ML20090H152
| ML20090H152 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 03/09/1992 |
| From: | Shelton D ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1-976, NUDOCS 9203130328 | |
| Download: ML20090H152 (7) | |
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' f CENTEmon ENERGY Donald C. Shelton 300 Madison Avenue Vce President Nuclear Toledo. OH 436524001 Das Besse (419)249 2300-l-
Docket flumber 50-346 License !! umber flPF-3 Serial fiumber 1-976 l
. March 9, 1992 i
United States l'uclear Regulatory Commission Document Control Desk Washington, DC 20555
Subject:
Response to Inspection Report Number'30-346/91016 Gentlemen:
i Toledo Edison (TE) has received Inspection Report 91016 (Log.
tiumber 1-26u5) and.provides the fo]Iowing response.
Requirement:
10 CFR Part 50, Appendix,B, Criterion V, as-implemented by the Toledo Edison Nuclear Quality Assurance Manual,-
l Quality Requirement 5.4.1.2, requires-that. activities that affect quality shallLbe prescribed by. clear and complete documented procedures-an_d instructions of-a-type appropriate-to the circumstances and shall be accomplished in'accordance with thesefdocumentst violation 91016-01A:
Control Work procedure DB-Pti-00007,'Rev.~1, 6-requires, in part, thatimodification training requirements have been met anel that' functional tests, such as calibrations. haveibeen completed before i
signing off the specific requirements.
Contrary to the. above::
(1)
The Maintenance Work Order (MWO)-Verification.
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Checklist'for HWO 2-90-0059-03,'.had Block-2 signed and dated October.4, 1991,' indicating that trainingcrequirements had.beenimet, floweve r, 12-l reactor operators / senior-reactor operators-..did not receive their training until October 9 -110, 1991.
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Docket Number-50-346 License Number NPF-3 Serial Number 1-976 Page 2 (2)
The MWO Verification Checklist for MWO 2-90-0078 05, affecting modification 90-0078 had Block 5 signed andl dated October-13, 1991, indicating that all functional testing had been completed.
However,'the calibration phase of the level transmitters was not completed until November 2, 1991.
Response to Example (1):
Acceptance or Denial of the Alleged Violation Toledo Edison acknowledges the alleged violation.
Reason for the Violation During the Seventh Pefueling Outage, Modification-90-0059 was implemented to provide manual isolation
. valves and instrumentation to facilitate inspection and testing of the Service Water System, Prior to returning the system to service DB-PN-00007, ' Control of Work" requires that operator training be-completed.
However, due to a misunderstanding of the specific requirements as to the--training-that-must be completed prior to closure of a Maintenance Work Order (HWO), all training-was not completed prior to returning-the system to service.- The intent of completing modification training prior to returning a system to l
service is to ensure that licensed individuals are cognizant of system changes prior to operating those systems.
Nuclear Training-was. conducting _ classroom trainingEfor Modification-90-0059 during;the' refueling outage to; meet.the training requirements.
In discussions 1etween Nuclear Training and OperationsEon.0ctober'4 J1991, Modification ~90-0059 was,being reviewed,for completion i
to allow the Service-Water System to be' returned to-service. _ It was. recognized at that time that twelve licensed individuals had not completed the classroom training.
Nine individuals on the on-shift operating crew had completed their watch.at 0400 on October 4, 1991. They were scheduled to be in. training on their return to work the week of October' 7, 1991..At that time, the Contrcl Room Required. Reading Book was reviewed - and it was determined that all but one of the nine on-shif t operating 1 crew ' members had reviewed-the required reading associated with Modification-90-0059.
l The-required reading consisted of a. description of procedure changes associated with the modification.
The three remaining active licensed individuals that had not received the required-training priort to October 4.
1991, were assigned outage-related duties and were not assigned licensed duties.
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Docket Number 50-346 License Number NPF-3 Serial Number 1-976
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Based upon the above information 'and the f act that l
DB-PN-00007 does not specify the type of training that must be completed, the training for MWO 2-90-0059-03 was signed off as being completed.
i Corrective Actions Taken and Results Achieved i
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The individuals involved in this event have been counseled regarding the importance of properly following 9tocedures.
