ML20212P252
| ML20212P252 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 08/14/1986 |
| From: | Williams J TOLEDO EDISON CO. |
| To: | Paperiello C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 1-645, NUDOCS 8609030049 | |
| Download: ML20212P252 (15) | |
Text
a TOLEDO EDISON Docket No.-50-346 JOE VVILUAMS. JR so ,w.n s.m .eu w
[419; 249 P300 License No. NPF-3 (419124a s222 Serial No. 1-645 August 14, 1986 Mr. C. J. Paperiello, Director Division of Reactor Safety United States Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Dear Mr. Paperiello:
Toledo Edison has received Inspection Report No. 50-346/85039 (Log No.
1-1352) and Inspection Report No. 50-346/86009 (Log No. 1-1390) and provides the following response. This response also contains information pertaining to Inspection Report No. 50-346/86015 (Log No. 1-1431).
It should be noted that these nonconformances were discovered during Toledo Edison's System Review and Test Program (SRTP). The SRTP was .
established following the June 9, 1985 loss of feedwater event to review '
the history of systems important to the safe operation of the Davis-Besse Nuclear Power Station. As discussed in the Davis-Besse Course of
! Action (C0A), Serial No. 1182, these reviews are intended to: 1) identify i
problems which may impact the ability of those systems to perform the necessary functions for safe operation of the plant; 2) identify the corrective actions necessary to resolve those problems; and 3) identify any special testing of the systems that should be performed during restart.
The program also provides for review of the scope of surveillance testing conducted and identification of additional testing which is necessary to assure systems will perform their intended functions.
Violation: LER 85-022, Inadequate Post-LOCA flow to Containment Air 85039-01 Cooler (CAC) Units. During the review of the Service Water (SW) system as part of the SRTP, it was determined that only one of two independent trains of CAC would provide the required cooling during post-LOCA conditions. The report i stated that Technical Specification 3.6.2.2 which requires at least two independent containment cooling units to be operable had been violated and that this condition had existed since original startup. Two trains of SW supply cooling to the three CAC units. Upon receipt of a Safety 8609030049 860014 PDR ADOCK 05000346 G PDR EDISON PLAZA 300 MAD 1 SON AVENUE TOLEDO, OHIO 43652 THE TOLEDO EDISON COMPANY
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Docket No. 50-346 License No. NPF-3
, Serial No. 1-645 August 14, 1986 Page 2
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l Features A'ctuation System (SFAS) actuation signal, two of
'the three CACs will start ia low speed. An original design deficiency exists in that the SW cooling water supply to the non-running CAC is not isolated in the post-LOCA condi-tion. This results in shared SW flow to the running and non-running CAC and therefore less than design SW flow and cooling to the operating CAC. The design problem continued to exist because the surveillance tests written to satisfy the technical specification requirements do not ensure that adequate SW flow is available to the CACs. This condition has existed since the plant entered Mode 3 on July 24, 1977 and was identified by the performance of the SRTP on November 30, 1985.
Failure'to comply with Technical Specification 3.0.2.2 due
- to an original design deficiency is a violation.
Response: Acceptance Or Denial Of The Alleged Violation i
Toledo Edison acknowledges the alleged violation.
Reason For The Violation The apparent root cause of this condition is inadequate design / design verification testing during the plant
< preoperational startup phase in addition to inadequate surveillance testing as was previously identified in LER 85-022.
4 The system design /preoperational design verification testing reviewed the system using the proper post-LOCA l system conditions, two Containment Air Cooler (CAC) units with service water isolated to the non-operating CAC unit; however, the effect of a loss of the valve operating air was not appropriately considered when determining isolation i capabilities of the Service Water (SW) valves.
The SW Outlet Isolation Valves are air-operated ball valves designed to fail open to ensure adequate service water flow to the CAC units during accident conditions.
The valve operating air consists of Instrument Air, a non-seismically qualified, non-safety related system, and l a backup Air Volume Tank. The reliability of the operating
! air after an accident is questionable. It is assumed that after an accident the air sources cannot be relied on to operate the SW Outlet Isolation Valves.
