ML20214R635
| ML20214R635 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/13/1987 |
| From: | Shelton D TOLEDO EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 1-722, NUDOCS 8706080227 | |
| Download: ML20214R635 (10) | |
Text
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hD1 b TOLEDO
% EDISON Docket No. 50-346 DONAU] C. SHELTON va n m-eu r (419)249 2399 License No. NPF-3 Serial No. 1-722 April 13, 1987 Mr. A. B. Davis, Regional Administrator United States Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Dear Mr. Davis:
Toledo Edison has received Inspection Report 86032 (Log No. 1-1577, dated March 13, 1987) and provides the following response.
Toledo Edison concurs that the violations described in Inspection Report 86032 collectively indicate an inattention to detail, a lack of communications between personnel and a failure to adhere to procedures. As outlined in our February 27, 1987 discussions with your staff, actions have been initiated to improve performance in these areas. Also discussed was our efforts to trend and evaluate for early detection problem areas through the Potential Condition Adverse to Quality (PCAQ) process and the initia-tion of a Performance Indicators program.
Violation 86032-09:
" Technical Specification (TS) Limiting Condition for Operation (LCO) 3.3.2.1 requires that Safety Features Actuation System (SPAS) functional units shown in Table 3.3-3 be operable with the plant in the Modes shown in Table 3.3-3.
Table 3.3-3 shows that the " Instrument String for Containment Radiation - High Total Number of Units" is four and " Minimum Units Operable" is three with the plant in Modes 1, 2, 3, 4 or 6.
Table 3.3-3 shows action statement 9 as the action to be taken with an Instrument String, Containment Radiation - High, SFAS functional unit inoperable. Action 9 requires that if power operation is to proceed and if the number of operable units is one less than the total number of units, then the inoperable functional unit must be placed in the tripped condition within one hour.
8706080227 870413 PDR ADOCK 05000346 jygg1y00I G
pon THE TOLEOO EDISON COMPANY EDISON PLAZA 300 MAOISON AVENUE TOLEDO, OHIO 43052 TEO/
f Dockst No. 50-346 License No. NPF-3 Serial No. 1-722 Page 2 TS LCO 3.0.3 requires that when an LCO is not met, except as provided in the associated requirements, action shall be initiated within one hour to place the unit in at least hot standby within six hours, at least hot shutdown within the following six hours and cold shutdown within the subsequent twenty four hours, as applicable.
Contrary to the above, from 11:52 p.m. on January 7, 1987, until 8:20 a.m. on January 8, 1987, (a period of eight hours and twenty eight minutes) the Instrument String for Containment Radiation - High, an SFAS functional unit, was inoperable, reducing the number of operable units to one less than the total number of units; the affected functional unit had part of its trip functions bypassed; and action was not initiated within one hour to place the unit in hot standby within six hours, at least hot shutdown within the following six hours and cold shutdown within the subsequent twenty four hours."
Response
Acceptance or Denial Of The Alleged Violation Toledo Edison (TED) acknowledges the alleged violation.
Reason For The Violation On January 7, 1987 at 1920 hours0.0222 days <br />0.533 hours <br />0.00317 weeks <br />7.3056e-4 months <br />. Channel 1 Containment Radiation Level Detector, RE2004, was declared inoperable due to erroneous signal spikes. RE2004 detects Containment radiation levels and provides input to to the Safety Features Actuation System (SFAS). RE2004 was replaced and the Instrument and Control (I&C) maintenance technicians were completing the post maintenance testing activities associated with the replacement of RE2004. The testing was being performed using Surveillance Test ST 5031.04, " Con-tainment Radiation Monitor Input to SFAS Refueling Period Calibration".
The original failure of RE2004 had placed the SFAS Channel 1 Containment Radiation Channel in the Action Statement of Technical Specification 3.3.2.1.
Technical Specification 3.3.2.1 action requires that with a functional unit of SFAS inoperable, the inoperable unit he placed in the tripped condition within one hour. This was accomplished at 1920 hours0.0222 days <br />0.533 hours <br />0.00317 weeks <br />7.3056e-4 months <br /> by the operations shift once RE2004 was inoperable. After the RE2004 was declared inoperable, maintenance activities to investigate the spiking were initiated.
Prerequisite step 5.6 of ST 5031.04 states that the technician shall obtain permission from the Shift Super-
r.
Docket No. 50-346 License No. NPF-3 Serial No. 1-722 Page 3 visor to perform the test and, when in the Action State-ment of Technical Specification 3.3.2.1, obtain only the SFAS cabinet door key.
The I&C technicians obtained both the SFAS channel cabinet door key and the-Test Trip Bypass Switch (TTBS) key from the Shift Supervisor. The technicians used the TTBS key to bypass Channel 1 disabling the trip signal that is placed in the SFAS circuitry when it is in the tripped condition.
