ML20235X402
| ML20235X402 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 10/09/1987 |
| From: | Shelton D TOLEDO EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8710190342 | |
| Download: ML20235X402 (3) | |
Text
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TOLEDO
% EEE)lEiCird DONAU) C. SHELTON Vca Present-Nudear (419}249-2399 Docket No. 50-346 License No. NPF-3 Serial No. 1-758
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October 9, 1987 Document Control Desk United States Nuclear Regulatory Commission s
Washington, D.C.
20555
Subject:
Response to Inspection Report 87014 Gentlemen:
. Toledo Edison has received Inspection Report 87014 (Log No. 1-1658, dated September 9,1987) and provides the following response.
Violation 87014-02A, B: Technical Specification 6.8.1 requires that written procedures be established, implemented, and maintained covering the activities specified in Appendix A of Regulatory Guide 1.33, November 1972. The activities specified in Appendix A, Section A, Administrative Procedures, include procedure adherence. Nuclear Training Division Procedure NT-DP-0002, Revision 1, " Development, Review, Approval, and Control of Nuclear Training Division Procedures", dated October 10, 1986, states that NT-DP-0002 shall be followed by all Nuclear Training Division assigned personnel who revise Nuclear Training Division Procedures. The " Zone Manual" is a Nuclear Training Division Procedure. Administrative Procedure AD 1805.00.27 (DE-DP-0003), " Procedure Preparation and Maintenance", dated May 19, 1987, requires that the preparer of a change to a procedure developed for use within the Operations Department perform Steps 6.1.1 through 6.1.15 of AD 1805.00.27. Administrative Procedure AD 1839.00.16 is a procedure developed for use within the Operations Department.
8710190342 071009
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THE TOLEDO EDISON COMPANY EOfSON PLAZA 300 MADISON AVENUE TOLEDO. OHIO 43G52
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Dock 2t No. 50-346 License No.'NPF-3 Serial No. 1-758 4
Page 2 i
1 A.
Contrary to the above, on July 2, 1987, a Nuclear i
Training Department assigned individua1' revised the
" Zone Manual" without following the requirements of NT-DP-0002.
B.
Contrary to the above, in June, 1987, the preparer of a change to a procedure developed for use within the-Operations Department prepared a change.to AD 1839.00.16 without performing Steps 6.1.1 through 6.1.15 of AD 1805.00.27.
Response
As-stated in the Notice of Violation for Inspection 87014-02A Report 87014 "... the inspection showed that action had been taken to correct the identified violation and to pre"ent recurrence. Consequently, no reply to I
this violation is required and we have no further questions regarding this matter."
Based on the above, Toledo Edison considers noncompliance item 87014-02A closed.
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Response
Acceptance or Denial of the Alleged Violation 87014-02B Toledo Edison acknowledges the alleged violation.
Reason for the Violation A Toledo Edison employee was promoted to the position of Operations Superintendent (OS) to replace an individual who returned to shift. This promotion became effective on July 1, 1987. The newly appointed Operations Superintendent did not possess a i
Senior Reactor Operator's (SRO) License for Davis-Besse et the time of the promotion, but is involved in an expedited SR0 training program.
Administrative Procedure AD 1839.00, " Station Operations", states that the OS is responsible for maintaining an NRC SRO's License on the unit.
Recognizing that this requirement could not be met by the appointed OS, those OS responsibilities requiring a license were verbally assigned to licensed individuals. This verbal assignment of duties was interpreted as a procedure change to AD 1839.00.
The intent of the assignment of duties was to provide an interim measure for satisfying the requirements of the OS position.
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4 Dock:;t No. 50-346 j
License No. NPF-3 l
Serial No. 1-758
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Page 3 J
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Corrective Actions Taken and Results Achieved
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s After discussing this matter with the Quality Assurance Director it was decided that alternate provisions for the position of OS would be made. An intra-company memorandum was issued on September 3, 1987 detailing the interim measures for the OS position. The memorandum stated that the Assistant Plant Manager, Operations would assume the responsibilities of the OS until the
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OS designee received an NRC SRO license. The memorandum also listed activities which could be performed by the OS designate.
The organization chart for the Operations Department l
has been changed to reflect the changes described above.
Additionally, a memorandum has been issued by the Vice President, Nuclear to all site personnel as a reminder to follow the appropriate administrative procedurec for making changes to procedure requirements rather than verbal or written instructions.
Date_When Full Cotopliance Will Be Achieved Full compliance has been achieved, a
Very tr
- yours, la im RG:dem cc: DB-1 NRC Resident Inspector Document Control Desk l
A. B. Davis, Region III Regional Administrator i
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