IR 05000346/1978013
| ML19319B787 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 06/27/1978 |
| From: | Knop R, James Smith, Tambling T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19319B633 | List: |
| References | |
| 50-346-78-13, NUDOCS 8001270255 | |
| Download: ML19319B787 (14) | |
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OLJ U.S. NUCLEAR REGULATORY C0te*ISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-346/78-13 Docket No. 50-346 License No. NPF-3 Licensee: Toledo Edison Company Edison Plaza 300 Madison Avenue Toledo, Ohio 43652 Facility Name: Davis-Besse Nuclear Power Station, Unit 1 Inspection At: Davis-Besse Site, Oak Harbor, Ohio Inspection Conducted: April 11-14, 25-28, and May 9-12, 1978 T,d.l
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Inspectors:
T. N. Tambling (,[1.-7 h/ 7
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R. C. Knop (4/25-28/78)
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J. Smith Gkl7/7f
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(5/9-12/78)
Other Accompanying Personnel:
Dr. P. Shewman (4/26/78)
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Approved By:
R. C. Knop, Chief Reactor Projects Section 1
Inspection Summary Inspection on April 11-14, 25-28, and May 9-12, 1978 (Report No. 50-346/78-13)
Areas Inspected: Routine, unannounced inspection of maintenance activities, calibrations, nonroutine events, followup on Part 21 reports, chemical decon-tamination, conditions of the license and tour of plant areas. The inspection involved 158 inspector-hours onsite by three NRC inspectors.
Results: Of the seven areas inspection, no items of noncompliance or deviations were found in six areas; one apparent item of noncompliance was found in one
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area (Infraction - failure to adhere to procedures - Paragraph 3).
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O DETAILS 1.
Persons Contacted
- J. S. Grant, Vice President, Energy Supply
- T. Murray, Station Superintendent
- L. Stalter, Technical Engineer
- J. Evans, Assistant to Vice President, Energy Supply
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- B. Beyer, Maintenance Engineer
- J. Buck, Operations Quality Assurance Manager
- C. Daf t, Operations Quality Control Engineer I
- D. Hitchens, I&C Engineer
- W. Green, Assistant to Station Superintendent
- G. Hurrell, Power Engineering
- D. Briden, Chemistry and Health Physicist
- T. Hart, Quality Assurance Engineer W. Mitchell, Power Engineering The inspector also talked with and interviewed other licensee employees, including members of the technical, maintenance, operations, and QC staf f.
- Denotes those attending the exit interviews.
2.
Licensee Actions on Previous Inspection Findings (0 pen) Unresolved Item (50-346/76-12): The licensee was to rewrite T.P. 800.26, " Loss of Load and Offsite Power Test" to meet the intent of Reg. Guide 1.68.
This item is still open pending the answers to other questions and the rewriting of the test. The licensee is still evaluating possible design changes.
(Paragraph 13)
(0 pen) Unresolved item (50-346/77-06): The licensee was to establish a preventative maintenance program for the period recalibration of instrumentation and controls used to determine compliance with Technical Specification requirements. The inspector reviewed the program developed by the licensee, but found that no written guides and methodology had been established to provide the basis for determining which instrumentation should be selected.
(Paragraph 12)
3.
Maintenance
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i The inspector continued the examination of the licensee's maintenance activities started during a previous inspection. This examination includes the review of selected maintenance work orders for adherence
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to administrative procedures, adherence to technical specification
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requirements, post maintenance testing for operability, qualification
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of personnel performing the maintenance, and procurement control of replacement parts.
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O The inspector found several examples where the licensee apparently f ailed to adhere to the requirements of administrative and surveil-lance procedures. Technical Specifications 6.8.1 required that written procedures shall be implemented (i.e., adhered to).
The following are specific examples:
Surveillance Procedure (ST) 5013.03, control rod program veri-a.
fication performed March 30, 1978. This ST was performed to demonstrate operability after maintenance (trouble shooting)
on the API's.
Steps 5.3.2 of enclosure 6, step 5.11 (prerequisite)
and step 6.10 of enclosoure 12 were not properly signed off as having been completed. The inspector did note subsequent performance of the ST on March 31, 1978, was properly completed.
b.
Maintenance Instruction (MI) IL-1701 used in association with maintenance work order (MWO) IC 753-77 performed November 19, 1977. This MI has check off for each step of the procedure.
In the copy of the procedure attached to the MWO, the person performing the work failed to initial the steps.
