IR 05000346/1975014
| ML19319B358 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 08/18/1975 |
| From: | Knop R, Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19319B352 | List: |
| References | |
| 50-346-75-14, NUDOCS 8001150943 | |
| Download: ML19319B358 (13) | |
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U. S. NUCLEAR REGULATORY COMMISSION
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j OFFICE OF INSPECTION AND ENFORCEMENT l
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REGION III
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Report of Operations Inspection
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l IE Inspection Report No. 050-346/75-14
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i Licensee:
Toledo Edison Company j
Edison Plaza
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300 Madison Avenue Toledo, Ohio 43652
I Davis-Besse Nuclear Power Station License No. CPPR-80 j
Oak Harbor, Ohio Category:
B l
Type of Licensee:
j Type of Inspection:
Routine, Announced
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Dates of Inspection:
July 21-22, 1975
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Principal Inspector:
R. D. Martin
(Date)
Accompanying Inspector:
None i
Other Accompanying Personnel:
None i
Reviewed By:
R. C. Knop, Senior Insp to
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j Projects Unit 1, Reactor Operations Branch (Date)
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I SUMMARY OF FINDINGS Inspection Summary
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Inspection on July 21-22, (75-14) :
Review of selected administrative procedures, staff qualifications, and training program status; review of status of the test program; and review of preoperational test related activities of the Quality Assurance Department.
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Enforcement Items No items of noncompliance with NRC requirements were identified during this inspection.
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Licensee Action on Previously Identified Enforcement Items Not applicable.
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Other Significant Items
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A.
Systems and Components
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Flushing of demineralized water transfer system is in progress.
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Testing of Auxiliary Boiler essentially completed.
B.
Facility Items (Plans and Procedures)
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None identified during this inspection.
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C.
Managerial Items l
Unresolved Item: The licenseee is to assemble appropriate records
for later review by the inspector to demonstrate that the staff
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engineer assigned core physics evaluation responsibilities will i
meet the qualification requirements of ANSI 18.1.
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i Unresolved Item:
The licensee is to assemble appropriate records j
for later review by the inspector to demonstrate that the individual
assigned the position of Inspection Engineer will meet the Level j
III qualification requirements of ANSI N45.2.6.
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Unresolved Item:
The licensee is to resolve the apparent differences in the references to applicable fabrication codes between the
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AD1847.00 series of procedures and the FSAR.
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Unresolved Item:
The licensee is to review, and subsequently
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clarify with the Division of Reactor Licensing, the number and
types of operator licenses to be obtained.by members of the Technical i
Engineer's staff.
i D.
Noncompliance Identified and Corrected by Licensee
None identified during this inspection.
E.
Deviations
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None identified during this inspection.
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Status of Previously Reported Unresolved Items
Inspection Report No. 050-346/75-12, in the Management Interview l
portion, indicated that the licensee would look into the matter of certain procedures to be provided for review by the inspector.
J Since that time, the licensee has sent the Commission a letter
indicating a schedule for the transmittal of those documents.
The inspector considers this matter resolved.
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Management Interview
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A.
The following persons attended the management interview at the conclusion of the inspection:
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Toledo Edison Company
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J. Evans, Station Superintendent E. Novak, General Superintendent-Power Engineering and Construction D. Briden, Chemist and Health Physicist
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B. Beyer, Maintenance Engineer L. Stalter, Technical Engineer L. Crime, Inspection Engineer J. Orkins, I&C Engineer
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W. Green, Assistant to Superintendent
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K. Cantrell, Operations Quality Assurance Engineer
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J. Buck, Field QA Engineer
J. Lingenfelter, Assistant Engineer j
J. Zell, Assistant Engineer i
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j Babcock and Wilcox
4 E. Michaud, Test Program Manager
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B.
Matters discussed and comments were as follows:
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1.
The inspector informed the licensee that he had conducted a
tour of the facility and that he noted no significant deficiencies with regard to the test and operations activities in progress.
