IR 05000346/1976010
| ML19319B688 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 06/29/1976 |
| From: | Knop R, Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19319B613 | List: |
| References | |
| 50-346-76-10, NUDOCS 8001270166 | |
| Download: ML19319B688 (15) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION' N OFFICE OF INSPECTION AND ENFORCEMENT I
REGION III
Report of Operations Inspection
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IE Inspection Report No. 050-346/76-10 lTY Licensee:
Toledo Edison Company-
I Edison Plaza
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300 Madison Avenue Toledo, Ohio 43652 Davis-Besss Nuclear Power Station License No. CPPR-80
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Unit 1 Category:
B Oak Harbor, Ohio Type of Licensee:
PWR (B&W) 906 MWe Type of Inspection:
Row ine, /_nnounced Dates of' Inspection:
May 18-20, June 9-11, 13 and 14, 1976
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$ho 1sts a
Principal Inspector:
. D. Martin 6/
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Accompanying Inspectors: None
- Other Accompanying Personnel:
None Ib Reviewed By:
R. C. Kno C e Reactor Projects Section 2 (Date)
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SUMMARY OF FINDINGS g,,
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Inspection Summary Inspection on May 18-20 and June 9-11,13 and 14,1976 (76-10):
Review of preoperational test procedures, review of preoperational test results, and inapector witnessing of preoperational test activities.
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Enforcement Items
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The following items of noncompliance wh e found during the inspection:
A.
Infraction Contrary to Criterion VI, of Appendix B to 10 CFR 50, " Document Control", Toledo Edison Quality Assurance Procedure (QAP) 2060 and Administrative Procedure 1848.03, the controlled copies of the licensee's Administration Manual in the Control Room and the Shif t Foreman's office were not complete and up-to-date in that a complete copy of AD 1801.00 was not available in either sel on the evening of June 13, 1976.
(Paragraph 9, Report Details)
B.
Deficiency O
(s/j Contrary to Criterion V, of Appendix B to 10 CFR 50, " Instructions, Procedures, and Drawings" and Toledo Edison Quality Control Instruction
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3110, the QC designated inspector did not complete the witness points designated in the Quality Control Verification Sheet for Channel 2 of Section 7.6 of the Safety Features Actuation System Preoperational Test conducted during the period June 11-12, 1976.
(Paragraph 9, Report Details)
Licensee Action on Previously Identified Enforcement Items Not within scope of this inspection.
Other Significant Findings A.
Systems and Components
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Installation of the six, new design surveillance coupon holders was essentially complete, and the licensee is preparing to close the vessel in preparation for primary system hydrostatic test and hot functional testing.
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Facility Items (Plans and Procedures)
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None identified during this inspection.
C.
Managerial Items The licensee is rechecking the Master Punch Lists for all turned-over systems to assure that all outstanding items for those systems are accurately recceded on those lists.
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D.
Noncompliance Identified and* Corrected by Licensee None identified during this inspeqEion.
E.
Deviation
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Contrary to the commitment contained in Section 17.2.2.2.1 of the FSAR, the authorized representative of the Manager of Quality
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Assurance approved the Administrative Procedure AD 1847.17 " Record Retention Requirements" on May 20, 1976, when the contents of that procedure regarding the authority to define retention periods was in conflict with their QAP 2170 series.
Prior to the end of the inspection, the inspector verified that corrective action had been taken to correct this error and to prevent recurrence.
(Paragraph 2.c. (2), Report Details)
F.
Status of Previously Reported Unresolved Items
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Inspection-Reports No. -050-346/75-05 and No. 050-346/75-06
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These reports contai..ed references to the classifications being given to the tests being conducted on certain systems.
Further review by the inspector of the test classifications (nuclear safety related or non-nuclear safety related) currently in use by the licensee as well as clarifying discussions between the licensee and the inspector were conducted during this inspection. The licensee acknowledged that the testing of the revisions to the fuel oil system supplying the diesel generators will be handled as a nuclear safety related test.
The inspector has no further questions on this matter, and it
is considered resolved.
2.