Administrative Procedure (AD) 1844.0, Maintenance. Item 17 c.
states in part, "...if testing is required to satisfy sur-veillance, code, etc., the shift foreman shall record the applicable test number on the MWO and sign the MWO after
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i testing is complete. If no test is required the shift fore-man / foremen shall enter N.A. on the MWO."
MWO I&C 277-78,
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and I&C 738-77 and 77-0973 are examples where the required information was not entered on the MWO. The inspector did note that post maintenance testing records were available but had neither been attached to, nor referenced on the MWO.
d.
A.D. 1838.02, Performance of Surveillance and Periodic Tests.
Steps 6.1.2 states in part, that after the shift foreman reviews the test results, tie shall sign the data cover sheet indicating that Technical Specification requirements have been met.
ST 5031.14, SFRCS monthly test was performed November 1, 1977. During the performance of the ST there was a test deficiency associated with RC 3602. The shift foreman failed to note the deficiency and take the action required by the Technical Specifications. It was not until November 17, 1977, as a result of a subsequent review that the deficiency was noted and the defective instrument channel was tripped in accordance with table 3.3-1, item 8, action statement No. 3.
(The licensee reported the failure to the instrument channel, i
LER 33-77-90).
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O In the exit interview the inspector stated that these examples represented an item of noncompliance for f ailure to properly adhere to procedures as required by Section 6.8.1 of the Tech-nical Specifications. It was further stated that these examples represented a possible generic or symptomatic problem indicating a breakdown in the general adherence to all aspects of procedure requirements.
4.
Reactor System Decontamination The inspector interviewed representatives of the licensee to verify that adequate steps have been taken in the use of chemical decontam-ination solution to prevent uncontrolled introduction of these solu-tions or their residues within the reactor coolant system boundaries.
The discussion also covered possible degradation of components due to the use of chemical decontamination solutions.
The inspector found that decontaminations and decontamination solutions are under the control of the Chemistry and Health Physicist. All solutions have been evaluation for chemical Content and compatibility with the materials on which they are to be used.
To date, the licensee has not done any significant decontamination s
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on reactor coolant system components. And in these cases, the solvent V
has been water.
The licensee has no plans in the immediate future for reactor coolant system components decontaminations.
5.
Auxiliary Shutdown Cabinet, Part 21 Report ArepresentativeofthelicenseeinformedRegionIIIbytelegone on March 10, 1978, with a followup report on March 15, 1978,- con-cerning a potential defect in the mounting of the auxiliary shutdown cabinet. The defect involved a failure to anchor the cabinet by external gussets as called for by the applicable installation drawings.
Documentation associated with this defect was previously reviewed by the inspector (Inspection Report 50-346/78-07). During this inspection the inspector verified that the corrective action had been completed via MWO 78-0484
,1] Ltr to J. G. Keppler, From L. E. Roe, Serial No. 423, dated 3/15/78.
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Environmental Qualifications Of Taped Electrical Terminations, Part 21 Report A representative of the licensee informed Region III by glephone on April 14, 1978, with a followup report on April 17, 1978-concerning a potential defect in taped electrical terminations using "Scotchfil" brand electrical insulating putty covered by Scotch Band 33+ electrical tape.
The material was not qualified for the environmental conditions.
The inspector reviewed licensee's documentation associtted with discovery of this defect. Within this review, it was determinea that the licensee was made aware of the potential defect by a leter from the Bechtel Company dated April 4, 1978 (received by Toledo Edison Company April 11, 1978), advising them about a concern about the use of the "Scotchfil" taping method on several systems.
A study had been conducted by Bechtel at the request of Toledo Edison as part of a review in response to IE Bulletins. After an evaluation by the licensee, the defect was reported to the NRC under Part 21 requirements.
The inspector verified that the corrective action was scheduled for the current outage. A facility change supplement has been initiated O
and was scheduled for review by the Station Review Board and Station k
Superintendent.
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7.
Radiation Surveys The inspector reviewed a radiation survey report based upon readings performed at 100% power. It was noted that in several areas that radiation levels exceeded values predicaed in the FSAR. Also because of high radiation levels inside containment, the licensee has restricted entry during power operations. In the exit interview the inspector expressed concern about high neutron and gamma levels and their potential effect or ccess to containment, personnel and equipment. This item will remia unresolved pending review of the licensee's evaluation.
8.
Review of Nonroutine Events Reported by the Licensee The inspector reviewed licensee actions with respect to the following listed nonroutine event reports to verify that the events were reviewed and evaluated by the licensee as required by Technical Specifications, that corrective action was taken by the licensee, and that safety limits, limiting safety settings, and limiting conditions for operation were not exceeded. The inspector examined selected
Station Review Board minutes, the licensee investigation reports, logs, and records; inspected equipment; and interviewed selected personnel.
