ML20236G890
| ML20236G890 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 07/24/1987 |
| From: | Shelton D TOLEDO EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 1-741, NUDOCS 8708040412 | |
| Download: ML20236G890 (6) | |
Text
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bTO53 TOLEDO
%msEDISON Docket No. 50-346 OONAL(3 C. SHELTON va ommnt-Nuder (419] P49 2399 License No NPF-3 Serial No. 1-741 July 24, 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 87008
Dear Mr. Davis:
Toledo Edison has received Inspection Report 87008 (Log No. 1-1620, dated June 24, 1987) and provides the following response.
Violation 87008-04: " Technical Specification (TS) 6.2.3 requires tFat adminis-trative procedures be developed and implemented to limit the working hours of facility staff wbo perform safety-related functions.
Senior reactor operators (SRO's) are members of the facility staff who perform safety-related functions. The licensee's shift supervisors and assistant shift supervisors are licensed SRO's.
The TS requires that adequate shift coverage be maintained without routine heavy use of overtime.
The TS also requires that, if overtime is required on a temporary basis due to unforeseen problems, four guidelines shall be used. Guideline b. states that an individual should not be permitted to work more than seventy two hours in any seven-day period, excluding shift turnover time. The TS requires that any deviation from the guideline be authorized by the Plant Manager, his designect or higher levels of manage-ment, in accordance with established procedures and with docu-mentation of the basis for gra' ting the deviation.
Contrary to the above from March 26 through May 8, 1987, the licensee made routine heavy use of overtime to maintain adequate shift coverage in that during eleven different l
seven-day periods seven different SRO's worked as shift j
supervisors and assistant shift supervisors for sixty four or more hours, excluding turnover time.
8708040412 870724 PDR ADDCK 05000346 dUL891967 O
PDR THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MAOISON AVENUE TOLEDO, OHIO 43652 I
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Docket No. 50-346 License No. NPF-3 Serial No.'1-741 l
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Contrary to the above, the licensee allowed unauthorized devia-tions from TS Guideline b. by permitting one SRO to work 76 hours8.796296e-4 days <br />0.0211 hours <br />1.256614e-4 weeks <br />2.8918e-5 months <br />, excluding turnover time, in a seven-day period from April 5-11, 1987, and by permitting one SRO to work eighty hours, excluding turnover time and one SRO to work 76 hours8.796296e-4 days <br />0.0211 hours <br />1.256614e-4 weeks <br />2.8918e-5 months <br />, in a seven-day period from April 23-29, 1987."
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Response: As stated in the Notice of Violation for Inspection Report 87008, "the inspection showed that action had been token to correct the identified violations and to prevent recurrence.
Consequently, no reply to those violations (87008-04) is required and we have no further questions regarding these i
matters."
Based on the above, Toledo Edison cousfders noncompliance item l
l 87008-04 closed.
Toledo Edison acknowledges that overtime hours were worked in excess of Technical Specification Guideline b., however, we feel that the use of this overtime was authorized and approved by plant management through the review and approval of the l
shift manning schedule. The decision to place SRO licensed personnel on this schedule was carefully planned, discussed, approved and published knowledge. This decision was a measured one with regard for plant and personnel safety.
Violation 87008-06: " Technical Specification 6.8.1.f requires that written procedures shall be established, implemented and maintained covering fire protection plan implementat1on.
Davis-Besse Generic Guidance Memorandum POL-22 requires that a safety-related fire door.not be blocked open without first obtaining the shift supervisor's permission.
Contrary to the above on April 27, 1987, the licensee blocked open the safety-related fire door between the auxiliary feedwater pump rooms without first obtaining the shift super-visor's permission."
Response: As stated in the Notice of Violation for Inspection Report 87008, "the inspection showed that action had been taken to correct the identified violations and to prevent recurrence.
Consequently, no reply to those violations (87008-06) is.
required and we have no further questions regarding these-J matters."
