IR 05000346/1982008

IE Insp Rept 50-346/82-08 on 820301-0505.Noncompliance Noted:Failure to Meet Storage & Testing Requirements & Failure to Provide Written Authorization for Disassembly of Motor Control Ctr

ML20054K454
Person / Time
Site:	Davis Besse
Issue date:	06/16/1982
From:	Byron P, Rogers W, Streeter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20054K451	List: IR 05000346/1982008 ML20054K450 ML20054K453
References
50-346-82-08, 50-346-82-8, NUDOCS 8207020154
Download: ML20054K454 (8)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-346/82-08 Docket No. 50-346 License No. NPF-3 Licensee: Toledo Edison Company Edison Plaza, 300 Madison Avenue Toledo, OH 43652 Facility Name: Davis-Besse 1 Inspection At: Oak Harbor, OH Inspection Conducted: March 1 - May 5, 1982 Inspectors: W. R6ge,f rs Q f z-y

Approved By: Acting Chief '!N Projects Section 2C Inspection Summary Inspection on March 1 - May 5, 1982 (Report No. 50-346/82-08)

Areas Inspected: Routine resident inspection of actions on previous inspection findings, monthly maintenance observation, monthly surveil-lance observation, licensee event reports; IE Circulars; plant opera-tions; refueling activities; inspection during long-term shutdown; and locked valves. The inspection involved 228 inspector-hours onsite b two NRC inspectors including 60 inspector-hours onsite during off-shift Results: Of the nine areas inspected, no items of noncompliance or deviations were identified in six area Three items of noncompliance were identified in three areas (failure to meet storage requirements -

Paragraph 7; failure to meet testing requirements - Paragraph 8; failure to provide written authorization for disassembly of motor control center F16B - Paragraph 9).

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PDR ADOCK 05000346 G- PDR

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DETAILS 1. Persons Contacted

• T. Murray, Station Superintendent B. Beyer, Assistant Station Superintendent

• S. Quennoz, Assistant Station Superintendent

• J. Werner, Administrative Coordinator Miller, Operations Engineer Briden, Chemist arml Health Physicist L. Simon, Operations Supervisor Daft, QA Director

• J. Greer, QA Supervisor W. Green, Procurement Services Manager R. Phillips, Material Control Operations Manager C. Roshorg, Procurement Director

• Denotes those attending the exit interviews on March 15 and May 5, 198 The inspectors also interviewed other licensee employees, including members of the technical, operations, maintenance, I&C, training, construction, and health physics staf . Action on Previous Inspection Findings (Closed) Open Item (346/81-18-05). The inspector verified that EP 1202.11, SP 1104.11 and SP 1104.06 had been revised or temporarily modified to provide the correct information require (Closed) Noncompliance (346/81-04-01). The inspector verified that ST 5099.02, " Miscellaneous Instrument Daily Check", had been revised to clarify the containment purge logging requirements. Also, the inspector verified that proper entries had been made in the con-tainment purge log throughout January, February and March of 1982 with no discrepancies note . Monthly Maintenance Observation Station maintenance activities of safety related systems and com-ponents listed below were observed / reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides and industry codes or standards and in conformance with technical specification The following items were considered during this review: the limiting conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicable; functional testing and/or calibrations were

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-performed prior. to returning components or systems to service; quality control records were maintained; activities.were accomplished by quali-fled personnel; parts and materials used were properly certifie Work requests were reviewed to determine status of outstanding jobs and to assure that priority is assigned to safety related equipment maintenance which may affect system performanc The following maintenance activities were observed / reviewed:

Changeout of the motor cutoff switch on Westinghouse 13.8 KV air circuit breakers to the A and B buse Following completion of maintenance on the A and B 13.8 KV bus, the inspector verified that these systems had been returned to service properl During followup of LER 82-06 and subsequent resident inspector obser-vation of the motor cutoff switch changeout, a problem with the capability of 13.8 KV/4.16 KV switchgear arose. The problem concerns an unmonitored failure of this switchgear in an unanalyzed conditio Specifically, the mechanical linkage, if slightly warped, will not go the full length of travel and the "b" contact will not close. With-out the "b" contact closing, current to the close-in solenoid cannot be provided. The licensee is checking for warpage and removing any warpage by hammer blows and adding washers behind the contact relay so the mechanical linkage has less distance to travel in accordance with Westinghouse Field installation instructions. Westinghouse has informed the licensee that the problem is unique to Davis-Besse, however, the inspector considers this failure mechanism to be generic and has submitted this item as a generic issue to NRC supervision for revie . Monthly Surveillance Observation The inspector observed technical specifications required surveillance testing on the Control Room Emergency Ventilation, TRAIN #1, ST 5076.02'

and Boric Acid Heat Tracing, Weekly Test, ST 5011.1 and verified that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that-limiting conditions for operation were met, that removal and restoration of the affected components were accomplished, that test results conformed with technical specifications and procedure requirements and were reviewed by personnel other than the individual directing the test, and that any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personne The inspector also witnessed portions of the following test activities:

PT 5186.01, Locked Valve Verification ST 5030.16, RPS Monthly Functional Test in Shutdown Bypass for Channel ._ ._ _ -- _ . . . _ . .

