IR 05000346/1976003
| ML19319B433 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 03/26/1976 |
| From: | Knop R, Kohler J, Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19319B431 | List: |
| References | |
| 50-346-76-03, 50-346-76-3, NUDOCS 8001151001 | |
| Download: ML19319B433 (15) | |
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U. S. NUCLEAR REGULATORY COMMISSION
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h OFFICE OF INSPECTION AND ENFORCEMENT
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REGION III
Report of Operations Inspection IE Inspection Report No. 050-346/76-03
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Licensee: Toledo Edison Company Edison Plaza 300 Madison Avenue Toledo, Ohio 43652
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Davis-Besse Unit 1 License No. CPPR-80 Oak Harbor, Ohio Category:
B i
Type of Licensee:
PWR (B&W) 906 MWe Type of Inspection:
Routine, Announced Dates of Inspection:
Febru ry 23-25, 1976
'l.,$NL 2 s!7[,
Prinicpal Inspector:
.R.
D.
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'(Dat'e)
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.iccompanyingInspectorj (February 23, only)
'(Date)
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Other Accompanying Personnel: None Reviewed By:
R. C. Knop Ch ef 7d Reactor Projects (Date)
Section 1
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SUMMARY OF FINDINGS
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' Inspection Summary
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Inspection on February 23-25 (76-03):
Review of preoperational tests and test program; review of flushing program; review of Overall Leak Rate Test for containment; and review of activi-ties of QA/QC staffs related to preoperational testing.
Enforcement Action
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No items of noncompliance with NRC requirements were identified during this inspection.
Licensee Action on Previously Identified Enforcement Items Not within scope of this inspection.
Other Significant Findings A.
Systems and Components Preoperational Testing of the SEAS System has begun.
B.
Facility Items (Plans and Procedures)
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None identified during this inspection.
C.
Managerial Items Licensee has taken interim action to provide management control mechanism to monitor and control construction force work on turned-over systems, and to provide review chain for evaluating any retesting of those systems which are
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affected.
D.
Noncompliance Identified and Corrected by Licensee None identified during this inspection.
E.
Deviations None identified during this inspection.
F.
Status of Previously Reported Unresolved Items
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Inspection Report No. 050-346/75-22 (Page 6)
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The inspector reviewed-the activity schedules developed
.to assure that QA department regular audits and sur-
. veillance will satisfy FSAR' commitments. This matter
- is considered resolved.
(Paragraph 3b, Report Details)
2.
Inspection Report No. 050-346/75-12 (Page 4)
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The inspector reviewed the' draft version of TP 273.01, Auxiliary Feedwater System Preoperational Test, and
noted that testing of the Service Water System back-up capability for that system was included as committed to in the above referencaireport. This issue is con-sidered resolved.
.3.
Inspection Report No. 050-346/75-22 (Page 6)
The inspector reviewed the completed procedure CP 6051.01 which the licensee utillzed to reelean the Core Flood Tanks rather than to certify the construction cleaning of
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those units.
No deficiencies were noted in this review i
and this matter is considered resolved.
(Paragraph 4a,
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Report Details)
I 4.
Inspection Report No. 050-346/76-01 (Page 7)
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i The inspector reviewed Temporary Modification T-85 to TP310.01.2 "SFAS Preoperational Calibration" which adds a test sequence-to demonstrate SFAS-logic operability by the imposition of multiple simulated inputs to the SFAS
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and observing: actuating relay action. This satisfies
th.e commitment made in the referenced report and this matter is considered resolved.
s Management Interview
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A.
The following persons attended the management interview at i
the conclusion of the inspection:
i J. Evans, Station Superintendent
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-J. Lenardson,-QA Manager E. Novak, Davis-Besse Project Engineer
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-T.-Murray, Operations Engineer
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L. Stalter, Technical Engineer f-s L. Grime, Inspection Engineer i
l 13. Eichenauer, Field QA Representative
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W. Green, Assistant to Station Superintendent
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B.
Matters discussed and comments were as follows:
1.
The inspectors reviewed the more significant aspects of the meeting with the licensee's representatives with regard to the review of the structural proof test and leak rate test of the facility containment.