Based on the above, Toledo Edison considers noncompliance
.j item 87008-06 closed.
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Docket No. 50-346 l
License No. NPF-3 l
Serial No. 1-741 Page 3 Violation 87008-10: "10 CFR 50, Appendix B, Criterion II requires that a quality assurance program.shall be documented by written policies, procedures, or instructions and shall be carried out throughout plant life in accordance with those policies, procedures or instructions.
i Toledo Edison Nuclear Quality Assurance Manual states, "All l
maintenance shall be prescribed and controlled by a Maintenance-Work Order (MWO) and associated documents."
Contrary to the above, on April 16, 1987, a system engineer performed maintenance on the component cooling water ventila-i tion system without a MWO."
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Response: Acceptance Or Denial Of The Alleged Violation 1
Toledo Edison acknowledges the alleged violation.
Reason For The Violation l
The Component Cooling Water (CCW) pump room ventilation is designed to maintain the room temperature between 60 and 104*F.
The safety-related system provides two (2) 100% capacity fans, j
and motor-operated exhaust and recirculation dampers.
Cooling and ventilation is ensured by one (1) of the two (2) fans. A temperature switch will automatically start one of the fans when the room temperature reaches 104*F, opens the motor-operated j
outside eir louvers and modulates the exhaust and recirculation air dampers through temperature indicating controllers.
The fan shuts off when the temperature in the room is less than 80*F.
Loss of either safety-related train of CCW pump room ventilation will result in the system's inability to tolerate an additional single failure. With the failure of either CCW pump room vent-ilation train the associated CCW pump and train is considered inoperable and Technical Specification Action Statement 3.7.3.1 applies.
The Systems Engineer was conce ned that the automatic initiation function of Train #2 of CCW pump room ventilation might not be actuating properly and may be inoperable. This concern was identified during a walkdown of the system with Operations in.
which a local start of the fan was attempted without success.
The Systems Engineer suspected that a fault may be present in the auto start feature which could affect the manual actuation feature of the system. This inopcrability would have made CCW Ventilation Train #2 inoperable causing entry into Technical i
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t Docket No. 50-346 License No. NPF-3 l
Serial No. 1-741 Page 4 Specification Action Statement 3.7.3.1. "The Systems Engineer obtained authorization from the Shift Supervisor to investigate if the ventilation fan would automatically start, however, he did not specifically ask the Shift Supervisor to authorize immediate plant maintenance per AD1844.00, Control of Work.
It was mistakenly thought that TP850.59, CCW Pump Room Ventilation Test, could be used as a guideline to verify the operation of the temperature switch that automatically starts the CCW pump room ventilation. The individual felt that this action did not constitute maintenance on the system, therefore, an MWO and craft support was not requested.
The root cause of this violation was an insufficient understanding of the requirements for the control of plant maintenance as set forth in AD1844.00, Conduct of Maintenance, and AD1844.02, Control I
of Work.
Corrective Actions Taken And Results Achieved l
After determining that the temperature switch would not auto-matically initiate CCW Room Ventilation Train #2, the Shift Supervisor was informed and Technical Specification '-tion Statement 3.7.3.1 was entered. Additionally, Maintenance Work Order (MWO) 1-87-1046-00 was created to repair the problem.
i Subsequently, the circuitry was repaired and Control Room Ventilation #2 returned to service.
The system engineer involved has been counselled on the consequences of potentially rendering safety-related equipment inoperable without the use of the required approval, tracking and historical documen-l tation process as required in AD1844.00 and AD1844.02.
Additionally, this occurrence was discussed with System l
Engineering personnel to emphasize the importance of conducting work within the program established at Davis-Besse.
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Date When Full Compliance Will Ee Achicved Full compliance has been achieved.
I Violation 87008-09: "10 CFR 50, Appendix B, Criterion 11 requires that the quality assurance program shall provide control over activities affecting the quality of systems and components consistent with
-their importance to safety, i
The licensee implements this requirement through the Nuclear Quality' Assurance Manual (NQAM).
