IR 05000346/1985037
| ML20151V126 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 02/03/1986 |
| From: | Jackiw I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20151V113 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.1, TASK-TM 50-346-85-37, NUDOCS 8602110206 | |
| Download: ML20151V126 (25) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-346/85037(DRP)
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: November 5, 1985 through January 4, 1986 Inspectors: W. G. Rogers D. C. Kosloff B. L. Burgess D. S. Butler J. K. Heller R. L. Nelson E. R. Swanson P. R. Wohld Approved By: tw CNif 8' d Y/
ReactorProjectsSection28 Date Inspection Summary Inspection on November 5, 1985, through January 4, 1986 (Report No. 50-346/8503/(DRP))
Areas _ Inspected: Routine, unannounced inspection of previous inspection findings, Licensee Event Reports (LER), operational safety, Interim Performance Enhancement Program, TMI Action Items, maintenance, surveillance, IE bulletins, Part 21 reports, and allegation followup. Special inspection by resident and regional inspectors of ifcensee actions identified as a result of the root cause investigation of malfunctioning equipment during the transient of June 9, 1985. The inspection involved 723 inspector-hours onsite by eight NRC inspectors including 109 inspector-hours onsite during off-shift Results: Of the ten areas inspected, no violations or deviations were identified in nine areas and one violation was identified in the maintenance area (installation of an improper component - Paragraph 7).
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DETAILS 1. Persons Contacted Toledo Edison J. Williams, Jr., Senior Vice President Nuclear
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T. Murray, Nuclear Mission Assistant Vice President
- L. Storz, Plant Manager S. Quennoz, Nuclear Engineering Group Director
- S. Smith, Assistant Plant Manager, Maintenance M. Schefers, Information Management Director
- W. O' Conner, Assistant Plant Manager, Operations D. Lee, Plant Outage Manager C. Daft, Quality Assurance Engineering Manager
- L. Ramsett, Quality Assurance Director J. Ligenfelter, Operations Engineering Manager M. Stewart, Nuclear Training Ofrector R. Peters, Nuclear Licensing Manager S. Wideman, Senior Licensing Specialist J. Wood, Mechanical and Structural Engineering Manager J. Byrne, Quality Assurance Auditor T. Stiefel, Document Control Coordinator
- J. Helle, Director, Nuclear Facility Engineering B. Beyer, Nuclear Projects Director J. Michaelis, Operations Superintendent M. Beier, Quality Engineering Supervisor
- T. Chowdhary, Nuclear Engineering Services Manager
- J. Moyers, Quality Assurance Operations
- R. Flood, Technical Support Manager
- E. Salowitz, Planning Superintendent
- T. Bloom, Senior Licensing Specialist NRC
- Rogers, Senior Resident Inspector
- 0 Kosloff, Resident Inspector B. Burgess, Project Inspector P. Wohld, Regional Inspector D. Butler, Regional Inspector
- J. Heller, Resident Inspector E. Swanson, Senior Resident Inspector R. Nelson, Senior Resident Inspector
- Denotes those personnel attending the January 10, 1986, exi The inspectors also interviewed other licensee employees, including members of the technical, operations, maintenance, 1&C, training, health physics and nuclear materials management department staf _ _ _ . . _ - _ _ _ _ _
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2. Licensee Action on Previous Inspection Findings (Closed) Open Item (346/80025-04): Commitments regarding loss of Non-Nuclear Instrumentation. The inspector determined through record review and discussion with licensee personnel that all the committed actions were completed except on The remaining action is the replacement of the multiplexers for the plant compute This item is closed. Implementation of FCR 84-083 is an open item (346/85037-01). (Closed) Violation (346/81003-04): Failure to properly implement Regulatory Guide 1.3 All items had been reviewed and closed out except Section A, concerning improper implementation of the maintenance training program. The inspector reviewed the completed training of three current maintenance personnel and determined that they had received the required training specified in AD 1828.11
" Maintenance Section Training." The licensee is now preparing to upgrade training requirements in this area. The upgrading will be monitored under SALP open item RP-99510. The corrective actions associated with this violation are considered complete and the item is close (Closed) Violation (346/83001-01): Drawing control breakdow The inspectors reviewed the drawing control process and determined that the licensee had taken adequate actions in this area. The inspection consisted of a review of applicable procedures and interviews of cognizant plant and engineering staff. Also, numerous drawings were selected and compared with the appropriate drawing indices. Minor discrepancies noted in the drawing distribution process were corrected in a timely manner. However, the inspectors were concerned with the small sampling size, approximately 25 every quarter, being used to audit approximately 100,000 drawing Appropriate licensee managers were made aware of this concern and it is being addresse This item is close (Closed) Violation (346/03001-02): Inadequate corrective action in the maintenance area. The short term corrective actions for this violation were reviewed in IER 85025. The licensee's original long term corrective action program for the violation included seventeen area Two updates were made to the NRC Region III regarding long term corrective actions planned and being taken to assure proper performance of maintenance. 8y the second update, identification of additional actions and combining of existing actions resulted in thirteen areas requiring corrective actio These areas later became a part of the Performance Enhancement Program (PEP) or the Interim PEP (IPEP).