(Paragraph 1, Report Details)
2.
The inspector noted that he had provided comments to members of his staff on various procedures.
(Paragraph 2, Report Details)
3.
The inspector summarized his review of QA department activities.
(Paragraph 3, Report Details)
4.
The inspector summarized his review of flushing activities (Paragraph 4, Report Details), summarizing his concern over the reported instances of nonobservance of cleaned boundary controls.
5.
The inspector requested and received a commitment that the licensee would provide suitable instructions to
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clarify the circumstances under which Temporary Modi-N,,/
fications and/or Deficiency Reports are required in the implementation of Test Procedures.
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i REPORT DETAILS
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Persons Contacted
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The following persons, in addition to those listed under the Managem~ent Interview section of this report, were contacted i
during this inspection.
_ Toledo Edison Company R. Brown, Assistant Engineer G. Hurrell II, Senior Assistant Engineer
K. Cantrell, Operations Quality Assurance Engineer
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J. Buck, Field QA Engineer W. Alton, Station Technical Assistant P. Narducci, Quality Control Engineer W. Russell, Instrument Mechanic R. Franklin, Training Coordinator B&W Company i
E. Michaud, Test Program Manager l
Bechtel Construction Management R.. Bush, Engineer C. Hawley, Engineer
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M. Gesler,-Engineer R. Hayes, Engineer C..Granrud, Engineer i
Bechtel-Startup s T. Reddaway, Project Start-up Engineer J. Landon, Start-up Coordinator Bechtel (GPDE)
H. Chang, Engineer Resul ts 'of Inspection 1.
Containment-Integrated Leak Rate and Proof Test Procedures
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The inspectors met with the licensee, his representatives, and subcontractors to discuss their review of the draft version
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of the integra.ed leak rate and structural proof test procedures for
['_sh the containment. The items covered are summarized below:
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Containment Weighting Factors
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a.
The licensee has not furnished the containment weighting factors, nor the basis for their selection, used to compute the weighted average containment temperature and pressure during the ILRT.
The inspector stated that the weighting factors were necessary in order to independently verify the test results. The licensee acknowledged this, b.
Inoperable Sensors The licensee's procedure did not address the steps that would be taken in the event that an RTD, humidity, or pressure sensor becomes inoperabic during the preoper-ational ILRT. The licensee acknowledged this.
c.
System Lineup for Preoperational ILRT The licensee said that there was a conflict in some cases with simulating a DBA condition, and operating systems
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that are required to maintain the plant in a safe condition during the test.
The conflict arises in the valve lineup decision for the decay heat removal system.
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During the preoperational test, with new fuel in the core, the decay heat removal system is not required to maintain the plant in a safe condition. However, all periodic ILRTs performed after the preoperational test will require the decay heat removal system to operate.
The inspector stated that 10 CFR 50, Appendix J, Section III.A.1.d
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requires the decay heat removal system to operate during the preoperational test.
However, the licensee had intended to line up the plant to simulate a DBA condition with the LPCI valved in and the decay heat removal system valved out.
This is possible only during the initial test because there is no decay heat load.
The inspector stated that guidance would be provided to resolve lineup of the decay heat removal system during the preoperational ILRT.
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The following positions are bastd on 10 CFR 50, Appendix J,
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Section III.A.1.d.
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.(1)' The decay heat removal system can be filled with O
water and operating.
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(Basis:
" Systems that are required to maintain the plant in the safe condition during the test shall be operable in their normal mode and need not be vented.")
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(2) The LPCI system can be filled with water and lined up as if to operate. However, the exposed isolation valves of the decay heat removal portion of the system now become containment isolation valves and are required to be Type C tested.
The leakage from these Type C tests should be added to the results of the ILRT as a test penalty.
(Basis:
" Systems that are normally filled with water and operating under post accident conditions such as the containment heat removal systems need not be vented.")
In summary, the licensee can select either line-up (1),
with decay heat removal operating, or line-up (2)
simulating a DBA.
