ML20098E138
| ML20098E138 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 05/27/1992 |
| From: | Shelton D CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1-987, NUDOCS 9206010292 | |
| Download: ML20098E138 (5) | |
Text
.
CENTERDOR ENERGY Donald C. Shehon 300 Madison Aenue Vee Presdent wutlear Toledo, OH 436520X)1 Dam Besse (419)249 2300 Docket Number 50-346 License Nun.ber NPF-3 Serial Number 1-987 May 27, 1992 United States Nuclear Regulatory Commission Document Control Desk Vashington, DC 20555
Subject:
Response to Inspection Report Number 50-346/92003 Gentlemen:
Toledo Edison has received Inspection Report 92003 (Log Number 1-2640) and piovides the following response.
It is Toledo Edison's understanding that this required response is due 30 days from the April 28, 1992, receipt date rather than 30 days from the April 17, 1992, letter date.
Violation 92003-02:
Technical Specification 6.8.1.a requires that written procedures be established, implemented and maintained covering activities recommended in Appendix A of Regulatory i
Guide 1.33, November 1972.
Regulatory Guide 1.33 Appendix A.Section I, lists procedures fc1 performing maintenance.
DB-HN-00001, Rev 1 Conduct of Haintenance, paragraph 6.5.4 requires that maintenan<e tasks shall be performed in accordance with Maint ance Vork Order (HVO) packagec.
Contrary to the above, on March 1, 1992, personnel performed troubleshooting activities on lov vacuum pressure circuitry which was outside the scope of vork as defined by HVO 7-91-0395-01.
Response
Acceptance or Denial of the Alleged Violation roledo Edison acknowledges the alleged violation.
92060104575 920527
$DR ADOCK 05000346
/
I PDR y
Overc%g Companies Cineland Etectoc iHuminotmg 10!edo [dron ru
Docket Number 50-346 License Number NPF-3 Serial Number 1-987 l' age 2 Reason for the Violation On March 1, 1992, at 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br />, the unit experienced an Anticipatory Reactor Trip System (ARTS) initiated reactor i
trip from approximately 40 percent power.
The unit had been l
increasing power from approximately 6 percent after the completion of planned maintenance activities in the containment which vere unrelated to the reactor trip.
Maintenance-I&C personnel-vere troubleshooting e reviring of the main turbine vacuum trip system under Ha..itenance Vork Order (MVO) 7-91-0395-01 by checking the condition of the vacuum pressure switches in junction box JT 5306. The I&C personnel vere unavare that part.of the revtring under the HVO had introduced a redundant power source to the circuit they were checking and that the circuit was actually energized. The redundant power source had been added by the installation of a jumper between terminals 1 and 5 on terminal block EHC-B.
Believing the circuit to be de-energized, the I&C technician performing the pressure svitch check used a multimeter set in the ohms mode. The 160 technician incorrectly placed the leads of the multineter across terminals 2 and 5-vhich effectively bridged an open contact resulting in actuation of the high exhaust hood temperature trip circuitry which triggered a main turbine trip.
Because indicated reactor power was greater than the ARTS arming setpoint, the turbine trip resulted in an ARTS initiated reactor trip.
The primary cause of the reactor trip is attributed to personnel error. During troubleshooting of the reviring of the main turbine vecuum trip system, an I&C technician incorrectly placed leads of a multimeter across the wrong two terminals. This action resulted in the actuation of the high exhaust hood temperature trip circuitry and a subsequent reactor trip.
l Contributing to the cause of the reactor trip are several work control issues as they relate to the work performed under HVO 7-91-0395-01.
The MVO vas created to address concerns documented in Potential condition Adverse to Quality Report (PCA0R) 91-0395.
The PCAOR documents that l
the redundant turbine lov vacuum-trip pressure switches vere I
not vired into the trip circuitry, and that the as-built l
viring in the field did not correspond to the electrical connection drawings.
HVO 7-91-0393-01 was to correct these l
viring inconsistencies.
Docket Number 50-346 License Number NpF-3 Serial Number 1-907 Page 3 Several aspects of MVO 7-91-0395-01 reflect inadeguate gre-job plannli [ Mid evaluatiEi' The MVO had been scheduled such that it could be performed during Mode 1 operation with the turbine on-line.
During discussiens between Haintenance i
and Engineering it was decided by Maintenance that the work should be performed with the turbine off-line, but the HVO did not reflect this decision.
Additionally, the verification of cesputer alarms associated with the pressure I
svitches could not be performed with leads lifted as specified in the HVO. The re'*
of the pressure switches resulted in the addition of a ant power source-to the turbine vacuum trip circuitry, i was unknown to the 16C Maintenance personnel performing the work.
Vork practices during preparation for and performance of HVO 7-91-0395-01 vere inadequate.
