ML20141D162
| ML20141D162 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 05/09/1997 |
| From: | Jeffery Wood CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1-1125, 50-346-97-03, 50-346-97-3, NUDOCS 9705200018 | |
| Download: ML20141D162 (8) | |
Text
W CENTERDOR
~ ENERGY 5501 N State Route 2 419-749-2300 John K. Wood Oak Hartre, OH 43449 FAX: 419-3218337 Vce President. Nuclear DavwBesse Doclet Number 50-346 License Number NPF-3 Serial Nmnber 1-1125 May 9, 1997 United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555
Subject:
Response to NRC Inspection Report Number 50-346/97003 Ladies and Gentlemen:
Toledo Edison has received Inspection Report (IR) 50-346/97003 (Log Number 1-3816) and the enclosed Notice of Violation. The Response to the Notice of Violation is attached. After discussion with the Senior Resident Inspector for the Nuclear Regulatory Commission (NRC) at the Davis-Besse Nuclear Power Station (DBNPS) on May 5,1997, it was agreed that this response to IR 97003 would be submitted by May 9,1997.
In the transmittal letter for the Inspection Report, the NRC communicated their concern about I
procedure adherence violations at the DBNPS. The management and staff of the DBNPS share this concern. Although the attached reply to the Notice of Violation addresses the specific examples of procedure adherence and their respective corrective actions, additional actions have been initiated to re-emphasize the importance of procedure adherence to the DBNPS staff.
In our response to IR 50-346/96014 (Serial Number 1-1122) dated April 4,1997, Toledo Edison identified that procedure usage requirements described in DB-OP-00000, " Conduct of Operations," are not completely consistent with the requirements found in DB-DP-00013, j
" Surveillance and Periodic Test Program." Toledo Edison committed to evaluate DB-OP-00000 and DB-DP-00013 for inconsistencies by May 30,1997. Procedure alterations identified by this i
review will be completed and personnel involved in surveillance testing will be trained on these procedure changes by July 31,1997.
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Docket Number 50-346
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License Number NPF-3 i
Serial Number 1-1125 t
Page 2 Efforts have been initiated to heighten the awareness of procedural compliance issues with the i
staff. On March 25,1997, an internal memorandum (DSM-97-25013) was distributed to all Managers and Superintendents onsite for the purpose of providing a basis for presentations to all site personnel on the topic of procedural compliance. These presentations focus on the individual and leadership behaviors necessary for the DBNPS to strive for effective procedural compliance.
The management staff has initiated efforts to evaluate the adequacy and consistency of policies and procedures that establish the requirements and expectations for procedure compliance. Due to the forced plant outage that began with the plant trip on May 4,1997, management attention was diverted to the safe conduct of this outage. As a result, in order to complete a comprehensive review, the results of this evaluation, along with the identified action plans, will be provided by June 27,1997.
Should you have any questions or require additional informatio:1, please contact Mr. James L.
Freels, Manager - Regulatory Affairs, at (419) 321 8466.
Very truly yours, DLM/dic attachment ec:
A. B. Beach, Regional Administrator, NRC Region Ill A. G. Ilansen, NRC/NRR Project Manager S. Stasek, NRC Region 111, DB-1 Senior Resident inspector Utility Radiological Safety Board
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, Docket Number 50-346 l
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Liccnse Number NPF-3'
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. Serial Number 1-1125 6
Attachment Page1 n
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i Renly to a Notice of Violation (50-346/97003-01[DRP1) f l
Alleged Violatiom l
L 10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings," states in i
part that, " Activities affecting quality shall be prescribed by documented instructions,
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procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with tirse instructions, procedures, or drawings."
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Davis-Besse Technical Specification 3.3.1.1 stated that,"As a minimum, the reactor protection system instrumentation channels and bypasses of Table 3.3-1 shall be operable...".
Technical Specification Table 3.3-1 Item 8,"High Flux / Number of Reactor Coolant Pumps l
On," required that with one channel inoperable, associated action statement 3 be invoked.
l Administrative procedure DB-OP-00005 (Revision 05)," Operator Logs and Round.c," Section t
j 6.2.2.d stated in part that, "The following are entries which shall be recorded in the U' nit Log:.
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.. Entering / Exiting a Technical Specification Action Statement."
I Maintenance Work Order (MWO) 1-96-0708-00, " Replace DH-100, Leak Test Valve for Pressurizer Auxiliary Spray Line," specified in step 3 to " Refill, pressurize, inspect and verify no leaks." In addition, step 1 of the MWO specified, in part, to "Tagout and dram pipmg using... DH-2736 along with DH-2735 to isolate the RCS."
