IR 05000346/1975005
| ML19319B549 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/08/1975 |
| From: | Knop R, Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19319B540 | List: |
| References | |
| 50-346-75-05, 50-346-75-5, NUDOCS 8001270083 | |
| Download: ML19319B549 (12) | |
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O U. S.
- UCLEAR REGULATORY CO'01TSSIO::
OFFICE OF ISSPECTIO'; A'?D E::TODCE'iE:;T
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i REGIO:. I!I Report of Operations Inspection n' n'
IE Inspection Repor: No. 030-346/75-05 D
D QQ Licensee Toledo Edison Company
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Edison Plaza
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_.~3 300 'iadison Avenue Toledo, Ohio 43652 Dr.vis-Besse ::uclear Pcuer Station License :?o. CPPR-50 Unit 1 Category S
Oak Hzrbor, Ohio Type of Licensee:
Pi!R (B&I7) - 906 l.le Type of Insp,2 tion:
Unannounced, Routine Dates of Inspecticn:
March 12, 13 and 14, 1975 Dates of Previous Inspection:
March 3 - 7, 1975 (Construction)
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Principal Incpector:
R. D. Martin
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(Date)
l Accompanying Incpector:
!!cne Other Accompanyin'., Personnel:
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Revieued T,y:
R. C.
Knop
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Senior Inspector O
(bate)
Reactor Operations Branch
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SUP ARY OF FINDINGS t
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l Enforcement Action
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A.
Items of Noncernliance i
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No items of noncompliance uith NRC requiranents were identifled during the inspection.
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B.
Deviations j
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Contrary to Section 17.2.11 of the FSAR, the licensee approved f
the results of test procedure TP0401.01.1, and phases I and IT l
i of TP0401.05.2 and TPO'+01.06.2 vithout the review of (1)
l documentation of test results and (2) the review of test
results by appropriate oersonnel by the Operations Quality i
Assurance Engineer.
(Paragraph 3.a and 3.b, Report Details)
2.
Contrary to Section 17.2.11 of the FSAR, test procedure TPO401.Ol.1
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was utilized to conduct a preoperational test and the test l
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procedure was not revieued and appraved by the Manager o#
Quality Assurance.
(Para;;raph 3.a, Report Details)
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3.
Contrary to Section 17.2.11 of the FSAR, a surveillance test
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S procedura (ST5002.02) i:as revised and approved for use tritboat
l the approval of the hnager of Ouality Assurnace.
(Paragrar,h 4, Report Details)
4.
Contrary to Section 17.2.2.2.1 of the FSAR, adninistrative l
procedures covering quality affecting activities (AD 1828.03, AD1828.0!., and ADIS28.07) were approved for use without the review and approval of the Manager of Quality Assurance.
(Paragraph 6, Report Details)
i These deviations were identified by the inspector.
Licensee Act.fon on Previous 1v Identified Enforcement Matters j
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Not applicabic.
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l Design Changes:
Not applicable.
Unusual Occurrences:
No unusual occurrences were identified.
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Other Sinnificant Findings
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A.
Current Findinrs I
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The licensee is currently attempting to conplete all procedures
identified for station operation (except annunciater response procedures) by mid su.mer of 1975.
2.
All precperational testing has been suspendcd at the present time pending approval of revisions to the admi.nistrative proceduren which govern the cor. duct of the testing program and I
the flush'.ng program.
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B.
Status of P eviousiv Reperted Unresolved Items I
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Inspection Repcrt 1o. 050-346/74-06 cummarized, in the :tana;;enert Interview Section, certain comnitments made by the licen.see regarding preventing of the usa of incomplete procedures.
The
l licensee has nou developed a methed, with appropriate procedurt.1 controls, for preventing the use of station procedures with blank spaces.
The inspector has no further questions on this natter.
2.
Inspection Report :so. 050-346/74-09 surocrired, in the 'Mncccr:mt Intervieu Section, cer h in cornitrents t,cde by the licenro'
with regard to k nrion Review Enard rcvicu of test and proceduce classirications.
As surccarizci. in Pare;raph 3.0. c E ti
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report, this commitment was satisfied on Decc.ber 30, 1974
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3.
Inspection Report :o. 050-346/75-02 surmiarizcd, in the 'hnat,enent i
Interview Sectica, certain concernc cf the inspector over the j
adequacy of reviews to be given flu.shing procedures far safety i
related systems.
By action of the Statica Review Coard su:carized l
in this report, the Board has elected to review these procedurcs.
j The inspectccs consider this natter resolved.
