level of incorpora-tion of vendor and engineering recommendations to ensure that any appropriate i
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Dockst No. 50-346 Licensa No. NPF-3 Serial No. 1114 January 18, 1985 Page 4 test guidance is included in the test and maintenance procedures, where required. This program is discussed further in Toledo Edison letters, Serial No.1024 and 1111, dated February 10, 1984 and December 21, 1984, respectively.
The results of this review will be utilized in the development, as neces-sary, of a program f or all safety related components as specified in Generic Letter 83-28. Section 3.2.
The program developed to address these concerns will be implemented in accordance with the Integrated Living Schedule Program.
As discussed in the NUTAC position with regard to a vendor interface program and as endorsed by Toledo Edison, no generic formal vendor inter-face program is being implemented at Toledo Edison. As such, additional vendor recommendations will only be reviewed for test requirement guidance as applicable to the final VETIP implemented at Davis-Besse.
Toledo Edison understands the importance of this activity and as such, will continue to proceed towards resolution of the concerns identified in Generic Letter 83-28.
Very truly yours,
[b T 'b "
RPC:JSH/DLM:nif cc: DB-1 NRC Resident Inspector
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