These individuals have been further instructed to ensure all, training is complete, regardless~of shift assignment, prior to signing the training completion block.
Training for,all licensed individuals was completed on i.
October 10, 1991, i
l Corrective Actions to Prevent Recurrence Procedures DB-PN-00007.." Control of Work",'and NG-EN-00301, " Plant Modification," will be revised to allow for release of a system to Operations prior to training completion provided other administrative controls (i.e., Unit Log entries or Operating Night Orders) are in place to prevent any individual'from performing license duties until that' individual receives the required training.
This actionLis consistent with the intent of ensuring training-is conducted-for significant plant modifications prior to licensed individuals operating those systems.
Date When Full Compliance will be Achieved-Full compliance was achieved?on 0ctober lo,-1991, when.
l all licensed individuals completed training on Modification 90-0059.
In addition, the corrective actions noted above to prevent 1 recurrence.w111-be implemented by. September.4, 1992.
l Response to l
Example-(2):
Acceptance or Denial of the Alleged Violation l
l Toledo Edison-acknowledges the alleged l violation +-
Reason' for the Violation During the preparation of MWO'2-90-0078-05 for
. Modification 90-0078, : all of: the - tes tingL requirements.
were specified:as. functional tests. These included DB-MI-0324$, " Channel Functional Test and Device.
Calibration of 83C-ISLSP9A6, A7,tB8;and B9 SFRCS' Steam
-Generator Actuation-Channel 12 LevelLInputs":and.
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Dochet Number 50-346 License Number NPF-3 I
Serial Number 1-976 Page 4 l]
i DB-SC-03180. " Remote Shutdown, Post Accident Monitoring j
Instracentation Monthly Channel Check."
Following the completion of work for HWO-2-90-0078-05, functional testing was being performed and it was discovered th t DB-MI-03245 and.DB-SC-03180 could not be completed prior to system turnover to Operations since the procedures required the system to be placed in service upon test completion.
However DB-MI-03245 was parti. ally completed and the test acceptance criteria we re me t.
The Planner responsible for the modification then signed for the functional testing being completed.
intending that DB-MI-03245 snd DB-SC-03180 be redefined as Post Modification Tests to be completed after the system was returned to service.
However, he neglected to properly document this in the MWO.
Upon review of the MWO for closure on October 19, 1991, this discrepancy was identified, the test deficiency was noted and dispositioned as being acceptable.
The MWO was closed by Operations and the Modification placed in service or. November 3, 1991.
DB-MI-03 45 and DB-SC-03180 should have originally been
' designated as Post Modification Tests'instead of-Functior.al Tests.
Per DB-PN-00007, the proper actions the Planner should have taken would be'to have noted and dispositioned the testing' deficiency prior to signing for the completion of-functional testing.
Corrective Actions Taken'and Results Achieved The intent of DB-PN-00007 and DB-PF-01025
" Pre-Maintenance and Post-Maintenance Testing Requirements" has been-re-emphasized.to the-individual involved..In particular, the categorization of test-
. requirements vas-discussed as intended by DB-PF-01025; As was noted above, the testing deficiency was noted and dispositioned as acceptable.
The required testing was completed and the modification.was placed in service on November s.1991.
. Corrective Actions to Prevent Recurrence-Procedures.DB-PN-00007 and DB-PF-01025 were reviewed to determine if enhancements could be made to -better clarify the specification of proper testing-requirements. DB-PF-01025 will be revised-to better clarify the properscategorization of test requirements for planners-to be used when completing the TNO Tests Requirements cheet.. Revision:of:this procedure will be completed by May;15, 1992.
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Docket Number 50-346 Licence ' lumber NPF-3 Serial Number 1-970 4
Page 5 Date when Full Compliance will be Achieved Full compliance was achieved on November 3,-1991, upon
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successful completion and review of required testing.
The corrective actions to prevent recurrence noted above will be implemented by May 15, 1992.
