ML20214S353
| ML20214S353 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 05/14/1987 |
| From: | Shelton D TOLEDO EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8706090238 | |
| Download: ML20214S353 (2) | |
Text
N TOLEDO Docket No. 50-346
!!t)!kICIr0 License No. NPF-3 DONAd) C. SHELTON Vce Presdent-Nudear M19l 2492399 Serial No. 1-719 May 14, 1987 Mr. A. B. Davis, Regional Administrator United States Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Dear Mr. Davis:
Toledo Edison, in Inspection Report 50-346/84-09 (Log No. 1-992), was cited for a violation (84-09-12) with respect to the failure of the Station Review Board (SRB) to review temporary modifications associated with nonconformance reports (NCRs). This failure was contrary to Technical Specification, Sections 6.5.1.6.d and 6.5.1.7.a, which require the SRB to review all proposed changes or modifications to plant systems or equip-ment that affect nuclear safety and recommend written approval or disapproval of changes or modifications to the Plant Manager.
Toledo Edison responded to this violation in Serial No. 1-459, dated August 17, 1984, and stated "The SRB Charter is being revised to include in Subcommittee Instructions the requirements to review dispositioned nonconformances (NCRs and SDRs [ Supplier Deviation Reports]), which are dispositioned use-as-is, use-as-is temporarily, or repair." This review, -
which was committed to in the response to the violation, has resulted in duplicate review of documents, thereby imposing unnecessary burden on the SRB activities, and has prompted a re-review of the commitment as made.
The following sets forth the review logic to determine the extent of SRB review needed to satisfy Technical Specifications with regard to the aforementioned violation.
a)
NCRs and SDRs dispositioned as "use-as-is" or " repair" can fall into either one of two categories:
1) those for which an engi-neering justification which verifies the accepted condition is in compliance with the design documents (i.e., does not represent a modification); or 2) those identified as requiring a change to the design documents (i.e., does represent a modification). When the disposition represents a modification, a Facility Change Request (FCR) must be initiated to reconcile the accepted condi-tion with the design documents.
SRB review of the modification is obtained as part of the FCR approval process. Therefore, it is not necessary for SRB to review NCRs and SDRs dispositioned as "use-as-is" or " repair".
tAAY 1819ffI THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO. OHIO 43652 8706090238 870514 M
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a Dockat No. 50-346 l
License No. NPF-3 Serial No. 1-719 Page 2 b)
NCRs dispositioned "use-as-is temporarily" may involve a temporary modification. Since temporary modifications are not within the scope of the normal FCR process, NCRs dispositioned as "use-as-is temporarily" will be reviewed by the SRB.
This also applies to Potential Condition Adverse to Quality Reports (PCAQs) as they have replaced the Nonconformance Report.
SDRs are not dispositioned "use-as-is temporarily" and, therefore, would not result in a temporary modification.
Based on the above, and in order to accurately define SRB responsibilities per Technical Specifications, Toledo Edison revises its corrective action
[p' for Violation 50-346/84-09-12 to state the following:
"The SRB Charter will be revised to require SRB review of NCRs and PCAQs which have been dispositioned use-as-is temporarily for plant systems or equipment that effect nuclear safety."
Toledo Edison will implement this commitment revision and provides this correspondence for documentation purposes.
If you have any questions, please contact George Honma, Compliance Supervisor, at (419) 249-2309.
Very trul
- ours, 4h DCS:C :RMC:p1f cc: DB-1 NRC Resident Inspector C. E. Norelius, Region III I
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