Inspection Report No. 050-346/75-22 This report discussed the controls to be developed by the liceneee over construction force activities on turned-over-3-OV r
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systems. The inspector reviewed Start-up Administrativ,e Procedure 10-A " Construction Work Permit Procedure" approved May 5, 1976. This procedure addresses these controls and calls for review by appropriate parties to evaluate the need
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for additional testing of systems modified by work forces under this procedure.
This matter is considered resolved.
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3.
Inspection Report No. 050-346/75-17 This report indicated the concern of the inspector over the
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conformance of an existing building on the site as an interim QA record storage facility th the requirements cf ANSI N45.2.9.
During this inspection the, licensee indicated that the building in question is no longer being considered as a record storage facility; however, the licensee indicated his intention to consider that area as a warehouse location Jor the storage of safety related components.
The inspector considers this matter resolved.
4.
Inspection Report No. 050-346/76-01 This report indicated TP 130.01.0 " Reactor Service Crane" did not conform to the test abstract contained in the FSAR.
During this inspection, Revision 1 to that procedure was
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reviewed, and the inspector noted that the omitted areas have --
been addressed. This matter is considered resolved.
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5.
Inspection Report No. 50-346/76-01
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This report indicated the licensee's intent to reconvene the Company Nuclear Review Board (CNRB) to participate in preoperational activities as outlined in the FSAR.
The inspector reviewed the CNRB meeting minutes for March 3,1976 (Meeting Number 2) and March 25, 1976 (Meeting Number 3).
The inspector has no further specific questions on this matter, and will continue to review CNRB activities as a part of his regular inspection activities.
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6.
Inspection Report No. 050-346/76-03 This report indicated that the licensee would include appropriate steps in heating, ventilating, and air-conditioning (HVAC)
system test procedures relative to controls over and confirmation of system damper settings established by construction phase -
duct work balancing activities. The inspector informed the licensee during this inspection that he has noted the existence of these controls on recent HVAC test procedures, and considers this matter resolved.
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Inspection Report No. 050-346/76-04
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kw This report noted the concerns of the inspector over an apparent
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conflict in the procedures utilized by the licensee to exercise administrative control over design changes.
During this
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inspection, the inspector reviewed these matters with represent-atives of the licensee's Quality Assurance, Quality Control, and
' Operations staffs and the actions befug taken to clarify this
matter. The inspector has no further questions on this matter.
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Inspection Report No. 050-346/75-12 r
o This inspection report referred to the adequacy of planned testing of the decay heat r'moval system to demonstrate the e
ability to maintain pump suction under reduced reactor vessel level as during periods of primary system component maintenance.
During this inspection, the inspector reviewed the recent
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revision (Number 2) to TP 203.03 " Decay Heat Removal System
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Preoperational Test" and noted that the revisions included additional tests to determine the satisfaction of NPSH requirements during maintenance activities. This revision is in the final
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stages of review. 'The inspector has no further questions on
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Management Interview
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A.
.At the conclusion of the inspection, a management interview was.
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conducted on June 11, 1976 with Mr. J. Evans, Station Superintendent and members of his staff.
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Moreover, due to the witnessing of the preoperational test by the
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inspector-following the above exit, the inspector contacted Mr.
l Evans again on June 15, 1976, by telephone to summarize his additional findings.
B.
Matters discussed and comments were as follows:
1.
June 11, 1976 Exit Interview
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a.
The inspector summarized his findings of an item
which represented a deviation of the licensee from commitments made to the Commission. (Paragraph 2.c(2),
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Report Details)- The licensee acknowledged the
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inspector's findings.
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b.
The inspector summarized his findings relative tok closing out several previously unresolved items.
(Section F - Summary of Findings)
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The inspector summarized the comments provided to licensee c.
staff members on the preoperational test procedures reviewed during this inspection.
(Paragraph 1,, Report Details)
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d.- The inspector summarized the comments provided to licensee staff members on several~ Administrative Procedures.
(Raragraph 2, Report DeEsils)
The inspector indicated that he had reviewed the status e.
of the flushing program, the -testing program, and the QA program for station operations.
f.
