ML20209E858

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Responds to NRC Re Violations Noted in Insp Rept 50-346/85-12.Corrective Actions:Signed Off Maint Procedures to Be Kept at Work Site.Supervisors Will Continue Stressing Need to Use Procedures & Document Work
ML20209E858
Person / Time
Site: Davis Besse 
Issue date: 06/14/1985
From: Crouse R
TOLEDO EDISON CO.
To: Norelius C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
1-538, NUDOCS 8507120324
Download: ML20209E858 (3)


Text

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-v Docket No. 50-346 TOLEDO IEIIEiClfW License No. NPF-3 Serial No. 1-538 RICHARD P. CROUSE Vce Pressoent June 14, 1985

[$[loya Mr. C. E. Norelius, Director Division of Reactor Projects United' States Nuclear Regulatory Commission Region Ill 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Norelius:

Toledo Edison acknowledges receipt of your May 16, 1985 letter (Log No.

1-1167), Notice of Violation, and Inspection Report No. 50-346/85012.

Following an examination of the items of concern, Toledo Edison herein offers information regarding these items.

Violation:

10 CFR 50, Appendix B, Criterion V, as implemented by the Toledo Edison Nuclear Quality Assurance Manual, Section 17.2.5, requires that activities affecting quality be prescribed by documented instructions and procedures and accomplished in accordance with those instructions and procedures.

Contrary to the above:

A.

On March 26, 1985, completed work steps in pro-cedure MP 1401.41, related to the installation of the control rod drive mechanism subassembly, were not signed off at the time work was com-pleted as required by procedure AD 1844.00.

(346/85012-OlA)

B.

On March 29, 1985, completed work steps in pro-cedure MP 1401.41, related to the installation of a seismic clamp on a control rod position indicator, were not signed off at the time work was completed as required by procedure AD 1844.00.

(346/85012-01A)

C.

On March 26, 1985, after torquing bolts to hold the CRDM drive subassembly to the reactor head, the operator left the controls of the polar crane while the bolting tool was suspended over the re-actor. This was not in accordance with procedure SP 1104.46.

(346/85012-01B)

TOLEDO, OHIO 436hy 1 719 THE TOLEDO EDISON COMPANY EO! SON PLAZA

' ann unnen" AVENUE 8507120324 850614 ADOCK0500g6 DR

Dock 3t N2. 50-346 License No. NPF-3 Serial No. 1-538 June 14, 1985 Page 2 Response A:

(1) Corrective action taken and results achieved.

In the past it has been Toledo Edison's policy to have one set of procedures at the job site and one set of signed off procedures located in the Foreman's office.

This policy of maintaining the signed off procedures in the Foreman's office and not at the job site is responsible for the impression that the procedures are not being signed off as items are completed as required by AD 1844.00, Maintenance.

(2) Corrective action to be taken to avoid further noncom-pliance.

The above practice has been discontinued. A signed off copy of Maintenance Procedures will now be main-tained at the work site to properly identify the steps that have been completed. The Station is now in compliance with the administrative controls of Step 6.1.7.8 of AD 1844.00, Maintenance.

(3) The date when full compliance will be achieved.

Full compliance was achieved on June 7, 1985.

Response B:

(1) Corrective action taken and results achieved.

Shop Foremea have re-emphasized to their personnel the need to use procedures and document work activ-ities.

(2) Corrective action to be taken to avoid further noncom-pliance.

The Maintenance Supervisors will continue to stress the need to comply with the requirements of Procedure AD 1844.00, Maintenance.

This action, along with the corrective action de-scribed in Toledo Edison's Response A, will ensure future compliance.

(3) The date when full compliance will be achieved.

i Full compliance was achieved on June 12, 1985.

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Dockst No. 50-346 License No. NPF-3 Serial No. 1-538-

' June 14, 1985 Page 3 Response C:

(1) Corrective action taken and results achieved.

.The crane operator became ill while supporting the maintenance effort on the Control Rod Drive Mechan-isms and immediately left Containment. After a short rest, he communicated to the Shop Foreman that the tool had been left suspended from the polar crane.

The Foreman immediately had the bolting tool removed from the crane hook.

The crane operator was aware of the deviation from the procedure. All polar crane operators have re-ceived detailed instructions on the requirements of SP 1104.46, and review these requirements prior to operation of the polar crane.

(2) Corrective action to be taken to avoid further noncom-pliance.

Based on the above, Toledo Edison believes this to be an isolated occurrence, that training in the require-ments of SP 1104.46 is sufficient, and that no further corrective action is required.

(3) Date when full compliance will be achieved.

Full compliance was achieved March 26, 1985.

Very truly yours, f

y RPC:DAL:DJS:nif cc: DB-1 NRC Resident Inspector l

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