ML20091L000
| ML20091L000 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 08/23/1995 |
| From: | Stetz J CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9508280258 | |
| Download: ML20091L000 (3) | |
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..t 300 Madloon Avenue John P. Stolt
. Toledo, OH 43652-0001 Vice Pieeldent. Nuclear 419 249-2300 usesse
' Docket Number 50-346
' License Number NPF-3 Serial Number'l-1080
- August 23, 1995 United States' Nuclear Regulatory Commission Document Control Desk Vashington, D. C.
20555
Subject:
Response to Inspection Report 50-346/95005
-Gentlemen:
Toledo Edison has received Inspection Report 95005 (Log Number 1-3595) and the enclosed Notice of Violation; the response to which is provided below.
Reply to a Notice of Violation (346/95005-03(DRP))
Alleged Violation j
10 CFR Part 50, Appendix B, Criterion V, 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."
-Administrative procedure DB-HN-00001, conduct of Haintenance, Section 6.5.4.f.1 specified that " Personnel performing maintenance tasks shall ensure they have the proper tools and approved consumables to do the task correctly and safely."
Administrative procedure DB-MN-00001 also specified in Section 6.9.3.a that " Procurement of supplies and equipment for maintenance shall be performed in accordance with... NG-HS-00505, controlled Haterials Program."
' Administrative' procedure NG-HS-00505 specified in Section 6.4.1 that "The requester (of approved controlled materials) shall teview the Controlled Haterial Contaminant Evaluation (CMCE) and ensure that the
, approved product usage, category designation, and any restrictions are
. applicable.to the proposed usage of the controlled material."
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PDR ADOCK 05000346 j
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PDR Operating Componies:
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Dock t Nuaber 50-346 Lic:n:o Narber NPF-3 e
Serial Number 1-1080 Page 2
. Contrary to the above, on April 6-7, 1995, several controlled materials that were not approved for unrestricted use under the licensee's Controlled Materials Program were found stored in the auxiliary building and/or in use during maintenance activities without any restrictions placed on their use.
This is a Severity Level IV violation (Supplement I).
Toledo Edison Response 1.
Reason for the Violation.
Initial concerns regarding the inadequate control of consumable materials were documented by the Nuclear Regulatory Commission (NRC) in Inspection Report (IR) 95004 dated May 15, 1995, as an unresolved item (URI 346/95004-01).
The discussion of this issue in IR 95004 identified several consumable materials that were stored and/or in use in the auxiliary building, but had not been approved for unrestricted use in accordance with the Davis-Besse Controlled Materials Program.
The cause of this violation was inadequate knowledge of maintenance personnel regarding the requirements of procedure NG-HS-00505, Controlled Materials Program, as they apply to the Controlled Materials Contaminant Evaluation (CHCE) Index. The CHCE Index identifies controlled consumable materials which have been evaluated and characterized for use on and/or in various plant systems.
A contributing factor to this violation was that training of maintenance personnel regarding the use of the CHCE Index was not as detailed as necessary.
In addition, NG-HS-00505 is cumbersome, contains minor inaccuracies, and lacks adequate interface with other station procedures.
2.
Corrective Actions Taken and Results Achieved Potential Condition Adverse to Quality Report (PCA0R) 95-0296 was initiated on April 7, 1995, to document the inadequate control of consumable materials.
The suspect materials were immediately removed from their storage locations and a notice was issued temporarily banning the use and issue of these specific consumable materials.
In addition, signs vere posted at the tool rooms informing employees of their responsibilities regarding consumable material verification prior to use.
A memorandum was issued by the Superintendent - Hechanical Maintenance on April 28, 1995, which discussed compliance with the requirements of the Controlled Materials Program and the CHCE Index. Required reading of this memorandum was completed by appropriate station personnel on May 30, 1995.
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Dock 2t Nu bar 50-346 Licznaa Nu;b:;r NPF-3 e
Serial Number 1-1080 Page 3 A Quality Assessment surveillance of the Controlled Materials Program was conducted April 25 through May 18, 1995 (SR-95-ENVMG-01). One finding report was issued which documented Controlled Materials Program discrepancies identified during the surveillance. Additional-discrepancies associated with approved consumable materials listed in maintenance procedures were incorporated into PCA0R 95-0296.
3.
Corrective Actions to Prevent Recurrence The Continuing Training Program for Maintenance personnel vill be revised to provide mare detail regarding the use and requirements of the CHCE Index.
Initial' training of Maintenance personnel vill be completed by October 30, 1995.
Enhancements to the Controlled Materials Program are in progress. These enhancements include reduction in scope, process simplification, improved user compatibility and improved interface with other station procedures. The i
program discrepancies identified in SR-95-ENVMG-01, including those incorporated into PCA0R 95-0296, are being pursued in concert with this effort. Revision of the Controlled Materials Program vill be completed by December 15, 1995.
4.
Date When Full Compliance Vill Be Achieved.
Full compliance was achieved on April 7, 1995, when the original suspect materials identified in PCAOR 95-0296 were removed from their storage locations in the auxiliary building and restricted from use and issue.
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Should you have any questions or require additional information, please i
contact Mr. Villiam T. O'Connor, Manager - Regulatory Affairs, at (419) 249-2366.
Very truly yours, 4.
AVA/ eld cc:
L. L. Gundrum, NRC Project Manager H. J. Miller, Regional Administrator, NRC Region III S. Stasek, DB-1 NRC Senior Resident Inspector Utility Radiological Safety Board d
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