The inspector indicated that he inspected the installation of the surveillance coupon holders, and he had no questions on that matter at the present time.
However, he noted the substantial amount of metal chips present on the Core
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. Support Assembly as a result of_the holder installation.
As a consequence of these cleanliness conditions, the inspector requested and received a commitment from the
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r==*asured after the Core Support Assembly was cleaned.
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quent inspection.
2.
June 15, 1976 Telephone discussion with Mr. Evans The inspector indicated that he had witnessed a portion
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of TP 310.01 "SFAS Preoperational Test", and he had no technical questions regarding the conduct of the test.
b.
The inspector summarized his findings of noncompliance (Items A and B under Enforcement Items - Su= mary of Findings section).
The licensee acknowledged the inspector's
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REPORT DETAILS
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Persons Contacted The following persons were contacted during this inspection:
TECo Management
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L. Roe,'Vice President, Facilities Development
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TECo Operations Staff
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J. Evans, Station Superintendent
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T. Murray, Operations Engineer
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L. Stalter, Technical Engineer
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D. Briden', Chemist and Health Physicist B..Beycr, Maintenance Engineer
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J. Orkins, Instrument and Controls Engineer L. theime, Inspection Engineer J. Troknya, Office Supervisor W. Green, Assistant to Station Superintendent D. Miller, Assistant Engineer ~
R. Brown, Assistant Engineer
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J. Lingenfelter, Senior Assistant Engineer C. Gumphreys, Assistant Engineer
[N W.. Alton, Assistadt Engineer K. Yarker, Instrument Mechanic R. Luczak,' Instrument Mechanic
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R. Franklin, Training Supervisor J.' Hickey, Training Coordinator S. Hall, Shift Foreman
,R. Adney, Shift Foreman TECo Quality Assurance Department J. Lenardson, Manager K. Cantrell, Operations Quality Assurance Engineer J. Buck,' Operations Quality Assurance Engineer P.'Narducci, Quality Control Engineer E.,Wilcox, Field QA Specialist J. Marchese, QC Inspector C. Daf t, Field QA Engineer TECo Power Engineering and Construction Staff E. Novak, General Superintendent F. Miller, Nuclear Fuels Engineer G. Hurrell III, Senior Assistant Engineer
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TEco Purchasing Department
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R. Vick, Manager of Purchasing
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J. Werner, Director of Purchasing Bechtel Start p_
D. Brimmer, Assistant Project Start-up Engineer
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J. Landon, Flushing Coordinator
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ITI E. Michaud, Test Program Manager
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C. Endicott, Test Scheduler
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J. Albert, Test Engineer Results of Inspection 1.
Review of Test Procedures The following approv.1 test procedures were reviewed by the a.
inspector. The licensee was informed that the inspector had no questions regarding these approved procedures.
TP 267.01 Station Drainage System Preoperational Test.
TP 305.01 Reactor Protection System Preoperation Calibration
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Test.
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TP 330.04 Control Rod Drive Control System Integrated Test.
TP 600.05 R. C. Chemical Addition System Test During Hot
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Functional Testing.
TP 800.02 Nuclear Instrumentation Calibration at Power.
TP 800.15 Unit Power Shutdown Test.
t TP 800.26 Loss of External Load Including Loss of Offsite
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Power.
TP 800.29 Dropped Control Rod Test.
b.
The following comments were provided to the licensee on the indicated test procedures by the inspector.
These items are to be resolved either prior to implementing the test procedure or before final acceptance of test results, as appropriate.
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~~s (1) TP 110.01. Emergency Ventilation Systems Preoperational Test:
The acceptance criteria of step 8.7 is incorrect
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and should be revised since the criteria stated includes diesel starting times and load sequencer logic while the test will not be conducted using the emergency AC power
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sources.
(2) ~ TP 160.01, Containmezr Air Cooling System Test: The licensee is to take the necessary steps to address steps 3.2 and 3.7.of the. test abstract on page 14-21 of the
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FSAR regarding measurements-of -motor RPM.
