IR 05000346/1976004
| ML19326A037 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/22/1976 |
| From: | Knop R, Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19326A031 | List: |
| References | |
| 50-346-76-04, 50-346-76-4, NUDOCS 8001310615 | |
| Download: ML19326A037 (15) | |
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U. S. NUCLEAR REGULATORY COMMISSION
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OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
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Report of Operations Inspection
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IE Inspection Report No. 050-346/76-04 Licensee: Toledo Edison Company Edison Plaza 300 Madison Avenue Toledo, Ohio 43652 Davis-Besse, Unit 1 License No. CPPR-80 Oak Harbor, Ohio Category:
B
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Type of Licensee:
PWR (B&W) 906 MWe Type of Inspection:
Routine, Announced Dates of Inspection:
March 11-12, and April 5-7, 1976 Principal Inspector:
R. D. Marti G
Y/Sk/7(-
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Accompanying Inspectors: None Other Accompanying Personnel: None b
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Reviewed By:
R. C. Knop, e
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Reactor Projects Section No. 1 (Date)
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SUMMARY OF FINDINGS
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U Inspection Summary
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Inspection on March 11-12 and April 5-7, 1976 (,76-04):
Review of pre-operational test and system procedures; witnessing of flushing activities; review of test and cleaning records.
Enforcement Action No items of noncompliance with NRC requirements were identified during this inspection.
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Licensee Action on Previously Identified Enforcement Items
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Not within scope of this inspection.
Other Significant Findings A.
Systems and Components None identified during this inspection.
B.
Facility Items (Plans and Procedures)
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None identified during this inspection.
C.
Managerial Items
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Unresolved item: Licensee is to promptly resolve differences
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between FSAR, Project Start-up Manual, and Quality Assurance Procedures regarding the administrative controls over design changes.
D.
Noncompliance Identified and Corrected by Licensee l
None identified during this inspection.
E.
Deviations None identified during this inspection.
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Status of Previously Reported Unresolved Items 1.
Inspection Report No. 050-346/75-14 (pg. 4)
Report noted that licensee was to develop general cleanliness procedure to address commitment to ANSI N45.2.3.
Inspector reviewed Administrative Procedure AD 1844.05 and this matter is considered resolved.
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2.
Inspection Report No. 050-346/75-22 (pp. 2 and 11)
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Q Report indicated that licensee would demonstrate that flushing personnel would be cautioned to utilize correct cicaning procedure revisions.
Inspector reviewed memo of 12/5/75 from Project Start-up Engineer to Station Superintendent documenting those instructions. This matter is considered resolved.
3.
Inspection Report 050-346/75-22 (pg. 5),
Report noted licensee would develop cleaning procedure for mis-cellaneous containment penetrations. Licensee reviewed CP 6049.01.
This matter is considered resolved.
4.
Inspection Report No. 050-346/76-01 This report indicated that licensee would include certain precautionary instructions to the operating staff. The inspector reviewed a proposed revision to AD 1839.00 " Station Operations." This matter is considered resolved.
5.
Inspection Report No. 050-346/76-03 (pg. 12)
This report indicated that licensee would provide additional information as to why the core power distribution test would ut m-not be conducted until 40% full power.
The inspector reviewed
(G this matter with the licensee who indicated that the core
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power distributions would be measured at lower power levels
to assure that no gross anomalies were present, and that the 40% minimum limit applied only to the particular test procedure, not the observation of power distribution.
This matter is considered resolved.
Management Interview The rollowing persons attended the management interview at the conclusion of the inspection.
Toledo Edison
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i L. Roe, Vice President, Facilities Development
J. Evans, Station Superintendent D. Briden, Chemist and Health Physicist L. Stalter, Technical Engineer L. Grime, Inspection Engineer B. Beyer, Maintenance Engineer R. Franklin, Training Supervisor K. Cantrell, Operations Quality Assurance Engineer P. Narducci, Quality Control Engineer n/
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J. Buck, Quality Assurance Engineer
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W. Green, Assistant to the Superintendent Bechtel Start-up
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T. Reddaway, Project Start-up Engineer D. Brimmer, Assistant Start-up Engineer Babcock and Wilcox Company E.'Michaud, Test Program Manager B.
Matters discussed and comments were as follows:
1.
The inspector stated that he had provided comments on various
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Administrative and Test Procedures to the licensee's staff.