Section 22.4.1.1 of the NQAM s
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Docket No. 50-346 l
License No, NPF-3
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Serial No. 1-741 l
Page 5 requires that maintenance practices shall not compromise the safety-related features of the plant.
Exposing safety-related equipment to hazards for which it is not designed compromises safety-related features of the plant. The Emerger.cy Diesel Generator (EDG) Ventilation System is safety-related equipment.
Rags and plastic are hazards to a ventilation system if they enter the system. The EDG Ventilation System is not designed to function with rags and plastic passing through it.
Contrary to the above, on May 6, 1987, the licensee's poor housekeeping practices resulted in the EDG 1-2 being declared inoperable because of rags and plastic be.4ng ingested by the Emergency Diesel Generator (EDG) Ventilation System."
Response: Acceptance Or Denial Of The Alleged Violation
'foledo Uison acknowledges the alleged violation.
Reason For The Violat4.on The EDG Room Ventilation System consists
- v. two (2) safety-grade, 50 percent capacity supply air fans in each EDG room.
The fans are started automatically when the respective diesel engine is started. The ventilation systems provide adequate cooling to each " operating" diesel generator room. The return and exhaust air daspers are interlocked through room temperature controllers.
The dampers automatically modulete to maintain the room temper-ature for operating conditionc.
On May 6, 1987, EDG 1-2 was started for performance of ST5081.01, EDG Monthly Operational Test.
As stated in Potential Condition Adverse to Quality (PCAQ)87-222, "Upon start of EDG 1-2 packages of cleaning cloths and plastic bags fell from high in the room, pieces of cloth blew ort of the duct work."
After review of the work history on equipment in the room, it is believed that the rags (cheesecloth consistency) and the plastic bags (thin trash bags) were left on top of the ventil-ation duct work by workers after conducting preventive main-tenance activities on the ventilation damper hydramotor actuators.
Preventive maintenance activities were completed on April 22, 1987 and again on May 2, 1987. When the room ventilation system initiated on an EDG start (May 6,1987), the loose rags may have been shaken off the duct work and entrained in the flow through the_ recirculation damper into the ventilation duct work through the fans and discharged into the room.
The fans and subsequently the EDG were declared inoperable due to the unknown condition of the ventilation fan.
Docket No. 50-346 License do. NPF-3 Serial No. 1-741 Page 6 Toledo Edison feels this is a personnel error since adherence to AD1844 Control of Work and AD 1835.00, Plant Cleanliness Inspection Program, was not closely followed by personnel performing activities, rather than a poor housekeeping program.
As outlined in AD1844.05, Cleanliness Control, all station personnel are responsible for ensuring and maintaining cleanli-ness of their work areas and systems, on which they work. This is accomplished through adherence to AD1844.02 which requires the individuals who performed the maintenance to eneure that the housekeeping at-the job site is adequate, in accordance with AD1835.00, and attest to this fact by signing the House-keeping Acceptable Block on the Maintenance Work Order (MWO) under which the' work was accomplished.
Actions Taken And Results Achieved Upon satisfactory cleanup of the area, duct work and fans were inspected and the fans tested satisfactorily with no indication of damage.
The Maintenance Foremen have discussed the incident with their assigned personnel emphasizing the importance of adherence to AD1835.00 and AD1844.02. This was stressed by emphasizing to them how something as seemingly harmless as leaving cleaning rags on ventilation duct work could render the associated EDG inoperable.
It was also emphasized that although Toledo Edison supervision and management perform weekly housekeeping plant tours, it is everyone's personal responsibility to ensure housekeeping standards are followed.
Date When Full Compliance Will Be Achieved Full compliance has been achieved.
Sincerely yours, l
JCS:p1f cc: DB-1 NRC Resident Inspector-
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