He remarked that his review of the logbooks maintained in the shift foreman's office and the control room revealed that there was a variation between personnel as to identifying the times at which items entered in the station logbook occurred, and that this might warrant some attention on his part.
(Paragraph 1)
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I 2.
The inspector stated that he had reviewed the status of the preoperational test program.
(Paragraph 2)
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3.
The inspector stated that he had reviewed the status of the maintenance program controls, the present plans for preventive maintenance, and the status of cleanliness controls.
The
inspector stated that procedure AD 1844.05 does not fully address the cleanliness control requirements of ANSI N45.2.3 for general area cleanliness.
The licensee stated that additional procedural controls for these other areas will be reviewed.
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(Paragraph 3)
4.
The inspector stated that he had reviewed the status of the
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controls over calibration and test equipment as implemented by
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the maintenance and I and C staffs, and that no deficiencies were noted.
(Paragraph 4)
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5.
The inspector stated that he had reviewed the status of training of station personnel and that no deficiencies were noted.
i The status of staff training appears consistent with the status of facility construction and test progress.
The inspector will review the training, qualifications and record system for i
l maintenance personnel, which he understands is under development, l
during a subsequent inspection.
(Paragraph 5).
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6.
The inspector stated that he reviewed the records and the
j methods for recording the results of system flushing activities and that no deficiencies were noted.
The inspector r2 quested
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I and received a commitment from the licensee that an appropriate method will be developed for scheduling the sampling of fluid systems in operation or in lay-up status during the pre-operational phase.
(Paragraph 7)
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The inspector stated that he reviewed the present controls over the distribution and updating of drawings and vendor manuals and that no significant deficiencies were noted.
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inspector stated further that this area will be reviewed again
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after the station records management system is adopted and l
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implemented.
(Paragraph 8)
8.
The inspector stated that he had reviewed selected activities of the Quality Assurance Department relative to preoperational
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testing and operational preparedness activities.
He stated his understanding that the QA department is aware of their surveillance responsibilities as described in section 17.2 of the FSAR and that this program will be developed in the near future.
He also stated that he had reviewed the logbook of
Audit Finding Reports (AFR's) and noted that a large number of AFR responses were overdue with no explanatory comments as to any time extensions granted to those personnel responsible
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for responding to the AFR's.
This area will be reviewed in
greater detail at a later date.
(Paragraph 9)
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9.
The inspector stated that he had reviewed available records on the qualifications of selected staff members and that the
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information would not satisfy the requirements of applicable standards by the time of fuel loading.
The licensee indicated that he would collect the appropriate additional documentation l
for review by the inspector at a later date.
(See unresolved I
items described earlier).
i 10'.
The inspector stated that he had observed some evidence of j
progress in formulating definitions of safety-related work
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activities which would define for licensee personnel the
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areas where direct QA involvement in those activities would be required.
However, the inspector. expressed his concern
that agreement by the affected parties had not yet been reached while review and approval activities on Administrative and Quality Assurance Procedures continued.
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REPORT DETAILS g
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l Persons Contacted
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The following persons, in addition to those listed under the Management l
Interview section of this report, were contacted during this inspection:
a Toledo Edison Company
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L. Kurfis, I&C Foreman
D. Dean, Office Supervisor
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S. Hall, Shif t Foreman
F. Johnson, Maintenance
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R. Kwiatkowski, Chemical and Health Physics Foreman
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Bechtel Start-up R. Burdick, Flushing Engineer
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M. Parenteau, Project Start-up Engineer l
Results of Inspection i
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1.
Facility Tour i
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The inspector conducted a tour of the facility and the following
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observations are considered noteworthy:
a.
Flushing of the demineralized water transfer system was in progress. Procedure CP 6037.02 was being utilized and the inspector noted that 7 minor modifications had been made to the procedure.
Review of the modifications disclosed no
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discrepancies against the current requirements of the AD 1801 series of procedures.
Pursuant to a question raised by the inspector, a later verification of the cloth used as a catch screen during the flushing operations showed the cloth to
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for that class of system.
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b.
A review of the cleanliness condition of equipment turned over
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to the licensee revealed mixed conditions.