Davis-Besse administrative procedure DB-DP-00013 (Revision 04), " Surveillance and Periodic Test Program," Section 6.3.7.h stated in part that, " Test prerequisites and procedure j
steps shall be performed in numerical sequence... unless optional sequencing is allowed by the procedure..."
Contrary to the above:
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- a. The NRC identified that when nuclear instrument NI-6 was declared inoperable on January 31,1997, one channel of the reactor protection system associated with the high flux / number of reactor coolant pumps on trip was inoperable as well. However, no unit log entry was made to record entry into Technical Specification 3.3.1.1 action statement 3.
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- b. On February 19,1997, the NRC identified that personnel performed work outside the scope of the MWO in that the tagout establishing the isolation boundary was changed from that j
stated in the MWO and the auxiliary spray line was not refilled upon completion of the j
maintenance activity as required by the MWO.
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. c. On February 24,1997, the NRC identified that surveillance procedure DB-PF-03030 (Revision 00)," Service Water Pump 3 Quarterly Test," steps 4.7.2 through 4.7.5, were completed before step 4.7.1, with no optional sequencing provision allowed in the i
procedure.
' This is a Severity Level IV violation (Supplement 1).
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Docket Number 50-346
' License Number NPF-3 Serial Namber 1-1125 o
Attachment Page 2 Reason for the Violation
- a. The reason for this alleged violation is incomplete identification of all the affected Technical Specification (TS) Action requirements during the process of reviewing and determining the operability of Reactor Protection System (RPS) Channel 1. On January 31,1997, the power range nuclear instrument, NI-6, reactor imbalance signal to RPS Channel I was discovered to provide an erroneous indication. This event was reported in Licensee Event Report 97-001 submitted on February 21,1997. When this failure occurred, the Assistant Shin Supervisor reviewed the TS and made a Unit Log entry.
4.
A review of the DBNPS Unit Log generated that day and sent to Records Management indicates that the proper Technical Specification Limiting Condition for Operation, Actions 2 and 3, were entered and noted in the Unit Log by the Assistant Shift Supervisor on duty that day. The Assistant Shift Supervisor that made the Unit Log emry in question was interviewed. Although the individual involved remembers the event in question, he does not recall editing the log prior to locking the log at the end of the shift. The Unit Log entry in question occurred on January 31,1997, at i154 hours.
The Shin Supervisor involved was interviewed. The Shift Supervisor remembered the event.
Ile stated that when the failure occurred, the Assistant Shin Supervisor reviewed the Technical SpeciGcations and made a Unit Log entry. The Shift Supervisor independently reviewed the Technical Specifications as well. The NRC Resident Inspector (RI) was in the Control Room at the time and approached the Shift Supervisor about the missed Action in the Unit Log. The Shift Supervisor, havingjust reviewed the Technical Specifications, reached the same conclusion and agreed with the RI The Shift Supervisor discussed the Technical Specification with the Assistant Shift Supervisor who had made the initial log entry. The Shift Supervisor believed the Assistant Shift Supervisor altered the original log entry to accurately reflect the Action Statements required. This Shin Supervisor made a Unit Log entry 15 minutes aRer the initial Unit log entry regarding the piecement of RPS Channel 1 in Bypass and this entry reflects Actions 2 and 3. This Unit Log entry was at 1209 hours0.014 days <br />0.336 hours <br />0.002 weeks <br />4.600245e-4 months <br />. The Shift Supervisor stated that this entry was not edited. Base i on this information, the period of time that the log was not accurate was less than 15 mimes. It is concluded that the initial review may have overlooked the second Action statement. Once the Action statement was identified, the Unit Log was corrected to reflect the Action statements entered.
- b. The reason for this alleged violation was that the individual responsible for preparation of this Maintenance Work Order (MWO) inappropriately provided requirements for testing within the body of the MWO which were not within the nonnal conventions of MWO preparation.
This particular MWO was written by an individual who was a new planner. The MWO contained severcl items that are not routinely a part of the MWO body. The information regarding the refill, pressurization and verification that no leaks exist, is generally not included in the body of the MWO but rather as part of the test requirement sheets. The test requirement sheets contained similar information and stated, " Verify no leaks thru valve, welds and cap threads, and valve packing." Since the information to refill, pressurize, inspect and verify no leaks was within the body of the MWO, the group affected (Operations) was not
Docket Number 50-346
' License Number NPF-3 Serial Number 1-1125 Attachment Page 3 aware of the direction provided in the MWO and therefore did not realize the MWO needed to be corrected as the maintenance activities were accomplished.