He reviewed the more significant comments and understandings (Paragraphs 1 and 2, Report Details)
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2.
The inspector stated that he had reviewed the controls to be used by the licensee when returning equipment to service following maintenance. He requested that the licensee consider
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the use of independent verification for selected procedure
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steps when the surveillance test used to demonstrate operability (as defined in Technical Specifications). of a system requires a; t ma # vr
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additional steps after the operation of the repaired system is completed. The licensee agreed to consider this recommendation, and will discuss their decision with the' inspector during a
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subsequent inspection.
(Paragraph 3, Report Details)
3.
The inspector stated that he had received a status report on
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the modified reactor vessel surveillance specimen holders, and
.he understood a modified unit would be arriving on site on April 15,'1976, for installation during Hot Functional Testing.
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(Paragraph 4, Report Details)
4.
The inspector indicated that he had reviewed the progress of
Training, Test Program Scheduling, Flushing, and Housekeeping activities, and that no deficiencies were noted during that review.
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The inspector discussed his review of the activities relative to SEAS modifications and noted that while he had no technical concerns over the corrective actions taken, the utilization of the approved procedures outlined in the Start-up Manual to achieve these changes resulted in a review chain different than'that described in the Quality Assurance Procedures (QAP's)
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activities of the Quality Control group and that review activity was underway. The inspector indicated that this item would be considered unresolved pending the prompt resolution of differences between the FSAR, QAP's and the Project Ctart-up Manual regarding control over changes.
The licensee indicated this-prompt action would be taken.
The inspector will review the progress of the licensee during the next inspection.
6.
The inspector briefly summarized his observations made during i
the tour of the facility.
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REPORT DETAILS v
Persons Contacted
,e The following persons, in addition to those lis.ted under the Management Interview section of this report) were contacted during this inspec-tion.
Toledo Edison Company J. Orkins, Instrument and Controls Engineer T. Murray, Operations Engineer J. Hickey, Training Coordinator
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J. Lingenfelter, Senior Assistant Engineer
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D. Dean, Office Supervisor D. Hitchens, Assistant Engineer W. Alton, Assistant Engineer R. Jadgchew, Assistant Engineer G. Waugh, Assistant Engineer R. Brown, Assistant Engineer C. Alm, Assistant Engineer Bechtel Start-up J. ' Landon, Start-up Flushing Coordinator Babcock and Wilcox J. Lindamood, Test Engineer J. Marshall, B&W Construction Co.
Results of Inspection 1.
Test Procedure Review The inspector provided the licensee comments on the following test procedures.
a.
The inspector informed the licensee that he had reviewed the following approved test procedures, and that no significant deficiencies were noted during that review:
TP 205.03 High Pressure Injection System Functional Test TP 271.08 OTSG Level Verification TP 330.0L Control Rod Drive Control System Preoperational Calibration TP 330.02 Control Rod Drive Control System Operational Test 6-
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TP 600.13 Pressurizer Operational and Spray Flow Test TP 700.01 Auxiliary Neutron Monitors Set-up and Source
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Response Test
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TP 800.13 Unit Load Rejection ~ Test
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TP 2400.27.1 BWST Level to SEAS Preop Calibration b.
The inspector provided the licensee w'ith comments on the following test procedures (approved procedures except where noted).
Significant items are summarized below:
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(1) TP 160.02 Containment and Penetration Room Purge System Preoperational Test Procedure The inspector understands that the present plans of the licensee call for installation of filter system units in heating and ventilating systems prior to conducting the final balancing of those systems.
(2) TP 200.18 Quench Tank Acceptance Test The inspector understands that"the licensee will pursue the determination of the design basis for the quench tank and cooler system and will establish test acceptance criteria accordingly.
The inspector will determine if regional guidance is available for<this matter.
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(3) TP 256.01 Station Response to Loss of Instrument Air n
Test (Proposed major modification)
p This proposed major modification to this procedure reflects a complete change in the manner in which this test is to be conducted.
The licensee now intends to test each safety related, air operated device by isolating that device from its air supply and verifying that the device goes to its
" safe" position. The previous version of the test called an integrated test by reduction of system pressure and monitoring of actuated device responses. The licensee noted that a recent revision (No. 17 - not yet received by inspector) to the FSAR abstract of this test (pp. 14-44)
reflects this change in test conduct. The inspector informed the licensee that he would pursue with his manage-
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ment a recommendation that the licensee also be required to conduct isolations of supply air headers to demonstrate
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that the pneumatic devices are correctly connected to their respective headers as shown on facility drawings.