In the latter case, a Type C test of the containment isolation valves of the decay heat removal portion of the system is required to be performed and added to the results of the ILRT.
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d.
Vent Valves Located In Containment Purge Supply and Exhaust The containment purge supply and exhaust lines contain 1/4
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inch normally open, vent valves which vent to the annulus between the primary containment and the shield building.
This valve position appeared to be in violation of the requirement to provide double isolation valves for lines
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that penetrate containment. The inspectors requested that the licensee furnish the basis for these valves being open.
The licensee stated he would furnish such a basis.
(By telephone conversation on February 26, 1976, the licensee noted to the inspector that these valves are described j
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in the response to Question 6.2.23 of the FSAR, and it is their intent to assure that these valves are open prior to conducting the preoperational ILRT.
The inspectors have
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no further questions on this matter.)
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Division of Responsibility
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The licensee has not adequately described the division of responsibility that will exist between the thres parties taking part in the test.
The parties involved are-Chicago Bridge and Iron Company, Bechtel Corporation and Toledo Edison Company.
The licensee will include such a discussion in a future revision to the procedure, f.
Isolation Valve Closure No provision was included in the procedure to account for automatic containment isolation valves that were closed for some period prior to the test.- Appendix J requires these valves to be closed by normal valve operator action; therefore, the licensee will exercise these valves from the control room immediately prior to the start of the leak rate test.
g.
Containment Inspection The licensee did not include a description of the containment inspections required by 10 CFR 50, Appendix J, Section V, to be performed prior to any Type A test.
The licensee will orovide such a description.
h.
Local Leak Rate Test Schedule (
The licensee plans to perform the local leak rate tests within a two month interval before the performance of the Type A test as permitted by available test personnel and
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equipment.
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Instrument Error Analysis
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The licensee was informed that an instrument error analysis will be necessary. They requested guidance in supplying such an analysis. The licensee is referred to the following reports:
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Quad-Cities Unit 1 Integrated Primary Containment Leak Rate Test, 1976.
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BNTOP-1, " Testing Criteria for Integrated Leak
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Rate Testing of Primary Containment Structures for Nuclear Power Plants," 1972.
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/- s-(3) ANS N274, Working Group 56.8, " Reactor Containment
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Leakage Testing Requirements," Draft No. 1, 1975.
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The licensee acknowledged-the following three positions presented by the inspector:
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(1) All syste:ns that are to remain pressurized throughout-the ILRT should be leak tested before and after the completion of the ILRT. A leak rate of a pressurized system which is greater at the c6nclusion of a test than the initial test should be added into the results
.of the final ILRT.
(2) The plot defined by the least squares fit of the leak rate data including the allowance for instrument error must fall below the line defined by 75% of the allowable
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leak rate at DBA pressure.
(3) The plot defined by the least squares fit of the leak rate data including the 95% confidence interval (+ two sigma) must fall below the line defined by 100%
of the allowable leak rate at DBA pressure.
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The licensee was asked to clarify tne meaning of
" temporary closure devices" installed on containment
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leaks discovered during the containment structural ('
test (VST-70-6449).
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The licensee stated their position that the Davis-Besse 1 containment is not a prototype containment, thus no additional special' testing of structural integrity is required.
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The licensee recognizes that all instrumentation uti-s
lized during the above tests will have to conform to instrument standards and quality controls comparable to those required by the Toledo Edison Quality Assurance Program.
2.
Review of Procedures The inspector reviewed the following procedures with the
licensee:
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a.
TP0120.03 - Fuel Handling Sys. tem Integrated Test.
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No deficiencies were noted during the review of this approved procedure.
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b.
TP150.03 - containment Vessel Local Leak Rate Test.
The licensee indicated that data sheets would be attached t'o this approved scoping procedure and appropriate corrections, either on the data sheet or in the body of the procedure, would be made to convert volumetric leak rate to mass leak rate as required to assure that the acceptance criteria is met.
c.
TP161.01 - Containment Air Recirculation System Preoperational Test.
No deficiencies wema noted during the review of this approved, procedure.
