ML20235W516

Responds to Violation Noted in Insp Rept 50-346/88-39. Corrective Actions:Review of Rev 7 to Updated SAR Per Potential Condition Adverse to Quality Rept 88-0887 to Determine Whether Changes Improperly Incorporated Initiated

ML20235W516
Person / Time
Site:	Davis Besse
Issue date:	02/28/1989
From:	Shelton D TOLEDO EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
1-865, NUDOCS 8903130070
Download: ML20235W516 (6)

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TOLFDO EDISON A Centenor Energy %mny DONAU3 C. SHELTON

%ce Presdna-Nuclear l8P"*3 Docket Number 50-346 License Number NPF-3 Serial Number 1-865 I

February 28, 1989 United States Nuclear Regulatory Commission Document Control Desk Washington, D. C.. 20555 Subj ect

• Response to Inspection Report 88039 Gentlemen:

Toledo Edison (TE)'has received Inspection Report 88039 (Log Number 1-2003) and prcvides the following response.

Violation 88039-02: "10CFR50.59(b)(1) requires the licensee to maintain records of changes in the facility as described in the safety analysis report. The records must include a written safety evaluation.

Contrary to the above, in July 1988, the licensees issued Revision 7.to the updated safety analysis report which included a change in the facility (the addition of an emergency diesel' generator protective relay (SIV-2) (sic) to the list of-protective relays not to be bypassed during an essential bus undervoltage condition or loss coolant accident) and did not maintain a safety evaluation for the change because it was not performed."

do Response Acceptance or Denial of the Alleged Violation Toledo Edison acknowledges the alleged violation.

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. U$@ Reason for the Violation ,

S Changes to the Davis-Besse Updated Safety Analysis Report (USAR) osto axD are processed in accordance with Nuclear Group Procedure Rg NG-NL-806, " Preparation And Control of USAR Changes." Section oo 6.2.5 of NG-NL-0806 requires that a written safety evaluation 8@ accompany USAR Change Notices (UCN) submitted for clarifications

- or corrections to the USAR. An exception is made to this

$ct requirement for editorial changes. Editorial changes are defined

$$c as changes which do not affect any substantive information or 300 MADISON AVENUE TOLEDO, OHIO 43652 ggol THE TOLEDO EDISON COMPANY EDISON PLAZA I t

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.Dackst-Nu2bsr 50-346

. License Number NPF-3 Serial Number 1-865 Page 2 change the intent of a statement or requirement in the USAR. The subject change, which added protective relay 51V-1 to the list of protective relays not bypassed during an essential-bus undervoltage condition or a loss of coolant accident, was improperly processed as an editorial change.- Therefore, no safety evaluation was generated for this change.

Corrective Actions Taken and Results Achieved-As indicated in Inspection Report 88039, Potential Condition Adverse to Quality Report (PCAOR) 88-0887 was written to document the lack of a required safety evaluation. A new UCN (UCN 88-0068) was generated to clarify the-function of the 51V-2 relay and to make an editorial correction (51V-1 should have been 51V-2). The safety evaluation for this UCN was approved on.

November 18, 1988.- This safety. evaluation provides assurance that an unreviewed safety questions was not created by the previous UCN incorporated into Revision 7 of the USAR. A review of Revision 7 of the USAR was initiated in response to-PCA0R 88-0887. to determine whether other changes were improperly incorporated as editorial changes without a safety evaluation.  ;

No additional USAR changes were identified which should have had safety evaluations. The subject occurrence was determined to be an isolated event and no further corrective actions were deemed necessary.

Date When Full Compliance Vill Be Achieved l Full compliance has been achieved with the completion of the l corrective actions listed above.

Violation 88039-04 (A, B,-C): A. Operations Procedures DB-0P-00000, " Conduct of Operations,"

Section 6.3.3 requires that when a relief for a Reactor j Operator (RO) is necessary at any time, other than normal shift turnover, the panels are to be walked down and  ;

evolutions being performed by others discussed, j contrary to the above, on November 2, 1988, an R0 who was aware that a valve checklist was not complete (valve DH 1517 was mispositioned) was relieved by an RO vho was not made aware of the mispositioned valve.

B. Operations Procedure DB-0P-00000, Section 6.14 requires that during normal operations or when performing surveillance tests if a component is found out of position or if a condition is discovered which would prevent a component from 1 performing its designed function, the control room Senior Reactor Operator (SRO) shall be notified immediately. Also, the shift supervisor or assistant shift supervisor shall perform an evaluation and verification of the system. i l

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1. $ 4-Dockst Nu;ber 50-346 License. Number NPF-3 Serial Number 1-865-Page 3 Contrary to the above, on November 2, 1988, in preparation-for performing surveillance test ST 5074.01, the licensee

' discovered.both-suction valves for decay heat pump No. I shut, thus preventing the system from performing its designed function, and did not report it to the control room SRO.

C. Operations Procedure DG-0P-00100, " Shift Turnover," Section 6.1.8, requires a panel walkdown by,both on-coming and off-going crews. Implicit in this procedure is that the walkdown shall be adequate to assure that plant personnel are cognizant of the plant status.

Contrary to the above, on October 10, 1988, for several shifts prior to the start of Decay Heat Pump Number 1, a control panel light indicated ~that both suction valves on the Decay Heat pump were closed and this condition was not identified and rectified during the panel walkdowns.

Response: Acceptance or Denial of the Alleged Violation Toledo Edison acknowledges the alleged violation.

Reason for the Violation Parts A, B, and C of Violation 88039-04 involve a single event and are discussed concurrently herein. 88039-04D will be addressed separately.