-(4) TP 263.01 Service Water Preop Test P
The inspector understands that the licensee will modify the above test procedure to demonstrate and document the
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operability of the service water system to provide make-up water to the component cooling water system.
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(5) TP 370.01.1 Environmental Radiological Monitoring System Preop Test
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Review of this procedure against-the FSAR abstract (pg.14-56) indicates that the procedure as written does not address the items listed in the abstract. The licensee noted that many of the missing items will be covered by TP 800.01 and TP 800.03. The inspector after discussions with the licensee, understands that appropriate steps will be taken to review these procedures and the above abstract to assure that all test items are addressed and to make any changes prompted by that review. The inspec-tor will review these activities during a subsequent inspection.
(6) TP 410.01 Diesel Generators Preoperational Test The inspector understands the following actions will be taken by the licensee:
(a) The licensee will determine if the " Break-in Run" described in section 6.1.2 of IEEE 387 will be con-ducted at the site or if this das completed by the vendor providing the units.
g (b) The licensee will review the design of the air
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starting system and the FSAR description of that system's capabilities to clarify what is meant by an air reservoir being capable of providing for 5 starts. The inspector informed the licensee that the test to demonstrate this successive starting capability should be conducted in such a fashion that the engine cannot start for the first four attempts and then demonstrates a start on the fifth attempt.
(What constitutes an " attempt" to start is to be resolved with the licensee.)
The inspector will review these matters during a subsequent
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inspection in the near future.
(7) TP 500.01.1 Reactor Coolant System Chemistry Preop Test The inspector understands that the licensee will revise this procedure to make it applicable throughout the ini-tial power ascension phase as indicated by test abstracts on pages 14-66, 14-89 and 14-97 of the FSAR.
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(8) TP 500.03 Initial Radiochemistry Test
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The inspector understands that the licensee will revise s
section 1.4 of the test procedure to conform to the requirements of Table 4.4-2 of the Technical Specifications, when those specifications become-applicable.
(9) TP 600.14 Reactor Coolant System Expansion and Restraint The inspector understands that the licensee will develop a suitable control method, such as a checklist of hangers and measurement points, to assure that all hanger set-tings and system expansion measurements are completed before proceeding to the next temperature plateau.
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(10) TP 600.19 Power Conversion System Expansion and Restraint The comment on TP 600,14 above regarding a control method
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applies to this procedure as well. Moreover, the inspector
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understands that the licensee is considering additional tests in this general area with regard to dynamic testing of those piping systems which undergo high-rate temperature transitions such as the Auxiliary Feedwater System. The
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inspector will review the licensee's progress in this area
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during subsequent inspections.
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(11) TP 800.25 Shutdown From Outside of the Control Room i
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a shift foreman to be one of the senior licensed operators present in the control room during the conduct of this-test.
2.
Administrative Procedure Review The inspector provided members of the staff of the licensee with com-ments on the following approved administrative procedures:
AD 1802.00 Technical Information Center Indexing and Retrieval AD 1804.00 Reports Management AD 1805.01 Davis-Besse Manual Control and Revision AD 1807.00 Control of Conditions Adverse to Quality AD 1807.01 Action Item Record AD 1809.00 Occupational Safety and Health AD 1825.00 Supplier / Contractor Control Procedure
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AD 1826.00 Fuel Handling Administration AD 1827.00 Emergency Plan v-9-
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AD 1828.05 Lesson Plans (/h-AD 1828.06 Required Reading Lists x_,
AD 1828.15.1 Requalification AD 1838.02 Performance of Surveillance and Periodic Tests AD 1839.00 Station Operations AD 1847.05 Materials Packaging and Shipping AD 1847.07 Transfer of Material from the Design and Construction Phase to the Operational Phase AD 1848.00 Station Records Management AD 1848.01 Control of Station Correspondence AD 1848.13 Control and Disposition of Records Generated by DBNPS Instrumentation and Control AD 1850.00 Radwaste Management 3.