Docket No. 50-346 License No. NPF-3 Serial No. 1-645 August 14, 1986 Page 3 1
In the event of a Loss of Coolant Accident (LOCA), the Safety Features Actuation System (SFAS) signal causes the operating CAC units to stop and two (2) of the units to start in slow speed. The SW Outlet Isolation Valves for the operating units open to their full open position to allow full service water flow through each air cooler. The SW Outlet Valve of the secured CAC unit would then be' shut by air pressure; however, since valve operating air cannot be relied on post-accident, the valve must be assumed to remain open. The final configuration would be: two CAC units running in slow speed and the SW Outlet Isolation Valves open to all three CAC units, including the non-operating CAC unit.
Additionally, Surveillance Test (ST) 5063.02, " Containment Air Cooling System Refueling Test", did not adequatel '
verify system operability (i.e., system lineup to ensure appropriate service water flow to the CAC units).
ST 5063.02 verifies proper system lineup of each cooler individually; however, it does not verify that one of the units stops and its SW Outlet Isolation Valve shuts.
Corrective Actions To Be Taken To Avoid Further Violations The Air Volume Tanks for the SW Outlet Isolation Valves will be upgraded prior to. entering Mode 3 to provide a motive source for valve closure which can be relied on following an accident. This will ensure closure of the SW Outlet Valve for the standby CAC unit.
ST 5063.02 will be revised prior to entering Mode 3 to verify that the standby CAC unit and its respective SW Outlet Valve will close upon an SEAS actuation.
In addition, as stated in the COA, Toledo Edison's upgrade program includes the formation of a Systems Engineering group. The Systems Engineers have been assigned specific systems and are responsible for developing a detailed j
knowledge of their systems. One of the group's responsibilities will be to review the appropriate portions of the preventative maintenance program and surveillance test program to ensure system operability is maintained and verified by testing.
Toledo Edison notes that discrepancies associated with j proper stroking tine of the CAC SW Outlet Valves also i have been identified and are currently being resolved in plant modifications and testing. Additional LERs describing this problem will be submitted by August 18, 1986.
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9 Docket No. 50-346 License No. NPF-3 Serial No. 1-645 August 14, 1986 Page 4 Date When Full Compliance W111 Be Achieved ST 5063.02 will be revised and the upgrade of the Air Volume Tank will be completed prior to entering Mode 3.
The Systems Engineering group has been formed as described in the Davis-Besse Course of Action.
Violation: LER 86-001, Inadequate SW Building Ventilation. During 85039-02 the review of problem reports on the SW system as part of the SRTP, it was determined that the as-built configura-tion of the SW Pump Room Ventilation System was inadequate to provide the required ventilation design flows during post-LOCA conditions. The report stated that Technical Specification 3.7.4.1 which requires two independent SW trains to be operable had been violated and that this condition had existed since 1983. Facility Change Request (FCR)81-054 was implemented on November 29, 1984 to up-grade the dilution pump to function as a backup SW pump to meet Appendix R dedicated shutdown criteria. FCR 81-054 required the addition of a wall that cut one of the two SW Pump Room Exhaust Vents in half. This resulted in only a small amount of air being drawn through the SW Pump Room and limited the cooling capabilities of the SW Pump Room Ventilation System. The licensee has determined that had the design post-LOCA heat loads been produced with an outside temperature of 95 degrees, the ventilation system could not have removed the heat from the SW Pump Room which would have resulted in a failure of the SW Pumps and a loss of SW supply to safety-related loads. The root cause of this occurrence is an inadequate technical review of the modification to the ventilation system including the lack of post modification testing. This condition has existed ,
since FCR 81-054 was implemented on November 29, 1984 and '
was identified during the performance of the SRTP on December 12, 1985.
Failure to comply with Technical Specification 3.7.4.1.:Ls a violation, i
i i
Docket No. 50-346 License No. NPF-3 Serial No. 1-645 August 14, 1986 Page 5 Response: Acceptance Or Denial Of The Alleged Violation Toledo Edison acknowledges the alleged violation.