Moreover, the
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licensee is to provide galculations or documentation
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which substantiate the acceptance criteria established for the cooler " effectiveness".
The licensee is also to determine the appropriate fan capacity values (step 8.1.4 of procedure) and to clarify whether the values shown on Table 6-5 (page 6-24) of the FSAR relate to single or multiple fan operation.
(3) TP 170.01, Axuiliary Building Radioactive Ventilation System:
The licensee was informed that the acceptanca criteria in the procedure (steps 8.41 and 8.42) do ne t adequately address criterion-4.2 of the test abstract on page 14-24 of the FSAR.
(4) TP.275.03, Main Feedwater Valve Preoperational Test: The
/N licensee was informed that the 15 second closure time for (
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the valve is not in accord with.their submittal for the Technical Specifications on the Steam and Feedwater
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Rupture Control System.
(5) TP 315.01, Steam and Feeduater Rupture Control System
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Preoperatienal Test:
The licensee is to revise this procedure as appropriate to include the testing of the differential pressure inputs to this system.
-(6) TP 330.03, CRDM Functional Test:
The licensee will-revise step 5.15 of this procedure to conform to the requirements of their procedure AD 1801.00 regarding the time period
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for reverification of test prerequisites. Moreover, the licensee will consider the adoption of an appropriate tracking system to assure that all the testing of all 61 units are completed as required.
(7) TP 340.01, Seismographic Monitoring System Test: The licensee, for the present, will consider sending the
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seismic monitoring system primary sensors to the manufacturer for recalibration if their previous calibrations were i
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completed more than 18 months prior to the expected fuel loading date. The licensee was informed that the inspector
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will obtain additional guidance as to whether such recalibrations j
will be required.
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i (8) TP 800.20, Rod Worth Measurements:
The licensee is to conduct a review of the methodology of this procedure
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(regarding the use of the Reactimeter) to provide assurance
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that power coefficient effects, predominantly the doppler
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effect, are satisfactorily accounted for.
This material
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will be reviewed by ?he inspector during a subrequent inspection.
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Review of Administrative Procedurds
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The inspector provided represent" tives of the licensee with ccaments a
on the following approved Administrative Procedures:
a.
AD 1828.10, Davis-Besse Operator Training Program:
The inspector.
noted that the FSAR description of the training program for i
replacement operators lacks sufficient detail to permit a
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datailed review of this pro'cedure; however, the inspector did
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not note any significant deficiencies in the program when
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compared to the program being used.for initial staff trainingt The licensee was informed that the inspector intends to pursue
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with his management whether or not the licensee's FSAR description
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should be made more specific in this area.
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AD 1839.00.1, S tation Op erations :___The inspec to r..inf o rmed.. the. _ _ _....
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licensee that no significant deficiencies were-noted during
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the review of this procedure.
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c.
AD 1848.03 Distriuution of Controlled Documents;
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AD 1848.07 Control and Disposition of Records
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Generated by the DBNPS Operations Section; AD 1848.09 Control and Disposition of Records Generated by the Technical Section; AD 1848.11 Control and Disposition of Records Generated
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by the Inspection Section.
AD 1848.12 Control and Disposition of Records Generated i
by the DBNPS Office Supervisor.
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AD 1848.17 Record Retention Requirements.
(1) As a result of the inspector's review of this group of
procedures, the licensee was informed that the central files of the station would now be viewed as one of the
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quality assurance record storage facilities of the licensee N/
which must meet the requirements of ANSI N45.2.9 "hequirements for Collection, Storage, and Maintenance Quality Assurance
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Records for Nuclear Power Plants".
This conclusion is
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based on the duration of quality record storage in the
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central files, as well as the quantity of records to be
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(2) 13ue inspcetor also noteh that during.his review of approved procedure AD 1847.17 " Record Retention Requirements" he
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However, several of the station operating records are quality
- records as defined by the QAP 2170 series, and QAP 2172-indicates that only the QA Manager or his designee-may
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establish retention periods for quality records.