The water treatment plant was much improved compared to the inspection of April 1975, but the area of the station air compressors showed considerable
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dust accumulation on the equipment.
It was noted that overhead
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construction work was in progress.
These items were brought attention of the licensee.
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The inspector was informed that the lube oil system, except for the DC pump, had been turned over to operations and was
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being used to circulate oil thru the turbine bearings.
i d.
Testing of the Auxiliary Boiler was essentially complete except for the forced draft fan and the oil system.
e.
The inspector reviewed the following logbooks:
(1)
Station Logbook for period 6/9/75 - 7/19/75
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(2) Jumper and lifted wire logbook (Operations)
(3) Jumper and lifted wire logbook (Start-up Phase)
No deficiencies with regard to licensee commitments or station procedures were observed.
The inspector was informed that the
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Operations Engineer and occasionally, the Station Superintendent
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review the station logbook. The inspector suggested that these individuals consider initialling the last page reviewed or utilize some other appropriate method to document their review.
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The inspector also noted that a major fraction of entries in the station logbook do not include the time at which the event described in the entry took place.
The licensee was informed that such time inforr.1 tion may prove useful to station ranagement
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at a later date when attempting to reconstruct the background of significant events.
v 2.
Tes't Program Status The inspector was briefed on the status of the test program for facility preoperational testing.
As of this inspection, no preope-rational testing (safety-related system testing) has occurred since the last inspection of operations activities (Inspection Report 050-346/75-12).
The Test Program Manager was provided with a listing of tests, the dates for which the inspector wishes to be kept specifically informed.
This is the listing referred to in Inspection Report 050-346/74-06.
This information was provided directly to
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l the Test Program Manager at the request of a representative of the
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licensee since the staff of this individual has test scheduling responsibility.
3.
Facility Maintenance Controls a.
Corrective Mainter.ance
Administrative Procedure AD 1844.00 will govern the conduct of corrective maintenance on safety-related systems at the station. This procedure is in an advanced stage of development-7-
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and is undergoing licensee review at the present time.
The fs)
inspector was informed that it is also being reviewed at the
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group leader level, and, when the final version is approved, the station crafts will be made generally aware of'its contents.
This procedure includes the provisions of the Maintenance Work Order (MWO) System to be used at the station, and interfaces with the Material Control procedures to assure that properly inspected repair parts are used.
The assignment of crafts to specific work duties will be left to the fore =en responsible for' completing the maintenance described on the MWO.
The record system which will be used by them to assure the aclves of the availability of suitab]v trained and qualified craft personnel is still under development and will be reviewed by the inspector at a later date.
AD 1844.00 covers the areas of record retention, clissification of maintenance, and the administrative controls ove r maintenance instructions and procedures review and approvals.
Che inspector had reviewed a draft copy of AD 1844.00 prior to thi: inspection (see paragraph 10 of this report).
During this inspiction, he received the current version undergoing review, and noted that the review by the licensee had already dealt with those areas over which he had concerns.
The review of this current version by the inspector did not disclose any significant deficiencies.
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s b.
Preventive Maintenance
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Administrative Procedure 1844.01 will provide the administrative controls over the preventive maintenance (PM) program.
This procedure is currently under review.
The inspector was provided a draft copy of this procedure for his review and he will provide comments on this procedure at a later date.
The details of the PM program are not yet established for the facility except in general terms.
The licensee presently plans to utilize an over-all plant PM schedule, with the PM requirements for specific components generated from vendors information as well as operating experience gained at other plants with similar equipment.
It was noted that the licensee may utilize PM frequencies which are less conservative than those recommended by equipment manufacturers when they judge a different frequency is warranted based on their experience.
PM activities on safety-related equipment will be implemented using the MWO system subject to its controls as outline in AD 1844.00.
The inspector will review this prcgram in greater detail after further information about it is available.
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Cleanliness Contial
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The inspector reviewed procedure AD 1844.05 " Cleanliness
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Control" which was approved on June 24, 1975.