Under normal conditions, SFAS actuates on a 2 out of 4 logic channels tripping. When in the Action Statenient, the inoperable SFAS channel would be tripped establishing a new logic requiring only one additional channsi (1 out of 3) to trip for an actuation of SFAS. When the affected channel was placed in test trip bypass, this changed actuating logic from a 1 out of 3, to that of requiring 2 out of the 3 remaining logic channels to trip for an actuation of SFAS. It should be noted that a 2 out of 3 logic is established during certain normal surveil-lance testing as permitted by Tech Spec 3.3.2.1. Action Statement 9.
When the alarm for the channel being bypassed first came in, Operators responded in accordance with the alarm procedure by reporting the condition to the Shift Super-visor. The Shift Supervisor stated that maintenance was being performed in the channel and that was the reason for the alarm. No further questions arose with respect to the condition of the channel; it was incorrectly assumed that the Action Statement van met with the channel in the
" bypass" condition. As a part of the oncoming Shift Supervisor's required turnover process, the Technical Specification requirements are reviewed to ensure compliance.
During this review, it was realized that the channel did not meet the Action Statement. The condition was identi-fied to operations management and the channel was removed from the " bypass" position.
The root cause of this violation has been determined to be the I&C technicians failure to properly follow procedures (ST 5031.04 prerequisite step 5.6) which states when in the Action Statement of Technical Specification 3.3.2.1 only the SFAS cabinet door (access to the trip switch) shall be obtained.
Additionally, the Shift Supervisor did not question why a Test Trip Bypass Switch (TTBS) key was being obtained, nor did he review with either the workern or the on-shift
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Dockot No. 50-346 License No. NPF-3 Serial No. 1-722 Page 4 personnel the Technical Specification requirement for the channel to remain in the tripped condition.
Corrective Actions Taken And Results Achieved The individuals involved received counseling on the conse-quences of their actions.
Included in this counseling was a re-emphasis of their responsibility to review Technical Specification Actions and to adhere to procedures.
Additionally, the conduct of shift operations and maintenance procedures have been amplified to better coordinate the work activities to be performed. The need for Shift Super-visors and Operators to maintain attention to detail in stressed in the supervisors' meetings. These meetings are scheduled with operations management on a regular basis to discuan items which affect shift operations and provide written feedback to all operations personnel through meeting minutes.
Date When Full Compliance Will Be Achieved Full compliance han been achieved.
Violation 86032-08:
" Technical Specification 6.8.1 states in part ".
written procedures shall be entablished, implemented, and maintained covering the activities referenced in Appendix "A" of Regulatory Guide 1.33 November 1972." Section 1 of Appendix A of Regulatory 1.33, November 1972, is Administrative and Operational Procedures.
Contrary to the above, Administrative and Operational Procedures were not adhered in thatt a.
On January 20, 1987, when the Auxiliary Feedwater System (AFWS) was made inoperable, the AFWS "Manuni System Bypass" indicating light van not illuminated an required by System Operating Procedure SP 1106.06,
" Auxiliary Feedwater System," Section 1.1.
b.
Between December 20, 1986, and January 3, 1987, seven mode changen were made while containment air cooler service water dischargo valve SW-1357 wns listed as inoperabic and Technten) Specification Limiting Condition for Operation action statement 3.6.3.1 van listed as applicable. This la contrary to the
Dock;t No. 50-346 License No. NPF-3 Serini No. 1-722 Page 5 requircreents of PInnt Procedure PP No. 1102.01,
" Pre-Startup Checklint."
c.
From December 7 through 16, 1986, the inoperability of the meteorologicni tower was not reported to the shift supervinor during the performance of Surveil-Innce Test Procedure (ST) No. 5035.01 na required by Administrative Procedure (AD) No. 1839.00, " Station Operations," Section 6.8.3."
Responnes Acceptance Or Denini Of The Alleged Violation Toledo Edison (TED) acknowledges the alleged viointion.
i n.
Reason For The Violation l
l On January 20, 1987 at 1530 hourn, Auxiliary Feedwater l
(AFW) Train 1-2 wnn declared inopernbic for Static-0-Ring PSL 107C steam preneure switch repincement. The train was declared inoperable and an entry van made in the Renetor j
Operator's log and the (Jnit log noting the inoperability.
l llowever, the inopernbility of AFW Train 1-2 was not recorded on the Control Room Status Board nor van the blue system statun l
light turned on to indicate the nyntem ntatun inaccordance i
with Synteen Procedure (SP) 1106.06, Auxiliary Feedwater Syntem.
SP 1006.06, " Auxiliary Feedwater Syntem," requires the operator to turn on the "Manunt Syntem Bypann" blue e
Indienting light whenever any condition which enunen the i
AFW nyntem to depart from its normal operationni status.