This procedure (AD 1847.17) was reviewed and approved by the designee of the QA Manager, and the above conflict with -
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the requirements of QAP 2172 was not recognized and
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Before the conclusion of the I
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acti 4-Anitiated by the licensee to correct this cond
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Consequently, the licensee wil. not be required to respond to this deviation.
3.
Test Program Scheduling The inspector was briefed on the status of the Test Program for the
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facility. No deficiencies were noted in upcoming test activities with regard o regulatory requirements or licensee commitments.
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During the reviaw of testing activities, it was noted that the licensee has not provided abstracts in the FSAR for the following major systems tests:
Araxiliary Feedwater System
Steam and Feedwater Rupture Control System Make-up System Main Feedwater Stop Valve Piping Dynamic Testing h
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It was noted that such tests are to be performed by the licepsee, N- /
utilizing all appropriate technical and administrative controls.
The licensee was informed that the inspector will contact his management to see if the abstracts of the planned tests should be submitted as revisions to the FSAR.
4.
Control over Turned-Over Systems
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Previous inspection. reports (No. 050 346/75-06, No. 050-346/75-22, and No. 050-346/76 '1) have. discussed the actions by the licensee
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to control any-wot.
y construction. forces on systems.which have been turned over for licensee testi and operation.
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During this inspection, the inspdctor confirmed that the licensee had approved and issued Start-up Administrative Procedure 10-A
" Construction Work Permit Procedure" on May 5, 1976.
This procedure established controls over the work on turned-over systems by construction forces and calls for subsequent review by appropriate personnel to determine if any completed preoperational testing of the repaired or modified system is required.
The inspector reviewed six completed Construction Work Permits
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No deficiencies relative to the controls established in the Start-up Procedure were noted during this review.
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5.
Review of Test Packages
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TP 180.01, " Station Fire Protection. System":
The inspector reviewed-this partially completed test procedure.
The package
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was reviewed for conformance to tha iequirements of the. licensee's-AD 1801 series of administrative procedures regarding test conduct, identification of deficiencies and procedure modification controls.
No significant deficiencies were noted during this review.
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." 200.01, " Reactor Internals Vent Valve Removal and Replacement, Exercise, and Inspection Test":
The inspector reviewed this
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test package and noted the following:
(1) The measured opening forces for the vent valves were in
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the range of 22-25-lbs. to lif t the valves from their seats and 120-125 lbs. to achieve full opening.
These
. fully open forces did not meet t.e. acceptance criteria of the test procedure revision in use (Revision 2).
Based on a memorandum (SOM Number 135) from the B&W Site Operations Manager, revision 3 to the test procedure was modified to reflect an acceptance criteric of 130 lbs.
for the full open force.
The memorandum indicated that B&W had incorrectly transmitted the vendor's force values. -
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_.-_y The inspector reviewed the B6W instruction manual (01-0012-01) for the 14" Internals Vent Valves Manufar
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[nt tured by Atwood and Morrill Company, Salem, Massac,huss*rtm and confirmed that the vendor identified forces were 25 lbs.
to unseat and 130 lbs. to hold open (approximate values for new valves). Moreover, the vendor's inspection records for the supplied valves showed the measured unseating forces to be 20 lbs. while the full open force was 125 lbs. for each valve. The inspector had no further questions on this matter.
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(2) The inspector also noted that the detailed inspections of-.
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the valve surface condi. tion as-called for in revision 2
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of the procedure could hot be accomplished.
Revision 3.
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of the procedure substantially reduced the degree of detailed inspection reiuired. The inspector noted that t
FSAR Section 4.2.2.4, pages 4-20h and i indicate that-during refueling outages ".
the valve disc can be
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raised and a remote visual inspection of the valve body and disc sealing faces can be performed for evaluation of observed surface irregularities." The inspector understands that the licensee will discuss-the adequacy of their
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present inspection method (as a result of their test procedure results) with the Office of Nuclear Reactor Regulation to meet their above FSAR commitment.
The acceptablity of these test results will be treated as an
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-open-item by the -inspector pending the results of these fiscussions.
J 6.
Flushing Activities The inspector reviewed the status of system flushing activities at the facility. He noted that the flushing of the majority of safety related systems is more than 50% complete.
