ML20247F805
| ML20247F805 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 03/27/1989 |
| From: | Shelton D TOLEDO EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1-867, NUDOCS 8904040041 | |
| Download: ML20247F805 (3) | |
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. TOLEDO
%ms EDISON A Centenor Erergy Company DONALD C. SHELTON Docket Number 50.-346 va nwomammc (419)P49 2300 License Number NPF-3 Serial Number 1-867 March 27, 1989 United States Nuclear Regulatory Commission Document Control Desk Washington, D. C.
20555
Subject:
Response-to Inspection Report (IR) Number 50-346/88037 Gentlemen Toledo Edison received IR Number 88037 (Log Number 1-2038, dated February 24, 1989) and provides the following response:
Violation 88037-02:
As a result of the inspection conducted on December 1, 1988 through January 15, 1989, and in accordance with the " General Policy and Procedures for NRC Enforcement Actions," 10CFR Part 2, Appendix C (1988), the following violation was identified:
Technical Specification 6.8.1.a requires that written procedures be established, implemented and maintained covering the applicable procedures recommended in Appendix A of Regulatory
""ide 1.33 (November 1972).
One section of the regulatory guide requires that maintenance that can affect the performance of safety-related equipment should be properly planned and performed in accordance with procedures or drawings appropriate to the circumstances.
Licensee administrative procedure DB-PN-00007, " Control of Vork," Section 6.4.1 requires the planner to review the P& ids, drawings and vendor nanuals to identify corrective actions and necessary documentation for the maintenance task.
Contrary to the above, on December 18, 1988, procedure DB-PN-00007, Section 6.4.1, was not implemented when the maintenance planner failed to review the necessary drawings for the safety-related Group 3 and 4 control rod drive programmer drawer and therefore was not able to identify the proper corrective actions for the maintenance work.
f g9 8904040041 890327 DR ADOCK 05000346 e\\ 1 9 PDC THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO. OHIO 43652
r Docket Numbar.50-346 i,
License Number NPF-3 Serial Number 1-867 Page'2
Response
Acceptance or Denial of the Alleged Violation Toledo Edison acknowledges the alleged violation.
Reason for the Violation Toledo Edison's investigation concluded that the failure to properly implement the procedure was due to personnel errors by a Maintenance Planner and an Instrument and Control (I&C)
Mechanic. There were several factors that contributed to these personnel errors.
Maintenance work at Davis-Besse Nuclear Power Station is-controlled by Procedure DB-PN-00007 (AD 1844.02),. control of Vork. This procedure instructs planners to perform appropriate walkdowns and review P& ids, drawings, procedures and vendor manuals to identify corrective actions and prepare the necessary documentation for the maintenance work to be performed.
It is the' responsibility of each planner to determine what additional resources ($f any) are needed to develop an adequate work plan.
In this instance, the planner did not select the_ appropriate resources to develop and review the work plan, considering the potential effect the' task could have on plant operations (i.e.,-
the only resource used to develop the work plan was an I&C Hechanic). The following factors contributed to the planners decision to select only one resource. The selected I&C Mechanic was considered very knowledgeable of_the CRD System due to his extensive past experience on that system and the work plan was being developed early in the morning (approximately 2:00 a.m. to 3:00 a.m.) therefore, few resources were readily available.
The I&C Hechanic erred in that he did not perform an adequate review of drawings when he assisted in developing the plan. As a result, the I&C Mechanic advised the planner that no precautions were necessary. The following factors contributed to the mechanic's error.
The I&C Mechanic had a preconception that the work would have no affect on plant operation and he had difficulty in locating the drawings he needed.
Corrective Actions Which Have Been Taken and Results Achieved I&C Maintenance technicians were provided training that addressed the lessons learned from the CRD dropped rod incident.
The Davis-Besse Document Control group has ensured that a complete, controlled set of CRD drawings is available in the I&C Department and has refiled the complete set according to the vendor figure series number.
In addition, a cross-reference between figure number, vendor number, and the Toledo Edison assigned number has been established on the Drawing Control
l
. Docket'Numbar 50-346 Licensa Number NPF-3
~- Serial Number 1-867 Page 3 System. This will allow the drawings to be easily filed by any of their associated numbers. The importance of selecting the appropriate resources and expertise to develop work plans for maintenance that can affect the performance of safety-related equipment has been re-emphasized to all planners.
As an additional precaution, a sign has been placed on all CRD Programmer Drawers cautioning to place a rod group on auxiliary power while performing maintenance.
Date When Full Compliance Vill Be Achieved Instrument and Control Maintenance Technician training was completsd on February 2, 1989. The Document Control corrective action vere completed on February 6, 1989. The corrective action for the planners was completed on March 23, 1989.
Very tr ly yours,
%3 EBS/dlm cc:
P. M. Byron, DB-1 NRC Resident Inspector A. B. Davis, Regional Administrator, NRC Region III T. V. Vambach, DB-1 NRC Senior Project Manager
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