Changes to the HVO description of work did not adequately describe the work to be performed. Changes vere made in order to accomplish the work scope and the HVO vas not changed. Vhen unexpected conditions vere encountered, continuity r. hecks in the field began without properly notifying Operations and without adequately developing ae action plan taking into account the changed status of the plant.
Documentation in the HVO of the work performed was incomplete.
In addition, the decision to continue work under the HVO vith the turbine on line was made without adequate onsideration of alternatives and consequences. When planned maintenance activities were completed in containment, the work on the main turbine vacuum trip system was still in progress.
Operations management decided to place the turbine on-line, increase power to a steady-state level below the ARTS arming setpoint, and assign two operators the responsibility of tripping the turbine manually in the event of a loss of main turbine vacuum.
The schedule called for completion of. turbine vacuum trip work prior to placing the turbine on-line.
Deviation from the work schedule occurred without a thorough review by Davis-Besse management.
Compliance to station procedures was not maintained.
Contrary to DB-PN-00007, Control of Vork, the HWO vas not re-routed to the Shift Supervisor / Shift Manager for. review of changes made to the HVO after granting permission to comnence work._ Contrary to DB-HN-00001, Conduct of Haintenance, and DB-MI-05013, Plant Hiscellaneous Pressure Switch Calibration, vires vere disconnected and jumpers installed without completing the jumper and lifted vite log or contacting the Shift Supervisor,
- -~
Docket tiumber 50-346 License Numbe;r !JPF-3 Serial Number 1-987 Page 4 Corrective Action Taken and Results Achieved Potential Condition Adverse to Quality Report 92-0084 vas initiated on March 1, 1992, to-document the reactor trip.
Potential Condition Adverse to Quality Report 92-0134 vas initiated on March 24, 1992, to document vork control issues related to MVO 7-91-0395-01.
Licensee Event Report (LER)92-002 was issued on March 31, 1992, in accordance with 10CFR50.73(a)(2)(iv) describing this event.
A revision to LER 92-002 vas issued on May 8, 1992.
On April 29, 1992, a memorandum was issued by the Manager -
Plant Maintenance to I&C and Electrical Maintenance personnel discussing the proper use of the Jumper and Lifted Vire Log, as voll as proper Shift Supervisor notification.
Corrective Action to Prevent Recurrence Vith regard to the personnel error, this event and the surrounding circumstances vill be reviewed by Haintenance personnel during the Continuous Training Program.
In addition, training vill be performed on the proper use of test equipment. These actions vill be completed by June 26, 1992.
Corrective actions for the work control' issues described in the " Reason for the Violation" section are described below, l
l Required reading of this LER vill'be performed by appropriate Operations, Haintenance, and Planning personnel-by June 26, 1992.
DB-MN-00001 vill be changed to require the Jumper and Lifted l
l Vire Log to be completed concurrent with the actual work activity.
This change vill be completed by July 1, 1992.
Changes to the requirements for pre-evolution briefings are being processed.as part of the corrective actions for LER 91-008-01.
The pre-evolution briefings vill include the Operating Crev, the Craf t Supervisor, Craft Personnel, and Engineering support _as appropriate.
The briefing should identify the individual responsible for performing the-evolution, the purpose and objective of-the evolution, and the equipment or systems involved.
In addition, the briefing vill review the responsibilities of all personnel-involved and the expected system responses and clearly _
specify parameter values at which action vill _be taken to l
stop the evolution or mitigate possible failures.
These changes vill be completed by Hay _ 29, 1992.
.-_u,__..
. _.. -.... _ _. _ _ _, _.. _ _.... _, _. _ _ - _. ~ _ _. _. _ _.._..
Docket llumber 50-346 License !Jumber NPF,.
Serial 11 umber 1-907 Page 5 In addition, a step vill be ndded to DB 0P-06901, Plant Startup, which requires the Duty Plant Manager, Operations Manager, and Haintenance Manager to review plant status prior to raising reactor power to 15%.
During this review, attention vill be focused on safety systems and equipment protective features that may be in off-normal conditions.
This change vill be completed by June 1, 1992.
Date Vhen Full Compliance Vill Be Achieved The corrective actic.is to prevent recurrence described above vill be implemented and full compliance achieved by July 1, 1992 n
should you have any questions or require additional information, 1, lease contact Mr. R. V. Schrauder, Manager - 14uclear Licensing, at (419) 249-2366.
Very truly yours, k
(,y A.D AVA/dlm cet A. B. Davis, Regional Admints rator, 14RC Region III J. B. Ilopkins, NRC Senior Project ManaFer V. Levis, DB-1 14RC Senior Resident Inspector Utility Radiological Safety Board l
l f
. =.
...-