ML20205M680
| ML20205M680 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 10/25/1988 |
| From: | Shelton D TOLEDO EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 1-839, NUDOCS 8811030210 | |
| Download: ML20205M680 (6) | |
Text
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TOLEDO
% EDISON Acnanargg % y DoNitD C. SHELTON v # - a.,.,
Docket No. 50-346 License No. NPF-3 Serial No. 1-839 October 25, 1988 United States Nuclear Regulatory Commission Document Control Desk Vashington, D. C.
20555
Subject:
Response to Inspection Report (IR) No. 50-346/88012 Centlement Toledo Edison received IR No. 88012 (Log No. 1-1931, dated September 22, 1988)
.and provides the following response.
Violation 88012 01A:
10CFR50, Appendix B, Criterion V. "Instructions, Procedures, and Drawings," requires in part that activities affecting quality be accomplished in accordance with appropriate procedur:.s. This requirement is implemented by the Toledo Edison Company Nuclear Quality Assurance Manaal, Section 5, Paragraph 5.4.1.1 which states in part that activities that affect quality shall be accomplished in accordance with procedures.
A.
Nuclear Group Procedure NG-DS-205, "Plant Maintenance,"
dated November 25, 1986, Paragraph 6.7.4 "Scope of Vork "
states, in part, that the Assistant Plant Manager, Maintenance, shall ensure that only work specified in the Maintenance Vork Package is to be performed.
Contrary to the above, on February 7, 1987, the Assistant Plant Manager failed to ensure that only work specified in the Maintenance Vork Package vas performed in that after plant staff unsuccessfully attu pted to perform a functional check of the timing sequence of the oil failure I
safety control switch, PSL-2807, and associated timer for l
D the control room emergency ventilation system condensing l
unit per Maintenance Vork Order 3-87-1174-01, they obtained
(
an uncontrolled manufacturer's instruction for testing the o
$t time delay and conducted this test prior to incorporating it into the work package.
O THE TOLEDO ED' SON COYPM4Y EO:SCN PLAZA 300 VAC? SON AVENUE TOLEDO. CH O 43652 O
j
Dockat No. 50-346 License No. NPF-3 Serial No. 1-839 P, age 2 Responses Acceptance or Denial of The Alleged Violation Toledo Edison acknowledges the alleged violation.
Reason For The Violation Procedure NG-DS-205 establishes the requirements, methods, interfaces, and responsibilities of Nuclear Group Divisions for the conduct of malatenance at Davis-Besse (DB). The requirements of Section 6.7.4 are implemented by AD 1844.02, "Control of Vork".
AD 1844.02 specifically states that maintenance activities are to be performed as directed by approved MVO packages. The purpose of this procedure is to ensure that work is performed and documented properly. The performance of the post maintenance test for Control Room Emergency Ventilation System (CREVS) oil pressure switch PSHL i
28017 prior to its incorporation into the Maintenance Vork Order (MVO) vas due to failure to follow procedure. The new instructions for the functional check of the oil pressure timing sequence should have been incorporated on an MVO continuation 1
sheet and reviewed and approved prior to performance.
Responsible personnel should have incorporated the instruction l
into the MVO prior to performance but did not take the 1
l appropriate action prior to performance of the test.
Corrective Action Vhich Nave Been Taken and Results Achieved Personnel involved in the maintenance activity are avare of the specific procedural violation described above and the procedural requirements for performing post maintenance testing.
Personnel i
failed to adhete to AD 1844.02 requirements in that they failed to incorporate the subject test prior to performance. TE believes that AD 1844.02 is an effective mechanism for controlling vork and post maintenance / modification testing.
Therefore, no further action is considered necessary.
Date Vhen Full Compliance Vill Be Achieved Tull compliance vas achieved prior to issuance of the violation.
Violation 80012-01B Quality Assurance Division Procedure (OADP) No. 2.2 (QA-0C-07002.02), "Qualification and certification of Personnel Performing Quality Control Activities," Revision 1, dated October 16, 1987 Paragraph 6.4.3, requires, in part, that ind Widuals who meet the education and experience requirements for a specific level and discipline, and who have been previously certified in that discipline shall be qualified based on., among other things, completion of Generic and Discipline qualification cards.
A
_ Dock 0t No. 50-346 Licen:] No. NPF-3 Serial No. 1-839
,Page 3 Contrary to the above, on July 14, 1988, the inspector determined that several Davis-Besse certified OC inspectors had not completed the qualification cards.
Responses Acceptance or Denial Of The Alleged Violation Toledo Edison acknowledgos the alleged violation.
Reason For Violation Quality Assurar.ce Department Procedure (OADP) 2.2, issued on June 2, 1986, superseded Quality control Instruction (OCI) 3020. "Qualification and Certification," which was the previous mechanism for fulfilling ANSI N45.2.6 1978 requirements. QADP 2.2 enhanced the qualification prneess by implementing a qualification card system which requires training, testing, performance demonstration (as needed) and required recdtng for each inspection discipline (e.g.,
mechanical, electrical, etc.).
After implementation of CADP 2.2, TE determined a "grandfather clause" vas needed in the procedure to clarify hov 1..spection personnel previously qualified (incumbent) under OCI 3020 would comply with the new qualification process.
The "grandfather clause" vould allov valver of performance demonstrations on ths OC Generic. and Discipline qualification cards.
Prior to this revision (Rev. 1 issued 10/30/87), an internal audit (AR-87-INSPT-01) of TE's QC inspector qualification process identified that four nev inspectors had not completed qualification cards.
