ML20042F095

Responds to Violations Noted in Insp Rept 50-346/90-02. Corrective Actions:Maint Technician Involved in Tagging Violation Counseled on Importance of Procedure Adherence W/ Regard to Personnel Safety

ML20042F095
Person / Time
Site:	Davis Besse
Issue date:	04/30/1990
From:	Shelton D TOLEDO EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
1-915, NUDOCS 9005070219
Download: ML20042F095 (3)

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TOLEDO EDISDN

' A Centerar Erergy Conwany DONALD C. SHELTON -

Vce Present~Nui.iaer Docket Number 50-346 " * * *

• License Number NPF-3 Serial-Number 1-915 i

April-30, 1990 United States Nuclear Regulatory Commission "

Document Control Desk Vashington, D. C.- 20555 Subj ec t : Response to Inspection Report 90002 Gentlemen:

Toledo Edison'(TE) has received Inspection Report 90002 (Log Number 1-2262) l and provides the folloving response.

- Requirement " Technical Specification 6.8.1.a requires that,vritten proc'edures ,

be established, implemented, and maintained covering the  !

activities recommended in Appendix A of Regulatory Guide 1.33, ,

November 1972. Appendix A of-Regulatory Guide 1.33; recommends-- I procedures be used for equipment control (e.g.,: locking and-tagging) and states that. maintenance which can affect the performance of safety-related equipment:should be-performed in-accordance with written procedures or docum G ted instructions j appropriate to-the. circumstances."

J The two examples cited as violations of these requirements'are paraphrased below.

Violation o0002-07A Procedure DB-0P-00015, Rev. O, " Safety Tagging," dated June 26, l 1989, is required to be implemented for equipment control,(e.g;,

locking and tagging).

Contrary to the above, the required procedure was not implemented  !

in that; on January 9, 1990, work was perforud on:the Emergency 1 Diesel Generator Number 1 (EDG) Motor Driven _ Circulating 4 Lubrication Oil Pump without implerenting the applicable i requirements of Procedure DB-0P-00015. .

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9005070219 900430 3 PDR ADOCK 05000346 ,

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THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE . TOLEDO. OHIO 43652

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Docket Numbcr 50-34'6

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License Number NPF-3 Serial Number 1-915 ,

Page 2 Response Acceptance or Denial of the Alleged Violation Toledo Edison acknowledges the alleged violetion.

Reason for the Violation On January 9,1990, Preventive Maintenance- (PM) Number 0723 was being performed for EDG Number 1. The instructions utilized during the performance of PM 0723 are included on a continuation sheet for-the_PH Vork Order. Step 5.16 of the continuation sheet requires the user to stop the pumps (which are listed individually) and visually check the flexible coupling for wear.

The maintenance technician performing this task interpreted the step to include moving the flexible coupling by-hand. Prior to '

performing the check of the flexible coupling for the motor driven circulating lubrication oil pump, the motor-vas deenergized at the request of the EDG system engineer. '" Danger Do Not Operate" (DNO) tags had been provided for electrical isolation of two additional lubricating oil pumps covered under step 5.16, hovaver; no safety ,

tagging was provided for the pump in question. The circuit isolation method used by the maintenance technician for personnel-protection was not authorized by the Safety tagging procedure ,

(DB-0P-00015). This violation is: attributed'to personnel error. I Corrective Action Taken and Results Achieved The maintenance technician involved in the t'agging violation was-counseled on the importance of procedure adherence with regard to personnel safety. - Additional personnel involved in the performance of PM 0723 verc also reminded of the procedure requirements regarding safety tagging.

Actions to Prevent Recurrence.

A safety bulletin was issued to all station personnel on April 25, 1990 to reinforce the need for adherence to safety ,

tagging requirements. The safety bulletin included a summary of recent events involving safety tagging concerns.

Violation 90002-07B: Procedure DB-MN-00005 Rev. O, " Housekeeping Controls," dated August 8, 1988, is required to be implemented whenever work on open safety-related systems could result in foreign materials entering safety-related systems and affecting the performance of safety-related systems.

Contrary to the above, DB-MN-00005 was not implemented in-that; on

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January 9, 1990, a pocket comb was found inside EDG Number 1, indicated that at some previous and unknown time work had been performed on EDG Number 1 without implementing the applicable requirements of Procedure DB-MN-00005. S

m Dockst Nunber 50-346' License Number NPF-3 Serial-Number 1-915 Page 3 Responses Acceptance or Denial of the' Alleged Violation Toledo Edison acknowledges the alleged' violation I Reason for the Violation On January 9, 1990, during the performance of a PM for EDG 1-1, a pocket comb was found in the upper camshaft area. The comb was-located in an area which could not have caused the EDG to become inoperable if_it had not been found. As stated in Inspection '

Report 90002-the-source of the comb was not determined. The discovery of the~ comb was documented-by the EDG system engineer'on Potential _ Condition Adverse to. Quality Report (PCAGR) 90-0011.

The evaluation from PCA0R 90-0011 determined that this was the first time that' foreign material had been found in the upper camshaft area'of the diesel. No. foreign' material was found during-a subsequent inspection of EDG 2. ,

Corrective' Action Taken and Results Achieved The comb was promptly removed from EDG11 upon discovery. . A

. subsequent inspection'of EDG 2 confirmed that a similar condition- r did not exist -

Actions to Prevent Recurrence The existing administrative controls contained in Procedure DB-MN-00005 adequately address hounekeeping requirements for vork on open safety related systems. The presence of foreign material in EDG 1 was determined to be an isolated. occurrence and no further corrective actions vero deeeed necessary. ,

When Full Compliance Vill Be Achieved '

Full compliance was_ achieved on February.7, 1990 vith satisfactory completion of the inspection for EDG 2.

If you have any questions regarding this matter, please contact Mr. R. V. Schrauder, Manager - Nuclear Licensing,_at (419) 249-2366. '

Very truly yours,

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RWG/ssg cc: P. M. Byron, DB-1 NRC Senior Resident Inspector 'j A. B. Davis, Regional Administrator, NRC Region III T. 'V. Vambach, DB-1 NRC Senior Project Manager J

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