ML20063C454
| ML20063C454 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 07/30/1982 |
| From: | Crouse R TOLEDO EDISON CO. |
| To: | Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20063C432 | List: |
| References | |
| 1-285, NUDOCS 8208270264 | |
| Download: ML20063C454 (7) | |
Text
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TOLEDO Docket No. 50-346
(([)l[j()[Q License No. NPF-3 RCHAno P. CnousE vanset Serial No. 1-285 N"**
I4191259 5221 July 30, 1982 Mr. R. L. Spessard, Director Division of Project and Resident Programs United States Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Spessard:
Toledo Edison acknowledges receipt of your June 16, 1982 letter (Log No.
1-638) and enclosures, Appendix, Notice of Violation and Report 50-346/
82-08, referencing the violation of 10 CFR 50, Appendix B, Criterion V and XIII. The three violations listed are: one Severity Level IV and two Severity Level V (Supplement I).
In the SALP meeting on July 13, 1982 and subsequently in a letter dated June 23, 1982 (Serial No. 1-280) Toledo Edison requested an extension of the response deadline.
This extension was verbally approved on July 29, 1982.
Following an examination of the items of concern, Toledo Edison herein offers information regarding the items of violation and, as Attachment I, our assessment of your concerns related to the 1980 Performance Appraisal Branch Inspection.
Violation:
10 CFR 50, Appendix B, Criterion XIII states in part,
" Measures shall be established to control the handling, storage...of material and equipment in accordance with work and inspection instructions to prevent damage and deterioration."
Section 5.13 of the Quality Assurance Manual states
" Toledo Edison, its agents, and suppliers / contractors are required to establish approved written handling storage and shipping procedures which are compatible with the Toledo Edison Nuclear Quality Assurance Program."
Section 7.19.3 of Quality Assurance Procedure 2130 states,
" Level C items shr.ll be stored indoors, or equivalent with all provisions and requirements set forth in level B items except that heat and temperature control is not required."
Section 7.19.4 of Quality Assurance Procedure 2130 states,
" Level D items may be stored outdoors in an area marked and designated for storage, which is well drained for THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO. OHIO 43652 e20s270264 e20e2o AUG 6 E02 PDR ADOCK 05000346 G
Docket No. 50-346 License No. NPF-3 Serial No. 1-285 July 30, 1982 Page 2 storage.... Items shall be stored on cribbing, or equivalent...."
Section 7.20.1 of Quality Assurance Procedure 2130 states,
" Access to storage areas shall be controlled and limited only to personnel designated by the responsible organization."
Section 7.20.2 of Quality Assurance Procedure 2130 states, "The storage areas shall be cleared as required to avoid the accumulation of trash, discarded packaging materials, and detrimental material."
Section 6.3.3 of AD 1847.03 states that the areas used for storage of plant materials shall not be used for the storage of chemicals, paints, solvents or inflammable materials.
Section 6.2.2 of AD 1847.03 states in part, "All covers, caps, plugs or other covering shall be maintained intact and in a protective condition."
Contrary to the above, measures were not established to assure the control, handling and storage of material and equipment as demonstrated by the following examples:
Level C cable was stored outdoors in front of the United Engineers and Constructors (UE&C) fabrication shop and level C cable and unistrut were stored outdoors by the Catalytic Construction storage trailers from March 8 - 11, 1982.
Response
(1) Corrective action taken and results achieved.
The cable and unistrut were removed from area.
(2) Corrective action taken to avoid further non-compliance.
Indoctriaation of Nuclear Construction Department (NCD) personnel was performed on NCD 6080.01, " Control of Material and Equipment". This training is documented by Intercompany memorandum NC 82-1660.
(3) Date when Full Compliance will be Achieved.
Full compliance was achieved on March 11, 1982.
Level C cable was stored in a trash pile outside the gatehouse from March 8 - 11, 1982. The reel and its QA tag were plainly visible to all personnel entering the gatehouse.
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Docket No. 50-346 License No. NPF-3 Serial No. 1-285 July 30, 1982 Page 3
Response
(1) Corrective action taken and results achieved.
Cable was placed in Level C storage.
(2) Corrective action taken to avoid further non-compliance. Personnel training documented by memo NC 82-1660.
(3) Date when full compliance will be achieved.
Full compliance was achieved on March 11, 1982.
Level D cable was not stored in a well drained area i
or on cribbing but in mud outside the UE&C fabric-ation shop from March 8 - 11, 1982.
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Response
(1) Corrective action taken and results achieved.
The Level D cabic was removed from the area.
(2) Corrective action taken to avoid further non-compliance. Personnel training documented by memo NC 82-1660.
(3) Date when full compliance will be achieved.
Full compliance was achieved on March 11, 1982.
I Access to the east outside storage area at the ware-house was not controlled in that the gate was open and the storage area was unattended at 5:40 p.m. on March II, 1982.
Response
(1) Corrective action taken and results achieved.
The outside storage areas were secured.