Reason For The Violation The cause of the inadequate Service Water Pump (SWP) Room ventilation has been determined to be the lack of an adequate technical review of the FCR which upgraded the wall between the SWP Room and the Dilution Pump. This inadequacy also included the lack of appropriate post-modification testing. It should be noted that although the post-implementation actions of FCR 81-054 were completed on November 29, 1984, the SWP Room ventilation modifications were completed in the last quarter of 1983.
The SWP Room Ventilation System was modified in 1983 as a result of a design change that upgraded the Dilution Pump to function as a backup Service Water Pump to meet Appendix R dedicated shutdown criteria.
The wall between the SWP Room and the Dilution Pump had to be upgraded to a three (3) hour fire wall which resulted in the closing of the original air inlet to the SWP Room.
The exhaust fans were installed external to the SWP Room within a missile shield and a new air inlet port was installed in the SWP Room roof. However, shrouding separating the fan suction from the exhaust and backdraft dampers was not called for in the design. This condition allowed the operating fans to recirculate their exhaust around and through the idle fans. This resulted in only a small amount of air being drawn through the room and limiting the cooling capabilities of the ventilation system.
Corrective Action Taken and Results Achieved Service Water Pump high temperature alarms were received during the summer of 1984. Temporary fans were installed in the SWP Room which remedied these high temperature problems. Facility Change Request (FCR)84-147 was initiated to provide permanent modifications to the SWP Room ventilation.
Following the June 9, 1985 loss of feedwater event, the v SRTP review of the SWP high temperature alarms and the SWP Room Ventilation System found that the ventilation flows from the SWP Room were less than the original design values.
Docket No. 50-346 License No. NPF-3 Serial No. 1-645 August 14, 1986 Page 6 The recommended corrective actions were included in FCR 84-147. These modifications have been completed to provide adequate ventilation in the SWP Room.
Appropriate portions of Test Procedure (TP) 850.92, Service Water Ventilation Operating Test for FCR 84-147, were run to verify the adequacy of the SWP Room ventilation. The temperatures taken throughout the SWP Room indicate uniform air circulation in the room.
Additional investigation conducted after the submittal of LER 86-001 revealed that the design basis heat load can be created under normal operating conditions. LER 86-001 will be revised to reflect this new information.
Corrective Actions To Be Taken To Avoid Further Violations As stated in the response to Violation 85039-01, Toledo Edison's upgrade program includes the formation of a Systems Engineering group. The responsible Systems Engineer
- will maintain cognizance of those FCRs involving their assigned systems.
Date When Full Compliance Will Be Achieved Full compliance has been achieved with the modification of the SWP Room Ventilation System.
LER 86-001 will be revised by October 31, 1986.
The Systems Engineering group has been formed as described in the Davis-Besse Course of Action.
l l Violation: LER 86-002, Emergency Diesel Generator (EDG) Air Start 85039-03 System pressure inadequate. During the review of the periodic testing requirements of the EDG System as part of the SRTP. it was determined that preoperational Test Procedure (TP) No. 410.01.1, performed August 11-17, 1976, had not shown that the EDGs could start five times with a single air receiver pressurized to 200 psig. The report states that this is a condition which is outside the design basis of the plant. Section 8.3 of the Updated l Safety Analysis Report (USAR) indicates that the air
! receivers have sufficient capacity to start the EDG five times. The normal operating range for the air receivers is 200-250 psig. TP 410.01.1 verified the capability of each of the air receivers to start the EDG five times from I an initial pressure of 250 psig. However, the operating procedure for the EDG, SP 1107.11, " Diesel Generator
Dsckst No. 50-346 License No. NPF-3 Serial No. 1-645 August 14, 1986 Page 7-Operating Procedure," stated that the EDG would be operable if the air receiver pressure is greater or equal to 200 psig. Since TP 410.01.1 had not performed the five starts at the air receiver's minimum acceptable pressure setpoint of 200 psig, the original design basis for the EDGs had not been demonstrated by testing. The licensee identified that the root cause of this occurrence was the lack of an adequate technical review in that the wrong EDG air receiver setpoint was being une,,d for EDG operability.
