ML20202F319
| ML20202F319 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 11/26/1997 |
| From: | Jeffery Wood CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1-1143, 50-346-97-11, NUDOCS 9712090059 | |
| Download: ML20202F319 (5) | |
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,y CENTERf07 ENERGY b501 N $"iate Route 2 419-249-2300 John K.Woao Oak Hartor.oH 41449 FAX. 419-3214337 VC4 Prescent
- Nuclear Davis Besse Docket Number 50-346 License Ntunber NPF-3 Serial Number I-1143 November 26, 1997 United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 l
l
Subject:
Response to Inspection Report 50-346/07011 Ladies and Gentlemen:
Toledo Edison has received Inspection Report (IR) 50-346/97011 (Log Number 1-3908) and the enclosed Notice of Violation issued on October 31,1997.
The violations involve the failure of personnel to adequately adhere to test procedure requirements during calibration of pressure switches in the auxiliary feedwater system; and incomp:ete corrective actions related to a 1995 problem associated with measuring and test equipment specified in surveillance procedures for certain calibration activities. Toledo Edison provides the a:tached response to the subject violations.-
Should you have any questions or require additional information, please contact Mr. James L.
Freels, Manager - Regulatory Affairs, at (419) 321-8466.
Very truly yours,
. by D H u dic A. B. Beach, Regional Administrator, NRC Region III cc:
A. G. Hansen, NRC/NRR Project Manager NRC Region III, DB-1 Resident Inspector
}k Utility Radiological Safety Board 9712090059 971126 PDR ADOCK 05000346 G
PDR unitamDM i
Docket Number 30-346 License Number NPF-3 Serial Number 1-1143 Attaclunent Page1 Renly to a Notice of Violation (50-346/97011-02)
Alleced Violation 1.
10 CFR 50, Appendix B, Criterion V," Instructions, Procedures, and Drawings," requires in part, that " Activities affecting quality shal' be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be eccomplished in accordance with these instructions, procedures or drawings."
Davis-Besse Administrative Procedure DB-DP-00013, Surveillance and Periodic Testing," (Revision 4), step 6.3.7.j, requires that Measuring and Test Equipment used in testhg shall satisfy the requirements of the test procedure und be within its calibration due date.
Surveillance Procedure DB-MI-03906," Channel Calibration of PSL 107 A-D, Auxiliary Feed Pump Turbine 1-2 Inlet Isolation on Low Pressure Interlocks," (Revision 02), Step 6.1.1, requires the use of four 0-72 psi test gaugee with 0.05 percent accuracy or equivalent.
Contrary to the above, on August 26,1997, the NRC identified that maintenance personnel did not use four 0-72 psi test gauges with 0.05 percent accuracy or eauivalent while performing DB-MI-03906. Altematively, test gauges recommended in the instrument information sheets for the subject instruments were employed that were less accurate than required by the surveillance test procedure.
This is a Severity Level IV violation (Supplement I).
Response to Alleced Violation Reason for Violation As discussed below in the response to violation 50-346/97011-03, previous corrective actions to address discrepancies between the design calculation, instrument data packages and surveillance procedure were not properly implemented. Contributing to this violation was a failure to review the existing design calculation as required by procedure DB-MI-00001, " Control, Review and Revision ofI&C Data Packages," when supervision determined that the test gauges recommended in the instrument data package were acceptable after their use was questioned.
Corrective Stens Taken and Results Achieved Potential Condition Adverse to Quality Report (PCAQR) 97-1141 was initiated to document the use of test gauges with less accuracy than specified by the surveillance procedure. As documented in PCAQR 97-1141, an evaluation was performed and determined that the additional error introduced by using test gauges with less accuracy than required by the
Dc:ket Number 50-346 License Number NPF-3 Serial Number 1-1143 Attachment Page 2
- surveillance procedure was compensated for by the unassigned error assumed in design calculation C-ICE-50.01001,"Setpoin'. for SOR Pressure Switches PSL 106A-D and 107A-D,"
revision 1. Therefore, the pressure sv, itches are considered to be in calibration and capable of performing their intended fune'ica.
