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On November 20, 1984 at 0415, Davis-Besse Unit I was entering Mode 6 after beingdefueled since October 7, 1984. Fuel movement had already begun when it was notedby an NRC inspector that the operability of the Emergency Ventilation System (EVS)servicing the Spent Fuel Pool (SFP) storage area had not been formally verified.Technical Specification (TS) 3.9.12 requires that with one EVS train inoperable,the other train must be operable per TS 4.6.5.1 and TS 4.9.12 and be operatingwhenever irradiated fuel is in the SFP. When discovered, EVS train 1 was inoperableand EVS Train 2 was running, but was not proven operable per TS 4.6.5.1.a by theperformance of the EVS Monthly Test ST 5067.01 in the previous 31 days. SinceTS 3.9.12 was a prerequisite for fuel movement in the SFP, all fuel movement wasstopped until ST 5067.01 could be completed. Subsequent actions prior to fuelmovement was to check the PP 1102.01 Pre-Startup Checklist and ST 4092.02 CoreAlteration Prerequisite and Periodic Checks, to ensure all other necessary TechnicalSpecifications were being met. It was also noted that the computerized test schedulewas in error in that ST 5067.01 not only satisfied TS 4.6.5.la (applicable in Modes 1thru 4), but was also required for TS 4.9.12.1 which is applicable in all modes.

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This event is being reported under 10CFR50.73 (A)(2)(1)(B) as an operation or conditionprohibited by Technical Specifications.

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Description of Occurrence: On November 20, 1984 at 0415, Davis-Besse Unit I wasentering Mode 6 after being defueled since October 7, 1984. Fuel movement hadalready begun when it was noted by an NRC inspector at 0700 on 11/20/84 that theoperability of the EVS (VC) servicing the SFP(ND) storage area had not been formallyverified. Four assemblies had been moved as documented in the Unit Log. TechnicalSpecification (TS) 3.9.12 requires that with one EVS train inoperable, the othertrain must be operable per TS 4.6.5.1 and TS 4.9.12 and be operating wheneverirradiated fuel is in the SFF. EVS train 1 was inoperable due to maintenance onits damper and EVS train 2 was running. EVS train 2 though had not been provenoperable per IS 4.6.5.la, since 8/19/84.

TS 4.6.5.1.a requires operability to be demonstrated by initiation of EVS from theControl Room with flow thru one High Efficiency Particulate Air (IIEPA) filters andcharcoal adsorbers for a period of at least 15 minutes. ST 5067.01 meets therequirements of TS 4.6.5.la.

This event is being reported under 10CFR50.73 (a)(2)(1)(B) as an operation or- condition prohibited by Technical Specifications.

Designation of Apparent Cause of Occurrence: The plant procedures PP 1102.01Pro-Startup Checklist and ST 5092.02 Core Alteration Prerequisite and PeriodicChecks did not identify TS 3.9.12 as a prerequisite for fuel movement in theSFP storage area and for the Mode 6 entry. The computerized test schedule and ST5067.01 EVS Monthly Test did not identify the EVS Monthly Test as satisfyingTS 4.9.12.1 which requires EVS testing whenever irradiated fuel is in the SFP(all modes). These documents used as checks prior to fuel movement and Mode 6entry to aid the Shift Supervisor to determine if the plant is in the properstatus for fuel movement after being defueled.

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Analysis of Occurrence: The requirements for the EVS servicing the SFP storage areato be operating or operable, ensure that if radioactive material is released from anirradiated fuel assembly it will be filtered through HEPA filters and charcoaladsorbers prior to discharge to the atmosphere. The operability of this sytem andthe resulting iodine removal capacity are consistent with the assumptions of theSafety Analysis.

Even though EVS train 2 testing was not documented per ST 5067.01 in the previous31 days, the train was started from the control room and run for approximately 3hours on 11/19/84 which is documented in the Unit Log. EVS train 2 was also startedon 11/20/84 at 0405 hours from the control room and refueling activities did not commenceuntil 0415 as documented in the Unit Log. However, An indication of flow through the -

HEPA filters and charcoal adsorbers was not verified formally either time.

Fuel movement was stopped at 0700 on 11/20/84 and ST 5067.01 was satisfactorilycompleted at 0730 on 11/20/84 for EVS train 2. Even though EVS train 2 had not beenproperly tested, it was running and could have performed its safety function asdemonstrated by the completion of ST 5067.01 for EVS train 2 after fuelcovement was stopped. There were no test deficiencies when EVS train 2 was tested.

Corrective Action: Immediate action was to stop all fuel movement and complete ST5067.01 for EVS train 2. Plant procedures PP 1102.01 and ST 5092.02 were modified toinclude TS 3.9.12 as a prerequisite to Mode 6 entry and fuel movement in the SFPstorage area. The computerized Surveillance Test (ST) program was updated toinclude EVS testing in Modes 5 and 6, along with modes 1 thru 4. EVS testing inModes 5 and 6 may be limited though to a prerequisite for fuel movement within the'SFP storage pool or crane operation with loads over the SFP storage pool. Above andbeyond this, all mode checklists in PP 1102.01 have been reviewed against TechnicalSpecifications. The ST computer program is also being reviewed to determine ifthere are any other discrepancies with regard to scheduling per TechnicalSpecifications.

Failure Data: No similar occurrences have been reported.

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Report No: NP-33-84-17 DVR No(s): 84-175

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Dacember 26, 1984Log No. K84-1392File: RR 2 (NP-33-84-17)

Docket No. 50-346License No. NPF-3

U. S. Nuclear Regulatory CommissionDocument Control DeskWashington, D. C. 20555

Gentlemen:LER No. 84-016

Davis-Besse Nuclear Power Station Unit iDate of Occurrence: November 20, 1984

Enclosed is Licensee Event Report 84-016 which is beingsubmitted in accordance with 10CFR50.73, to provide 30 day writtennotification of the subject occurrence.

Yours truly,

ffw&-Stephen M. QuennozPlant ManagerDavis-Besse Nuclear Power Station

SMQ/bec

Enclosure

cc: Mr. James G. Keppler,Regional Administrator,USNRC Region III

Mr. Walt RogersDB-1 NRC Resident Inspector

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| \THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MAOiSON AVENUE TOLEOO. OHIO 43652 ' l

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