No significant deficiencies were noted in the procedure during this review within the scope of the procedure as outlined in section 1.6
" purpose".
However, it was brought to the attention of the
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licensee that ANSI N 45.2.3, to which the licensee is presently
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committed, also addresses general area cleanliness on a routine basis, which is beyond the purpose of AD 1844.05.
The licensee indicated that he intends to provide suitable procedural controls to cover this area.
These controls will be reviewed by the inspector at a later date.
4.
Calibration and Test Equipment Control
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l The inspector reviewed the implementation of controls utilized by l
the Maintenance and Instrumentation and Control departments over
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their calibration and test equipmeat.
This review was conducted against the requirements of:
AD 1849.00 " Measuring and Test Equipment Control and Calibration"
MP 1410.03 " Maintenance Tesc Equipment Calibration" IC 2100.00 " Test Equipment Calibration" The review consisted of reviewing records of calibration, methods of implementation of procedural requirements, identification of
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equipment and required calibration dates, and general departmental
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work policies with regard to this equipment.
No deficiencies were no~ed during this review.
It was also noted by the inspector that I 2100.00 had only recently been approved.
Up to this time, the l
calibration of safety-related components has not been done pending approval of IC 2100.00 except for 9 components.
The licensee has identified these components and plans to reverify their calibration at a later date.
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Training Program Status The inspector revitwed the status of the training programs for the
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l station staff and the following items are considered noteworthy:
a.
The guard force has completed their training including-l
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(1)
120 hour0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> State of Ohio Training i.
(2)
40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> (on site) training on security plan, health physics, emergency plan, and eneral station indoctrination a-9-
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The fire brigade had received their State of Ohio certification.
c.
All station employees have received at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of quality assurance training conducted by the QA department.
d.
Personnel to be licensed are continuing their training at a pace consistent with the status of the plant construction (approximately 360 hours0.00417 days <br />0.1 hours <br />5.952381e-4 weeks <br />1.3698e-4 months <br /> of training thus far in 1975).
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e.
Personnel associated with the preoperational testing program l
have received instruction on the procedural controls and l
purposes of the AD 1801 and 1805 series of procedures which control the test program and procedure development and review.
As mentioned in section 3.a above, the training and record keeping i
systems for station maintenance crafts are under review and development
at the present time.
6.
Staff Qualifications Review a.
Technical Engineer Staff The inspector reviewed the background qualifications of the staff of the Technical Engineer against licensee commitments in i
the FSAR and ANSI N18.1.
No deficiencies were noted in this I
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review with the following exception.
Sufficient documentation g
was not available for review by the inspector to determine if the
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individual who will be responsible for " Reactor Engineering and Phyaics" as described in section 4.4.1 of ANSI N18.1 will meet the background qualifications indicated for that position.
The i
licensee indicated that he will accumulate the appropriate
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documentation for review by the inspector at a later date.
The inspector and the Technical Engineer also discussed the present station plans with regard to the eventual licensing of
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members of the Technical Staff in light of section 13.1.2.2.3 of the FSAR which indicates that all individuals reporting directly to the Technical Engineer, except the Assistant Engineer (Nuclear),
will obtain Senior Reactor Operator Licenses.
The inspector was informed that these plans have changed, and that suitable clarification with Reactor Licensing will be obtained on this issue.
This matter will be considered unresolved by the
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inspector for the present time.
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Inspection Engineer
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The inspec'ar reviewed the duties and responsibilities of this
\\-s position with the Inspection Engineer (IE) designee of the i
licensee.
The IE Staff is just being assembled and their primary j
activities at the present time are related to determining the
extent of their duties and their internal procedures.
In
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j reviewing the qualifications of the IE, sufficient documentation
was not readily availabic for review by the inspector to
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determine if the IE designee will meet the background qualifications l
for a Level III Capability as described in section 3.1 3 of l
The licensee indicated tha't he will accumulate j
the appropriate documentation for review by the inspector at a j
later date.
l 7.
