ML20112A032

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Responds to NRC Re Violations Noted in Insp Rept 50-346/84-22.Corrective Actions:Procedures Pp 1102.01 & ST 5092.02,re pre-startup Checklist & Core Alteration Prerequisite,Modified to Include Tech Spec 3.9.12
ML20112A032
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 02/15/1985
From: Crouse R
TOLEDO EDISON CO.
To: Norelius C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
1-498, NUDOCS 8503180134
Download: ML20112A032 (5)


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Docket No. 50-346 gg %sm EDISON rotsoo License No. NPF-3 Serial No. 1-498 N$ce

**8' February 15, 1985 Mr. C. E. Norelius, Director.

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Division of Reactor Projects United States Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Norelius:

Toledo Edison acknowledges receipt of your January 17, 1985 letter (Log No. 1-1098), and enclosures, Appendix A, Notice of Violation, and Inspec-tion Report No. 50-346/84-22 (DRS).

Following an examination of the items of concern Toledo Edison herein offers information regarding these items:

1.

Violation:

Technical Specifications 4.9.12.1 and 4.6.5.1 state in part:

"The emergency ventilation system servicing the storage pool area shall be demonstrated operable at least once per 31 days whenever irradiated fuel is in the storage pool."

contrary to the above, on November 20, 1984, during core alterations, the emergency ventilation system servicing the storage pool area had not been demon-strated operable since August 19, 1984. The second emergency ventilation system was not operable because of maintenance.

This condition was promptly corrected by the licensee following identification by the NRC inspector.

This is a Severity Level V violation (Supplement I).

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8503180134 850215 PDR ADOCK 05000346 G

PDR THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO. OHIO 43652 FEB 191985 g,j, O

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' D:ckst -Ns. 50-346

" License.No. NPF-3

' Serial No. 1-498,

s February '15, 1985 Page 2-

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Response: - (1) Corrective action taken and results achieved.

On November 20, 1984, Davis-Besse Nuclear Power Station.. Unit No. 1.was entering Mode 6, after being defueled-since October 7, 1984. Fuel move-ment had already begun when it was identified by

the'NRC inspector that:the operability of the Emer-gency Ventilation System (EVS) servicing the Spent

. Fuel Pool storage area had not been verified oper-able'per Technical Specification 4.6.5.1.a by the-performance of the EVS Monthly Test, ST 5067.01, in the previous 31 days. Technical Specification 3.9.12 requires that with one EVS train inoperable, the other train must be operable per Technical Specification 4.6.5.1 and 4.9.12.

All fuel movement.was stopped and ST 5067.01 was completed for EVS Train 2.

There were no test de-ficiencies upon completion of testing EVS Train 2.

' Additionally, this event was reported under 10 CFR 50.73(A)(2)(1)(B) as an operation or, condition pro-hibited by: Technical Specification in Licensee Event Report (LER)84-016.

(2)_ Corrective action'taken to avoid further noncompliance.

Procedures PP 1102.01,' Pre-Startup Check List. and ST 5092.02, Core Alteration Prerequisite and Periodic Checks, were modified to include Technical Specifica-tion 3.9.12, as a prerequisite to Mode 6 entry and

. fuel movement 'in the spent fuel pool storage. area.

Additionally, all mode checklists in PPJ1102.01 were reviewed against Technical Specifications.

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The Surveillance Test Schedule System was updated to include EVS testing in Modes 5 and 6, along with Modes I through.4..Also, the Surveillance Test Schedulo

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System is being reviewed to determine if there are any

.s additional discrepancies with regards to scheduling, per Technical Specifications.

'(3) Date when full compliance will be achieved.

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~ The review of-the Surveillance Test Schedule System 4

will be completed by March 29, 1985.'

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.c D:ckst'Na.L50-346 License No. NPF-3 LSerial No.-1-498 February-15, 1985 f

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2.