The inspection of original corrective actions was documented in IER 83020. During this inspection period the inspector reviewed the original corrective actions and the corrective actions identified in the two update Status of IPEP actions is shown in Paragraph 5 of this repor .________ _ _ .
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Status of corrective actions in the original seventeen areas:
(1) Brief maintenance department on the importance of using "as found" data. The licensee required recording of "as found" data during troubleshooting in AD1844.00, " Conduct of Maintenance," on January 8,198 (2) Closed in IER 8302 (3) Closed in IER 8302 (4) Establish a separate electrical group under the direction of i a permanent lead electrical support engineer. A separate electrical group has been established headed by the Electrical Maintenance Suryrintendent. This superintendent position is fille (5) Increase the size of the maintenance planning group by two planners and two data clerks. The positions committed to have been fille (6) Provide all maintenance management personnel with Kepner-Tregoe training. Due to the hiring of more personnel in the maintenance department, a number of individuals need to receive trainin The assistant plant manager for maintenance has scheduled these individuals for training in 198 Completion of the training is an Open Item (346/85037-02).
(7) Establish performance standards, goals and objectives down to the foreman level. Establishment of performance standards will be the end result of PEP action plan E/SP-9. Progress in this area will be monitored as Open Item RP-9962 (8) Require additional management involvement through the plant cleanliness inspection program and the job observation progra Procedures AD1835.00, " Plant Cleanliness Inspection Program,"
and AD1844.03, " Job Observation," now require the additional involvemen (9) Issue a standing order to give further direction on the conduct of maintenance. Alttough the standing order was not issued its intent has been accct311shed by Procedures AD 1844.00, " Conduct of Maintenance," and AJ 1844.02, " Control of Work."
(10) Form a " Quality Circles" pilot program in the mechanical group. A " Quality Circle" was formed in the mechanical group but was dissolved when new management was hired in the summer of 198 (11) Implement an improved preventative maintenance (FM) progra The licensee now has a permanent PM specialist in the planning department to coordinate the program. Some PM activities are
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i ll now scheduled at a fixed interval instead of on a fixed !
- anniversary. Preventative maintenance and inspection of l valve motor operators was expanded. Vibration analysis and '
trending will be conducted in a manner similar to the program ,
present at the Callaway Nuclear Power Station. The responsible individual for vibration analysis will be the station performance
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supervisor reporting to the operations engineering manager. An
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expanded lube oil analysis and trending program was established in the chemistry and health physics departmen (12) Implement.five conversion units for the Davis-Besse Maintenance 1 Management System. The conversion units are in servic (13) Establish additional training for various maintenance
! department management personne The. staff and shop personnel l were trained on administrative procedures in spring of 198 Long range training programs were established for the shop .
Long range. staff training is in development. On January 10, 1986 the Assistant Plant Manager - Maintenance committed to establish the shop and staff training program under an :
administrative procedure prior to July l', 198 This commitment is considered an Open Item (346/85037-03).