Maintenance Controls The inspector discussed the licensee's plans to revise section 17.2.14 of the FSAR regarding the clearance procedures used to assure proper operating status of equipment af ter the completion of maintenance work. The proposed revision would indicate that the shift foreman is responsible for aligning the system for post main-tenance checkout and releasing the system for service.
The inspector requested that the licensee consider that the surveillance testing, which is required by the Technical Specifications prior to declaring a system operable, may be done in such a-fashion as to. require additionalk n a
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steps to be taken (closing breaker, opening isolation valve, etc.)
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upon completion of the operational aspects of the test.
In those s
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operating status of a system, the licensee was requested to consider requiring an individual to verify that those supplemental steps were properly completed by the individual completing the actions.
The licensee agreed to take this matter under consideration and to advise the inspector of his decisions during a subsequent inspection.
4.
St.rveillance SpecLmen Holders In discussions with the licensee's staff and representatives of Babe,ock and Wilcox, the following tentative information concerning the specimen holders was obtained:
a.
Davis-Besse 1 will be provided with a prototype holder (design
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b.
lThe unit will be fitted with some form of measuring equipment
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It is not possible to determine at this time the impact this prototype ('~')),
testing may have on the testing schedule for the facility.
G 5.
Training Activities The inspector reviewed the current status of training activities.
The following items are noteworthy:
a.
All training committed to in the FSAR except for Phase V is completed.
b.
System reviews are now under way in preparation for licensing examinations.
c.
System walkdowns for all license candidates are in progress.
d.
Staulated and NRC exam schedules are tentatively set to be completed by September 1, 1976.
Plans are being formulated for QA review training required by e.
QAP's.
No deficiencies were noted in this review of training activities relative to licensee commitments.
6.
Test Program Scheduling The inspector reviewed the present sta;us of the Test Program Schedule, and changes to that schedule! caused by slippages in turn-over dates for systems.
No deficiencihs were noted when reviewing the schedule modifications against tescing commitments identified in the FSAR.
The inspector reviewed the Deficiency..og maintained by the Test Program Manager as required by AD 180l!04.
No deficiencies were noted during this review.
The inspector was informed that clarif:;ing information for use by test personnel regarding the usage of t;emporary procedure changes ortestdeficiencyreportsduringpreoI}erationaltestinghadreceived Station Review Board (SRB) approval anit was undergoing review by
the Q,A/QC staff. This matter had been discussed with the licensee durir.Lg the February 23-25 inspection, and during the Management Intetyiew on February 25.
The inspector noted his concern over the lengt3 of time it has taken the licensee to resolve this issue whicN is so pertinent to preoperational testing activities.
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Flushing Activities a.
Procedure Review The inspector reviewed the following cleaning' procedures for con-formance to the requirements of AD 1835.00 " Instructions for
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Flushing Program."
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CP 6016.01 Procedure for Component Cooling System CP 6065.01 Cleaning Procedure for Make-up and Purification System
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Cleaning the Nitrogen Purge and Blanket System CP 6049.01 Procedure for Cleaning the Decay Heat System j"'
Procedure for Cleaning Miscellaneous Containment CP 6059.01 Penetrations.for "GLRT" and "LLRT."
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No deficiencies were noted in the review of these procedures j
against the requirements of AD 1835.00, commitments made in
the FSAR, and commitments made to the inspector.
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The. inspector then planned to review CP 6062 " Reactor Vessel
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Cleaning." This was originally designated as a TECo proce-
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dure, but cleaning of the vessel and substantial portions of the i
RCS are part of the B&W contract.
Thus the station superintendent
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approves individual B&W Field Construction Procedures (FCP's)..........
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These FCP's reference B&W Construction Company Quality Control
.j Administrative Procedure 9A-128 (issued February 24, 1975; revised April 9, 1975).
The inspector found that the general
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requirements of 9A-128 and the specifications for cleaning
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water effluent purity are in agreement with AD 1835.00.
I Moreover, each cleaning procedure has the requirement:
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. tests
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are to be witnessed by TECo Health Physics personnel and Bechtel Cleaning Coordinator."
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In addition to this, the acceptance testing of the effluents
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is performed, evaluated, and approved by TECo Laboratory per-sonnel.
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The inspector reviewed the following FCP's, and noted they were approved by TECo as required, and were in agreement with
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AD 1835.00.
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Procedure No.
Title Rev. No.