The illumination of thin blue lightn nerven an a reminder and indiention to the operator that the system is in an l
inoperabic neatus.
At about 3:40 p.m. the NRC inspector noted that the blue indicating light for the AFW nystem van not on and that the nyntem unn not listed an inoperable on the Equipment Statun Bonrd.
Additionally, nn nented in Innpection Report 86032, "The j
innpector nnked the l<enctor Operator (RO) at the RO'n denk why the blue light for the AFW nyntema van not on.
The RO ntated that ho thought both AFW nyntemn were opernble. The RO entled the Shift Supervisor nnd nnked him the ntatun of the AFW nyntems. The R0 then informed the innpoctorn that one AFW wnn inopernble turned on the appropriate blue light nnd entered the ntatus of the AFW nyntem on the Equipment Statun Board."
Dockot No. 50-346 License No. NPF-3 Serial No. 1-722 Page 6 The cause of this example of failure to follow the procedure has been determined to be personnel error. The Operator logged the system status in the logs, however, he failed to update the Status Board and turn on the blue indicating light per the procedure.
Action Taken And Renults Achieved The individual involved has been counseled on this incident emphasizing procedural compliance.
As previously stated in the February 27, 1987 discussions with NRC Region III manage-ment, Operations and Maintenance management have met with Operations and Maintenance personnel stressing procedural compliance and cognizance of pinne conditions at all times.
Additionally, as previously discussed, Operations Management is scheduling meetings on a regular basis to discuss topics that relate to all Operatorn. This provides a method for each shift to be aware of what the other shifts are doing.
Date When Full Compilance Will Be Achieved Compliance han been achieved with the counseling of the individuals involved and the meetings that have been held with Operations and Maintenance personnel.
b.
Rennon For The Violation On Decembnr 10, 1987, a Maintenance Work Order (MWO) for the repair of Containment Air Cooler (CAC) 1-2 Service Water outlet Valve SW 1357, was signed authorizing work commencement by the Shift Supervinor. An encionure for the MWO ntated that the work on the temperature controller could make SW 1357 inoperable. Technical Specification (TS) 3.6.3.1 and TS 3.6.2.2 were identified as the applic-able Technical Specificationn affected. The condition van noted on the Equipment Statun Board, and SW-81, a downntream manuni isointion valve, was closed.
The techniciann evaluated the temperature controller and determined that some parta nhould be repinced to correct the maintenance concern. The necessary parts were unavail-able and were pinced on order. All maintenance activity conned on December 11, 1986 until the paren were obtained.
(The Control Room was not notified of this development.)
The Unit wan in Mode 5 at the time and preparations were being made for hentup and neartup.
Severn1 extenniva mentchen were conducted of the open MWO filen main-tained in the Control Room to asnure there were no HW0n which would prevent modo change. The SW 1357 MWO was
Docket No. 50-346 License No. NPF-3 Serial No. 1-722 Page 7 generated after these checks and not logged against a mode change checklist. The Prestartup Checklint was signed off for the first mode change and subsequent mode changen although SW 1357 had been declared inoperable and the condition noted on the Status Board and in the Unit log.
The neatus of SW 1357 and the authorization of mode changes was not questioned until January 8, 1987. At this i
time, it was determined that the work that had been conducted to date had not rendered SW 1357 inoperable and the valve should not have been declared inoperable.
The work that had been performed was on the temperature control portion of the actuator. The capability of the valve to operate if required to isolate containment upon generation of a Safety Features Actuation System (SFAS) signal was functional. This condition existed until January 8, 1987 when air (motive force to close the valve) was isolated to continue work after arrival of the necennary parta.
The Prestartup Checklist requiren that the status board be checked and any Technical Specification Action Statements be verified as not preventing mode change. This review van l
thought to have been performed because Operations personnel believed the Action Statements associated with SW 1357 were met. The reasoning being: Two out of the three containment Air Coolers were always operable as required by TS 3.6.2.2
" Containment Cooling System" and SW-81 isolated the contain-ment penetration as required by TS 3.6.3.1 Action c.
However, Table 3.6-2, which itemizes the containment i
penetrations, does not provide allowance for mode change l
with the SW 1357 penetration inoperable an permitted for other Table 3.6-2 penetrations. This inconsistency in the Technical Specifications an well an a basic misunderstanding of how Table 3.6-2 pertains to dual function valven (eg. SW I
1357, closed for containment isolation and open for the containment Air Coolers) are believed to be the causes of this violation.
