ML20005B030
| ML20005B030 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 05/22/1981 |
| From: | Crouse R TOLEDO EDISON CO. |
| To: | Heishman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20005B029 | List: |
| References | |
| 1-206, NUDOCS 8107060239 | |
| Download: ML20005B030 (7) | |
Text
r E$iSON Ibcket No. 50-346 Acnta P Crc.st License No. NPF-3
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mmw Serial No. 1-206 Fhy 2.', 1981 Mr. R. F. Heishman, Acting Director Division of Resident and Project Inspection U. S. Nuclear Regulatory Ccmnissicn Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Heishman:
'Ibledo Edison acknowle3ges receipt of your bhy 1,1981 letter (Log 1-503) and enclosures, Appendix A and report 50-346/81-01, referencing the violation of Technical Specification 6.8.1.
This violation is listed as a " Severity Invel V Violation (Supplenent I)" in Appendix A.
Following in examination of the itens of concern, 'Ibledo Edison herein offers information regarding the item of violation.
Violation-Technical Specification 6.8.1 requires the applicable procedures reca: mended in Appendix A of Regulatory Guide 2.33, Novenber 1972, to be established, implenented, and maintained. Appendix A of Regulatory Guide 1.33, Novenber 1972, includes Administrative and "aintenance Procedures. Administrative Procedure AD 1844.00, "bhin-c.anance", states in Section 6 "As a minimum, nuclear safety related maintenance performed at the Davis-Besse Station shall be controlled by a Maintenance Work Order (bMO)." Enclosure 5 of AD 1844.00 states that "All Maintenance Pbrk Orders on safety relatal equipment which renove equipTnt frun service shall have an Enclosure 13, Work Require-ments Checkoff List, prepared prior to approval by the bhintenance Engineer." En.:losure 13 provides the checkoff list for redundant equipmnt requirenents, notliication to the operators of the renoval and return to service of the equignent, and post maintenance testing requirements.
Contrary to the above:
a.
In Seistesnber 1980, several pipe supports for Dmrgency Diesel Generator 1-1 fuel lines were disassembled or renoved without a Maintenance Work Order being cc pleted ' o control the work.
c THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO. CHIO 43552 8107060239 810624' PDR ADOCK 05000346 O
F Docket No. 50-346 Page 'IWo Serial No. 1-206 May 22, 1981 b.
On Septaber 3,1980, Maintenance Work Order (MO) 80-59-1 was approved for the rcmwal of eight pipe supports frm the 1-2 diesel generator fuel lines without an Enclosure 13, Work Re-quirments Checkoff List, being prepared.
Response
(1) Corrective action taken and results achieved. During a Sur-veillance walkdown of the systs on Decm ber 4, 1980, Quality Control found, and reported the disassm bled hangers. All hangers were then expeditiously reasse:cbled.
'Ihe procedural violation of doing work other than authorized by the IWO was then recognized. Also, the Architect Engineer, Be"htel, was requested to perform a seismic analysis of the system under the as-found conditions.
'Ihe A/E Report, LER notification, subsequent reanalysis and in-spection 50-346/81-09 are all dev,=nted in Section 3 of Inspec-tien Report 50-346/81-01.
(2) Corrective action to be taken to avoid further nonompliance. To strengthen management or administrative controls in the future, Toledo Edison is making changes in the following areas:
A.
Quality Assurance /Qmlity Control coverage B.
Training of personnel C.
Tracking of open work itms D.
Identification of potential mode limitations As the contractual terms with the maintenance contractors vary frm those with the modification contractor, certain differences l
in the program for each will be discussed.
l A discussion of each of the above four areas follows:
A.
QA/QC coverage
- 1) All Maintenance Contractors now work under the Toledo Edison Quality Assurance Program to ensure ongoing sur-l veillance of their activities and to ensure that required plant conditicns are met.
L
- 2) Modification Contractors will work under their own 'Ibledo Edison approved QA programs. Quality Assurance has scheduled an audit of Contractor Programs which identify and track the status of safety related jobs, thereby en-suring that such work packages are closed to the extent necessary to lift operational and administrative limitations.
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Docket No. 50-346 Page % ree rerial No. 1-206
. y 22,1981 4.
L.
Train 2ng of Personnel All persons who are badged to enter DBNPS Protected Area un-escorted nust receive General Orientation Training, Part I.
In this training, personnel e.re instructed that only the work authorized on an approved Maintenance Work Order may be under-taken. Wis admonition is stressed and then repeated in the review synopsis. To add f,trther emphasis to this point, the Nuclear Training Department has changed the Gtyr I Test to in-clude questions on this particular itm.
In addition, the Nuclear Training Department is putting together Training Itdules which ernphasize the organization, philosophy and proceudres of the Maintenance Department. B is training will be given to all supervisory personnel who are regularly sployed on Site by Ccntractors. Wese personnel also review procedures on Maintenance Administration, changes to existing equi;rnent and systems, and safety tagging. In the future, the personnel will be required to document that they have read and understand these procedures.
During outages, other contractor supervisory personnel are brought on site for short periods of time. We Nuclear Train-ing Department is investigating the scope of training appro-priate for these personnel, together with the level of con-trol which can reasonably be enforced for such training.
C.
Tracking of Open Work Itm s
- 1) Tracking of Modification Work Modification work is being done by a Contractor under their own TED approved QA plan. m is contractor has their own tracking systs which ensures work cspletion before systs turnover to TED. We contractor also assigns each job to a cognizant individual such that increnental parts of the job status can be readily ascertained. W is systs was used during the last refueling outage on the Fire Protec-ticn Modifications and was proven effective.