Corrective Steps faken to Avoid Further Violations Procedures DB-MI-03903," Channel Calibration of PSL 106A-D, Auxiliary Feed Pump Turbine 1-1 Inlet Isolation on Low Inlet Pressure Interlocks," and DB-MI-03906, " Channel Calibration of PSL 107 A-D, Auxiliary Feed Pump Turbine 1-2 Inlet Isolation on Low Inlet Pressure Inteilocks,' were revised to conform with the current revision of design calculation C-ICE-050.01-001 The associated instrument data packages were also revised to conform with the current revision of design calculation C-ICE-050.01-001. These actions were completed on November 12,1997.
Date When Full Co:nnliance will be Achieved Full compliance was achieved on August 26,1997, wher. it was determined that the pressure switches were in calieration and capable of performing their intended function.
Reply to a Notice of Violation (50-346/97011-03) l Alleced Violation 1
2.
10 CFR 50, Appendix B, Criterion XVI," Corrective Action," requires, in part, that
" Measures rhall be established to assure that conditions adverse to quality... are i
promptly identified and corrected."
Contrary to the above, corrective actions established to address inconsistencies between the test gauges specified by surveillance procedure DB-MI-03906, design calculation C-ICE-050.01-001, and associated instrument information sheets that were identified in October and November 1995, were not completely implemented. Although the surveillance procedure, design calculation and instrument information sheets all required revision, only the surveillance procedure had been revised as of August 26,1997.
Tbis is a Severity Level IV violation (Supplement I).
Re_s,ponse to Alleced Violation Reason for Violation Potential Condition A.dverse to Quality Report (PCAQR) 95-0884 was initiated on October 17, 1995, as a result of an identified discrepancy between design calculation C-ICE-50.01-001, "Setpoint for SOR Pressure Switches PSL 106A D and IC7A-D," revision 1 and procedures DB-l j
Docket Number 50-346 License Number NPF-3 Serial Number 1-1143 Attachment Page 3 '
Mi-03903, " Channel Calibration of PSL 106A-D, Auxhiary Feed Pump Turbine 1-1 Inlet Isolation on Low Inlet Pressure Interlocks (DB-MI-03903)," and DB-MI-03906, " Channel Calibration of PSL 107 A-D, Auxiliary Feed Pump Turbine 1-2 Inlet Isolation on Low Inlet Pressure Interlocks (DB-MI-03906)." A change to the procedures h-d revised the required test gauge accuracy to 0.5%; the calculation specified a test gauge accuracy of 0.05 percent.
During the im estigation of PCAQR 95-0884, the apparent cause was determined to be the failure to properly implement commitments intended to ensure that the M&TE used in the field did not allow an instrument to be calibrated with its setpoint outside of the acceptable values such that, a Technical Specification or operational limit was exceeded. Potential Condition Adverse to Quality Report 95-0986 was initiated to address this programmatic issue.
Remedial corrective actions identified in PCAQR 95-0986 included, in part: 1) perform a cross-check on M&TE against each design calculation, pmcedure and instrument data package; 2) initiate an addendum to PCAQR 95-0986 should any discrepancies be identified during this revie,v; and 3) initiate a procedure change request to address the discrepancy in procedures DB-MI-03903 and DB-MI-03906. To date one additional discrepancy between procedures and design calculations has been identified. Specifically, between design calculation C-ICE-48.01.00 and procedures DB-MI-03113," Channel Calibration of 59A-ISP2002 Containment Pressure Input to SFAS Channel 3 (DB-MI-03113)," and DB-MI-03114,"Channei Calibration of 59-ISP2003 Containment Pressure Input to SFAS Channel 4 (DB-MI-03114)." This discrepancy only involved the procedures and the design calculation as the instrument data packages agreed with the design calculation.