(14) Establish a required reading program for the maintenance department staff and shop personnel. AD 1828.11, " Maintenance Section Training," was revised to designate a reading list of l
procedures, facility design changes, Special Orders, temporary 1 l
procedure modifications and other irformation determined to be i applicable by the Assistant Plant Manager - Maintenanc (15) Instruct all maintenance personnel on the requirements of conducting maintenanc Training was given on AD 1844.00,
" Maintenance," in the spring of 1984. AD 1844.00 recently went through a major revision and training for maintenance personnel is scheduled for mid-January'198 (16) Improve communications within the maintenance department ,
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through regular meetings between managers, supervisors and shop personnel. The inspector ascertained through discussion with the assistant plant manager for maintenance that numerous planned meetings are held daily, weekly and monthly with the superintendents, foremen and craft personne ,
(17) Monitor this corrective action program using Quality Assurance (QA) personnel. QA monitoring of this corrective action program was marginal with only one audit being conducte '
The inspection results for the thirteen areas identified in the final revision to the response to the notice of violation are listed below:
(1) Perform an organizational review of the maintenance area. As a result of the review: (1) Reporting responsibilities were
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changed to require discipline supervisors to report directly to the maintenance engineer. (2) A.new maintenance engineer was appointed. (3) Responsibility for facility change requests was transferred to the facility modification department. (4)
Administration of contractors was reassigned to the facility modification departmen (2) Establish a management by objectives (MBO) program. This action has been established as PEP plan E/SP-9 and will be monitored as Open Item RP-9962 (3) Perform a major revision of procedure AD1844.0 The procedure was revise (4) In.plement the Davis-Besse maintenance management system (DBHMS).
DBMMS has been implemente (5) Define the role of the maintenance planning group. The planning group evolved into a planning department with approximately fifty individual (6) Evaluate and correct deficiencies in quality circle The quality circles concept was terminated by new managemen The licensee established training councils and post maintenance critiques to provide the craft feedback which the quality
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circles were intended to provid (7) Evaluate the preventative maintenance (PM) program. The PM program review was documented in Section K of the original respons (8) Establish a commitment tracking system. Implementation of this system was included in IPEP action 7-1(08).
(9) ' Evaluate the plant cleanliness inspection progra The program was considered viable and is still activ (10). Revise the job observation progra The job observation program was revised and is still activ (11) Establish a water treatment task force. The task force was established, the water treatment building problems evaluated, corrective actions recommended and the task force disbande (12) Review training in shops and for the staf Review of Section M of the original response providss the status of this actio (13) Improve materials planning and coordination. A materials task ,
force was formed under the materials manager. The warehous has been inventoried. Each maintenance discipline is identifying specific spare parts need . _ _ _ __ . ___ _ - _ _ _ _ . . _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ - _ _ _ _ _ _ _ _
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. (Closed) Open Item (346/83019-02): Limiting conoition for operation for the main steam safety valve The inspector informed the licensee that the Technical Specification as written will be considered appropriat This item is close (Closed) Violation (346/83024-02): Failure to properly update some design document The inspector determined that a Facility Change Request (FCR) was generated for the logic diagrams and that the diagrams are now again considered controlled documents. The inspector observed that logic diagrams had been added to the FCR
. checklist. The inspector determined that two FCRs had been generated to correct the deficiencies in the Updated Safety Analysis Report and piping class sheets. This item is close (Closed) Open Item (346/84001-04): 0perability of 120VAC essential buse Disposition of this item has been assigned to NRR.. The issue involved is another example of Generic Issue 48. Therefore, the outcome of Generic Issue 48 will resolve the item. From the'IE perspective this item is considered close (Closed) Open Item (346/84004-02): Failure of a main steam safety valve to open upon demand. . Inspection of the valve by the licensee revealed that damage to the spindle, disc holder, disc and guide caused internal interference, preventing the valve from openin This item is close (Closed) Unresolved Item (346/84004-03): Failure of a main steam safety valve to close after lif tin The licensee disassembled the valve and found a cotter pin broken and some internal valve damag This item is close (Closed) Open Item (346/84006-01): Implementation of Facility Change Request 83-0136 to replace the auxiliary feedwater pump turbine governors. Replacement of the final governor is being monitored under the licensee's corrective actions to the June 9, 1985, even This item is close (Closed) Violation (346/85008-02)(DRS)): Failure to trend and evaluate valve leak rate data per the requirements of Section XI of the ASME Code. .The inspector reviewed test procedure changes and discussed valve leak rate testing with the responsible licensee enginee This indicated that the licensee's program for valve leak rate. trending and evaluation is in full compliance with the Cod This item is close . (0 pen) Open Item (346/85008-03(DRS)): Maximum valve stroke time The' licensee is re-evaluating valve stroke timing due to changes made to the motor-operated valve limit switch settings which change valve stroke times indicated at;the control room pane This item remains open pending further activity by the licensee and inspector revie .