On December 10, 1985, confirmatory testing of EDG 1-2 air start system was performed to prove the 200 psig operabil-ity setpoint. The EDG started four times and as such was unsuccessful in starting five times as required. EDG 1-2 was then subsequently successfully tested at a starting pressure of 210 psig for each air receiver. EDG 1-1 will be tested during its maintencnce outage prior to restart.
Davis-Besse technical specifications do not address the requirement for five starts cf the EDG, therefore the Technical Specification Limiting Condition for Operation (LCO) was not violated; however, the possibility exists that the EDGs would not have performed their intended safety function under certain conditions. This condition has existed since the plant entered Mode 3 on July 24, 1977 /
and was identified during the performance of the SRTP on December 10, 1985.
The lack of a suitable test program to verify the adequacy of the original design and therefore the operability of the system is a violation.
Response: Acceptance Or Denial Of The Alleged Violation Toledo Edison acknowledges the alleged violation.
Reason For The Violation The cause of this condition has been determined to be inadequate design verification testing of the Emergency Diesel Generators (EDG).
In reviewing the EDG system, it was noted that the EDGs were not tested to demonstrate that they satisfied the requirement of being able to start five times from normal
,EDG air receiver pressure which ranges between 200-250 psig.
Preoperational testing performed this five start air test at the maximum receiver pressure of 250 psig. The operating
Docket No. 50-346 License No. NPF-3 Serial No. 1-645 August 14, 1986 Page 8 procedure for the EDGs (SP 1107.11) stated that an EDG would be operable if at least one corresponding air receiver contained a pressure of 2200 psig. EDG 1-2 would not start on the fifth attempt with an initial reservoir pressure of 200 psig.
Corrective Action Taken And Results Achieved Test Procedure (TP) 850.37, EDG Air Start System Test, was modified to permit the test initiation pressure,to be raised to 210 psig. The EDG Air Start System receivers were pressurized to 210 psig. EDG 1-1 and EDG 1-2 have been successfully started five times using each of their air receivers as stated-in Section 8.3 of the USAR.
In accordance with the results received from conducting TP
-850.37 on the EDGs, the air receiver operating band has been revised to 220-250 psig.
As a result of the new operating band, the Low Air Receiver Pressure Alarm and the Air Compressor Start Setpoints have been revised. The appropriate procedures have been revised to reflect these new setpoints.
Corrective Actions To Be Taken To Avoid Further Violations As stated in the response to Violation 85039-01, the Systems Engineering group has been formed to provide engineering personnel dedicated to developing a detailed knowledge of assigned systems. The responsible Systems Engineer will maintain cognizance of those FCRs involving their assigned systems. This includes changes to system testing procedures.
As discussed in LER 86-002, a Request for Engineering Assistance (REA) was written to evaluate the EDG air system components to determine if they can operate at the new system pressure. During review of the start /stop pressure switches for the EDG Air Compressors, it was discovered that the 30 psi dead band was adjustable. The dead band was adjusted and the shutoff setpoint for the air compressors was set at 250 psig. The REA to evaluate air system components was subsequently voided.
Date When Full Compliance Will Be Achieved Full compliance has been achieved with the retest of the EDG and the revision of the appropriate setpoints and procedures.
The Systems Engineering group has been formed as described in the Davis-Besse Course of Action.
Docket No. 50-346 License No. NPF-3 Serial No. 1-645 August 14, 1986 Page 9 Violation: LER 86-004, SFAS Testing of High Pressure Injection 85039-04 Valves. During the review of tha periodic testing require ments of the SFAS as part of the SRTP, it was determined that current testing does not actuate High Pressure Injection (HPI) valves HP-2A, HP-2B, HP-2C, and HP-2D from a SFAS test signal as required by Technical Specification Surveillance Requirement 4.5.2.e.l. Technical Specification 3.5.2 requires that two Emergency Core Cooling Systems (ECCS) subsystems be operable. Surveillance Requirement 4.5.2.e.1 requires a verification at least once every 18 months while shutdown that each automatic valve in the flowpath actuates to its correct position on a safety injection test signal.