However, the inspector clarified the following points with the licensee:
(1) Air balancing and filter testing reports for safety related systems which are produced by subcontractors are acceptable provided the work done and measurements made are controlled in accordance with the requirements of the licensee's
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QA manual. The licensee acknowledged this.
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(2)
The inspector requested and received a commitment from the licensee that prior to conducting pre-operational tests on safety related ventilation systems, the licensee will verify that all reason-ably accessible balancing dampers in the duct work are still set properly as recorded in the balancing
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reports, d.
TPl70.05 - Control Room Heating, Ventilating, and Air Conditioning Preoperational Test Procedure.
The inspector understands that this approved procedure is to be revised, and that the revision will include the timing of closure dampers as described in Questions 15.4.5 and 15.4.8.2 of the FSAR.
e.
TP200.06 - Reactor Coolant Pump Initial Operation Test.
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No deficiencies were noted during the review of this-approved procedure.
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TP0201.03 (Rev. 1) - Core Flooding System Functional Test.
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No deficiencies were.noted during the review of this approved procedure, however, the inspector understands
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that the flow test of the Core Flood Tanks is under evaluation and will be added at a later date.
The inspector will review this addition when it becomes available.
g.
TP204.01 - Containment Spray System Preoperational Test.
The inspector understands that the smoke or air testing of the spray nozzles is yet to be decided upon and will be a portion of the Surveillance Test Procedure for the system which is under development.
The inspector also understands that the system timing responses as dis-cussed in Q.6.2.26 and on page 6-28 of the FSAR will be
included as part of the response tima preoperational test procedure being developed by the licensee.
h.
TP305.01 - Reactor Protection System Preoperational Calibration Test.
The inspector understands this draft version is under-going revision at the present time.
The final version
.will be reviewed when it becomes available. The in-('s spector also understands that the licensee will add a
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section to this procedure which will verify the actu-ation logic of the system by simulating multiple in-puts to the RPS to verify trip actuation.
Moreover, during the review of this procedure with the licensee, it became clear that the Surveillance Test presently developed for this system would not satisfy
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the " Channel Functional Test" as defined in the present version of the draft Technical Specifications for the facility in that the master relays are not deenergized as part of the procedure.
The licensee agreed to review this matter further.
1.
TP08000.ll - Core Power Distribution.
The inspector noted that TP0800.24 "Incore Detector Testing" should be completed as a prerequisite for this procedure. The licensee noted the comment.
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suggests that core power distribution should be evaluated at several power levels (e.g., 25%, 50%, 75%,
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100% of' full power), the licensee plans to do this evaluation at 40%, 75%, and 100%. While this is.not contrary to any regulatory requirement, the licensee-agreed to provide the inspector with supporting in-formation as to why the reactor would be raised to
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40% of full power prior to evaluating the core power distribution.
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TP800.24 - Incore Detector Testing.
No deficiencies were noted during the review of this approved test pro'cedure.
k.
AD1835.00.4 - Instructions for Flushing Program.
No deficiencies were noted during the review of this approved procedure.
1.
AD1835.01.0 - Control of System Cleanliness.
No deficiencies were noted during the review of this approved procedure.
m.
TP2400.24 - RCS Pressure to SEAS Preoperational Calibration.
O No significant deficiencies were noted during the review of_this procedure; however, the inspector understands that, due to other considerations, the licensee plans a substantial revision to this procedure.
3.
Quality Assurance Department Activities The inspector reviewed selected activities of the QA staff
since the last Operations Inspection.
a.
Audit Activities The inspector reviewed audit No. 397, the report for which is still being finalized. This audit was conducted on February 19, 1976 with the exit interview conducted February 24, 1976 uhile this inspection was in progress.
Review of the audit with regard to conformance to the QAP's controlling the conduct of audits disclosed no
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deficiencies. The audit addressed the activities
/'~N of the Startup Organization.
This audit will be s
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reviewed further by the inspector during a subsequent
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inspection.
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b.
Activity Schedule The inspector reviewed the activity schedule by which-the licensee will assure that the regular audit and surveillance activities to which the licensee is committed in the FSAR are satisfied.
No deficiencies were noted during this review.