2_/ Ltr to J. G. Keppler From L. E. Roe Serial No. 429 dated 4/17/78.
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Loss of intermediate range nuclear instrument NI-3 (NL-33-a.
77-68).
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Steam generator 1-2 level exceeded 348 inches (NP-33-77-72).
Standby component cooling water heat exchanger service water c.
outlet isolation valve closed (NP-33-77-lll).
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Inlet balancing dampers to emergency ventilation fans found closed (78-004).
Containment spray pumps inoperable (78-008).
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Diesel generator 1-1 turbocharger replacement (78-018).
Decay heat cooler outlet valve settings (78-019).
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Both auxiliary f eedwater systems inoperable (NP-32-77-11).
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Loss of D.H. flow and NI channel due to operator error j
(NP-33-77-7).
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Containment emergency air lock surveillance not performed as
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required (NP-33-77-15).
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Decay Heat Pump 1-1 suction valve closed (NF-33-77-26).
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Containment integrity violated due to inoperable air lock (NP-33-77-36).
Containment isolation valve RC240A inoperable (NP-33-77-40).
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Boration flow path inoperable (NF-33-77-43).
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AFT turbine 1-2 failed to start on actuation signal (NF-33-o.
77-45).
Loss of power to CS pump 1-1 discharge valve and containment p.
relief valve isolation valve (NP-33-77-48).
Auxiliary feed pump 1-1 declared inoperable to replace cooling q.
water relief valve (NP-33-77-62).
RCP l-1-2 tripped and declared inoperable (NP-33-77-64).
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Low specific gravity for station battery IN, cell 32 (78-013).
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API declared inoperable (78-16, and 77-34).
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MS 101 inoperable (78-24).
SFAS channel 3 inadvertently placed test trip bypass (78-32).
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During the exit interview, the inspector requested supplemental reports for LER's78-018, 78-16, 78-21, 78-34, 78-24 to cover final corrective action. Assignment of cause code for LER 78-18 was also requested. LER NP-33-77-111, NP-33-77-45 and NP-33-77-64 will be held open pending completion of investigations.
The Facility Change Request (FCR) written for NP-33-77-64 close out had been cancelled with followup investigation based upon a memor-andum. Apparently no tracking mechanism had been assigned to the memorandum to insure the work had been completed.
FCR written for followup on LER 33-77-45 was initiated August 18, 1977, and no apparent action had been taken since September 22, 1977.
During the exit interview the inspector informed the licensee of this apparent breakdown in their tracking mechanism for closeout of LtR's.
The inspector noted that the licensee had identified and corrected nine items with respect to Technical Specifications.
No other items of noncompliance were identified.
The following licensee event reports were reviewed and closed out I
on the bases of an inoffice review and evaluation.
CCW heat exchanger 1-1 outlet isolation valve declared inoperable (78-09).
Personnel airlock failed leak rate test (78-12).
PDIS 26860, Feedwater/ steam generator delta P switch did not actuate at desired setpoint (78-15).
API for control rod 12 inoperable (78-21).
Unidentified RCS leakage greater than 1 gpm (78-25).
Failure of AF 3820, AFP l-1 to S/G l-1, stop valve to open during l
testing (78-27).
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SFRCS channel 1 S/G l-1 level indicator inoperable (78-28).
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H blower motor trip (78-35).
AFP l-2 inoperable to allow maintenance to repair steam leak (78-36).
9.
Condition 2.c(3) (n) to the Licensee
Condition 2.c(3)(n) to the facility operating license required the licensee to install flow measuring devices to measure at least 40 gpm for boron dilution when the plant is operating in either the hot leg drain mode or the pressurizer spray mode.
The inspector reviewed the licensee's documentation on the design specifications, installation drawings, and seismic qualifications of the instrumentation to verify that the required flow system and
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flow monitoring system had been properly installed. Testing of the system had been done under T.P. 203.03, decay heat removal system preoperational test.
10.
Plant Tour _
A plant tour was conducted by the inspectors on April 26, 1978, accom-panied by Dr. P. Shewmon of Ohio State University.
11.
Calibration V
a.
Record Review The inspector reviewed selected records relating to the cali-bration of equipment associated with safety related and/or functions to determine if calibrations were in conformance with Technical Specification requirements and other requirements established by the licensee. The inspector established his review to:
(1) Verify that the frequency of calibration had been met.
(2) Verify that during calibration of the selected components that service status of the component or system was in conformance with applicable Technical Specific tions.
