ML20198B497

Forwards Comments on Util Sys Review & Test Program,Assuring That Sys Important to Safe Plant Operations Fully Functional.Reliance on Previous Test Results to Demonstrate Functionality Should Be Minimized

ML20198B497
Person / Time
Site:	Davis Besse
Issue date:	10/28/1985
From:	Stolz J Office of Nuclear Reactor Regulation
To:	Williams J TOLEDO EDISON CO.
References
NUDOCS 8511060506
Download: ML20198B497 (4)

Text

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/ October 28, 1985 o r .

Docket No. 50-346 DISTRIBUTION 2 Docket Filef BGrimes Gray File Mr. Joe Williams, Jr. NRC PDR ~ JPartlow EBrach Vice President, Nuclear L PDR ACRS-10 H0rnstein Toledo Edison Company ORB #4 Rdg Ringram WPaulson Edison Plaza - Stop 712 HThompson CMcCracken GEdison 300 Madison Avenue OELD ADeAgazio Toledo, Ohio 43652 EJordan CVandenburgh

SUBJECT:

DAVIS-BESSE SYSTEM REVIEW AND TEST PROGRAM By letter dated September 10, 1985, Mr. Williamson, Chairman and Chief Executive Officer of Toledo Edison, provided the " Toledo-Edison Course of Action," (C0A) which describes the actions Toledo Edison intends to take to address and resolve the general concerns regarding Davis-Besse Nuclear Power Plant operations that were identified in our letter dated August 14, 1985 (H. Denton (NRC) to J. Williams (TED)). One part of the proposed C0A is the System Review and Test Program whose stated objective, among other things is to " prepare and conduct a test program to assure that systems important to safe plant operations are fully functional." NRC considers this program to be an important aspect of your Restart Course of Action and has therefore assigned a dedicated review team to perform a detailed review of the System Review and Test Program and to monitor its implementation.

Members of the NRC test review team were at the Davis-Besse site recently and held preliminary discussions with appropriate Toledo Edison staff. Although many of the specifics of the program are still developing, the discussions were beneficial to the NRC review team in that they provided the review team with a general understanding of the proposed program. Based on this general understanding, the review team has developed some general comments on the program and its direction. These comments are provided in the enclosure to this letter. We request that, as the System Review and Test Program develops, you submit information, as appropriate, that fully addresses each of these comment areas.

Should you have any questions regarding this letter or NRC review team activities, please contact Conrad McCracken (301) 492-8595 or Chris Vandenburgh (312) 790-5601.

Sincerely,

=c.uua w m ut J M J. M W *i John F. Stolz, Chief 8511060506 e51028 Operating Reactors Branch #4 PDR ADOCK 05000346 P PDR Division of Licensing

Enclosure:

As Stated cc w/ enclosure:

See next page g jy u p

ORB #4:DL ORB #4:DL AC[:g:DL / f U CMcCr cken;cr GStolz GLc inas M.JACKiW 10/,2 /85 /85 10/ /85 jggy

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Mr. J. Williams Toledo Edison Company Davis-Besse Nuclear Power Station Unit No. I cc: t Donald H. Hauser, Esq. Ohio Department of Health The Cleveland Electric ATTN: Radiological Health Illuminating Company Program Director P. O. Box 5000 P. O. Box 118 Cleveland, Ohio 44101 Columbus, Ohio 43216 _

Mr. Robert F. Peters Attorney General Manager, Nuclear Licensing Department of Attorney Toledo Edison Company General Edison Plaza 30 East Broad Street 300 Madison Avenue Columbus,_0hio 43215 i Toledo, Ohio 43652 Mr. James W. Harris, Director Gerald Charnoff, Esq.

Shaw, Pittnan, Potts Division of Power Generation

. and Trowbridge Ohio Depar.tment .of Industr.ial Relations P

1800 M Street, N.W. 2323 West 5th Avenue I P. O. Box 825 Washington, D.C. 20036 Columbus, Ohio 43216 Paul M. Smart, Esq. Mr. Harold Kohn, Staff Scientist Fuller & Henry Power Siting Commission 300 Madison Avenue ' 361 East Broad Street P. O. Box 2088 Columbus, Ohio 43216 Toledo, Ohio 43603 Mr. Robert B. Borsum President, Board of -

Babcock & Wilcox Ottawa County Nuclear Power Generation , Port Clinton, Ohio 43452 Division Suite 200, 7910 Woodmont Avenue j Bethesda, Maryland 20814 --

Resident Inspector .

U.S. Nuclear Regulatory Commission 5503 N. State Route 2

! . 0ak Harbor, Ohio 43449 4

' Regional Administrator, Region III U.S. Nuclear Regulatory Commission '

799 Roosevelt Road Glen Ellyn, Illinois 60137 O

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.. . un DAVIS-BESSE SYSTEM REVIEW AND TEST PROGRAM COMMENTS 1.

Information should be submitted which provides a detailed description of the System Review and Test program (SRTP) process. Reference should be ~

made, where appropriate, to any "special administrative" and " traditional" administrative procedures upon which the program relies. This description should specifically addr.ess how the proposed SRTP will fully satisfy each of the program objectives identified in the September 9,1985 Course of Action (C0A): Report.

2.

Particular consideration should be given to how SRTP will meet the fifth stated objective of assuring that systems important to. safe plant opera-

-tions are fully functional.

If SRTP intends to rely, to any degree, on other test programs, such as surydillance and periodic tests, to achieve 4

the fifth objective, then a detailed description should be provided which describes how SRTp will interact with these other test programs to witness tests, review test results, etc., and otherwise assure that the systems important to safe plant operations have been demonstrated to be fully functional.

3.

Reliance upon previous test results to demonstrate that systems are func-tional should be minimized. Only in exceptional cases where, for example, it is not prudent to run a particular test, or where a fully satisfactory test has been completed in the recent pas't, should previous test results

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scos au co 'astus WHilhLLt LOLUMBUS 14U9111 U6 be considered. -Specific justification should be submitted for each such instance.

4. With respect to systems falling under SRTP, a specific justification k

should be provided for each safety-related system that is not considered ~

to be important to safe pla.nt operations. Justifications may be provided on a generic basis for common items such as any structural components that are being excluded from SRTP, but should be on a system-specific basis for process and/or stand-alone systems such as the polar crane.

PendingfurtherSRTPdefinitionanddiscussion, safety-reiated' systems 4

~s hould be considered to be those (1) included on the Davis-Besse Q-list, 4

(2) included in the Davis-Besso technical specifications, and/or ~

(3) relied upon for mitigation or prevention of design basis accidents (USAR,Section15).

5. In general, the degree of docupentation and specificity for the SRTP should be such that the NRC test review team can ultimately gain assu'r'ance that (1) the SRTP will fulfill its stated objectives, (2) the appropriate systems and system functions have been included in SRTP, (3) that the

. proposed SRTP tests will adequately demonstrate that the systems function in the anticipated configurations and operating conditions (4) that the ,

tests are properly performed and test results properly reviewed, and

. (5) that any and ail exceptions related to SRTP' are adequately documented, justified, reviewed, and approved.

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