ML20235S680
| ML20235S680 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 06/19/1987 |
| From: | Shelton D TOLEDO EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 1-734, NUDOCS 8707210746 | |
| Download: ML20235S680 (6) | |
Text
hma TOLEDO
%s EDISON Docket No. 50-346 DONAU3 C. SHELTON Vce Pres <lva-Nutinar (419) P49 2399 License No. NPF-3 Serial No. 1-734 June 19, 1987 Mr. A. B. Davis, Regional Administrator United States Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Response to Inspection Report 87004
Dear Mr. Davis:
Toledo Edison has received Inspection Report 87004 (Log No. 1-1600, dated May 8, 1987) and provides the following response. The response to Inspection Report 87004 was extended to June 19, 1987, per discussions with Masre. P. M. Byron and R. W. DeFayette of your staff.
Violation 87004-02:
" Technical Specification 3.8.1.1 requires that with either an offsite circuit or diesel generator or the required A.C. electrical power sources inoperable, demonstrate the operability of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within one hour and at least once per eight hours thereafter and by performing Surveillance Requirement 4.8.1.1.2.a.4 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> while the plant is in Modes 1, 2, 3 or 4.
Technical Specification 3.0.3 requires thac when a Limiting Condition for Operation (LCO) is not met, except as provided in the associated action requirements, action shall be initiated within one hour to place the unit in a Mode in I
which the technical specification does not apply.
Contrary to the above, on March 25, 1987, the li,censee declared a diesel generator inoperable and failed to l
demonstrate the offsitt power sources to be operable within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after the initial demonstration and failed to initiate action within one hour to shut down the plant when the plant was in a condition not encom-pessed by the applicable LCO or its Action Statement."
8707210746 870619 PDR ADOCK 05000346 JUM 2 4N G
PDR THE 10LEDO EDISON COMPANY EDISON PLAZA 300 MAD' SON AVENUE TOLEDO, OH:0 43652 I O I E d'l
L sDocket.No. 50-346
, License No..NPF-3 Serial NoJ1-734 g
Page 2
Response
Acceptance Or Denial Or The Alleged Violation
[
Toledo Edison acknowledges the alleged violation.
Reason For The Violation On March 25, 1987 with the plant operating at 100% power, L
the Emergency Diesel Generator (ED9) 1-1 was taken out of service for scheduled maintenance at 0720 hnurs. A unit log entry was made stating that EDG Iv1 was out of service and Technical Specification (TS) 3.8.1.1, Action (a.) had been entered. TS 3.8.1.1 requires that, as a minimum, two independent circuits'between the offsite transmission network and the onsite Class 1E distribution system and two separate and independent diesel generators-be operable.
If TS 3.8.1.1 cannot be met, the applicable Action Statement is entered..TS 3.8.1.1, Action Statement (a.) requires the operability of the remaining AC sources'(two circuits of offsite AC power and the remaining EDG) be demonstrated.
The offsite power sources are determined to'be operable by verifying circuit' breaker alignments and indicated power availability within one hour and at least once per eight hours thereafter. The EDG is demonstrated operable by l
verifying the' diesel starts and accelerates to 900 rpm within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The operability of the offsite AC power sources was demon-strated at 0745 hours0.00862 days <br />0.207 hours <br />0.00123 weeks <br />2.834725e-4 months <br /> on March 25, 1987. EDG 1-2 was demonstrated to be cperable at 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br />. At 1910 hours0.0221 days <br />0.531 hours <br />0.00316 weeks <br />7.26755e-4 months <br />, it was noted that verification of offsite AC power had not been performed within the required 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The surveillance una completed at 1920 hours0.0222 days <br />0.533 hours <br />0.00317 weeks <br />7.3056e-4 months <br /> when both offsite AC sources were demonstrated to be operable.
H 1
The operability requirements were being met individually by various methods ranging from readings by licensed operators and equipment operators to monitoring of voltage fluctuations by the load dispatcher and fuse control by tagging procedures. These controls, which were in place at the time of the missed surveillance, ensured the partmeters of interest were within specification, even though they were not specifically monitored to determine offsite power availability to satisfy the action statement.
i'
l Dockot.No. 50-346 a
License No. NPF-3 l
Serial No. 1-734
.Page 3 The-root cause of this violation is personnel error.
The personne1' assigned. responsibility for identification and tracking of LCO action statements did identify the requirements and'immediate verification of lineup.(offsite power available) as required per TS 3.8.1.1, Action (a.).
was' performed.- However, senior licensed personnel on shift i
failed to assign the task of performing the' required surveillance test to reverify operability.
. Factors which contributed to not-performing this reverifi-cation within the required time are:
1)
A high level of activity is experienced on the day shift, 0800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> to 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br />. This may have.
hindered the close monitoring of the required reveri-fication of offsite power.
2)
Only-senior shift personnel (Shift Supervisor and Assistant Shift Supervisor) were assigned the respon-sibility of tracking surveillance requirements (SRs).
This contributed to.other licensed personnel.on shift not' aggressively monitoring the status of SRs.