With regard to the MWO tagging and testing activities contained in block 4 of the MWO, the Maintenance Personnel performing the MWO were aware that the tagging and testing activities required in the MWO are governed by administrative procedures. These administrative procedures were being followed. This created the belief that since changes in tagging and testing were made in accordance with the administrative procedure, the work specified in the MWO body was perfonned properly. As a result, the MWO was not updated to reflect the actual work accomplished.
- c. The reason for this alleged violation is that restrictions imposed by DB-DP-00013,
" Surveillance and Periodic Test Program" are more prescriptive than similar requirements found in DB-OP-00000," Conduct of Operations." This difTerence in requirements was identified during the investigation of a Notice of Violation (50-346/96014-01) issued to the DBNPS on February 25,1997, which involved performance of surveillance procedure steps out of sequence on December 30,1996. The individuals performing surveillance procedures, in both cases did not apply the more prescriptive requirements of DB-DP-00013 for sequencing of steps.
Corrective Stens Taken and Results Achieved
- a. On January 31,1997, the Unit Log was brought into compliance by reflecting the applicability of Action 3 for TS 3.3.1.1, Reactor Protection System Instrumentation.
- b. Management expectations with regard to the content of a MWO were discussed with the planning individual involved. A mentor was assigned to the planner to review work and provide assistance and direction where needed. This oversight will build the planner's skills and ensure MWOs are corrected prior to implementation.
- c. The procedure DB-PF-03030 for Service Water Pump 3 was completed and acceptable test results were obtained on February 24,1997. As a result of Notice of Violation 50-346/96014-01, required reading was issued to Plant Operations personnel on Mmch 27,1997, which reviews the differences between administrative procedures DB-OP-00000 and DB-DP-00013.
This required reading clarifies management expectations with regard to performance of surveillance procedures.
Corrective Steos that will be Taken to Avoid Further Violations i
- a. Refresher training is being provided to all SROs with regard to operability determinations.
This training reviews the definition of operability and the factors to consider when making operability determinations. This training will be completed by Jane 30,1997.
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Docket Number 50-346
~ ~ License Number NPF-3 Serial Number 1-1125 Attachment 4
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- b. The Maintenance Superintendents will discuss the MWO for this violation with Maintenance personnel. This discussion will reinforce expectations regarding compliance with or altering the actions specified in a MWO. These presentations will be completed by May 30,1997,
- c. The corrective steps taken to avoid further violations documented in the response to Inspection Report 50-346/96014 (Serial Number 1-1122) submitted to the NRC on April 14, 1997, are also applicable to this Notice of Violation. Administrative procedure DB-OP-00000 and DB-DP-00013 will be evaluated for differences with regard to guidance on the use of procedures by May 30,1997. Procedure alterations identified by this review will be completed and personnel involved in the surveillance testing will be trained on these procedure changes by July 31,1997.
Date When Full Compliance Will Be Achieved
- a. Full compliance was achieved on January 31,1997 when the applicable Actions for TS 3.3.1.1 were entered into the Unit Log.
- b. The changes in the tagging were intended to address systera configuration concerns raised by Operations personnel. The tagout provided to accomplish the work, although different than specified in the MWO, was satisfactory to accomplish DH 100 replacement as indicated by clearance holder acceptance of the clearance. The other issue raise regarded the MWO direction to refill, pressurize, inspect and verify r.a leaks. The system configuration of the DH 100 piping and the vent valves available prevented completely refilling the piping. This was discussed with Engineering and determined to be satisfactory. As noted in the inspection report, the Resident inspector was in agreement with the Engineering conclusions. Based on the factors noted above, the DBNPS was considered to be in full compliance when the work activity was completed on February 25,1997.
- c. The DBNPS was in fun compliance with the quarterly surveillance requirements for Service Water Pump 3 upon obtaining acceptable test results on February 24,1997.
Reply to a Notice of Violation (50-346/97003-02[DRP])
Alleged Violation:
- 11. Technical Specification 3.5.2 required, in part, that "Two independent ECCS Subsystems shall be operable..."
Technical Specification 4.5.2.f required, in part, that "Each ECCS subsystem shall be demonstrated operable by performing a vacuum leakage rate test of the watertight enclosure for valves DH-11 and DH-12 that assures the motor operators on valves DH-11 and DH-12 will not flood for at least seven days following a LOCA:.. 2. After each opening of the l
watertight enclosure."