Violation 91016-01B:
Potential Condition Adverse to Quality Reporting (PCAQ) procedure NG-QA-00702, Rev. 2,. step 6.1.5 requires that a new PCAQ be generated if additional potential-conditions adverse to qualityLare found that violate the same requirements _ addressed in an existing PCAQ.
and the existing PCAQ has been closed or sent to Document Systems.- Step 6.1.7 requires that if the existing PCAQ is still open, the new condition be identified as a continuation' sheet of the original-l 4
PCAQ.
Contrary to the above.-neither a new PCAQ-nor a contiauntion sheet to PCAQ 91 0521 was; written as a result of.the No. 2 emergency' diesel generator failure to develop rated voltage within 10 seconds on November 8, 1991.
Responsen Acceptance or Denial of the Alleged Violation Toledo Edison acknowledges the_ alleged violation.
Reason for Violation On November 8 1991, during performance of the No. 2 Emergency Diesel-Generator (EDG) Monthly Surveillance Test,DB-SC-03071, No. 2-EDG was_ idle started:and idle released to full speed. Approximately 30-45 seconds later, the. System Engineer noticed an absence of elect o ual generator output as_ indicated _on the frequency and voltage meters.. Within-the next fiveL seconds, the th), 2lEDG field flashediand-frequency and voltage indicators responded.
The System Engineer 1 informed the EDG operators of the indications and' proceeded _to inform Systems Engineering management.
Systems Engineering recommended to the Shift Supervisor to maintain'No. 2 EDG paralleled to the grid to ensure-
- operability,-and recommended installing a strip chart recorder and. performing a fast timed start'to verify.
the ten aecond start criteria was met.
A six channel strip _ chart was installed while the engine was running and-the engine-was shut down. _Within five to ten minutes, the-engine was fast started reaching rated speed and voltage in 7.7 seconds. No abnormalities were noted on the strip chart. -Operations maintained' l
the operable-status of No. 2 EDG with Systems Engineering concurrence.
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Docket Number 50-346 bicense Number NPF Serial Number 1-976 Page 6 O,erations and Systems Engineering discussed the.
t similarities between this delay and the failure of No. 2 EDG on October 21, 1991, and. concurred that:a problem existed which appeared to degrade over time.
A decision was made to formulate an action plan tc troubleshoot the EDG field flash circuitry. Although i
System Engineer discussed the plan with Systems Engineering and Operations management on November 12 1991, the question as to whether or not a. PCAQ shou: <
be written to document the_ discrepancy was not discussed.
Following-further discussions on November 20 Systems Engineering determined:that PCAQR should have been written and initiated PCAQR 91-0584.
At this time, the action plan to-correct the EDG field flash circuit discrepancy was well underway.
Corrective Actions Taken and Results Achieved i
As noted above, PCAQR 91-0584 was-initiated on November 20. 1991.
Corrective actions taken as a result of_the No. 2 EDG failure on November 8, 1991 and subsequent failures of No. 2 EDG are described in TE's-letter of December-6.
1991 (Serial Number 1-967).
In order to reinforce TE management expectations of the
- PCAQR process, Systems Engineerien-personnel were-briefed on this event and the procedural requirements related to the initiation of PCAQRs was emphasized.
Support of the PCAQR process was further promoted-site-wide through an article in the-Davis-Besse weekly newsletter. This was completed ~on-March 6, 1992.
Corrective Actions ~Taken to Prevent Recurrence:
Based u; son a-review of prior PCAQRs and results of a-September 1991 Quality Assurance audit,-failure to initiate a PCAQR for-a condition requiring one is-not a wide-spread or repetitive occurrence.- In addition, TE believes-its' existing procedural controls over the PCAQR process are sufficient to prevent' recurrence.
Date-when Full Compliance will be Achieved Full-Compliance was achieved on November 20,fl991, when; a PCAQR.for the event describedLabove-was initiated.
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' Docket Number 50-346-.
License Number NPF-3
-Serial Number 1 976 Page 7:
Should you have-any questions or require additional information, please contact'Mr.
R..W. Schrauder, Banager - Nuclear Licensing, at (419) 249-2366.
Very tr
- yours,
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NKP cci A. B.. Davis, Regional Administrator 3 - NRC Region III-J. B. Hopkins, NRC/NRR DB 1 Senior Project Manager W. Levis, bRC Senior Resident Inspector Utility. Radiological Safety' Board h
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