ML20154F996

Requests Addl Info Re Licensee Response to Generic Ltr 83-28,Items 3.2.1 & 3.2.2,submitted No Later than 881015

ML20154F996
Person / Time
Site:	Davis Besse
Issue date:	09/14/1988
From:	De Agazio A Office of Nuclear Reactor Regulation
To:	Shelton D TOLEDO EDISON CO.
References
DB-88-045, DB-88-45, GL-83-28, TAC-53748, NUDOCS 8809200211
Download: ML20154F996 (4)

Text

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• . l September 14, 1988 l

Docket No. 50-346 DISTREBUTLON: ,

Serial No. DB-88-045 Err,m es t i NRC & Local PDRS PDIII-3 r/f KPerkins MVirgilio PKreutzer ADeAgazio OGC-WF1 Mr. Donald C. Sheltnn Edordan BGrimes Vice President - fluclear ACRS(10) PDIII-3 Gray Files <

Toledo Edison Company Edison Plaza - Stop 712 300 Madison Avenue Toledo, Ohio 43652 l

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION - RESPONSE TO GENERIC LETTER 83-28(TAC 53748)

The NRC staff has perfonned a review o.' the information you provided in response to GL 83-28, items 3.2.1 and 3.2.2, and determined that the information is insufficient with regards to both these items. Your immediate attention in '

this matter is requested, since these issues have remained outstanding for 5 years. (he subject items are restated below for your infonnation, followed by  ;

a brief discussion of each item and guidelines for your use in preparation of t your additional submittals.

3.2 Post-Maintenance Testing (All Other Safety-Related Corrponents) i Position l The following actions are applicable to post-maintenance testing:

1. Licensees and applicants shall submit a report documenting the extending of test and maintenance procedures and Technical Speci-fications review to assure that post-maintenanct 7perab111ty testing of all safety-related equipment is required to be conducted and that f the testing demonstrates that the equipment is capable of perfonning  ;

its safety functions before being returned to service.

2. Licensees and applicants shall submit the results of their check of vendor and engineering recomendations to ensure that any appropriate test guidance is included in the test and maintenance procedures or the Technical Specifications where required.  !

l Docurrentation Required  ;

Licensees and applicants should submit a statement confirming that actions 3.2.1 and 3.2.2 of the above position have been implemented. '

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Mr. Donald C. Shelton Discussions with your staff in December 1987 did not result in assurance that the requirements as stated in GL 83-28 had been satisfied. Our staff has reviewed previous correspondence regarding the GL items; TED Procedure No.

AD1844.00, "Conduct of Maintenance"; and portions of the System 'deview and Test Program (SRTP). The procedure and the SRTP did not appear to be related to the post-maintenance items in the Generic Letter. Your letter dated December 18,1987 (Serial No.1454), described your configuration management program and proposed a schedule for completion of specific usks. One task was that of a vendor technical manual review to be completed by October 31, 1988, and that the vendor test recomendations be incorporated into surveillance and periodic test procedures by February 29, 1989. This task may partially satisfy GL item 3.2.2; however, the letter refers to "surveillance and periodic test procedures," and does not specifically state that maintenance procedures are included as part of the task.

According to the generic letter, you are required to submit a report documenting your actions regarding item 3.2.1, and to submit your results from item 3.2.2.

We suggest that these submittals restate your original commitments; respond to each in sufficient detail, specifically focusing on the GL issues (i.e., post-maintenance testing); and document completion or schedules for completion.

Your response should address the following:

1. Regarding item 3.2.1: ,

a. Review of plant test and maintenance procedures and Technical ,

Specifications, ensuring post-maintenance operability testing of all safety-related components is required. Include a description of all changes implemented as a result of the review,

b. Review of methods for perfonning #"9ctional testing of structures, systems, and components, followi.3 maintenance, to demonstrate that equipment is capable of perfonning its safety functions prior to being returned to service. Include a description of all changes implemented as a result of the review.

c. Criteria and responsibilities for review and approval of maintenance, and for perfonning inspections of post-maintenance testing activities.

2. Regarding item 3.2.2:

a. Review of vendor-recomended test guidance,

b. Review of engineering recomendations,

c. A description of changes implemented to ensure that vendor and engineering recomendations are included in test and maintenance procedures, or the Technical Specification, where required, i

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. . i 1 Mr. Donald C. Shelton  ! '

To maintain our review schedule, the information requested above for items 3.2.1 and 3.2.2 should be submitted not later than October 15, 1988.  ;

This request for additional information was approved by the Office of Management 8

and Budget under the control number 3150-0011 which expires September 30, 1989.

1 Comments on burden and duplication may be directed to the Office of Management i and Budget, Reports Menagement, Room 3208, New Executive Office Building, Washington, D.C. 20503. '

1 Sincerely, hl Albert W. De Agazio, Sr. Project Manager i Project Directorate III-3 l Division of Reactor Projects - III, IV, Y and Special Projects cc: See next page I

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! Office: ll 3 PM/PDIII-3 PD/P J I-3 l Surname: L A/PDi'rer PKreut ADeAgazio.tg KPe ing j Date: q / g /88 7 /g3 /88 C/ p /SS i

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Mr. Donald C. Shelton Davis-Besse Nuclear Power Station Toledo Edison Company Unit No. 1 cc:

David E. Burke, Esq.

The Cleveland Electric Radiological Health Program 111uminating Company Ohio Department of Health P. O. Box 5000 1224 Kinnear Road Cleveland, Ohio 44101 Columbus, Ohio 43212 Mr. Robert W. Schrauder Attorney General Manager, Nuclear Licensing Departrent of Attorney Toledo Edison Company General Edison Plaza 30 East Broad Street 300 Madison Avenue Coluctus. Ohio 43215 Toledo, Ohio 43G52 Mr. James W. Harris, Director Gerald Charnoff. Esq. (Addressee Only)

Shaw, Pittman, Potts Division of Power Gvneration and Trowbridge Ohio Department of Industrial Relations 2300 N Strcet N.W. 2323 West 5th Avenue Washington, D.C. 20037 P. O. Bnx 825 Columbus, Ohio 43216 Regional Administrator, Region III U.S. Nuclear Regulatory Commission Ohio Environmental Protection Agency 799 Roosavelt Road 361 East Broad Street Glen Ellyn, Illinois Co'umbus, Ohio 43266-0558 President, Board of Mr. Robert B. Borsum County Commissioners of Babcock & Wilcox Ottawa County Nuclear Power Generation Division Port Clinton, Ohio 43452 Suite 525, 1700 Rockville Pike Rockville Maryland 20852 State of Ohio Public Utilities Commission Resident Inspector 180 East Broad Street U.S. Nuclear Regulatory Commission Columbus, Ohio 43266-0573 5503 N. State Route 2 Oak Harbor. Ohio 43449 l

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