On November 2, 1988 the plant was in Hode 5 with Decay Heat (DH)

Pump 2 recirculating the Reactor Coolant System (RCS). The annual Emergency Preparedness Exercise was in progress. The day shift had reported to work at 0400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> on November 2 because of an Emergency Preparedness drill. The midnight shift had earlier performed a surveillance test which required the disabling of.DH Pump 1. Subsequent to the test, DH Pump 1 was declared operable and returned to standby status. However, DH 1517 (DH suction valve from the RCS) was left closed based on its status prior to the test. Decay Heat 2733 (DH suction valve from the Borated Water Storage Tank (BVST) had been closed since October 24, 1988, thereby isolating both available suction paths for DH Pump 1. On the morning of November 2, 1988 the day shift began preparations to switch Decay Heat pumps in order to perform testing on DH Pump 2. Pre-startup checklist were performed for DH Pump 1 and Component Cooling Vater (CCW) Pump 1 as part of those preparations. One exception was noted; that being DH 1517 was shut. The pre-startup checklist for CCV Pump 1 was completed and returned to the Assistant Shift Supervisor, however, the checklist for DH Pump 1 was not completed due to the exception involving DH 1517.

Dockst Nu;b:r 50-346-

. License Number NPF-3

-Serial Number 1-865 Page 4

' Davis-Besse normally maintains two.RO's in the control room, though only one is required by Technical Specifications when the plant is in Mode 5. Both R0's attend the shift turnover meetings and are responsible for maintaining cognizance of plant status.

At.approximately 0835 hours0.00966 days <br />0.232 hours <br />0.00138 weeks <br />3.177175e-4 months <br /> on November 2 the Reactor Operator (RO) involved with the DH Pump pre-startup checklist left the control room for a break. The Assistant Shift Supervisor informed the remaining control room R0 that the pre-startup checklist for CCV Pump 1 and DH Pump 1 had been completed (through only the CCW Pump checklist had been returned) and that the DH Pumps should be swapped. When DH Pump 1 was started at 0840, abnormal flow indications were observed and DH Pump 1 was immediately secured.

As described in Violation 88039-04, this event was attributable to several personnel errors involving failure to follow procedures. These errors center around an. improper turnover by the RO who left the control room prior to starting DH Pump 1.

This RO was aware of the system lineup discrepancy involving DH 1517, but failed to communicate that information to the other RO or Assistant Shift Supervisor.

Personnel involved in this incident have been counseled with emphasis being placed on the importance of ensuring proper communications while performing assignments and maintaining strict adherence to procedure requirements.

In addition, the Plant Manager discussed this event with the personnel from each shift prior to startup from recent refueling outage (December 1988) to stress the importance of the procedure breakdown which occurred. The Plant Manager also met with the Shift Supervisors and the Operations Manager separately to discuss this incident.

Date When Full Compliance Vill Be Achieved Compliance with the corrective actions stated has been achieved with the counseling of the personnel involved-in this incident and the discussions held with the remaining shift personnel.

Violation 88039-04D: Section 6.27 of procedures DB-0P-00000, " Conduct of Operations" requires the status of inoperable equipment to be recorded to assure that licensed operators on duty'are aware of equipment that is inoperable, Contrary to the above, from November 22 - 28, 1988, Containment Air Cooler Number 2 was inoperable without being recorded as required by the procedure.

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. . Docket.Nu;b2r 50-346 i

. License Number NPF-3 USerial Number 1-865 Page So Responses: -Acceptance or Denial of'the Alleged Violation Toledo Edison accepts the alleged-violation.

Reason for'the Violation On November 20, 1988, Maintenance Vork Order (M'V0) 1-88-2730-00 vas signed by the shift supervisor (SS).to allow cleaning of the l air side of Containment' Air Cooler (CAC) Number 1-2. On.

November 22, 1988, the SS signed the Technical Specification-Operability Checkoff List for the MV0'(1-88-2730-00)- authorizing vork on the service water side of CAC 1-2. . The. checkoff list

' indicated that 'this work rendered CAC 1-2 inoperable and' noted CAC 1-1 and CAC 1-3 as' redundant equipment required to be operable'in Modes 1 through 3. The checkoff list also listed DB-PF-04725, " Containment Air. Cooler.1-2 Performance Test" as the-applicable retest requirements for the MVO.

DB-PF-04725 was performed on November 23, 1988, however,'^the test results review was not completed until November 29, 1988. The lack of reviewed test results made.CAC 1-2 administrative 1y inoperable from November 22 until November 29, 1988.-

During the-test CAC 1-2 had been operating and CAC 1-3.was lined up as the second operable CAC required by Technical Specifications (TS). On November 27, 1988, a reactor operator, who had re.cently come on shif t, noted that CAC 1-1 and CAC 1-2 were operating'and CAC 1-3 was lined up for-service. The oncoming shift had not been made aware that CAC 1-2, although running, was not operable. Upon encountering what was determined was an abnormal lineup, the RO opened'the breaker for CAC 1-3.

This left only one CAC running which was operable.- CAC 1-2 was capable of performing its intended safety function, as verified by testing, but technically inoperable due to lack of reviewed test'results. Technical Specifications 3.6.2.2 required two operable CAC's for the existing plant conditions (Mode 3).

Corrective Action Taken and Results Achieved Procedure DB-OP-00000, Conduct of Operations is being revised to include improved methods for tracking and delineating equipment that is out-of-service. In addition, improvements to the Centrol Room Status Board are being evaluated to provide better indication of equipment that is out of service or in an abnormal lineup.

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.Dockdt Numbar 50-346

-License Numb er NPF-3:

Serial Number 1-865

~ Page'.6 Date Vhen Full Compliance Vill'Be Achieved Full Compliance.Will be achieved by April 15,~1989 with approval' of recommended procedure changes and incorporation of improvements to the Control Room Status Board.

Very truly yours, RVG/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 j

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