Flushing Program Records Rt.ent
The inspector reviewed a sampling of flushing program records (Cleaning and Flushing Logbook - entries to July 17, 1975) with regard to water j'
quality determinations (influent and effluent) and test sample results.
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No deficiencies were noted either in the data or the manner of record I
keeping.
In discussions with the licensee, the inspector noted that I
a system has not yet been developed to establish a sampling schedule
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for cleaned systems which are put into operation or which are left
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in a " lay-up" status.
The inspector recognized that the individual cleaning procedures stipulate final system conditions at the time
the cleaning procedure is completed, but he requested and received
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a commitment from the licensee that a sampling schedule system would
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be devised to monitor the condition of these cleaned systens.
8.
Drawing and Vendor Manual Control The. inspector reviewed the manner by which the licensee is informed of engineering drawing changes and vendor manuals and drawing changes.
This system and the manner in which the documents are distributed for information to appropriate parties and filed was reviewed against
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procedures AD-1811.00 " Drawing File Procedures".
No deficiencies in the implementation of these procedures was noted; however, the ir.apector understands that these items will be included in the over-all station records management system being developed.
Development of this system will be reviewed during subsequent inspections.
In a related matter, the inspector reviewed the manner by which the station can initiate and/or be made aware of design changes.
The following items are noteworthy:
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a.
The station staff communicates design needs or problems 7S to TECo Engineering via a Start-up Field Report (SFR).
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b.
Evaluation of these SFRs is the responsibility of TECo i
Engineering including any required reports such as under 10 CFR 50.55(e), and after licensing, reviews as required by 10 CFR 50.59.
c.
If the station considers such evaluations to require additional
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review by TECo Engineering, they communicate this by additional
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SFRs.
This method is currently' in use and will be retained
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throughout the preoperational phase.
I d.
The effects of design changes on the results of preoperational
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tests or test procedures planned or completed is not a formal review procedure.
Each design change or revision notice is sent to the section heads who are then to revicw the change for effects on their area of responsibility, including any test or operating procedures for which their group is responsible.
9.
Quality Assurance Department Activities
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The inspector reviewed some of the current activities of the QA department as regards their involvement with the preoperational testing phase.
The following items are noteworthy:
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a.
The system by which the surveillance activities, as committed
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to in section 17.2 of the FSAR, of the QA department will be accomplished has not yet been established.
The inspector will
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be reviewing during subsequent inspections the progress in
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developing and the degree of implementation by which the licensee
meets this commitment to the Commission, b.
The inspector indicated that in his review of test procedures thus far, he rarely observed the use of QA " Hold and Witness Points".
The licensee representative indicated that the use of such hold points was a part of the program which still needs to be developed. The inspector will review this development during subsequent inspections.
The next audit of operations activities by QA is scheduled for c.
August 4, 1975.
Audit number 335 (a mini-audit) was conducted in April 1975.
No other audits have been conducted of operations
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activities since January 6-10, 1975.
The inspector reviewed the logbook of Audit Finding Reports (AFRs) and noted that a major fraction of the recently issued AFRs have replies out-standing which are overdue.
This area will be reviewed in greater detail during subsequent inspections.
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10.
Procedure Review
l During this inspection, the inspector provided a representative of s
j the licensee with comments on the following procedures:
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AD 1823.00.2 " Jumper and Lifter Wire Control Procedure" AD 1844.00
" Maintenance" l
AD 1847.00
" Material Control" l
AD 1847.01
" Material Receiving"
AD 1847.03
" Materials llandling and Storage" AD 1847.04
" Stock Material issue" AD 1847.06
" Materials Inspection Procedure"
No significant deficiencies were noted in these procedures.
Section 3 of this report already noted that the areas about which the
inspector had comments in AD 1844.00 above had already been changed
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by the review process of the licensee.
In Inspection Report 050-346/75-05, the inspector noted that, as a result of a review by the licensee of the test procedures against
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Regulatory Guide 1.68, the need for certain additional procedures
were identified.
During this inspection the inspector received l
a briefing on the status of the development of these additional procedures.
No deficiencies were noted in the actions being taken by the licensee.
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