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Docket Number 50-346
' License Number NPF-3 Serial Number 1-1125 Attachment Page 5 Contrary to the above, the licensee identified that, on May 24,1996, the inspection port on the watertight enclosure was opened, the vacuum leakage rate test was not thereafter performed, and the associated emergency core cooling system (ECCS) subsystems were not declared l
1 This is a Severity Level IV violation (Supplement 1).
Reason for the Violation The reason for this alleged violation was an inadequate 10 CFR 50.59 Safety Evaluation for the modification that installed the inspection cover in 1987. Facility Change Request (FCR)85-303 was installed during the fifth refueling outage in 1987 to add level switches in the Decay Ileat Valve Pit to alert the operators when water begins to accumulate in the pit. This FCR also added an inspection port in the valve pit cover to allow visual verification of an indicated water level.
This inspection opening is used to verify no water is in the pit just prior to plant startup. This opening is also utilized to inspect portions of the decay heat piping located within the pit during hydrostatic testing, which must be performed in Mode 3 at full Reactor Coolant System pressure and temperature in accordance with ASME Section XI requirements. Use of the inspection port for these purposes avoids the need to disturb the watertight pit access covers.
The Safety Evaluation for the modification acknowledged that Technical Specification 4.5.2.f requires a vacuum leakage rate test following each opening and subsequent reclosure of the Decay 11 eat Valve Pit. However, this Safety Evaluation erroneously assumed that this Technical Specification was not applicable for this inspection port cover since the closure device was specifically designed for the purpose of sealing.
Concetive Stens Taken and Results achieved On February 12,1997, at 1521 hours0.0176 days <br />0.423 hours <br />0.00251 weeks <br />5.787405e-4 months <br />, after determining that the missed surveillance test could not be performed in Mode 1, a plant shutdown was initiated. At 2005 hours0.0232 days <br />0.557 hours <br />0.00332 weeks <br />7.629025e-4 months <br />, Toledo Edison received verbal notification of enforcement discretion from the NRC regarding Surveillance Requirement 4.5.2.f, and terminated the plant shutdown. Enforcement discretion was granted until a shutdown of suflicient duration to perform the Surveillance Test or until a license amendment is approved exempting the inspection cover from the surveillance requirement. On February 13,1997, Toledo Edison submitted a follow-up letter (Serial Number 2449) providing documentation relative to the verbal request for enforcement discretion. The NRC provided written Notice of Enforcement Discretion by letter dated March 5,1997, (Log Number 5008).
On February 14,1997, Toledo Edison submitted a license amendment application (Serial Number 2448) to revise Smveillance Requirement 4.5.2.f to allow the inspection port to be opened without requiring performance of the vacuum leakage rate test upon closure (License Amendment Request Number 97-0006). License Amendment Number 215 was approved on March 24,1997, to allow the Decay Heat Removal Valve Pit watertight enclosure inspection port to be opened for inspections in Modes 1 to 3 without requiring the performance of the vacuum leakage rate test (Log Number 5021).
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Docket Number 50-346
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License Number NPF-3 Serial Number 1-1125 l
Attachment P
Page 6 LER 97-005 was issued on March 13,1997, documenting this event in accordance with 10 CFR 50.73(a)(2)(i)(B) as a condition prohibited by the plant's Technical Specifications.
Corrective Stens that will be Taken to Avoid Further Violations Several changes have occurred in the procedures and culture at the DBNPS since 1989 which should contribute to the prevention of further occurrences. These include enhancements to the modification process and safety review and evaluation process along with greater experience and maturity within the engineering staffin the area of 10 CFR 50.59 Safety Evaluations. These improvements should preclude the type of omission that occurred in 1987 when the impact of adding this inspection port was not properly evaluated during the performance of FCR 85-0303.
A dedicated team of personnel will thoroughly review a sampling of the 10 CFR 50.59 Safety Evaluations written in the 1985 to 1990 time frame. Specific Safety Evaluations will be selected for this review based on the subject matter of the evaluation, with emphasis on those Safety Evaluations involving Technical Specifications, Updated Safety Analysis Report compliance, and commitments to regulatory agencies. Based on the results of this review, a larger sample of Safety Evaluations will be reviewed if deemed appropriate. This team will also review the appropriateness of the DBNPS 10 CFR 50.59 screening process. These reviews are scheduled to be completed by November 28,1997.
Date When Full Comnliance Will Be Achieved Power operation continued from February 12,1997, until March 24,1997, under the conditions of the verbal notification of cnforcement discretion Toledo Edison received from the NRC regarding Surveillance Requirement 4.5.2.f. Full compliance was achieved and the enforcement discretion tenninated on March 24,1997, when License Amendment Number 215 was approved to allow the Decay Heat Removal Valve Pit watertight enclosure inspection port to be opened in Modes 1 to 3 without requiring the performance of the vacuum leakage rate test to perform inspections.
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