ML20215C278

Responds to NRC Re Violations Noted in Insp Rept 50-346/86-16.Corrective Actions:Administrative Procedure AD 1827.06, Tornado, Changed to Emergency Procedure AD 1827.06, Tornado

ML20215C278
Person / Time
Site:	Davis Besse
Issue date:	09/26/1986
From:	Williams J TOLEDO EDISON CO.
To:	Guldemond W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
1-673, NUDOCS 8610100199
Download: ML20215C278 (4)

Text

r TOLEDO Num EDISON JOE VVILUAMS. JR.

Docket No. 50-346 sono va w w

[419)249 2300 (4191249 s22a License No. NPF-3 Serial No. 1-673 September 26, 1986 Mr. W. G. Guldemond, Chief Division of Reactor Projects United States Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Dear Mr. Guldemond:

Toledo Edison acknowledges receipt of your August 27, 1986 letter (Log No. 1-1454), Notice of Violation and Inspection Report No. 50-346/86016.

Following an examination of the two items of concern set forth in the Notice of Violation, Toledo Edison herein offers the following information regarding these items:

Violation 1: Technical Specification 6.8.1 requires that written procedures shall be established, implemented and maintained. 10 CFR 50, Appendix B Criterion V states in part, " Activities affecting quality shall be prescribed by ... and shall be accomplished in accordance with these instructions, procedures, and drawings". Section 5.1.1 of the licensee's Nuclear Quality Assurance Manual (NQAM) states, " Division directors performing activities covered by this QA Manual shall ensure these activities are carried out in accordance with approved procedures." Toledo Edison Administrative Procedure AD 1827.06, " Tornado", requires that the Load Dispatcher notify the station that a tornado watch or warning exists for the vicinity of the station.

Contrary to the above, a tornado warning was issued by the Weather Service for the vicinity of the station at 9:11 P.M.

on June 10, 1986, and the load dispatcher did not notify the station. (86016-01)

This is a Severity Level IV Violation (Supplement 1). gg OSb 8610100199 860926 PDR 0 ADOCK 05000346 PDR THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO, CHIO 43652 1

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Docket No. 50-346 License No. NPF-3 Serial No. 1-673 September 26, 1986 Page 2 (1) Acceptance Or Denial Of Alleged Violation Toledo Edison admits the alleged violation.

(2) Reason For The Violation On June 10, 1986, at 9:11 p.m. a tornado warning was issued by the U. S. Weather Service for Ottawa County. Previous to this, no severe weather watches or warnings had been issued until a tornado was spotted at 9:03 p.m.

The Load Dispatcher did not notify the Davis-Besse Control Room of the 9:11 p.m. weather warning which was contrary to Administrative Procedures AD 1827.06 " Tornado." However, the Davis-Besse Nuclear Power Station Security Force did notify the Davis-Besse Control Room upon learning of the tornado from;the Ottawa County Sheriff's office. The apparent root cause is the Load Dispatcher's inadequate training in standard operating procedures as they apply to Davis-Besse.

(3) Corrective Action Taken And Results Achieved At 9:15 p.m. the Control Room Operators placed the control room ventilation system in the recirculation mode in response to the tornado warning. This action placed the Davis-Besse Nuclear Power Station in the same state of readiness as if the Load Dispatcher had notified the Control Room as required.

The failure of the Load Dispatcher to notify the Davis-Besse Control Room per AD 1827.06 has been brought to their attention per an intra-company memorandum dated June 24, 1986. This memo reinforced the requirements of AD 1827.06 to notify the Davis-Besse Control Room of any severe weather information as soon as it becomes available.

l (4) Corrective Actions To Be Taken To Avoid Further Violation p

Administrative Procedure AD 1827.06, " Tornado", has been changed to Emergency Procedure EP 4100, " Tornado." Annual

! training for the Load Dispatchers will be conducted on thn requirements of EP 4100.

(5) Date When Full Compliance Will Be Achieved l

l Full compliance was achieved on June 24, 1986 upon i

issuance of an intra-company memorandum to the Load l Dispatchers outlining their requirements of Procedure

! EP 4100 " Tornado." On August 26, 1986 the U. S. Weather j Service issued a tornado watch for Lucas County. The Control Room was adequately informed by the Load Dispatcher of this tornado watch.

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D:ckst Ns. 50-346 License No. NPF-3 Serial No. 1-673 September 26, 1986 Page 3 Violation 2: Technical Specification 6.2.3 requires that no person performing safety related work should be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period or more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period, or more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any seven day period without authorization and the basis for granting the deviation by the super-intendent.

Contrary to the above, between June 7 and July 11, 1986 two I & C personnel worked more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, 15 individuals worked more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period, and 22 individuals worked more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a seven day period. (86016-06)

This is a Severity Level IV Violation (Supplement 1).

Response: (1) Acceptance Or Denial Of The Alleged Violation Toledo Edison admits the alleged violation.

(2) Reason For The Violation During the period of June 2, 1986 through July 18, 1986, Toledo Edison was subjected to a strike by its bargaining unit personnel. As a result of the strike, plant mainten-ance activities were being conducted by management personnel. This group of individuals included Technical Support, Training and other staff personnel who are not normally considered " key maintenance personnel." These j individuals had not been specifically trained in the requirements of the affected Technical Specification section. Additionally, Station Procedure AD 1800.01 l

entitled " Control of Overtime for Key Personnel" had not yet been formally issued and implemented.

(3) Corrective Action Taken And Results Achieved Toledo Edison has taken the following actions:

j 1. A list of all individuals considered to be key I maintenance personnel was compiled and those individuals who had exceeded the maximum allowable hours were identified.

A review of the work performed by these individuals j was conducted to identify any errors or discrepancies.

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Docket No. 50-346 License No NPF-3 Serial No. 1-673 September 26, 1986 Page 4 A review of the work performed by the affected individuals did not identify any errors or discrep-ancies in the work. The review included assurance that critical and important work steps had been verified as correctly completed by Quality Control personnel.

2. Maintenance Department management personnel were immediately made aware of the Technical Specification requirements pertaining to control of overtime.

3. AD 1800.01, " Control of Overtime for Key Personnel" was approved for issuance on July 29, 1986.

4. Working hours for key maintenance personnel have been restricted to that identified in the Technical Specifications since the discovery of the violation.

5. A review was conducted to identify possible past generic or recurring problems in this area. No such problems were identified.

(4) Corrective Steps Taken To Avoid Further Violations The full implementation of AD 1800.01, including training of Maintenance Department management personnel, will preclude further violations of this Technical Specification requirement.

(5) Date When Full Compliance Will Be Achieved Full compliance will be achieved by September 30, 1986 with the completion of training of Maintenance Department management personnel on the requirements of AD 1800.01.

Very truly yours, W LLUHQ y

JW:DJS:p1f cc: DB-1 NRC Resident Inspector

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