(2) Corrective action taken to avoid further non-compliance. Material Control and Quality Engineering personnel were informed that the outside storage areas were not to be left unsecured, unless there were Material Control or Quality Engineering personnel inside the outside storage areas to monitor activities.
(3) Date when full compliance will be achieved.
Full compliance was achieved on March 15, 1982, l
Accumulated trash and debris was adjacent to the Q 1evel storage area which contained level C & D cable
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Docket No.' 50-346 License No. NPF-3 Serial No. 1-285 July 30, 1982
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outside the UE&C fabrication shop from March 8 - 12, 19o2.
I;esponse:~
(1) Corrective action taken and results achieved.
Trash and debris were removed.
(2) Corrective action taken to avoid further non-compliance. Personnel Training documented in memo 82-1660.
e (3) Date when full compliance will be achieved.
Full compliance was achieved on April 1, 1982.
Chemicals, inflammable material and ether based ink (110 *F flash point) were stored in the warehouse used to store plant materials and components on March 9, 1982 and again on April 8, 1982.
Response
(1) Corrective action taken and results achieved.
The flammable material was segregated within the warehouse from nuclear safety related material.
(2) Corrective action taken to avoid further nona compliance.
Flammable material was segregated inside the warehouse to establish an eight-foot separation between flammable material and safety related material stored in the warehouse.
In addition, the Nuclear Material Control Procedures were determined to require a revision. The revision has been completed.
(3) Date when full compliance will be achieved.
Full compliance was achieved on July 7,1982.
The weld preparation surface of a twenty inch flange-was not protected on March 3, 1982.
Response
(1) Corrective Action Taken and Results Achieved.
The prepared surface was covered.
3 (2) Corrective Action Taken to Avoid Further Noti-Compliance. NCD personnel were informed of the requirements and need for protection of weld preparation surfaces. They were also infermed of the materials considered appropriate to protect weld nreparation surfaces.
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(3) Date when tull compliance will be achieved.
Full compliance was achieved on March',4',1982.
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,;There was evidence that these conditions existed for some tlme.
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Violadion:
Section 6.2 of Nuclear < Construct' ion Department Procedure J
l 6050.01 states in part "All work performed by the NCD within the station. shall be en_ered by a Maircenance Work O'rder (MWO) or Work Request (kR)."
1 Contrary to the above, Motor Controlicester F16B was
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disassembled on the 603' level in the turbine building to allow movement of the MCC to the 525#31evel in the auxiliary building without a MWO cr WR 00 do so.
Response
It is Tolede,. Edison's position that, due to the particulce i
physical ciriunstances involved, disassembly of the MCC 'was e
(Ti 3 Satt of the n'c ymal installation process. Therefore, the 1,
MCC installation MWO provided sufficient authorization to disassemble MCC F16B.
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q Violation:
10 CFR 50, Appendix B, Criterion XIII states in part,
", Measures shall be established to control the handling, storage....of material and equipnent in accordance with work and incpection instructions to prevent damage and
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deterioration."
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i' SeccionES.13 of the guality Assurance Manual states,
.,' Toledo Edison, its, agents and suppliers / contractors are s
3 required tc. establish approved written handling, storage, t
agd shipping procec'ures which are compatible with the
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Toledo Edison Nuclear Quality Assurances Program."
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i QAP 2 30, " Handling, Storage and Shipping," includes f
i ANSI B 30.2.0, "Satety Standard for Overhead and Gantry j(
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Cranes" in the references. ANST.B 30.2.0 C 1967 requires a
the Ognning rope on standby crarvs/to b2 inspected at least semi-annually. ANSI B 30.2pl falzeferenced as a i
standard used in the design, fabrication, installation and testing of cranes in rasponse to question j in Section 9.1.4 uf the FSAR.
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Contrary to the above, the p'olar' crane rope was not inspected within six months prior to the removal of the reactor head.
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Docket Noa 50-346 License No. NPF-3 Serial No. 1-285 July 30, 1982 Page 6
Response
Paragraph 3 of your cover letter dated June 16, 1982 (Log No. 1-638) states that no reply is required to this item.
Very truly yours, f
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RPC:LDY: lab attachment cc: DB-1 NRC Resident Inspector i
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Docket No. 50-346 License No. NPF-3 Serial No. 1-285 July 30, 1982 Attachment I Since Toledo Edison responded to the P.A.B. Report dated April 17, 1982, we have been involved in major efforts in the procurement area to:
1) procure materials for the 1982 refueling outage currently in progress; 2) evaluate the feasibility and needs of a new warehouse for further upgrades of the existing facility; and 3) evaluate the need for increased manage-ment involvement and control in the area of Material Mangement/ Procurement.
Although TED has made a significant improvement in the area of material control and handling since 1980, we recognize the need for additional improvements. Therefore, the Procurement Division of Toledo Edison has recommended impicmentation of a Materials Management Department. This department will establish a systematic approach to material management and thus provide a level of management and material control consistent with the dynamic requirements of the nuclear industry.
Toledo Edison is confident that the Material Management Departiaent will help alleviate NRC concerns in the area of procurement management.
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