A review of a sampling of Water Quality Log Sheets used in the analysis of the cleanliness of the Component Cooling Water, High Pressure Injection, and Decay
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Heat / Low Pressure Injection systems was performed.
No deficiencies
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with regard to the requirements of AD-1835.00 " Instructions for Flushing Program" were observed during this review.
Core Flood Tank Testieg During the review 4 TP 2(,.03 ( vision 1) " Core Flooding System Functional Test" at an ea+ - ter
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the inspector noted that 2e.Acensee had not specified a flow test
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of the core flood tanks to verify-that they would discharge into
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the vessel in accordance with their design.
At the time, that test.
was under evaluation and was to be added at a later date.
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The inspector now understands that the licensee does not intend to
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conduct a flow test of the tanks since such a test is rot identified in the FSAR test abstract'for core flood tank testing. The inspector indicated that he planned to pursue this question with his management-to determine if the Office of Nuclear Reactor Regulation had completed its review of that proposed test abstract, and had concluded that it constituted a suitable core flood tank testing program.
The inspector will consider this as an open item until he obtains.the appropriate information.
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8.
Master Punch List Controls a::
The inspector reviewed the contro5s. of _the. licensee. in assuring that nonconformance or engineering inspection report _ findings which
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affect. turned-over systems are added to the Master Punch List in a timely fashion. These controls are to assure that the affected items will be considered and appropriately dispositioned prior to preoperational testing of systems.
This area was discussed previously -
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in IE Report No. 050-346/75-22. The inspector selected NCR's added to the Bechtel QC Punch List and checked the Master Punch List for affected systems to see if they had been eppropriately transferred.
He noted that NCR B086B affected Start-up Systems 49A, 493, and 52 -
but was entered on the Master Punch List for system 52 only. A
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sampling of six other NCR's showed no deficiencies in the Master
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Punch Lists with ;cgard to their entries._
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Before the: conclusion of the inspection, the inspector determined
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that all system engineers of the start-up organization (responsible for maintenance of the Master Punch Lists) had been instructed to re-check their assigned systems. Moreover, the group icaders were to audit these results.
The inspector indicated that he will continue to follow these activities during subsequent inspections.
9.
Preoperational Tes t Witnessigg During this inspectiut. th: inspector witnessed portions of the conduct of preoperational test TP 310.01 "SFAS Preoperational Test".
The inspector witnessed the majority of the conduct of Section 7.6 of the test procedure for channels 3 and 4 of the SFAS.
The inspectoc concluded the following from this test observation:
a.
Test prerequisites were completed.
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Test personnel were adequately indoctrinated to conduct (,,1 the test.
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The test was. conducted in accordance with the procedure.
d.
Test results appeared acceptable (direct conformance to the acceptance criteria of the test will be evaluated at the conclusion of the test).
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Test personnel actions appeared appropriate and timely e.
during the conduct of the test,.
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f.
Test deficiency identification and. procedure modifications were conducted in accordance with the licensee's administrative requirements.
In evaluating this last item, the inspector sought to obtain a copy of AD 1801.00 "The Conduct of Preoperational Testing and Start-up
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Program". This procedure was not present, as required by the licensee's document control procedures, in either the control room or the shif t foreman's copy of the Davis-Besse Administration
Manual. -The licensee was informed'that this was an item of noncom-pliance in-that it is contrary-to-Criterion VI of Appendix 3 to 10 CFR 50.
During the review of the preoperational test on channels 1.and 2
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completed two evenings previous to the inspector's test witnessing,
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the inspector noted that the licensee's QC inspector did not witness one of the-witness points designated for channel 2 on the Quality Control Verification Sheet.
The licensee was informed that this failure to attend a witness point was contrary to their procedure QCI 3110, and was an item of noncompliance with Criterion V of Appendix B to 10 CFR 50.
10.
Quality Assurance Program for Station Ooerations During this inspection, the inspector received briefings on the status of program development to correct inadequacies identified
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The inspector will continue to monitor the development activities in these areas to establish an appropriate schedule for reinspection.
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