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l Managemort Interv_si l
A.
The following persons attended the management interview at the conclusion of the inspection:
Toledo Edison Corn.an.
L. Roe, Vice President, Facilities Development J. Evans, Statien Superintendeat J. Lenardson, OA ::anager T. Murray, Operations Engineer W. Green, /ssistant to Station Superintendent o
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D. Briden, Chemist and Health Physicist
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l J. Lingenfelter, Assistant Engineer
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l B. Beyer, Maintenance Engineer L. Stalter, Technical Engineer i
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Babcock and L'ilcox j
j E. Michaud, Test Program Manager i
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B.
Matters discursed and connents were as follows:
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1.
The inspectors inforced the licensee that a review of certain i
activities currently in progress at the statica against commit-l cents made in Section 17.2 of the FSAR disclosed several I
deviations from those cc=mitments.
For exanple:
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a.
Test results are not being reviewed as described in
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i 17.2.11.
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Test procedures are not being reviewed as described in
17.2.11.
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Some administrative procedure.; are not being reviewed as described in 17.2.2 2.1.
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The inspector requested a connirnent from the licensee that a
i mothed be established to assure that administrative and tain-t i
tenance procedures which require Manager of Quality Assursnce
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review and approval an indicatc-d in Section 17.2.2.2.1 and i
17.2.2.2.2 of the FSAR will receive that aoproval prior to a
j implementation of that procedure.
The licensee agreed to
provide such a method.
The inspector indicated that the
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liccncee vill be expected to respond to all these deviations j
and the adequacy of the response will be evaluated at that l
time.
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2.
The inspector informed the licensee that he had reviewed
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selected minutes of the Station Review Board and no deficiencies were observed.
3.
The inspector su==arized his revicw of the Test and Procedure Index.
(Paragraph 2, lleport Details)
4.
The inspector su=tarized his revieu of completed portions of test procedures TF0401.01, 0401.03, and 0401.06.
(Paragraph 3, Report Details)
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5.
The inspector summarized his revieu of the surveillance conducted on the 3451:V Switchyard 125tDC system since April 1974.
(Paragraph 4, Report Details)
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REPCRT DETAILS
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Persons Contacted _
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l The following persons, in addition to those listed under the .nagement l
Intervieu section of this report, were contacted during this inerccrion.
l To1edo Edison Commonv
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L. Grimes, Inspection Engineer J. Orkins, Inctrument Engineer i
D. Dean, Office Supervisor o
j F. Johnson, Malatenance Foreman
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Babcock and 5!ilcon
A Mercado, Test Scheduler i
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Bechtel Startun
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i R. Burdich, Startup Engineer
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Resulti, of Inspection i
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Station Revfew Bo;rd / F'M Minute. s The in:spector reviet.ed the minutes of the SR2 for c.neting '. x.ber 56 l
(June 18,1974) tv 5_
O! arch 7, 1975).
For the meetings revie;ed,
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the apprapriate r.embership was present and quorum. requironents: were s a i. f.s f i e d.
The following actions tal:en by the SRB are cen:sidered I
by the in.cpector to be of particular interest.
a.
Meeting 75 (November 19, 1974):
This was the meeting at which the SRL conducted its reviou of the Test and Proceduru Inden againct the requirements of Regulatorj Guider 1.33 and 3.6S with respect to areas which should he covered by operriting and test proceduces, respectively.
The inspector observcd no deficiencies as to the adequacy of their revicw.
The revieu
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indicated that certain areas were not covered by proceduces, and are to be provided.
The inspector uill revieu this tollowup action durin!; a later inspection.
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b.
Meeting 77 (December 10, 1974):
Durine this necting the SR,
reviewed the Tec,t and Procedure Inden (Carol Prog e.')
in-the purpose of acri;;ain:; classi fications to the tests and p: v.t.Jur;-
in that indev.
'i h i s review satisfie., the actionn to u m h t'w
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statina cermitted during the inspect:an of 'Jovember 23
7, 1974
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(Report ::o. 030-346/7'.-09).
An " Acceptance Test" classifienti.cn requires approval by the Station Superintendent of.the test
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The "Prcoperational Tast" i
I classification requires that the SRS revicu the pr,ceaure..nd the test results annd approval to the Statior Super:n-tendent as discussed in Section 14 of the FSA:1.
At this SRd
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36 previously unidentified procedures were classified as
" Acceptance Tests"
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(2)
29 previously unidentified procedures care crassified au
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"Preoperational Tests".