TECo
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Approved FCP-99 Clean RC Piping
12/8/75 i
FCP-131 Clean RV Head prior Installation of
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CRDM's
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FCP-144 Clean PZR
8/1/75 FCP-156 Clean RV
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FCP-188 Clean SG Upper and y)
Lower Head
12/8/75 The inspector reviewed the method of tracking the cleaning status of the systems and observed:
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(1)
Each component and section of piping is identified.
(2) A file is maintained for each FCP.
(3) Each file contains inspection record sheets and copies of TECo and Bechtel confirmation of cleanliness.
(4) When all identified sections are cleaned, the original records are transferred to BCM for ultimate transfer to TECo.
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The inspector reviewed the file for FCP 99.
No deficiencies were noted. The inspector noted that the B&W portion of cleaning responsibility for the RCS is essentially completed.
In response to questions regarding the cleaning of the tube
bundles of the Once Thru Steam Generators (OTSG's), the inspector was informed that the OTSG bundles were received as cleaned to Class B cleanliness levels, as required by program, and that steps have been taken throughout the construction phase to maintain that cleanliness. No further cleaning
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activities are planned for the OTSG's.
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Procedure Implementation The inspector witnessed portions of the implementation of CP 6016.01 " Procedure for Cleaning Component Cooling System" to verify that procedural requirements with regard to personnel duties, procedure conduct, and results evaluation were satisfied.
No deficiencies were noted during this review.
8.
Housekeeping Activities The inspector was briefed on the development of the licensee's plans to implement AD 1844.05 " Cleanliness Control" which address the commit-ment of the licensee to conform to the guidance in Regulatory Guide 1.39.
The inspector will follow the development of these plans during subsequent inspections.
9.
Modifications to Safety Features Actuation System (SFAS)
The inspector reviewed modifications made (or in the process of being implemented) on the SFAS system as a consequence of conditions found during the initial phases of the preoperational test of this system.
The inspector reviewed the information in the following Start-up Field (*)
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Raparta (SFR's) and related Start-up Field Rsport Replies-(SFRR's)
with members of the licensee's staff.
SFR Description E408 Essentially a ground loop type of problem resulting in varying the trip points of bistables from the values established during bench calibrations.
E407 This is basically an inadequate calibration procedure pro-blem which would have resulted in incorrect trip setpoints.
E405 This was a manufacturing deficiency relative to the wiring of the non Q-list monitor lights of the system.
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E404 This relates to the output relays not deenergizing during a 1/2 trip test when one of the type 4 relays in that string of relays (powering de valves) was deenerg'ized prior to inserting the 1/2 trip.
E406 This relates to the need for additional cable sup-
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ports to large cables to prevent the weight of the cable from opening the circuits at the connectors.
(Such circuit openings result in SEAS equipment or output relay deenergizations since the SFAS is a
"deenergize to operate" design' system.
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In reviewing the mar.ner by which these changes were handled, the inspec-tor noted that *ba "se of SFR's and S7RR's was handled in accordance.
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with the appr
.aduras contained in the-project start-up manual.
TEco enginee,
, and the manufacturer's representatives were involved where appropriate.
In reviewing the approved procedures used by the licensee to effect these modifications, the inspector noted that these procedures do not fully address the review chain described in section 17.2.3 of the FSAR nor do they incorporate all of the requirements contained in the 2030 series of Quality Assurance Procedures (QAP's). The inspec-tor informed the licensee that this matter would remain unresolved pending the prompt resolution of these differences.
The licensee commited to this prompt resolution during the Management Interview, and the inspector will review their progress during his next inspec-tion.
10.
Facility Tour The inspector conducted tours of the facility, and the following
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items are considered noteworthy:
a.
Grit blasting and repainting of the dome area of the contain-ment is in progress.
The precautions taken by the licensee
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continun to appser adsquate to minimize tha dirt accumulation on safety related equipment.
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Mirror insulation installation is in progress on the OTSG's.
c.
General area cicanliness is fair considering the grit blasting activities in progress.
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d.
The refueling canal was being flooded up to refueling level preparatory to wet fuel handling equipment preoperational tests.
e.
Flushing of the Component Cooling Water system was approximately 20% completed.
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f.
MSIV installation was in progress. Clean boundary controls were in effect and being utilized.
g.
Testing of the Circulating Water System is in progress, h.
A " Clean Room" with appropriate access controls and clothing requirements has been established over the refueling canal area.
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