Additionally AD 1844.02, Control of Work (HWO), Step 6.10.4 also ntates: " Work which han begun (Shift Super-visor han granted approval) but cannot be completed promptly l
may be suspended. Work on equipment required by Technical Specification may not be nunpended without the approval of l
the Shift Supervisor." This procedure van not followed l
when work was nunpended awaiting the arrival of parts.
l l
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i D:ckst No. 50-346 License No. NPF-3 i
Serial No. 1-722 j
Page 8
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Corrective Actions Taken And Resulta Achieved i
i SW 1357 temperature control feature was repaired and i
SW 1357 returned to an operable status on January 10, l
1987. As previously summarized, management meetings have i
been held with Operations and Maintenance personnel to l'
tions, the need for procedural compliance and that ensure everyona understands the importance of communica-disciplinary action, if necessary, will be taken.
Efforts have been initiated to provide improved communica-tions between Operations and Maintenance. These efforts i
include:
3 The Maintenance Shift Foreman attends the Operations j
shift turnover meetings, i
i Combined Operations Shift Supervisor and Maintenance l
Shift Foreman plant tours, and The Operations Shift Supervisor and the Maintenance Shift J
Foreman review Work Requesto and MW0s generated each shift.
The MWO equipment operability enclosure has been revised to provide better identification of how the work will affect the operability of the identified corponent.
Corrective Actionn To Be Taken To Avoid Further Violation 4
le i
Both Operations and Shop pernonnel did not fully understand l
the requirements of TS 3.6.3.1 Table 3.6-2 therefore, i
selected staff, engineering, and SRO licensed individuals l
will be provided Technical Specification training to re-emphasire the Technical Specification requirements.
3 A review of Technical Specification (T.S.) 3.6.3 indicaten that the Davis-Desse Technical Specification may be overly conservative in the application of T.S. 3.6.3.1 and Table 3.6-2.
Therefore, Toledo Edison will submit a license amendment request to redefine which containment isolation r
valves should be exempt from the provisions of T.S. 3.0.4.
Inconsistencies in the Technical Specifications are being identified in a second phase of the Technical Specification i
Verification Program (TSVP).
i The Maintenance Work Order process is currently under j
review with anticipated changes to improve human factor i
considerations in the process and streamline the manner i
in which HWas are statused prior to mode changen.
i i
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Docket No. 50-346 License No. NPF-3 l
Serial No. 1-722 Page 9 i
i 4
Date When Full Compliance Will Be Achieved Compliance has been achieved relative to the reemphasis of ensuring Operations awareness of plant status and steps 4
have been taken to improve communication between Operations and Maintenance. Additionally, due to the recent discovery of the existence of Technical Specification inconsistencies, the Operators have been directed to conservatively interpret
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the requirements. The license amendment request redefining the relationship between T.S. 3.6.3.1, Table 3.6-2 and i
T.S. 3.0.4 is expected to be submitted by September 1, i
1987.
l As stated in LER 87-003, the second phase of the Technical l
Specificiation Verification Program has begun, and it is estimated that the Technical Specification reviews and any retraining of personnel will be completed by December, 1
1987.
I
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c.
Reason For The Violation From December 7 through 16, 1986, Surveillance Test, ST 5035.01, Meteorological Monitoring System Channel Calibra-
?
tion, was performed by a contract personnel.
In reviewing the Surveillance Test, the Shift Supervisor found that portions of the Surveillance Test had been performed without the necessary prior approval of the Shift Supervisor. The Control Room was notified upon commencement of the test.
However, the individual performing the calibrations did not notify the Control Room to obtain permission prior to rendering t
each Technical Specification piece of equipment inoperable for calibration.
1 It should be noted that during the performance of this ST, i
no Technical Specification equipment was found to be i
inoperabic, t
l The root cause of this violation is the informal control of the contractor tasked with performing the ST combined with the lack of adequate communications.
It appears that the activity in the Control Room and the adverse weather conditions present made this test subject l
to a higher probability of error than those in the past.
The instrument calibrations have been performed for several l
years, and there have been no previous problems noted.
i Corrective Actions Taken And Results Achieved i
j An Environmental Compliance procedure has been written 1
which defines responsibilities and administrative controla necessary to perform ST 5035.01. This instruction provides
Dockst No. 50-346 License No. NPF-3 Serial No. 1-722 Page 10 the necessary Toledo Edison overview of contractors during performance of ST 5035.01. The instruction requires the personnel performing calibrations on Technical Specification instrumentation notify the Control Room prior to performance of tt:e ST and when removing the instrumentation from service.
Additionally, the contractor performing the calibration will no longer be responsible for communicating with the Control Room. A Toledo Edison management / Environmental Compliance Staff member will have overall responsibility for communication and administrative control.
Date When Full Compliance Will Be Achieved Compliance has been achieved with the additional Toledo Edston control of the enlibration of meteorological instrumentation.
Very tr
- yours,
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DCStJCStpif cet DB-1 NRC Renident Inspector
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