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61 procedures uere changed fron " Acceptance" to "Precpera-l tional" status.
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14 procedures were changed from "Prcoperational" to l
" Acceptance" status.
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The inspecter revieu of this reviced Test and Procedure Inde>
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is covered in Section 2 of this report.
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Meetin;; 82 (Januarv 7, 1973):
The S:E deciced that in its review of test results, that review uould it:clude :
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(1)
Test results l
(2)
Test deficiency sheets
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Chronolo;;ical test log
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Test summary report i
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d.
Meeting 92 (March 7, 1973):
The SnB decided that it would revies fluching procedures and results en flushing act!vitius l
perforn:ed on nuclear safety related systems.
rhis satisfLe, the concern expressed by the inspector over this t=tter du-inc
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the inspection of February 13-14, 1975 (Report No. 050-3',6/73-02).
j 2.
Inspector Review of Tent and Procedure Inder The inspector reviewed the test classifications assigned in the Test and Procedure Index using P.e ;ulatory Guide 1.63 as the basis for evaluation.
I!e found the folIcuing:
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The test of the Auxiliary Building ::en-radioactive Heating and Ventilating system is to be conducted as an 2cceptat.ce test.
The licensee was inforred that if portions of the s; stem, or
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any other ventilatica s:. sten has been desi; n._d to citigate the
consequences of a high energy line break, then a preaperatic 11 i
test classification should be considered.
This matter will be 1i resolved at a later date.
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b.
The test of the diesel fuel system between the outside fuel j
storage tank and the " day" tanks on the di.csel is classified
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as an acceptance test.
The icsue at the design classificatien of this system is currently an area of discussion betceen the licensee and the Divisicn of P.enctor Licensing.
The decision on the acceptability of the " acceptance" classificatio ', for the testing of this systca vill be deferred until the natter of design classification has been resolved.
c.
The liquid and solid waste disposal systems teuts are classificd
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as acceptance tests.
The licensee was informed that the i
inspector vill revicw this classification in the future.
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d.
The Reactor Vesuel Head Cooling Test is classified as na acceptance test.
This test refers to equipment uaee to provide air cooling to cables connected to the drive rechan; s t w nted
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on the vessel heed.
The acceptability of this test classifica-tion will be resolved at a later lue.
c.
The reactor coolant cheuistry test is classified as an accertunce
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test.
The licensee uas requested to furthe: cant ir the
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The licensee indicated that they
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l would concider the inspector's cot =wnts.
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The test of the Nitrcgen Purge and BlanPet System is classified
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as an acceptance test.
The inspector noted that sin a t h i:-
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system is used to pressurice the core flood ranks and stace
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the SI'B has classified the operatin; procedures for this system as nuclear safety related, the test of the syt w
should be reconsidered as requiring a prcoperctioncl test.
The licensee indicated that they would consider the ine p'e tor's ComlentS.
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Except for these si:: items, the inspector did not have any commente
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i The inspector then revir. red the classifications assigud to the l
station procedures listed in the index.
The revie'.' indicated tbc l
follouing procedures are not going to receiv: SPP revice v der tV l
present plans of the stution:
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The liquid waste disposal systems l
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The inte:; rated control systen l
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The feedwater system
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d.
The loss of condenser vacuum c:er';ency procedure l
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The explosion energency procedure i
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The toxic gas release energency precedure
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The ICS abnormal operation emergency procedure l
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Approximately une-half of the alacn response procedures i
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The fire protection systen periodic tests.
l The inspector inforn.ed the licensee that the above procedures are
covered by Section 6.8 of the standardiced Technical Specifications
as requiring review by the SKE.
'f oweve r, the inrpector understan k j
I that the lechnical Specificatian, for the statum are unde. r vii, c
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with the Divisinn of Reactor.icensing.
There Con, a final m.solutica of the rcelew to be aiven these procedureu wi.11 be defer: ed until
the requ.irenents of Section 6 of the ?cchnical Specificati.onw are established.
3.
Review of Test Pr oceriure Results, a.
The inspector revieved the cocpleted test procedure TPC401.01
"345KV Switchyard 125V DC System PreoperatLenol Test".
The procedure used was revision 1 dated February 15, 1974.
The conduct of the test was conpieted on December 23, 1974.
'Ihis test was conducted in phases, the early phases having been complcted in April, 197'.