In response to the audit finding, TE identified 22 incumbent inspectors who had not completed qualification cards.
Since the incumbent inspectors already held certifications required by QCI vas decided that those individuals could complete
- 3020, qualification cards prior to their recertification date. This decision was based on the fact that the "grandfather clause" valved the performance demonstration for these individuals leaving only required reading to be accomplished on the qualification cards.
Due to the work load in OC at this time, there vas some difficulty in completing the required reading. Since the incumbent inspectors had already completed previous teading lists (required by OCI 3020), TE believed that completion prior to their required recertification date vas adequate.
- However, there vere no provisions for this philosophy in the procedure.
The procedure should have been changed to clearly reflect the intent of the "grandfather clause".
Dock 3t No. 50-346 License No. NPF-3 Serial No. 1-839
,Page 4 Corrective Actions Vhich Have Been Taken and Results Achieved QA-DP-07001, Rev. 1 (previously numbered QADP 2.2) which vill be effective October 24, 1908, clarifies the "grandfather clause."
Al,' incumbent inspectors have completed applicable OC Generic and Disr.ipline qualification cards.
Date Vhen Poll Compliance Vill Be Achieved Procedure QA-DP-07001, Revision 1 vill be effective on October 24, 1988.
Violation 88012-010:
Toledo Edison Company procedure, NMP-4A-702 R1, dated May 25, 1986, "Potential Condition Adverse to Quality Reporting,"
Section 6.2.3, "Processing," states in part that, "Following supervisory reviev, all PCAO reports shall be hand carried to the shift supervisor for numbering, logging, completion of those sections of part 1 that apply, but vere not addressed, and determination of their reportability."
Section 6.3.3, "Technical Support Department Review," states in part that, "following reportability determination, the PCAQ report shall be forvarded to the Plant Technical Support Department for reviev and rubmittal to the PCAQ Review Board."
1.
Contrary to the above, on May 14, 1987, a Potential Condition Adverse to Quality Report (PCAQR) vas written by I
a Quality Control inspector concerning the HP E-7-1 Condenser internal steamline veld and pipe cracks. The PCAQR vas reviewed by his supervisor, but not delivered to the shift supervisor or to the PCAQR Review Board for review and processing.
2.
Contrary to the above, on July 10, 1986, a PCAQR vas va;isen by a OC inspector concerning deficiencies with Raychem splice documentation identified in MVO l-86-0991-04. The PCAQR vas reviewed by the OC supervisor, but not delivered to the shift supervisor or to the PCAQR Review Board for review and processing.
Response
Acceptance Or Denial Of the Alleged Violation Toledo Edison acknowledges the alleged violation.
Reason For The Violation Procedure NMP-QA-702, Revision 1, which became effective May 25, 1986, replaced other mechanisms for identifying and correcting nonconformances.
l Docket No. 50-346 License No. NPP-3 Serial No. 1-839 Pege 5 In regard to the concern with the broken veld and cracks on an unused steam line in HP Condenser E-7-1, there vas apparently some questions as to whether a PCAO condition existed.
Section i
6.2.la of NMP-QA-702, Revision 1. had provisions for contacting l'
a supervisor who is familiar with the identified activity to verify a PCAQ exists. This procedural step may have contributed to the PCAQR not being issued.
However, the step was not intend *4 to preclude the processing of a PCAQR once initiated.
Since the PCAQR had been initiated it should have been processed i
in accordance with the PCAO procedure.
Instead, the PCAQR vas not issued and a work request was generated to resolve the concern.
Systems Engineering evalueted the broken velds and cracks in the steam line and repeirs were accomplished via Maintenance Vork order (MVO) 1-68-0911-00.
The PCAQR vritten to address the Raychem splice concern was recommended for invalidation but was not hand carried to the Shift Supervisor which would have ensured forwarding to the PCAQ Review Board for reviev, At that time, only the PCAQ Review Board had the authority to invalidate a PCAQR once initiated.
TE acknowledges that both of the cases cited above are examples of failure to follow procedure. Neither case was a deliberate atteopt to suppress the identification or correction of a problem but both undermined the PCAO process as it was intended to be.
Corrective Actions Vhich Have Been Taken and Results Achieved f
New PCAQRs were issued to enrure proper resolution and documentation of the initial concern (PCAQR 88-0763 for the HP condenser steam line concern and PCAQR 86-0492 for the Raychem concean). Both have been satisfactorily resolved in accordance with W.-QA-00702, Revision O.
NG-QA-0702, Revision 2, etfective June 11, 1987, corrected any l
interpretive problems with the PCAQ process. To ensure that I
these types of problems do not recur in the future. TE recently I
conducted training for all supervisory personnel which included a detailed discussion of the supervisor's role in the PCAQ process. This training emphasized that once the PCAQR is initiated it must be proces*:d per the requirements of NG-QA-00702, Revision O.
I l
Dockat No. 50-346 I
License No. NPP-3 Serial No. 1-839 Page 6 Date Vhen Full Compliance Vill Be Achieved l
NG-0A-0702, Revision 2 vas issued on June 11, 1987. The supervisor's training was completed on October 14, 1988.
Very truly yours,
[ [K h EBS/dla cct P. Byron, DB-1 NRC Resident Inspector A. V. DeAgazio. DB-1 NRC Senior Project
.. nager A. B. Davis, Regional Administrator, Nhc Region III J. McCormick-Barger, NkC Region III E. G. Greenman, Director of Reactor Projects l
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