Surveillance Test (ST) 5031.07, " Integrated SFAS Test,"
currently strokes these valves with the control room handswitches only. Although the SFAS logic is tested in ST 5031.07 and ST 5031.01, "SFAS Monthly," the valves do not receive a periodic signal from the SFAS logic directly.
The root cause of this occurrence is an inadequate technical review of the procedures utilized to implement the surveillance requirements. This condition has existed since the plant entered Mode 3 on July 24, 1977, and was identified during the conduct of the SRTP on December 14, 1985.
Failure to comply with Technical Specification 3.5.2 due to inadequate surveillance procedures is a violation.
Acceptance Or Denial Of The Alleged Violation Toledo Edison acknowledges the alleged violation.
Reason For The Violation Technical Specification 4.5.2.e.1 requires verification that each avtomatic valve in the system actuates to its correct position on a safety injection test signal at least once per 18 months. The SRTP reviews indicate that HP-2A, 2B, 2C and 2D vere verified to ac tuate from a Safety Features Actuation System (SFAS) test signal during pre-operational design verification testing. However, when this test, TP 310.02, Integrated SFAS Test, was converted into an 18 month interval Surveillance Test, ST 5031.07, the method for testing the valves was inadvertently modified.
ST 5031.07 required cycling of the valves using the control room handswitches only.
The cause of these inadequacies has been determined to be the lack of an adequate technical review of the surveillance procedure to ensure system operability is verified.
'Dockst No. 50-346 License No. NPF-3 Serial No. 1-645 August 14, 1986 Page 10 Corrective Actions Taken And Results Achieved While reviewing the adequacy of testing on the Decay Heat Removal / Low Pressure Injection System (DHR), it was determined that DHR pumps suction valves DH2733 and DH2734 were also not being tested from a safety injection signal.
These valves receive confirmatory open signals from the SFAS to ensure the pumps will be aligned.to a source of borated water in the event of a LOCA. ST 5031.07 has been performed with DH2733 and DH2734 initially open. Monthly testing is conducted to verify operability of the SFAS
, logic and output modules. However, this test does not include exercising actuated equipment.
During Modes 1, 2, and 3, DH2733 and DH2734 are maintained in the open position. In Mode 4, the train that is required to meet the Low Pressure Injection (LPI) Technical Specification will have its respective suction valve DH2733 or DH2734 maintained open. No reliance is placed on the ability of these valves to automatically open in response to an SFAS signal. DH2733 and DH2734 have been successfully stroked quarterly using their manual actuation control switches.
This deficiency is described in LER 86-023.
Test Procedure (TP) 850,19, Integrated SFAS, has been written to perform an integrated SEAS test prior to restart. This test will verify the capability of the SFAS to actuate from a manual actuation, and to actuate SFAS associated equipment. This includes actuation of HP 2A, 2B, 2C, 2D, and DH2733 and DH2734 to the open position.
Corrective Actions To Be Taken To Avoid Further Violations ST 5031.07 will be modified to provide verification that each automatic valve that receives an SFAS signal will actuate to its correct position. This test will be utilized as the 18-month surveillance test after Restart.
As stated previously, the Systems Engineering group has been formed to provide an engineering staff dedicated to developing detailed systems knowledge. One of the group's responsibilities is to review the appropriate portions of the preventative maintenance program and surveillance test program to ensure system operability is maintained and verified by testing. In addition, this effort will be complemented by the establishment of a Qualified Reviewer Program. This program will provide improved technical reviews of procedures.
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Dockot'No. 50-346
' License No. NPF-3 Serial No. 1-645 August 14, 1986 Page 11 Date When Full Compliance Will Be Achieved Full compliance will be achieved with the satisfactory performance of TP 850.19. This will be accomplished prior to entering Mode 3.
ST 5031.07 will be revised by December 31, 1986.