The section ha d and SRB recernandel approval of the cempieted tect en February 4, 1975 and the Station Superintendent approved the test on February 10, 1975.
i There are no indications that the Operations Ouality i.ssurance l
En;;inee r (00AE) verified that the test results unre doc. rented i
and that the required analynes vere performed b: the p,roup responsible for preparation of the original procedure.
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verification la a cor.=itrent made by the license 2 in Section
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17.2.11 of the FSAR.
That section of the PSA:' (revised Decer.ber
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1974) also states that a test procedure will be apr> roved by l
l the "anager of Quality Assurance C a.'.) o r hi.s del o tt The
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portion of the test conducted in late Dece:hrr, 1974 utilitec i
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a procedure thich did not have the approval of the ".J.i.
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deviations f rom ccmi trent s nade to the '.3C.iare bi naght Ln l
the attention of the licensee.
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The inspector reviewed the miner modifications made to the procedure during the conduct of the test.
There were 8.inor i
modifications ande to the procedum, and these ac-e made in accordance uith the requirecents of the controllin:; administra-tive procedure (AD1S01) revision in effect at the time.
It
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was pointed out to the licensee that Criterion VI cf Append 1.x B to 10 CFR 50, requires that changes to documente vill undergo the same review as given the original documents.
Therefere, l
the minor codification procedure should be revised to reflect i
this requirenent.
The licensee stated that the procedure is
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undergoing entensive revision at the nr ant time and that this requirerent will be included.
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ncpector vill reviet the next revision of the ADIS01 series of procedures.
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The inspector found no technical deficiencies in the conduct of the test or the evaluation of the tcut results.
b.
The inspector reviewad the conpleted portions (Ph;ses I and
II; Phase III delayed until Hot Functional Testing) of tha following procedures:
TPO401.05.1 "4160V Preoperatienal Test" TP0401. C6.1 "480V Essential l'ni t Substatien Preoperationil Test" G
l The inspector found no techaicci deficiencies in the test
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results or the subsequent evaluation of results.
As in the j
above case, there was no indication of verification of (a)
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l test results docunentation and (b) result analysis by apprg riate l
personnel having been conducted by QA as committed to in Section 17.2.11 of the FSAR These test precedures ucre approved
by m?A and had recieved the reviers outlined in 17.2.11.
4.
Revieu of Survaillance Since the DC syste.a tested by TP0401.01 (Section 3.a of this report)
was conducted in April, 1974, the surveillance activities of the station on these batteries uas reviewod by the inspector.
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controlling preced"re for this activity is ST5002.02.
The data sheets on which the monthly readings of specific gravity and cell i
voltages are recorded were reviered for the folicwing dates:
April 17, 1974 October 21, 1974 i
May 17, 1974 November 19, 1974 June 21, 1974 January 2, 197f j
July 18, 19/4 Jr.c t..iry 2 3, 197; i
August 16, 1974 February 21, 1975 September 20, 1974 g
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The weekly test results for the same period.ere re"iewed on a j
samplin:; basis.
The inspector observed that the acceptance criteria t
I for the specific graviry of tha batteries s s changed on the data l
sheets for the period following May 17, 1974 L'p to the timu, the acceptable specific gravity range ::as 1. 200 1.220.
After May 17, i
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1974, the acceptable ranpe was 1.130 - 1.300.
Prior to that change, j
the surveillance test results indicated that the batterius were j
occasionally exhibitin;; a specific gravity cf 1.190 - 1.199, values
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below the acceptance criteria of 1.200.
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The inspector reviewed the master file for the procedure involved I
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a.
No inforir.ition was available in the file substantiating the i
basis fo_. the revision to the acceptancc cr it e r ia.
Discussions (
with the liccacec's representatives indicated a belief that j
j the change cas made based on verbal cormunications with the i
i manufacturer's representative.
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b.
No minor modificction request as receired by ADT.805.00 enisted
in the file which neuld jus'.if y a pracedure modification l
without a procedure revision.
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l The licensee was informed that changes ir. acceptance criteria in I
surveillance tests r.ast he vic,ted as major acdificaticas and c.ust be substantiated by appropriate :iccumentation and revicu.
T?e l i cen s.no ackned e'gm1 rb % cter's perition and indiccted that such was their intent.
The licensce stated that it i.3 bis tutcat
j to obtain confirmtion f rom the manuf acturer that the present
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acceptance criteria is appropriate.
The inspector found that the precedure had undergone a revision (Rev. O to nav. 1) on February 11, 1975.
