ML20133G757
| ML20133G757 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 09/24/1985 |
| From: | Williams J TOLEDO EDISON CO. |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 1-574, NUDOCS 8510160112 | |
| Download: ML20133G757 (2) | |
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%es EDISON License No. NPF-3 JOE WILLIAMS, JR Serial No. 1-574 s-e n+s -- w so: m noo H49;P n 5m September 24, 1985 Mr. C. E. Norelius, Director Division of Reactor Safety United States Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Norelius:
This letter revises Toledo Edison's previous response dated July 26, 1985 (Serial No. 1-547) to the Notice of Violation resulting from Inspection Report 50-346/85009 (Log No. 1-1177).
The following is Item I contained in the subject Notice of Violation.
Violation 1:
10 CFR 50, Appendix B, Criterion V, as implemented by the Toledo Edison Quality Assurance Manual, Section 17.2.5, required the licensee to prescribe activities affecting quality by documented procedures and to accomplish these activities in accordance with these procedures.
PT 5131.02, " Verification of Computer Calculations," states, "The frequency for performing this test shall be monthly at the beginning of a fuel cycle until the computer has been verified to consistently perform satisfactorily."
Contrary to the above, from the beginning of Fuel Cycle 5, which commenced Janua ry 15, 1985, through March 21, 1985, the licensee did not perform PT 5131.02 to verify, by hand calculations, the computer calculations of thermal power (346/85009-03 (DRS).
Toledo Edison's response to this item stated in part, "A new classification of test other than Surveillance Test (ST) and Periodic Test (PT) will be established to place a stronger emphasis on non-Technical Specification tests which have critical time restraints."
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Docket No. 50-346 License No. NPF-3 Serial No. 1-574 September 24, 1985 Page 2 The intent of this corrective action was to establish a means by which Toledo Edison personnel could differentiate between those pts which are required to be completed in a timely manner versus those pts where comple-tion of the test on a regularly defined frequency is less essential.
Upon further review and evaluation of the subject violation, Toledo Edison is revising the corrective _ action to be taken to avoid further noncompli-ance as follows:
All pts will be reviewed to determine if completion of the test is essential.
Periodic Tests requiring completion on regular intervals will be termed, " Critical Periodic Tests" and will be so noted on the Surveillance and Periodic Test Schedule. Administration Procedure AD 1838.02, Performance of Surveillance and Periodic Tests, will be revised to require that Critical Periodic Tests be completed on a timely basis.
The modifications to Administrative Procedure AD 1838.02 will be made by October 18, 1985.
PT 5131.02, Verification of Computer Calculations, has already been identified as a Critical Periodic Test on the Surveillance and Periodic Test Schedule. All other Periodic Tests will be reviewed and Critical Periodic Tests identified on the Surveillance and Periodic Test Schedule by April 4, 1986.
Toledo Edison has determined that this corrective action will establish a
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means by which Toledo Edison personnel can differentiate the importance of a Periodic Test without the necessity of creating a new classification of' test.
Very truly yours, JW/CAE/DJS cc: DB-1 NRC Resident Inspector