Violation: LER 86-007, CAC Fan running backwards. During the performance 85039-05 of post modification testing on the CAC System required in the performance of the SP.TP, it was determined that CAC fan 1-1 was running backward in low speed. The report states that this is a violation of Technical Specification 3.6.2.2 which requires at least two independent containment cooling units to be operable. During the performance of TP 850.31 "CAC Damper Test," on January 4, 1986, CAC fan 1-1 was found running back-ward in the low speed mode of operation. The fan ran in the correct direction in high speed. CAC fans run in high speed during normal plant operation to provide containment cooling and automatically start in low speed upon receipt of an SFAS signal. The likely cause of reverse rotation is due to swapping two of the three motor leads on the low speed motor during previous maintenance activities. A review of the Maintenance Work Orders (MW0s) performed since original startup testing has identified 51 maintenance activities involving the CACs, of which five could have resulted in the incorrect reconnection of the motor leads. These records however, do not contain sufficient information to identify when the fan was incorrectly reconnected. The earliest activity occurred on March 28, 1977 and the latest on July 18, 1984. ST 5063.02, ensures operability by verifying at least once per 18 months that each unit starts automatically on low speed on receipt of a SFAS signal. Although STs have existed since the original startup testing, ST 5063.02 does not record sufficient data to determine the direction of fan rotation. On January 11, 1986, the motor leads were connected properly and the fan rotation was verified visually. The root cause of this occurrence is inadequate technical review and post maintenance testing as well as inadequate technical surveillance procedures. This condition could have existed since the performance of the first MWO on March 28, 1977 and #
was identified during the performance of the SRTP on January 4, 1986.
Failure to comply with Technical Specification 3.6.2.2 is a violation.
Dock 2t No. 50-346 License No. NPF-3 Serial No. 1-645 August 14, 1986 Page 12 Response: Acceptance Or Denial Of The Alleged Violation Toledo Edison acknowledges the alleged violation.
-Reason For The Violation The root cause of the Containment Air Cooler (CAC) 1-1 fan running backwards appears to be a result of reversing two of the three motor leads during a maintenance activity on the unit. Contributory causes have been determined to be:
- 1) inadequate post maintenance testing, 2) inadequate Technical Specification surveillance procedures, and 3) inadequate reviews of the surveillance / post maintenance testing procedures to ensure that they would verify system operability.
On January 4, 1986, during the performance of the Containment Air Cooler Damper Test, TP 850.31, it was discovered that Containment Air Cooler (CAC) 1-1 fan operated backwards in low speed. The fan ran in the correct direction in the high speed mode of operation, which is the mode used during normal plant operation.
Subsequent investigation revealed that the low speed motor leads were reversed.
Slow speed operability is required to provide adequate heat removal capability when operated in conjunction with containment spray during post LOCA conditions.
A review of the original air balance testing for the CACs shows that design flows were met. This would not have been possible unless the fans were running in the correct direction at that time. Therefore, the reversed leads appear to be the result of a subsequent maintenance activity on the fan.
A review of the Maintenance Work Orders (MWO) generated over the years found several activities that would have required the leads to have been disconnected. If past maintenance testing did not require a rotation check in both the low speed and the high speed mode of operation, the error could go undetected. ST 5063.01, Containment Air Cooling Monthly Test, and ST 5063.02, Containment Air Cooling System Refueling Test, did not require verification of proper fan rotation.
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D:ckat Ns. 50-346 License No. NPF-3 ,
Serial No. 1-645 August 14, 1986 Page 13 Corrective Action Taken And Results Achieved Under Maintenance Work Order (MWO) 1-86-0100-00, the motor leads on the low speed starter for the fan were reconnected j properly. Proper rotation was verified by visual observation.
Work was completed January 11, 1986. ST 5063.02 has been modified to verify that the CAC fans are discharging air in slow speed. Verifying that each fan is discharging air j indicates that ic is running in the proper direction.
4 Corrective Action To Be Taken To Avoid Further Violation New Containment Air Cooling Monthly Surveillance Tests are being implemented to verify that the CAC fans are discharging air in slow and fast speed. This will provide verification of proper operation.
The Systems Engineering group has been formed to provide an engineering staff dedicated to developing systems knowledge.
As stated in the CCA, a cognizant Systems Engineer has been assigned to assist in providing resolution for maintenance problems (trouble shooting, preventative maintenance (PM) program).
