ML20246E089
| ML20246E089 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 05/03/1989 |
| From: | Shelton D TOLEDO EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1-874, NUDOCS 8905110141 | |
| Download: ML20246E089 (3) | |
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TOLEDO
%ms EDISON A Centenor Energy Company DONALD C. SHELTON Voe Presdent-Nucker
. Docket Number 50-346 License Number NPF-3 Serial Number 1-874 May 3, 1989 United States Nuclear Regulatory Commission Document Control Desk Vashington, D.
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20555 Subj ect: Response to Nuclear Regulatory Commission (NRC) Inspection Report 89005 Gentlemen Toledo Edison (TE) has received NRC Inspection Report 89005 (Log Number
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1i2058) dated March 22, 1989.
'A two week extension of the response due date was requested and granted per discussion with the Davis-Besse NRC Senior Resident Inspector on May 1, 1989. Toledo Edison provides the following response.
Violation 89005-02:
" Technical Specification 6.8.4 requires that certain programs shall be established, implemented, and maintained.
One of the programs required is a program to reduce leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to as lov as practical levels. The program shall include integrated leak test requirements for each system at refueling cycle intervals or less.
The licensee partially implements that program with Procedure DB-SP-00001 which required that performance test (PT 5164.04) be performed by August 4, 1988, and performance test (PT 5172.00) be performed by August 21, 1988.
Contrary to the above, the Radioactive Fluid Leak Reduction Program Outside Containment required by Technical Specification 6.8.4 was not implemented and maintained in that PT 5164.04 was not performed by August 4, 1988, and PT 5172.00 was not performed by August 21, 1988."
Response
Acceptance or Denial of the Alleged Violation Toledo Edison acknowledges the alleged violation.
g0 THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO, OHIO 43652 l
8905110141 890503 l
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Dockst Number 50-346
- Licensa Numbar NPF-3 S'arial Numbar 1-874
'Page 2 Reason for the Violation As noted in Violation 89005-02, Davis-Besse Technical Specification 6.8.4.a requires that a program be established, implemented and maintained to minimize leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident. This specification further requires that certain test requirements be performed at refueling cycle intervals or less.
l Toledo Edison currently implements this program with Administrative Procedure DB-SP-00001, " Radioactive Fluid Leak Reduction Program Outside Containment".
Procedure DB-SP-00001 describes the method by which the program is implemented, utilizing a combination of surveillance and periodic tests for the various systems included in the program.
Surveillance tests and periodic tests (PT's) are not administratively controlled in the same manner.
Administrative Procedure DB-DP-00013, " Surveillance and Periodic Test Program" contains specific guidance for the dispositioning of missed or postponed surveillance tests but provides no guidance for periodic or critical periodic tests.
Critical periodic tests are defined as those tests which are considered important to the continued safe operation of the plant. These tests verify the proper functioning of equipment and systems which are not addressed by Technical Specification Surveillance Requirements.
The periodic tests referenced in Violation 89005-02 (PT 5164.04 and PT 5172.00) were not performed within the required refueling interval specified in Technical Specification 6.8.4.a.
The lack of proper guidance for dispositioning periodic tests which were not completed within their scheduled interval was the primary cause to the subject noncompliance.
Corrective Actions Taken and Results Achieved Currently, any system leakage would be identified during routine periodic tours performed by Radiological Controls or Operations personnel.
In addition, local area radiation monitors are available to detect any abnormal trends.
The periodic tests identified in Violation 89005-02 as PT 5164.04, Reactor Sample Leak Test and PT 5172.00, Gaseous Radioactive Vaste System have been completed. Testing for the Gaseous Radvaste System was performed under DB-SP-4410, DB-SP-4411 and DB-SP-4412. A test deficiency for DB-SP-4412, Vaste Gas Decay Tank Leak Rate Test, re.nains outstanding. The leakage rate for Vaste Gas Decay Tank Number 1 (VGDTI) was not calculated due to a leaking relief valve. The relief valve discharge is part of a closed system which includes the VGDT.
This portion of the testing vill be repeated following repairs to the relief valve. These periodic tests vill be converted to surveillance test prior to their next due date and controlled under the surveillance test program to provide appropriate
J Dockat Numb 2r 50-346
~, h'icznaa Numbar NPF-3 E
Serial Number 1-874.
Page 3 controls and direction for the performance of tests required by Technical Specifications.- Additionally, a review was initiated
.I to determine whether other Critical Periodic Tests are used to
-l satisfy Technical Specification testing requirements. No further occurrences have been identified to date.
Corrective Action to Prevent Recurrence Any additional tests required by the Davis-Besse Technical Specifications which are identified during the review of Critical Periodic Tests will be converted to surveillance tests and controlled under the existing surveillance test program.
Additionally, Operations shift personnel have been instructed to give a higher priority to periodic tests which are beyond their late date and to complete scheduled periodic test prior to their late date.
Toledo Edison is currently evaluating options for improving the critical Periodic Test program. Consideration is being given to incorporating critical periodic tests into an existing administrative program or establishing a separate program to provide sufficient controls to ensure timely completion of test and provide additional guidance concerning test delays.
Date Vhen Full Compliance Vill Be Achieved The review of Critical PT's which satisfy Technical Specification test requirements vill be completed by May 8, 1989. Any additional findings vill be dispositioned in the manner discussed previously under Corrective Actions to Prevent Recurrence.
A final decision on an administrative program for controlling critical periodic tests and a schedule for implementing the program vill be completed by June 1, 1989.
Full compliance vill be achieved with the establishment and implementation of this program.
Very truly yours, s s RVG/dlm cc:
P. M. Byron, DB-1 NRC Senior Resident Inspector i
A. B. Davis, Regional Administrator, NRC Region III T. V. Vambach, DB-1 NRC Senior Project Manager l
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