(3) Verify that calibration procedure.s contained the following information:
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(a) Review and approval as required by Technical Speci-l fications.
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(b) Acceptance values for trip settings using applicable Technical Specification requirements.
(c) Detailed stepwise instructions.
(4) Verify that the technical content of procedures, if fol-lowed, would assure satisfactory calibrations.
(5) Verify that trip points conformed to Technical Specification i
requirements.
(6) Verify that two individuals having responsibility for per-forming calibrations are properly qualified.
(7) Verify for six gauges, instruments or other measuring /
testing devices used as primary standards in the cali-l bration of plant equipment that:
(a) Calibration frequency was met and accuracy verified.
(b) Accuracy is traceable to the National Bureau of Standards or other indepentent testing organization.
(c) Storage and control of the selected devices is proper.
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Observation of Calibration
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The inspector observed the calibration of the Steam generator 1-1 startup level transmitter and associated amplifier and level indicator to verify that the performance of the cali-brations was consistent with approved plant procedures. In addition, the inspector reviewed the calibration procedures for 20 plant flow, level, temperature, and pressure instruments.
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Acceptance Criteria
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The inspector used the following criteria:
(1) Technical Specifications.
(2) Calibration requirements established by licensee for systems required by LCO's, in Technical Specifications.
(3) ANSI Standard N45.2.4-1972.
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(4) Pattern and practice common to power industry.
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V (5) Inspector judgment.
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Findings No items of noncompliance or deviations were identified.
12.
Preventative Maintenance Program for Instrumentation and Control Systems Calibration The licensee committed to establish a management control system to assure periodic recalibration of instruments and controls used to determine compliance with Technical Specification requirements including those covered by Section XI of the ASME Code. This system was for instrumentation and control ytemsnotspecificallydelin-eated in the Technical Specification The inspectors reviewed and evaluated the scope of this preventative maintenance (PM) program developed by the licensee.
The PM area selected for review was the one developed by the instrument and con-trol (I&C) group.
Discussions with licensee personnel indicated the guidance for selection of instrumentation for inclusion into the PM program
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consisted of a review of the Technical Specifications and ASME (
equipment. The licensee stated no specific written guidance had been used, but that the list of inscrumentation had evolved through
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the ef forts of several persons working individually and as groups.
The inspector found no evidence of a systematic evaluation to show how each component was selected for or rejected from the PM program.
There was no evidence of listing components by safety related systems, limiting conditions of operations, support or auxiliary systems providing support roles to safety related or Technical Specification systems, or ASME systems.
During the exit interview the inspector stated that the PM program as established appeared to be deficient in that written guidance had not been provided and that there was no specific evidence to show the methodology used in selecting or rejecting components for the PM calibration program. The basic weakness was in the lack of criteria for selection of non-Q listed items used to support the
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surveillance and operability of safety related and/or Technical Specification systems.
While the TECO Nuclear Quality Assurance Manual (UQAM) provided
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guidance, general philosophy and references to Q-listed and ASME
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I&E Inspection Report 50-346/77-06 and licensee's response dtd
'N 5/17/77 and 2/8/78.
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it does required to support safety related systems and components, not provide a detailed listing nor the methodology for determiring an appropriate list. For example, exhibit C, item 1 of the NQAM identifies " structures, systems, and components which are on the Q-list" as one definition of " safety-related." Though acceptable for general guidance, this does not provide detailed FM program guidance for the various disciplines involved in the FM program.
There is a need for the development of a list of safety-related systems and associated components that have to be calibrated to ensure system operability.
This list will ptavide a link between the general guidance in the QA manual and a 'blish on a system
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basis which systems perform an active versus gassive safety role which in turn will dictate the degree and type of preventative maintenance. Item 2 of Exhibit 2, "non-Q list items which would have either a direct or indirect ef fect on the design basis and/or functions of Q-list structures, systems, or components," will most probably require a different approach.
In some cases, effects of "non-Q" or "Q" can be assessed by system review and identified and controlled as necessary during plant operation and maintenance.
The inspector stated that he considers this item unresolved until written guidance and methodology are established and implemented.
13.
Conduct of Loss of Load Test and Aspects of Station Electrical O
Design Related Thereto The inspectors met with Mr. Bill Mitchell of the Power Engineering Department of Toledo Edison, Mr. Terry Murray, Davis-Besse Station Superintendent, Mr. Bill Green, Davis-Besse on May 11, 1978 to discuss the following subjects:
Ef fect of a LOL (loss of load) and a subsequent generator
problem on initial reactor coolant pump flow assumption and pump coastdown.