Procedure change requests (PCRs) were initiated to reconcile procedures DB-MI-03903,03906, 03113 and 03114 with the appropriate design calculation. These changes were documented in PCAQR 95-0986 on June 27,1996, as being completed.
For procedures DB-MI-03903 and 03906, the PCRs were implemented to change the procedures, however, even though the PCRs clearly indicated that a change in the associated instrument data packages was required, they were not altered. The preparer of the procedure revision did not procerly identify the instrument data packages as requiring revision during the procedure change process. Further, design calculation C-ICE-50.01-001 revision 1, was also updated to revision 2 to change the M&TE assumption. Review of the various revisions of the design calculation indicated that revision 1 of the & sign calculation had been updated to revision 2 with the changes to the M&TE assumption, however, an additional change was made to revision 2.
Revision 2 included a change related to the DBNPS conversion to a 24-month fuel cycle and reflected the 24-month assumed drift. Additianally, the setpoint in the design calculation was revised from 18 +0/-8 psig to 16 +/-4 psig. This change was to be implemented under Setpoint Ct.ange Request (SCR) 96-5003. As of August 26,1997, this SCR had not been implemented in the field. The assumption for M&TE in revision 1 of the calculation was still applicable in the field and remained effectively unchanged as far as current plant configuration was concerned. In
- 4 Docket Number 50-346 License Number NPF 3 Serial Number 1-1143 Attachment hage 4
- summary, of the three documents requiring change, procedure, instrument data packages, and design calculation, only the procedure was updated.
Corrective Steps Taken and Results Achieved As discussec' in the response to violation 970011-02 and documented in PCAQR 97-1141, an evaluation was performed and determined that the additional error introduced by using test gauges with less accuracy than required by the surveillance procedure was compensated for by the unassigned error assumed in design calculation C-ICE-50.01-001, "Setpoint for SOR Pressure Switches PSL 106A-D and 107A-D," revision 1. Therefore, the pressure switches are considered to be in calibration and capable of performing their intended function.
i
. Corrective Stens Taken to Avoid Further Violation Procedures DB-MI-03903," Channel Cahbration of PEL 106A D, Auxiliary Feed Pump Turbine l
l-1 Inlet Isolation on Low lelet Pressure Interlocks," and DB-MI-03906, " Channel Calibration of PSL 107 A-D, Auxiliary Feed Pump Turbine 1-2 Inlet Isolation on Low Inlet Pressure Interlocks," were revised to conform with the current revision of design calculation C-ICE-050.01-001. The associated instrument data packages were also revised to conform with the current revision of design calculation C-ICE-050.01-001. These actions were completed on November 12,1997.
The review # M&TE against each design calculation, procedure and instrument data package initiated by PCAQR 95-0986 is on-going and documented in PCAQP 97-0081. In addition, a second review involving instrumentation design calculations revised to support the conversion to a 24 month fuel cycle will be completed. These reviews will be completed by April 1,1998.
A tracking system will be dc.veloped for changes to instrument data packages. The requirements for this system will be incorporated into procedure DB-MI-00001, " Control, Review and Revision ofl&C Data Packages." Implementation and training of personnel to the new system will be completed by April 1,1998 This event will be included in the next Engineering Support Continuing Training cycle which will be completed in the first quarter of 1998.
Date When Full Compliance Will be Achieved Full compliance was achieved with completion of the revisions to procedures DB-MI-03903,
" Channel Calibration of PSL 106A-D, Auxiliary Feed Pump Turbine 1-1 Inlet Isolation on Low Inlet Pressure Interlocks," and DB-Mi-03906, " Channel Calibration of PSL 107 A-D, Auxiliary Feed Pump Turbine 1-2 Inlet Isolation on Low Inlet Pressure Interlocks," and the associated instrument data packages on November 12,1997.
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