To handle the large volume of modifications to be done on pipe supports and restraints as a result of IE Bulletins 79-02 and 79-14, each item is tracked separately. Be Architect Engineer has already identified which items can be worked on at any time without impact on systs status, which can be worked on during plant operation but with special sphasis on sta.p by step control, and which itms need special analysis done by the Architect Engineer for plant conditions and circumstances associated with the work.
For any of the above 5.or1. to be done, a IMO is required which must be approved by the Maintenance Engineer and by the Shift Supervisor.
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Docket No. 5 ' 46 Page Four Serial No. 1-206 May 22, 1981
- 2) Tracking of Maintenance Work Maintenance work is being done by contractors who are working under the TED Nuclear Quality Assurance Program.
For major outages, a tracking system is snployed which reflects the work needed to return a system to operable status. 'Ihis system breaks jobs into sub-cmponents and identifies cognizant individuals. 'Ibe job which led to this occurrence had not been considered an outage job but rather was taken as a fill-in type job and therefore was not tracked adequately. For future major outages, all safety related jobs which are undertaken, will be tracked to the point that they no longer pose an operational limi-tation. Followup work such as painting, etc., is trans-ferred to a punch-list for close out.
Recognizing that the above tracking is designed for major outages, the Nuclear Reliability Department has developed a new prcige which tracks all work items, including main-tenance jobs. Reliability has begun testing the program in the Instrument and Control Group using current records and providing a daily update. When this program has been debugged and proven effective, its scope will be expanded to enempass all maintenvre activity at DBNPS.
D.
Identification of Potential Mode Limitations As has been noted, the full impact of this occurrence was not fully known until the Architect Engineer perforned their a-nalysis. In the future, cuch impact will be looked for, at each level of review of a work package. 'Ihis stems frcm ini-tiation of an EUR work package by the Architect Engineer and continues through approval of the bio by the Shift Supervisor.
Each review level which identifies the potential for a degrad-ed condition will alert all following levels of the potential and initiates analysis to determine the impact of the work on Plant status. As an example, this means that a cognizant individual may identify such a potential while preparing a F10.
It nay be remc7m1 of a hanger, placing of jumper cable, or similar necess ection to accanplish'the job. 'lhe b50 pm-parer would t' ':. ~n unicate the potential to Nuclear Engineer-ing and Const - uor to may request further analysis by the Architect Engineer.
In the past, an enclosure to the MO has been added by which the Shift Supervisor was made aware of any required redundant systems and any followup testing necessary to declare a sys-ten operable follcwing the empletion of the MO.
'Ihis en-closure has been modified by the Operations Section to note any associated Mode limitations for the work and added to Maintenance Procedure AD 1844.00.
T b
Docket No. 5-346 Page Five Serial No. 1-206 May 22, 1981' During the 1980 Refueling Outage, TED undertook a very long list of work itms. Sme associated with the refueling, sme Inservice Inspection, sme routine and preventative mainten-ance, and scrne to emply with revised Ibgulatory positions.
It is recognized that the sheer volume of work was great and in part led to the breakdown in controls which caused this preA>1m. Icoking forward to major outages in the futere, TED has established an on-site Engineering Department which will review and prioritize the necessary work packages, so as to control the amount of work.
It is the position of Toledo Edison knagment that by con-trolling the volme of work undertaken, by increased manage-ment attention and surveillance, and by impleenting the controls noted above, occurrences such as happened, will not be repeated.
(3) 'Ihe Date when full compliance will be achieved.
A.
QC Coverage
- 1) Placing Maintenance Contractors upJer the TED OA Plan is emplete and inpleented. 'Iherefore, the Station is in full empliance as of this date.
- 2) QA Audit of the modification contractors is scheduled to be empleted by June 30, 1981.
B.
Training of Personnel
- 1) Upgrading of the GT I Test is ccrtplete and implenunted.
Therefore, the Station is in full empliance as of this,
date.
- 2) Mditional training for supervisory personnel who are regularly sployed on site by contractors will be de-veloped by July 1, 1981.
- 3) Procedures to require doc mentation of procedure review by the same personnel noted in B2, will be revised by July 1, 1981.
C.
Tracking of Ndification Work
- 1) Tracking of modification work being done by contractors will be verified by a QA Audit by June 30, 1981.
- 2) Major scheduled outage tracking of all safety related jobs is in effect. 'Iherefore, the Station is in full empliance as of this date.
D.
Identification of Potential & de Limitaticns
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r Docket No. 5-346 Page Six Serial No. 1-206 May 22, 1981
- 3 to 140's has been revised and incorporated into AD 1844.00 by Tertporary Itxlification Request No. T-5557.
'Blis Itodification will be implemnted prior to June 1,1981.
Yours very truly, 1;;_:^ -
RPC/7DVDAH/cjb oc: NRC DB-1 Resident Inspector 9
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4 A'ICMIC MERGY ACI' OF 1954 SECTION 182 SUBMITTAL IN RESPONSE EDR DAVIS-BESSE NUCLEAR POWP:R STATIM i
UNIT 1 FACILITY OPERATING LICENSE NO. NPF-3 mis letter is subnitted in confonrance with Atmic Energy Act of 1954, Section 182, relating to Mr. R. F. Heishnan's letter of May 1,1980 (Log No.1-503). mis deals with deviation frm Davis-Besse Nuclear Power Station, Unit 1 Technical Specifica-tion 6.8.1.
- =_
Vice President, Nuclear i
Sworn to and subscribed before me this 22nd day of May, 1981.
[
Notary Public JUDITH H:RSC
f;eary Pathc. Wcad Coury. Chio f.'y Comrnission Expires Jr.e 30.1982