- Date When Full Compliance Will Be Achieved 1
Full compliance has been achieved with the completion of work on CAC fan 1-1 and the subsequent successful testing.
! The Containment Air Cooling monthly surveillance tests will be implemented by August 31, 1986.
The Systems Engineering group has been formed as described in the Davis-Besse Course of Action.
4 Violation 86009-03: Technical Specification Surveillance Requirement 4.7.1.2c requires that the Auxiliary Feed Pump Turbine (AFPT) Steam Generator (SG) Level Control System be demonstrated operable by the performance of a channel functional check on a monthly
- basis in modes 1, 2, and 3.
Contrary to the above, from July 24, 1977, when the unit first entered mode 3, until June 9, 1985, the AFPT SG Level Control System was not demonstrated operable in that ST 5071.04, " Auxiliary Feedwater System Channel Functional Test," did not test the AFPT SG Level Control System with steam
- generator level both above and below the level setpoint on a monthly basis as required by the surveillance requirement.
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Docket No. 50-346 License No. NPF-3 Serial No. 1-645 August 14, 1986 Page 14 Admission or Denial of the Alleged Violation Toledo Edison acknowledges the alleged violation.
Reason for the Violation As reported in LER 86-014, the review of the Auxiliary Feedwater. System Test Procedure Outline,.AFW-TPO-10, determined that the test used to satisfy Technical Specifi-cation (T.S.) 4.7.1.2c did not test each function on a monthly basis. T.S. 4.7.1.2c includes the requirement for a monthly channel functional test of the Auxiliary Feed Pump Turbine (AFPT) Steam Generator (SG) Level Control System when in Modes 1, 2, and 3. The Auxiliary Feedwater (AFW) System Channel Functional Test, ST 5071.04, was implemented as a result of LER 78-108, Failure to Perform Surveillance Requirements of T.S. 4.7.1.2c and 4.7.1.2d.
ST 5071.04 tests the system; however, the specific function of the system tested depends on actual SG level at the time of the test. Therefore, most of the tests would be conducted with the SG 1evel above the AFW control setpoint. This tests the portion of the controls that reduce the AFPT speed.
Other tests would be performed during plant startups and at low power levels with the SG level below the AFW control setpoint. This would test the part of the controls that increases the AFPT speed. However, both control functions were not tested monthly.
The presently installed AFPT SG Level Control System does not facilitate the use of an artificial SG 1evel signal, and, therefore, full testing is not possible without additional test circuitry. However, since over the course of a year's testing, the full range of control functions would be covered, it was originally determined in 1978 that T.S. 4.7.1.2c require-ments were being satisfied.
The cause of this condition has been determined to be:
- 1) the failure to provide adequate technical review of the surveillance test which was implemented to satisfy T.S. 4.7.1.2c,
- 2) failure to provide adequate test circuitry, and 3) failure to provide formal resolution once the testing limitations were identified.
Corrective Action Taken and Results Achieved Facility Change Request (FCR)86-108 has'been initiated to add a test circuit for the AFPT FJ Level Control System.
This FCR will allow for testing the level control system both above and below both level control setpoints.
4 D:ckat No. 50-346 License No. NPF-3 Serial No. 1-645 August 14, 1986 Page 15 Corrective Actions to be taken to Ensure Compliance ST 5071.04 will be revised following FCR 86-108 implementation to verify that the AFPT SG Level Control System is tested monthly as required.
As stated in the C0A, Toledo Edison's upgrade program includes the formation of a Systems Engineering group. The Systems Engineers have been assigned specific systems and are responsible for developing a detailed knowledge of their systems. The cognizant Systems Engineer reviews surveillance test modifications which affect their systems to ensure T.S. requirements are met.
Date When Full Compliance Will Be Achieved FCR 86-108 will be implemented, appropriate changes to ST 5071.04 will be made and subsequent testing of the AFPT SG Level Control System will be performed during the present outage.
The Systems Engineering group has been formed.as discussed in the Davis-Besse Course of Action.
Very truly yours, 5&L y h.
JW:JS:plf cc: DB-1 NRC Resident Inspector