IR 05000346/1975002
| ML19319B582 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 03/05/1975 |
| From: | Kister H, Knop R, Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19319B580 | List: |
| References | |
| 50-346-75-02, 50-346-75-2, NUDOCS 8001270106 | |
| Download: ML19319B582 (6) | |
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U. S. NUCLEAR REGULATORY COMMISSION I
0FFICE OF INSPECTION AND ENFORCEMENT
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REGION III
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l Report of Operations Inspection l
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IE Inspection Report No. 050-346/75-02
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Licensee:
Toledo Edison Company l
Edison Plaza l
300 Madison Avenue Toledo, Ohio 43652
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Davis-Besse Nuclear Power Station Licensee No. CPPR-80 j
Unit 1 Category:
B
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Oak liarbor, Ohio i
Type of Licensee:
,
Type of Incpaction:
Announced, Routine
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t Dates of Inspection:
February 13 and 14, 1975
Dates of Previous Inspection:
January 22 - 24, 1975 (Construction)
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Principal Inspector:
R. D. Martin
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f Accompanying Inspector:
11. B. Kister
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Other Accompanying Personnel:
None Reviewed By:
R. C. Knop
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Senior Inspector (Date)
Reactor Operaticus Branch
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'd SUMMARY OF FINDINGS Enforcement Action A.
Noncompliance
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No items of noncompliance with NRC requirements were identified during the inspection.
B.
Deviations No deviations were identified during the inspection.
Licensee Action on Previously Identified Enforcement Matters Not applicable.
Design Changas:
Not applicable.
Unusual Occurrences:
No unu'ual occurrences were identified.
Other Significant Finding A.
Current Finding The licensee has now completed and approved approximately 50% of the
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procedures identified for station operation (not including annunciator response procedures).
B.
Status of Previously Reported Unresolvnd Items Not covered by this inspection.
Management Interview A.
The following persons attended the management interview at the con-clusion of the inspection:
Toledo Edison Company J. Evans, Station Superintendent W. Green, Assistant to Station Superintendent B. Beyer, Maintenance Engineer D. Briden, Chemist and Health Physicist L. Stalter, Technical Engineer W. Mills, Assistant Engineer K. Cantrell, QA Engineer
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Babcock and Wilcox E. Michaud, Test Program Manager i'
Bechtel Start-up M Parenteau, Project Start-up Engineer R. Burdick, Start-up Engineer B.
Matters discussed and comments were as follows:
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1.
The inspectors described their review of the procedure being l
used by the station for system turnover from the construction phase and noted that they have no further questions on this
matter at the present time.
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The inspectors described their review of the status of the flushing program.
They noted that while they recognize that l'
development of individual system flushing proccdures, will the controlling procedure (AD 1835.00), which governs the undergo review by both QA and the Station Review Board (SRB),
l they question the decision to develop the implementing procedures
i for safety related systems without SRB review of the procedures j
or test results.
This item will be resolved at a later date.
The licensee noted that this method uas chosen to keep the (s)
review workload of the SRB at a reasonable level.
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3.
The inspectors noted that they had been informed of the current
j status of the start-up test program and had reviewed the proposed method for monitoring the status of individual tests.
l No deficiencies were noted, and the inspectors wish to continue l
j to be kept informed of future developments in the start-up j
program.
4.
The inspectors noted that they had briefly reviewed the methed by which QA audits of operating activities were conducted and l
that this area would be the subject of a later inspection.
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REPORT DET/sILS Persons Contacted The following persons, in addition to individuals listed under the
Management Interview section of this report, were contacted durin the inspection:
Toledo Edison Company, S. Hall, Shift Foreman Bechtel Start-up T. Reddaway, Senior Start-up Engineer Babcock and Wilcox A. Mercado, Test Program Scheduler Results of Inspectien n
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1.
System Turnover t
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The inspector reviewed the Toledo Edi. son Program for interim system turnover from construction.
The review included system definition, system scoping, boundaries, the mechanics for ensuring that systems are in fact complete as defined by the system release, methods for handling partial systems turnovers, control of outstanding work items, extent and depth of review by the Toledo Edison Technical Staff prior to acceptance including criteria used for accepting systems with outstanding work to be done and System Tagout.
The Toledo Edison Start-up Coordinators responsibilities were also reviewed and included the Bechtel Start-up Organization and interface with regard to coordinating the system turnover for Toledo Edison Company.
There are no outstanding comments regarding the System Turnover Program at this time.
2.
Flushing Program The status of the flushing program was revicwed.
A flushing schedule had been established which coordinates the expected system turnoven, as given by the construction schedule and the needs of the start-up test program.
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The individual flushing procedures for specific systems are developed under the guidelines established in administrative procedure AD i
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1835.00, " Instructions for Flushing Program".
The draft version of I
this procedure was reviewed by the inspectors.
At the present time, the SRB has recommended the procedure for approval by the Station Superintendant. The procedure is currently under review by the QA organizatior.
The acceptance criteria for system cicanliness l
used in the procedure and the test methods are based on:
I Babcock and W.'lcox Field Specification II-2 ANSI N45.2.1 - 1973 Regulatory Guide 1.37 a
No deficiencies or deviations were noted in the review of this
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procedure.
The inspectors noted that while the systen flushing procedures would be developed under the controls of AD 1835.00, these' procedures themselves, and the results obtained, will not undergo approval or
l review b; the SRB when a safety related system is involved.
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inspectors informed the licensee that they question this decision,
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and that this matter will be resolved at a later time.
The licensee clarified an aspect of'the program for the inspectors I
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by stating that Toledo Edison employees will witness and be respon-
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I sible for the final acceptance of test results.
This question was
raised because of the use of Bechtcl. Start-up Engineers as the
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j flushing engineers for implementation of the program.
l The inspectors noted that a flushing procedure on a non-safety l
related system uas in use.
CP 6014.01, " Turbine Building Cooling Water System", has been partially implemented as of the time of the j
inspection. The licensee was informe.1 that implementation of a
l flushing procedure.on a safety relatei system prior to final approval
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of AD 1835.00 would be considered an !. tem of noncompliance.
The j
licensee stated that he was aware that such would be the case, and that no flushing of safety related systems will occur until AD J
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1835.00 has received final approval.
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3.
9tatus of Test Program
The inspectors reviewed the current scatus of the Test Program and
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have no further questions at this time.
(See Paragraph 3 of Manage-l i
ment Interview of this report).
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Tciedo Edison Quality Assurance Audits i
l The inspectorn briefly reviewed the results of an audit (No. 320)
conducted on the operating staff activities by a Quality Assurancu
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audit team.
It was noted that the audit method used involved:
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t (a)
Identifying audit team members
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(b)
Identifying specific areas to be audited i
(c)
Identifying the basis for evaluation of the audit finding l
If an audit finds that an items does not meet the requirements of i
the criteria against which it is evaluated, an Audit Finding Report
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(AFR) is issued for that item.
This AFR identifies:
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(a) The reference on which the findings is based i
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The details of the finding (c) The recommendations of QA to the affected organization as to the action to be taken The AFR also indicates a scheduled completion data and the individual responsible for any corrective action.
The AFR is then sent to the responsible party for action.
Any corrective action to be taken is iadicated on the AFR by the
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responsible party and returned to QA for their review, which is
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also documented on the AFR.
It was noted by the inspectors that no
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system exists for keeping track of the status of AFR's to assure I
that the responses and reviews are occurring as scheduled.
The i
licensee stated that he would consider the developuent of a system l
to accomplish this.
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The inspectors noted that this audit system and its results would l
be reviewed in greater detail during a later inspection.
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