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- Licensee Event Reports Followup Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine that reportability requirements were fulfilled, immediate

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corrective action was accomplished, and corrective action to prevent recurrence had been accomplished in accordance with technical specifications, i

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LER 82-11 Quadrant Power Tilt'in excess of Transient Limit due to dropped ro LER 82-07 Siphoning of Spent Fuel Level below T.S. limi LER 81-50 Five CTMT isolation valves not tested at required frequenc LER 81-79 Five CTMT isolation. valves not tested at required frequenc LER 82-10 Dil-10 found mispositione LER 82-002 RE2007 SFAS Containment Radiation Monitors Failed Low

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LER 82-017 Valves CS20,' FW786 and FW790 found mispositioned IE Circular Followup For the IE Circulars listed below, the inspector verified that the

Circulars were received by the licensee management, that a review for applicability was performed, and that if the circulars were applicable to the facility, appropriate corrective actions were

!, taken or were scheduled to be taken.

IEC 78-13 Inoperability of Service Water Pumps IEC 81-06 Potential Deficiency Affecting Certain Foxboro 10-50 Mil 11 ampere Transmitters Review of Plant Operations - Procurement The inspectors reviewed the licensee's storage activities to ascertain whether materials and supplies used for safety related functions are maintained in conformance with the licensee's approved QA program and implementing procedures.

, The inspection was performed in two stages. The first stage was a j tour of the warehouse. The second stage was a tour of the station j grounds to ensure that once material was removed from the warehouse

, that proper storage requirements were being met prior to installation.

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a. During the tour of the warehouse the following items were identified:

(1) Several safety related cable on reels did not have the ends taped properly or not at all in accordance with Section 6.2.2 of AD 1847.03. Not all cable was found improperly taped but the improperly taped cable was intermixed with properly taped cable. This scme specific finding was identified in the 1980 Performance Appraisal Branch (PAB)

inspection. The above finding was identified to the li-

-censee who promptly took corrective actio (2) Safety related 18", 45' elbows staged in the Quality Engineering hold area had their weld preparation surfaces protected with cardboard and improperly tape Identical elbows from the same purchase order were stored in the warehouse with properly taped plywood discs protecting the weld preparation surfaces. This was identified to the licensee who promptly took corrective action by replacing the cardboard with plywood cover (3) Out-of-date material in excess of shelf life requirements had not been purged from the warehous Items which did not meet shelf life requirements were stored with items which did meet shelf life requirements presenting the possibility of unknowning use of nonconforming materia Also, the licensee used information tags as modified hold tags. The information on the information tags was frequently found to be incorrect. The PAB inspection of 1980 identified irregularities in the control / storage of material with shelf life requirement Licensee mar.sgement was present when this finding was mad (4) 9.oth the east and west safety related storage areas outside the warehouse were observed to be unlocked during the day-shif In addition, the east storage was also found unlocked on March 11, 1982 during the backshift. The inspectors entered the storage area and remained approximately five minutes. At no time were the inspectors challenged. The inspectors observed that a security patrol drove past the affected gate just prior to their entry and shortly after they departed the storage area. The licensee was notified of this occurrenc (5) Inflammable materials, paints, oil and ether based ink which has a flash point of 110* F were stored adjacent to safety related materials on March 9, 198 Section 5.3.3 of AD 1847.03, " Materials llandling and Storage Requirements" lists this as prohibited material. This same specific finding was identified during the 1980 PAB inspection. The inspectors questioned warehouse personnel and Icarned that management directed that these materials

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e be stored in the warehouse. The licensee stated that the other based ink would be removed immediately and the balance of the inflammables would be removed within two weeks. The inspectors returned to the warehouse on April 8, 1982 and again found inflammable materials including the ether based ink. The inspectors informed the licensee of their findings and expressed their concern about the repeatability of the finding (6) The inspectors noted the significant improvements which have been made in the physical facility, During the tour of the station grounds the following items were identified:

(1) Safety related cable was improperly stored. Six reels of 1cvel C cable requiring inside storage were stored outdoore in the mud adjacent to the United Engineers and Constructors (UE&C) fabrication shop. Numerous recis of level D cable were also in the mud in this same are Level D cable is required to be blocked off the ground and in an area of adequate drainage. Cable not on reels was laying in the mud in this same area. The laydown area outside the fabri-cation shop also contained cable reels which had no identi-fication tags; therefore, segregation between safety related and non-safety related material was not being maintaine In addition adjacent to the cable reels was a great deal of trash and debris. One reel of level C cable was on a trash pile next to the gatehouse in direct observation of all personnel entering the gatehous (2) A safety related 20" flange was stored in the service water tunnel on March 3, 1982 with its weld preparation surface unprotecte (3) Three pieces of safety related unistrut channel designated for inside storage, level C, were outside with one piece in the mu Items (1), (2), and (3) were brought to the attention of Q A hold was placed on all improperly stored cable. The flange's weld prep was covered with plywood and properly taped. The unistrut was stored properly. The above listed items are considered examples of noncom-pliance with 10 CFR 50, Appendix B, Criterion XIII (346/82-08-01).

