ML20207Q640
| ML20207Q640 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 12/05/1986 |
| From: | Williams J TOLEDO EDISON CO. |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 1-690, NUDOCS 8701280428 | |
| Download: ML20207Q640 (4) | |
Text
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hma TOLEDO
%mma EDISON Docket No. 50-346 JOE WILUAMS, JR.
Sena Vce Prescers-Nuder License No. NPF-3 l%$$$
Serial No. 1-690 December 5,1986 i
Mr. C. E. Norelius, Director Reactor Projects United States Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Dear Mr. Norelius:
Toledo Edison acknowledges receipt of your November 5, 1986 letter (Log No. 1-1493), Notice of Violation and Inspection Report No. 50-346/86023.
Following an examination of the concerns set forth in the Notice of Violation, Toledo Edison herein offers the following information regarding these items:
Violation 1:
10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Action," requires that measures be established for safety-related equipment to assure that conditions adverse to quality, such as deficiencies and nonconformances are promptly identified and corrected. The electrical control panels for Emergency Diesel Generators, the essential battery chargers, inverters, rectifiers and electrical distribution panels Y1, Y2, Y3, Y4, DIP, DIN, D2P and D2N are safety-related equipment items.
A.
Contrary to the above, on April 22, 1977, until Janua ry 10, 1986, the licensee did not promptly I
identify at least four deficiencies (potentiometers not locked, spray shields not installed, and two examples of door bolts not installed) in the electrical control panels for the Emergency Diesel Generators, the essential battery chargers, invert-ers, rectifiers and electrical distribution panels Y1, Y2, Y4, D1P, DIN, D2P and D2N.
B.
Contrary to the above, from January 10, 1986, through May 5, 1986, in two cases (potentiometers not locked and one example of door bolts not installed) the G701280428 B61205 Licensee did not promptly correct the deficiencies ADOCK 0500 6
{DR described in "A" above in the essential battery THE TOLEDO EDISON COMPANY EDISON PL AZA 300 MADISON AVENUE TOLEDO, OHIO 43652 DEC 1019B16
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~1 Dackst No. 50-346 License No. NPF-3 Serial No. 1-690 December 5, 1986 Page 2 chargers inverters, rectifiers and electrical distri-bution panels Y1, Y2, Y3, Y4, DIP, DIN, D2P and D2N.
This is a Severity Level IV Violation (Supplement 1).
Response: (1) Acceptance Or Denial Of Alleged Violation Toledo Edison admits the alleged violations 1.A and 1.B.
(2) Reason For The Violation Violation 1.A.
Since original plant startup, design reviews had not identified the requirement to seal the balance potenti-ometers as required for seismic qualification. Sealing the potentiometers with locking compound after each read-justment had not been identified during development of Station Procedures.
The second issue under Violation 1.A. concerned non-seismic l
domestic water lines which were routed over the top of the j
seismic category I station battery chargers. There was a lack of an adequate engineering review of the design of.
this installation which should have been designed as seismic category I.
The final item under Violation 1.A. was in regards to cabinet door bolting. Again, there was inadequate engineering review to identify the requirement to station personnel to have the doors bolted closed.
It had not been recognized that this item, which had been identified in correspondence (February 1986) with the vendor, was required for seismic qualification.
Violation 1.B.
The lack of prompt corrective action as cited was due to the lack of sufficient and timely review and evaluation of the potential problems by the cognizant individuals once identified under the licensee's Surveillance Report proce-l dures. This procedure allowed the timeliness of the response to be generally dictated by priorities placed on the problem by the individual preparing the response.
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Dock t No. 50-346 License No. NPF-3 Serial No. 1-690 December 5,1986 Page 3 (3) Corrective Action Taken And Results Achieved The balance potentiometers were readjusted and sealed.
The cabinet doors on the inverters, battery chargers, rectifiers, and distribution panels were bolted shut. The cabinet doors on the emergency diesel generator static exciter / voltage regulation cabinets were bolted shut.
These actions restored the seismic qualifications for the effected equipment.
The non-seismic domestic water lines over the station battery chargers were initially isolated and drained.
Subsequently, the lines were removed under modification FCR 86-0102.
The responsible engineers were counseled regarding the importance of timely pursuit of potential conditions adverse to quality.
(4) Corrective Actions To Be Taken To Avoid Further Violation Maintenance Procedure MP1410.70 was revised to include instructions to bolt the doors closed to maintain seismic qualifications. Maintenance Procedure MP 1410.71 was revised to include the sealing of potentiometers to maintain l
seismic qualifications.
l The changes to the Davis-Besse management organization, i.
which included the expansion of the engineering division on-site and the creation of a Systems Engineering Depart-I ment, will improve the engineering review of plant changes and help prevent this type of design review oversights.
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Further, development of system descriptions with detailed
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design bases is also being accomplished as part of the Configuration Management Program for Davis-Besse.
l The Surveillance Report procedure previously used by engineering personnel to address potential conditions adverse to quality has been replaced by the Nuclear Group i
Procedure NMP-QA-702, " Potential Condition Adverse to i
Quality Reporting". This procedure was designed to increase the awareness within the Nuclear Group of potential conditions adverse to quality and ensure timely review, evaluation, reporting and corrective action of problems once they are identified. This procedure ensures that the concerns are identified to a review board for proper assignment, prioritization, and followup action.
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-Dock:t No. 50-346
. License No. NPF-3
. Serial No. 1-690 December 5, 1986 Page 4 (5) Date When Full Compliance Will Be Achieved As identified in the discussion above, the hardware deficiencies have been corrected. The maintenance
-procedures have also been revised as noted.
Changes to the engineering division have been made. This includes expansion of the staff sizes, moving the entire organization to the site, and establishment of the Systems Engineering Department.
The Configuration Management Program is currently underway.
Systems Descriptions are scheduled to be completed by the end of 1987.
Nuclear Group Procedure NMP-QA-702, " Potential Condition Adverse to Quality Reporting," became effective on May 25, 1986.
Very truly yours,
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cc: DB-1 NRC Resident Inspector
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