' Violation:

. Technical' Specification 3.9.2~ states'in part: '"Each source range neutron flux monitor shall be demonstrated i operable within eight - (8) hours ' prior to the-initial -

start of core operations".

4 Contrary to the above, on November 20, 1984, the licensee was conducting core alterations'and the

. audib?.e indication portion of'the source-range neutron flux monitors-was discovered to be inoperable. Sur-

-veillance Test 5091.01,~ Revision 9. " Source Range-Functional Test," that was performed to demonstrate

. source-range neutron flux monitor operability was-determined to be inadequate.

This condition was promptly corrected by the licensee following-identification by the NRC inspector.

This in a Severity Level IV violation-(Supplement I).

Response: (1). Corrective' action taken and results achieved.

Upon determining that the NIMBIN audible source range

' indicator was inoperable, core alterations were sus-pended. ' Troubleshooting identified a defective rate meter module on;the-NIMBIN assembly. Under Mainte-nance Work Order (MWO)- 1-84-0214-02, the defective.

module was replaced.

Additionally,- this event was reported under 10 CFR

. 50.73. in' LER 84-018. -

'(2) - Corrective-action taken to avoid.further noncompliance.

A temporary. modification (T-8473) was made to ST 5091.01,

~ Source Range Functional Test,-to provide a functional test of the NIMBIN audible indication..A modification was also made to ST 5099.01,' Miscellaneous Instrument

- Shift 1 Check, to allow for proper comparison of NIMBIN

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to Reactor Protection System indication.

s(3) Date when full compliance will be achieved.

- Full compliance with corrective action has been com-pleted.

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Dockat No. 50-346 9-

' License No.-NPF-3-.

1 Serial No.-1-498:

' February 15, 1985-Page 4 3.

- Violation: -

J10 CFR 50, Appendix B, Criterion XII, states in part:

" Measures shall be established to assure that instru-ments used in-activities affecting quality are properly calibrated at specified periods to maintain accuracy within necessary' limits." Procedure MP 1410.03, Revision 10, " Maintenance Test Equipment Calibration,"

states in Section 6.5:

"A sticker shall be securely attached to all test equipment showing the due date of the next calibration."

Contrary to the above, the following examples of in-adequate use and control of Measuring and Test Equip-s ment (HTE) were identified:

a.-

An uncalibrated piece of MTE was used to perform ST 5084.01,' Revision 10, " Station Batteries Weekly Surveillance Test",

b.

-Four-uncalibrated hydrometers were found lying in the Electrical MTE' storage' locker on its -

- "IN-CAL" shelf without-calibration. stickers.

Both conditions were promptly corrected by the licensee

- following identification by the NRC inspector.

This is a Severity Level IV violation (Supplement I).

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bc Response:.(1) Corrective action taken and.results achieved.

Procedure ST 5084.01,= Station Batteries Weekly Sur-

'veillance' Test, was reconducted using a calibrated digital thermometer. There were'no test' deficiencies

- upon completion of the surveillance test.

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The four uncalibrated' hydrometers were removed from

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s the "In-Cal"'shelfs statused as out of calibration, t

and placed on-the "Out-of-Cal" shelf.

CorrectiveactiontakentoavoihLfurthernoncompliance.

-(2)

ST 5084.01, Station Batteries Weekly Surveillance _.

Test, will' be modified-to require the.use of digital thermometers and to verify 'a properly calibrated. in-strument prior-to conduct of the surveillance test.

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Drcket N3. 50-346-License No.-NPF-3 Serial No. 1-498 February 15, 1985 Page'5 Maintenance shop personnel were counseled on the calibration and storage requirements for mainte-nance and test equipment. A Maintenance Foreman ihas been assigned to control all maintenance and Ltest equipment.

(3) Date when full compliance 'will be achieved.

Procedure ST 5084.01 will be revised by April 1, 1985.

-Very truly yours, ffk = : - -

RPC:SGW:nif cc:.DB-1 NRC Resident-Inspector

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