Corrective Actions Taken And Results Achieved The responsible licensed personnel involved in the missed surveillance test (ST) were counseled on the importance of performing SRs associated with LCO Action Statements and operating the facility in accordance with Technical Specifications.
The Operations Superintendent has emphas1 zed that all licensed personnel are responsible for the timely completion of SRs contained in Tech Spec Action Statements. Also, the Shift Technical Advisors (STA) will now track SRs to provide additional awarehess and monitoring of timely sur-veillance performance.
Additionally, an effort to reduce the Shift Supervisor's administrative burden has been initiated. Previously, the Shift Supervisor was required to review and sign to verify completion of each ST.
A change has been implemented requiring the Shift Supervisor's review for only Operation's STs.
STs performed by other station personnel will be reviewed by the appropriate supervisor of the personnel performing the test. The Shift Supervisor will be notified of test comple-tion.
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I Docket No.-50-346 License No. NPF-3 Serial No. 1-734 Page 4 Licensed personnel Shift Turnover Checklists have been revised to require detailed information for actions required by all LCOs and the time and date the next surveillance is due. The STA's Turnover Checklist has also been revised in the same manner to provide additional awareness of SRs.
Date When Full Compliance Will Be Achieved The corrective actions taken to date should provide the additional visibility to LCO required actions to prevent further violations.
Violation 87004-10:
"10 CFR 50.59(b) requires that licensees furnish to the WRC at least annually a report containing a brief description of changes in the facility and procedures which are described in the Safety Analysis Report (SAR) and tests and experiment performed which are not described in the SAR including a summary of the safety evaluation of each.
Contrary to the above the licensee has not reported procedure changes and their related safety evaluations to the NRC at least annually.
Additionally, terts and experiments are only reported to the NRC if a safety evaluation and safety review are performed by a Facility Change Request (FCR)."
Response
Acceptance Or Denial Of The Alleged Violation Toledo Edison acknowledges the alleged violation.
Reason For Violation 10CFR50.59 authorizes the licensee to "make changes in the facility as described in the safety analysis report, make changes in the procedures as described in the safety anal-ysis report, and conduct tests or experiments not described in the safety analysis report.
The licensee shall Fubmit a report centainiDS a brief description Of any changes, tests and experiments, including a summary of the safety evaluation of each" at least annually.
r-Docket No. 50-346 License No. NPF-3 Serial No. 1-734 Page 5 1
Toledo Edison has not submitted a special report describing procedure changes, tests and experiments in accordance with 10CFR50. 59 (b) (2).
The apparent root cause of this violetion has been determined to be en oversight by Toledo Edison.
Toledo Edison annually updates the Safety Analysis Report (SAR) to reflect changes to the facility and submite a summary of the modifications to the fasility through the Monthly Operating Report. However, Toledo Edison has not submitted a report summarizing the chenges to procedures as described in the SAR and tests or experiments that were not performed in conjunction with plant modifications es required by 10CFR50. 59 'b) (2).
Safety reviews, and if necessary, safety evaluations, are performed and reviewed for facility changes, tests and experiments described in the SAR which could directly impact the safe operation of Davis-Besse, Unit No. 1 (e.g.
Facility Change Requests, System Procedures, Surveillance Tests, Test Procedures, Maintenance Procedures, Temporary Mechanical Modifications and Inste11ation of Jumpers and Lifted Wires).
l At the time of the audit, the nethod of controlling proper identification and evaluation of changes was through the use of the cafety review process.
If deemed necessary by the safety review., a safety evaluation is performed ip accordance with the requirements of Station Procedure AD 1845.01, Safety Evaluation and Review Pr4aparation or Nuclear Engineering Procedure, NEP-012, Safety Review and Evaluations. Presently, safety evaluations are performed i
by using NG-NE-304, Safety Review and Evaluation, and its implementing procedures.
Corrective Actions To Be Taken To Prevent Recurrence Toledo Edison will submit a summary of the 1986 changes, tests and experiments conducted in accordance with 10CFR50.59 by July 31, 1987. The reporting period has been scheduled to coincide with the Safety Analysis Report updating period. Therefore, the 1986 summary will report information for the period beginning January 23, 1986 and ending January 22, 1987.
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i Docket No. 50-346 License No. NPF-3 Serial No. 1-734 Page 6 l
The Nuclear Licensing Department has been identified as the department which will be responsible for coordinating the annual 100FR50.59(b) submittal. Procedure NG-NE-304, Safety Review and Evaluation, is being revised to state that a copy of approved cafety evaluations will be forwarded to Nuclear Licensing. NG-NE-304 will be revised by July 31, 1987.
bate When Full Compliance Will Be Achieved
)
l The submittal summarizing the 1986 Changes, Tests and Experiments as required by 10CFR50.59(b)(2) will be submitted by July 31, 1987. The actions necessa.ry to l
provide for the review of information necessary for future l
submittals will be implemented by July 31, 1987.
Very truly yours, DCS:JCS:p1f cc: DB-1 NRC Resident Inspector
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