The licensee indicated
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his intention to collate these documents into appropri-ate procedures, instructions, or the QA manual itself, the exact disposition not yet being decided on.
These schedules satisfy the commitment of the licensee reported in Inspection Report No. 050-346/75-22. This-matter is considered resolved.
c.
The inspector discussed what appeared to be some misunderstanding among licensee personnel with regard
to the mechanics of identifying witness points in test procedures.
The licensee agreed to provide instruction which would clarify when a step or an entire section of a procedure is to be witnessed.
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Flushing Activities
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Core Flood Tanks sm, The' inspector reviewed the documentation of the cleaning of the Core Flood Tanks.
Inspection Report No. 050-346/
75-22 had noted that the licensee was going to review the construction cleaning of those tanks, which was to be
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the final cleaning,.to assure that the cleaning met the licensee's controls and criteria.
In lieu of this, the licensee elected to reelean the tanks.
The inspector reviewed completed CP 6051.01 and noted that the correct revision (1) was used; four procedure deviation forms were properly-prepared and documented; and acceptance criteria were met.
No deficiencies were noted in this review and this matter is considered resolved.
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b.
Flushing Program Status
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The inspector reviewed the general status of the flushing
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program as reflected by the marked-up flushing P& ids.
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following items are considered noteworthy:
/'~'Y (1)
Station Air System Approximately 85% complete.
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(2) Service Water System Approximately 90% complete.
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(3)
Fuel Oil System Approximer.ely 100% complete.
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(4) Nitrogen Supply System Approximately 90% complete.
(5) Make-up and Purification System Approximately 5%
complete.
(6) Component Cooling Water Approximately 1% complete
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(7) Clean Radwaste System Approximately 75% complete.*
(8) Miscellaneous Liquid Radwaste Approximately 10%
complete.*
The inspector understands that a procedure is being developed for portions of the reactor coolant system (Startup System 64) which were not provided by B&W, and therefore not scheduled to be cleaned by them.
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The inspector will review progress in this area at a later date.
c.
Logbook Review The inspector reviewed the Final Cleaned Tag Log being maintained by the Startup Organization, and no deficiencies were noted.
d.
In discussions with flushing personnel, it was brought to f-~~g the inspector's attention that frequent violations by f
i construction forces of final cleaned boundaries were
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occurring. These personnel indicated that this was a continuing problem when final cleaning had occurred on systems prior to interim release of that system to the licensee for operation and testing.
The inspector will review these problems during a subsequent inspection.
'5.
Test Program Statua The inspector received a briefing on the status of preoperational I
testing of the facility.
6.
Maintenance Activities a.
General The inspector reviewed a selected number of the Maintenance Work Orders (MW0s) initiated since the approval of procedure
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- Construction Cleaning will be accepted as final cleaning.
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AD 1844.0 " Maintenance" to observe adherence to this
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No significant deficiencies ss_s
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were noted.
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b.
Construction Force Work on Turned-Over Systems The inspector reviewed Special Order No. 65, dated December 29, 1975, which was issued as an interim method of controlling contractor work on systems turned over to the licensee.
Under this directive, construction forces will do work on turned-over systems following a modified version of the Maintenance Work Order in use for licensee personnel.
This directive includes the requirement that all such work orders, upon completion, will be forwarded to the Test Program Manager for evaluation of any required
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retesting of those systems.
The inspector understands this to be an interim measure until the licensee formalizes the system further.
The inspector will closely follow the licensee's progress in this area.
7.
Implemented Test Procedure Reviews The inspector reviewed several partially completed test
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packages. He noted that temporary modifications and deficiency (
reports had been prepared with all required approvals and
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reviews conducted in accordance with the AD 1801 Series of procedures. No deficiencies were noted in this review.
The tests reviewed in-'.uded:
TP120.01.1 - Fuel Handling System Preoperational Test TP201.03.1 - Core Flood System Functional Test s
TP401.07.1 - 480V Essential MCC Preoperational Test TP310.01.2 - SFAS Preoperational Test TP401.08.1 - 250/125 DC System Preoperational Test
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