ML20203F954
| ML20203F954 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 03/11/1986 |
| From: | Williams J TOLEDO EDISON CO. |
| To: | Chrissotimos N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 1-624, NUDOCS 8604280187 | |
| Download: ML20203F954 (4) | |
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TOLEDO EDISON Docket No. 50-346 JOE VVutAMs Jn
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License No. NPF-3 IC* NS S2 3 Serial No. 1-624 March 11, 1986 Mr. N. J. Chrissotimos Division of Reactor Projects United States Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Dear Mr. Chrissotimos:
Toledo Edison acknowledges receipt of your February 3, 1986 letter (Log No. 1-1324), Notice of Violation, and Inspection-Report No. 50-346/85037 (DRP).
In accordance with our discussion with Mr. I. N. Jackiv on March 4, 1986, we were granted an extension for this response until March 10, 1986. Following an examination of the item of concern Toledo Edison herein offers information regarding this item:
Violation: As a result of the inspection conducted on November 5, 1985 through January 4, 1986, and in accordance wir_h the General Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C.
(1985), the following violation was identified:
10 CFR 50, Appendix B, Criterion IV, " Procurement Document Control,"
states in part: "MeasureF shall be established to assure that applicable regulatory requirements, design bases, and other requirements which are necessary to assure adequate quality are suitably included or referenced in the documents for procurement of materials, equipment, and services."
In addition, administrative procedure AD 1846.00.05, " Requisition of Materials and Services" requires an adequate technical review be performed prior to procuring materials and services.
Further, 10 CFR 50, Appendix B, Criterion XV, "Norconforming Materials, Parts, or Components,"
states in part: " Measures shall be established to control materials, parts or components which do not conform to requirements in order to prevent their inadvertent une or installation."
0604290187 560311 PDR ADOCK 05000346 G
PM THE TOLEDO EDISON COMPANY E01 SON PLAZA 300 MADISON AVENUE TOLEDO. OHi3 47052 d0 MAR 171986 i It c t
Dockot No. 50-346 License No. NPF-3 4
Serial No. 1-624 March 11. 1986 Page 2 f
Contrary to the above, a pyrometer was procured with incorrect i
internal resistance and installed on Septembar 17. 1985 on l
Emergency Diesel Generator (EDG) 1-1 without assuring that the q
pyrometer conformed to requirements.
In addition the licensee 1
failed to perform an adequate technical review prior to procuring the pyrometer. The bearing temperature pyrometer (TI 21077) did not impact the operability of the EDG, 4
This is a Severity Level IV violation (Supplement 1).
(50-346/85037-07)
Response
(1) Corrective action taken and the results achieved.
Subsequent to the discovery of the installation of a pyrometer with the incorrect internal resistance on EDC 1-1, the following actions were taken:
A.
A comparison check between a pyrometer with the correct internal resistance and the incorrect pyrometer was conducted under Maintenance Work Order
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(MWO) 1-86-0225-00 on January 15, 1986. This check i
established that both pyrometers would provide temperature indication within the plus or minus 4*F manufacturer's tolerance at EDG operating
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temperatures.
i B.-
New pyrometers with the correct internal resistance were procured and installed in EDG 1-1 and 1-2 under 4
HW0s 1-85-0906-01 and 1-85-3712-01, respectively, to satisfy the disposition of nonconformance report (NCR) 85-2785.
i C.
Existing procedures were reviewed to identify possible programmatic inadequacies which led to the installation of the incorrect pyrometer and interviews were conducted with the personnel involved with the replacement. The results of these actions established that the causes of the violation were:
1.
The pyrometer was incorrectly procured because the 16C Shop Record which was utilized to prepare the Bill of Materials (BOM) did not l
contain sufficient information to correctly order the pyrometer. The part numbers were identical for both pyrometers, however, the internal resistance was different.
l
Dockst No. 50-346 License No. NPF-3 Serial No. 1-624 March 11, 1986 Page 3 2.
The pyrometer was incorrectly installed without performing proper verification because no procedure had been required for either calibration or installation. The vendor technical manual requires that resistance be verified as the same between the pyrometer and the thermocouple as part of the calibration process, however, the vendor manual was not required to be used at the time of the installation.
(2) Corrective actions to be taken to avoid further violations:
The appropriate information has been added to the I&C Shop Record to ensure that future procurement of the EDG pyrometer will be done correctly.
Actions are currently underway to address the potential generic concerns identified by this violation. As part of the commitments made in the Course of Action (COA) submittal (Serial No. 1182) to establish and maintain a Configuration Management Program, Toledo Edison is undertaking a comprehensive effort to upgrade the Instrument Index. The Instrument Index is a controlled listing of the instrument's service description, manufacturer, type, specification number, drawing numbers, etc.
Through reviews of the I&C Shop Records, Facility Change Requests, and other related documents, Toledo Edison will review and upgrade the Instrument Index as necessary. Also, as part of the Configuration Management Program, a walkdown of the plant will be performed to gather equipment information. This walkdown will include the plant instrumentation and will further validate the information in the Instrument Index.
It is currently envisioned that the Instrument Index, or a similar type document, will be utilized to prepare BOMs once the Configuration Management Progran is in place.
Also, as part of the programmatic improvements being instituted as a result of the commitments made in the C0A, Procedure No. AD 1844.00.15, Conduct of Maintenance, was revised on December 3, 1985 to require the use of procedures for safety related activities which cannot be performed as skill-of-craft. Maintenance Department personnel have been trained on these requirements.
Dockst No. 50-346 License No. NPF-3 Serial No. 1-624 March 11, 1986 Page 4 In addition, the Instrumentation and Control (16C) Departmental procedures are undergoing a major upgrade.
Existing procedures are being revised and new procedures are being generated to provide adequate technical direction for safety related calibration activities. As committed to in the COA, approximately 70 I&C procedures have been determined to be required prior to startup from the current outage with the completion of the upgrade effort scheduled for December 31, 1986.
As a result of the new procedural controls and the partial implementation of the upgraded I&C procedures, the I&C mechanic performing the work actually discovered the discrepancy between the replacement pyrometer (3 ohm) and the installed pyrometer (10.5 ohm) for EDG l-2.
It is believed that the discovery of the discrepancy is a strong demonstration of the effectiveness of the programmatic changes in preventing these type of problems. Therefore, no additional actions other than previously described will be taken.
(3) Date when full compliance will be achieved:
The Instrument Index upgrade will be completed as part of the Configuration Management Program prior to December, 1987.
Very truly yours, 3o~ t Ohl/iam1s bed JW:TJB:dem cc: DB-1 Resident Inspector r-
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