ML20065M211
| ML20065M211 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/15/1994 |
| From: | Shelton D CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1-1039, NUDOCS 9404250105 | |
| Download: ML20065M211 (4) | |
Text
A CENTERIOR V
ENERGY 6200 cak Tree Boulevard Mail Address Donald C. Shelton Independence OH P0.Bu 94661 Senior Vice President 216 44T3153 Cleveland. OH 44101-4661 NJclear Fox 216 447 3123 Docket Number 50-346 License Number NPP-3 Serial Number 1-1039 April 15, 1994 United States Nuclear Regulatory Commission Document Control Desk Vashington, D. C.
20555 Subj ec t :
Response to Notice of Violation - Inspection Report Number 50-346/94002 (DRP)
Gen t leinen :
Toledo Edison is in receipt of Inspection Report 94-002 (Log Number 1-2995) and the enclosed Notice of Violation; the response which is provided below.
Violation:
10 CFR Part 50, Appendix B, Criterion V, 94002-01
" Instructions, Procedures, and Drawings," states, in part that " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings... and shall be accomplished in accordance with these instructions, procedures, or drawings."
Procedure DB-MI-03730, Channel Calibration of Channel 2 Containment Vessel Atmosphere Hydrogen Analyzer, step 4.1.4 specifies that if, during performance of the procedure, any malfunction is found which could prevent the fulfil 1r
..t of channel functional test requirements, the shift supervisor and Instrumentation and Control (I6C) department supervisor shall be notified immediately.
9404250105 940415 PDR - ADOCK 05000346 0
PDR Operahng Compon;es
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Cloveiond Electoc fliummchng Tcledo Edison
I' Docket. Number 50-346 j
License Number NPF-3 Serial Number 1-1039 Page 2 Contrary to the above, on September 3, 1993, during performance of DB-HI-03730, revision 00, maintenance personnel identified a malfunction in containment hydrogen analyzer channel 2 which would prevent the fulfillment of channel functional test requirements and did not immediately notify the shift supervisor and I&C department supervisor.
This is a Severity Level IV Violation (Supplement I).
Response
Acceptance or Denial of the Alleged Violation Toledo Edison accepts the alleged violation.
Reason for the Violation on September 3, 1993, calibration of containment hydrogen analyzer (CHA) Channel 2 was in progress. In accordance with section 8.2.4 of DB-HI-03730, the technician performing the calibration vas'in the process of lifting leads from terminal strip TS1 in panel C3801. During this process, the technician inadvertently shorted the 120 VAC line voltage to ground which resulted in Channel 2 CHA power supply fuse Y218 bloving.
The technician, aware that Channel 1 was the standby channel, noted that power indicating lights for both channels were off. The technician was not aware that this was the proper indication for Channel 1.
The standby CHA channel has been maintained as a normally de-energized circuit since the Eighth Refueling Outage. The technician believed-that his actions in Channel 2 had caused Channel 1 to de-energize because both channels are located in the same cabinet.
The technician inappropriately attempted to verify the condition of CHA Channel 1 by trying to start the Channel 1 sample pump. The sample pump did not start and the technician correctly contacted the control Room and his supervisor.
It was later discovered that CHA Channel 1 power supply fuse Y119 had also blown.
Consequently, both CHA channels were coincidentally inoperable.
It is believed that fuse Y119 blev as a result of the attemp'.ed start of the Channel 1 sample pump due to the fusc being potentially under-rated. This condition 10 being evaluated under Potential Condition Adverse to Quality Report (PCA0R) 93-0415.
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I Docket Number 50-346 License Number NPF-3 Serial Number 1-1039 Page 3 No Technical Specification (TS) violation occurred because both power supply fuses were replaced and power was restored to both CHAs well within the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> outage time allowed by TS 3.6.4.1 for two inoperable CHAs.
Nevertheless, the action the technician took in attempting to start the CHA Cho'nel 1 sample pump was outside of the scope of DB-MI-03 30 and is considered an equipment control deficiene/
It is the expectation of Davis-BEsse management that manipulation of station equipment should only be performed under the cognizance of Operations personnel, unless the manipulation is specifically within the scope of a Maintenance Vork Order (HWO) or procedure. This expectation is generally understood by plant staff and is adequately proceduralized.
However, in the case of surveillance / periodic test procedure performance, training of maintenance personnel was not sufficient.
Corrective Actions Taken and Results Achieved Potential Condition Adverse to Quality Report (PCA0R) 94-0241 was initiated on March 2, 1994, to document concerns identified with equipment control issues related to the loss of power to both containment hydrogen analyzers.
A memorandum from the Operations Manager dated March 31, 1994, was distributed to all site personnel.
The memorandum provides information and guidance on management expectations regarding manipulation of equipment that may affect plant operations.
The equipment control deficiency described in this response was discussed with the involved technician and at an I&C Maintenance shop meeting.
In addition, equipment and procedural control issues vere discussed tt the Vice President - Nuclear's staff meeting on Acril 13, 1994. The meeting was attended by plant supervisory personnel.
Correct 1 1 Actions to Prevent Recurrence This issue vill be a topic of discussion at continuous training sessions for all maintenance craft and first i
line maintenance supervisory personnel. These i
sessions vill be complete by June 30, 1994.
Haintenance staff personnel vill complete required reading of this response by May 20, 1994, l
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Docket Number 50-346 License Number NPF-3 Serial Number 1-1039 Page 4 Date When Full Compliance vill be Achieved Full compliance vill be achieved by June 30, 1994, following completion of the continuing training sessions referenced above.
Should you have any questions or require additional information, please contact Mr. V1111am T. O'Connor, Manager - Regulatory Affairs, at (419) 249-2366.
Very truly yours, l
f DC h AVA/ eld i
cc:
J. B. Hartin, Regional Administrator, NRC Region III S. Stasek, DB-1 NRC Senior Resident Irspector G. Vest, Jr., NRC Project Manager Utility Radiological Safety Board 1
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