Blocking of fast transfer to of fsite power via synchro-check
relaying following disconnection of the TG (turbine generator)
from the switchyard.
Basis for the Technical Specification " Allowable setpoint of
3588 volts for the essential bus feeder breaker trip.
Ef f ect of a LOL and a subsecuent generator problem on initial a.
reactor coolant pump flow assumption and pump coastdown
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The inspectors' concern in this area is the assumption in the accident analysis 15.2.5 that a rapid transfer to offsite power l
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OO will occur if the 13.8KV is lost from the station auxiliary transformer. The station relaying as designed prevents fast transfer following a plant trip whenever breakers 34560 and 34561 are open.
House load following such a trip would remain on the TG for 30 seconds whereupon a manual transfer to offsite power can be initiated. This 30 second period when the 13.8KV bus voltage could degrade thereby reducing flow to something less than 1.00% with no fast transfer is not mentioned in 15.2.5 of the a.:cident analysis. TECO indicated they would discuss this inte nally and with B&W and respond to this concern.
During a followup telephone conversation on May 22, 1978 with Messrs. Fred Miller and Bill Mitchell of TECO Engineering they stated that this concern had been considered in the B&W analysis used and the reactor coolant pump coastdown show in 15-2.5 of the accident analysis is valid as depicted.
The inspectors had no further questions concerning this matter.
b.
Blocking of fast transfer to offsite power via synchro-check relaying following discennection of the TG from the switchyard
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The inspectors' concern in this area centered about the varicus faults that could be encountered (during the 30 second period s,,
following disconnection of the TG from the grid) and whether these faults have all been considered in implementing the fast transfer block logic. The discussion indicated that potential faults not included in this category were generator faults.
TECO indicated that they would discuss this internally.
During a followup telephone conversation on May 22, 1978 with Messrs. Miller and Mitchell of TECO Engineering, several features of the fast transfer were discussed. The operational and equipment protective features of this design area have not been fally evaluated at this date.
This matter is con-sidered unresolved pending further evaluation of the Davis-Besse fast transfer design.
c.
Basis for Technical Specification " Allowable" setpoint of 3588 Volts for the Essential Bus Feeder Breaker trip The inspectors' concern with this value was that it exceeded the nominal 10% bus undervoltage trip setpoint. Since most motors are sized and specified to start and accelerate their s
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loads at 10% undervoltage it was not evident why the " allow-able" was greater than 10%. Discussions with TECO at the meeting did not provide the basis but TECO indicated that they would determine the basis for the value and respond to the concern.
During a followup telephone conversation on May 22, 1978, with Messrs. Miller and Mitchell of TECO Engineering they established that this value had been determined by their architect-engineer (Bechtel Corp.) by analysis and that the value did not represent a starting or load acceleration problem for equipment powered from the 4160 or lower voltage buses. The inspectors had no further questions concerning this matter.
14.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. Unresolved items disclosed during the inspection are discussed in paragraphs 7, 12 and 13.
15.
Exit Interview p)
The inspector's met with licensee representatives (denoted in Para-t
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graph 1) on April 14 and 28 and May 12, 1978. The inspectors summarized the scope and findings of the inspection. The licensee's representatives made the following remarks in response to certain of the items discussed by the inspectors.
Stated that they would keep track of decontamination of reactor coolant system components noting the type and strength of chemicals used, method to remove residues, evaluation of cateria. compati-bility and any testing required to insure no physical degradation of the component.
(Paragraph 4)
Acknowledged the inspectors remarks regarding the apparent item of noncompliance.
(Paragraph 3)
The licensee acknowledged the inspector's concern about the high radiation levels inside and around containment and stated that they were evaluating the problem. As an interim measure they would perform a safety evaluation on the effects of continued operation with levels greater than predicted in the FSAR. The licensee also stated all problem areas have been properly posted and controlled in accordance with requirements.
(Paragraph 7)
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Acknowledged the inspectors comments and request for supplemental reports on certain reports. The licensee stated they would review their tracking mechanism for LER's and take appropriate action.
(Paragraph 8)
The licensee acknowledged the inspectors remarks regarding the PM program regarding calibration of components to determine compliance i
with Technical Specification requirements.
They stated that they would review the concerns.
(Paragraph 12)
Stated that they would review the inspectors questions regarding the conduct of the loss of load test and other aspects relating to the station electrical design.
Subsequent to the exit interview, a conference call was held with representatives of the licensee on May 22, 1978 where additional information was provided. At this time the inspector stated further review would be required on one
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of the items.
(Paragraph 13)
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