8. Refueling Activities The inspector verified that prior to the handling of fuel in the core, all surveillance testing required by the technical specifications and licensee's procedures had been completed; verified that during the outage the periodic testing of refueling related equipment was

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performed as required by technical specifications; observed three shifts of the fuel handling operations (removal, inspection and insertion) and verified the activities were performed in accordance with the technical specifications and approved procedures; verified that containment integrity was maintained as required by technical specifications; verified that good housekeeping was maintained on the refueling area; and, verified that staffing during refueling was in accordance with technical specifications and approved procedure Subsequent to removal of the reactor vessel head and upper plenum i

the inspector determined that all applicable inspection requirements had not been completed on the polar crane. Specifically, the docu- l

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mented rope inspection required at six month intervals or prior to

use (whichever greater) had not been done at the required frequenc The last rope inspection was at the end of July 1981 and was not ,

performed prior to the head lift in March 1982. Review of the crane -

inspection procedure revealed that the procedure specified an annual or at-refueling inspection frequency for the rope. This is considered an item of noncompliance 10 CFR 50, Appendix B, Criterion XIII. The licensee subsequently inspected the cable and revised his procedures to prevent recurrence of this problem. No response is require . Inspection During Long Term Shutdown The inspector observed control room operations, reviewed applicable

! logs and conducted discussions with control room operators during I

the inspection period. The inspector verified surveillance tests required during the shutdown were accomplished, reviewed tagout records, and verified applicability of containment integret Tours of containment, auxiliary building, turbine building access-ible areas, including exterior areas were made to make independent assessments of equipment conditions, plant conditions, radiological controls, safety, and adherence to regulatory requirements and to verify that maintenance requests had been initiated for equipment in need of maintenance. The inspector observed plant housekeeping /

cleanliness conditions, including potential fire hazards, and veri-fled implementation of radiation protection controls. The inspector by observation and direct interview verified that the physical security plan was being implemented in accordance with the station security plan, d

The inspector reviewed the licensee's jumper / bypass controls to verify there were no conflicts with technical specifications and verified the implementation of radioactive waste system control It was noted that general housekeeping improved during the month of April.

3 During a tour of the turbine building the inspector observed a worker disassembling a new essential- 480 V motor control center (MCC)

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which had been staged on the 603' icvel of the turbine building prior to installation in the Emergency Ventilation System (EVS) fan room on the 623' level of the auxiliary building. The inspector inquired why the disassembly was being performed and under what work authori-zation. The reply was that the disassembly was necessary to get the MCC into the EVS fan room and the work was authorized by

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'MWO 81-103-S Review of this NWO and all other 81-103 series MWO's provided no such authorization for the disassembly of the motor control center. This is considered an item of noncompliance with 10 CFR 50, Appendix B, Criterion V (346/82-08-02).

1 Locked Valves The licensee controls approximately 300 specific valve in critical safety systems on the plant site via locks with administrative control over the keys to the locks and over operation of the valve The keys to the locks are kept in a locked cabinet in the shift super-visor's of fice and possession of a key requires the permission of the shift supervisor. Once a valve's position is changed from its normal position it is logged in the " Locked Valve Log" along with the reason for the position change and the positioner initials for the position change. While the valve is in its abnormal position the lock is kept unlocked. When the valve is returned to its normal position the positioner initials that the action has been completed in the Locked Valve Log. An independent verification is also made when the valve is returned to its normal position and the verifier initials this to be so in the Locked Valve Log. The Locked Valve Log is required to be reviewed by each oncoming shift supervisor as part of his acceptance of shift responsibility. A valve verifi-cation of all the valves controlled by the locked valve log is performed on a monthly basi From mid-February to mid-March there were three instances of incon-sistencies between actual valve position and that stated in the Locked Valve Lo Valves DM-10, CS-20, FW786 and FW790 were found to be out of the documented position. These valves had no safety significance for the mode in which the plant was operating. As a result of this loss of control, the licensee has counseled all individuals who are allowed access to the locked valve keys in the importance of adherence to the locked valve procedure. The licensee will change the locks on the locked valves and every four days is performing the monthly veri-fication of the locked valves required for Modes 5/6 until licensee management regains confidence in the locked valve procedure. Also, the licensee is planning to go to a dedicated cabinet for the locked valve keys. After the third incident the inspector performed a valve verification of all the locked valves with no inconsistencies note . Exit Interview The inspector met with the licensee representatives (denoted in Paragraph 1) throughout the inspection period and on March 15 and May 5, 1982, and summarized the scope and findings of the inspection activitie