The inspector founJ no deficicacies in the technical ccatent of the revised procedure, but the procedure had not received that approval ef the MAq as co:rmitted
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to in Section 17.2 11 of the FSAR.
This deviation,cas brov;;ht to I
the attention of th licensee.
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Status of Company Nuclear Review naard (CNE)
The inspector requested information on the status of the C:M3 since Section 14.1.1.j of the FEAR indicates that the CNRB will act as an independent review group auditing test procedures and results.
The inspector revicued a memoranden dated Fchruary 14, 197 5 f ro.a the Vice President, Facilities Development to the present encur; wtc of the positions listed in Section 6.1.2.2 of the propmed Tec:mical Specificaticas centained in Section 16 of the ESAR.
ihe licenace indicated that the first meeting 'till probably occur in April, 1973.
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O 6.
Administrative Procedures-l i
The inspector was inforced that 211 further preoperaticnal tertin;;
has been cuspended pendin:; completion of revisiens tc certain of
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I the AD 1801 :eries of u.rocedures ahich.:;overn the c or.d uc t of testin;..
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The inspector was also informed t.F. t the cleaning of nuelu r 'nict:.
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t related systems is also suspended punding the completion of revisie.
to AD 1335.00, " Instructions for Flushing Program".
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i The inspector discussed cone ainor comments with the licensee on l
the following orceeduras:
l AD 1828.03 " General Orientation Training"
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AD 1823.04 " Personnel Training ::ecords" I
AD 1828.07 "Systens '!alk-tnreu;;ns and Oral B;aminations"
- i The incpecter inforced the licennee that thcae procedures cavared I
activities listeu, as qual ity v.t tect ing ac tiv ttles,.
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I of the FSA:1, and the Scction 17.2.2.2.1 comuits the licencee to j
havin:; the :iQA revieu and approve ru;h procedurcs.
'Th e thrna procedures listed above were appru<ed by the Station "up.rintr. der.c without revieu and approval of tN ':0A and thus repreacnt <. d viation from a connittent rade to the Cor. ins: un.
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Revim of OA Audit
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i Repor t No. G50-346/73-G2 descri:.v., a prellato,ty rexia. of
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(No. 320) perfomed by n QA audit tear on operatinns act;citier.
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This audit cas revia sd in greater detn;] during this inspec ti._ :.
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f The inspector found that 14 A.udit Tindings P.eports (ATR ' s ')
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issued to the station staff aa a resalt of the QA audit.
At the
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time of tnis inspection:
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a.
1 AFR was responded to by the Operation.s Staff ano approved by l
i, QA.
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b.
4 AFR's ucre responded to by the Operationu Staff but returacd j
as unacceptable by QA.
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t c.
9 AFR's vere resn.onded to bv the enerations Staff but had not
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yet been reviewed by the QA staff (2 we. Es since respca. w
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receiveu).
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l The inapec tor discusscd the AFR. ys te.a u th the licen s _o no ti.n, t h f need for aa adequate system of traching.ul status, th; need - -
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p rett.p t revieu o c,..J.R respenses, an u, t,:, c "alue et. specitic..i r. : 2.. -
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and recons.cnd ;t ions in :ll's to thr o.er.Lior of the facility.
7c inspecter also obo.crved that all naterial relative to i3 auiirs oi 0@P20 m
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b, a
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.I operations activities uere kept together in a file folder in the
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0QAF's office. The inspector inforned the licensee that since C/.P 2172 II.sts Audit Peports as QA records with a def;ned ret ntien
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period, and whose retention is controlled by QAP 2173, inprovement in the nanner of storing these records shoulc be initiated.
The
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licensee stated that improvements in record stcra:;c will bc made in the near future.
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i 8.
Facility Tour
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j The inspector uent on a tour of the facility and the following j
observations are considered noteworthy:
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a.
Plant computer hardware and softeare verification runs vare in
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progress.
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j b.
General Orientation Trnining was in progrEs for the station
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i staff, The trainin;; staf f hopes to complete this trainin<; by early su=cr.
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j c.
Construction cleaning of the prinary water stora;;e tank was in
progress.
l d.
Construction cleaning of the Doratcd k'ater Storage Tani had recently Lecn completed.
c.
Construction cleaning of the suction line to the one of the
cor.tainmca t spray pumps was in progrese,.
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f.
The operations staff uas in the process of attemptin;; to put
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the water treatment plant inoperation.
The diluation pump vac put into service to discharge the water in the intake canal to the lake to bring the intake canal water conditions into equilibrium uith the lakevater.
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