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m. (Closed) Open It'em (346/85008-06(DRS)): Inadequate maintenance of pump and valve surveillance test records. The inspector verified that test records have been improved and are now being maintained properly. This item is close n. (Closed) Violation (346/84018-01): Failure to supply class 1E power to a reactor coolant system high point vent valve. The licensee rewired power to the valve under a supplement to Facility Change-Request 80-120 and established specific power supply review requirements on the " Loss of Instrument Power Review Sheet" in engineering procedure NFEP-020, " Design Work Packages." This item is close o. (Closed) Unresolved Item (346/84019-06): Procedural deficiency in the safety evaluation section of the Facility Change Request (FCR)
form. The licensee modified the safety evaluation section of the FCR form as shown.in AD 1845.00, " Changes, Tests and Experiments,"
to require a written safety evaluation if the proposed FCR changed the facility as described in the Updated Safety Analysis Repor The procedure modification was issued on May 24, 1985. This item is close p. (Closed) Violation (346/84020-01): Lack of control over testing activitie The inspector reviewed numerous personnel records and determined that administrative procedures training had taken place, observed that the log and a completed copy of TP 641.00 were in the records vault, and observed that signs on the auxiliary feedwater pump room door provided adequate instructions to keep the door closed when not in use. This item is close q. (Closed) Violation (346/84029-01(DRS)): Failure to hase adequate procedures and drawings. The inspector verified source valve CV 74 was added to P & ID Drawing M-0298, Revision 34, Sheet 2,
" Containment and Penetration Rooms." In addition, CV 74 was added to plant procedure PP 1102.02.22, " Plant Startup Procedure" and surveillance test ST 5061.01.03, " Containment Integrated Leak Rate Test." Based on the licensee's action, this item is closed.
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r. (Closed) Violation (346/84029-03(DRS)): Failure to add local valve leakages to determine Technical Specification 3.6.1.2.b complianc The licensee has revised surveillance test ST 5061.02.08,
" Containment Vessel Local Leak Rate Test (LLRT)." Precaution 4.10 was added to inform the LLRT test leader to quantify the leak rate for each valve. Enclosure II, " Total LLRT Leakage Summary Sheet,"
provides a location to log individual valve leak rates and to determine the total leakag Based on these procedural changes, this item is close s. (Closed) Violation (346/85003-02): Failure to cap open safety-related piping during maintenance. The inspectors observed several maintenance activities-involving open safety-related piping and noted that piping was properly covered. This item is close .
. (Closed) Open Item (346/85003-03): Installation of flip-up covers on the reactor trip button The inspector observed that the covers are installed. This item is close (0 pen) Open Item (346/85004-06): Implementation of Facility Change Request (FCR) 83-0009. In a letter from TED to NRR dated December 12, 1985, TED stated that this FCR is scheduled for March, 1986. This item will remain open until the inspector can verify completion of the FC (Closed) Open Item (346/85010-04): Shift Technical Advisor (STA)
procedure changed to allow acquisition of a license The STA training procedure, AD 1828.21, has been revised. This item is close (Closed) Violation (346/85016-03): Failure to perform boron concentration sampling as required by procedure ST 5013.03, " Control Rod Program-Verification," and failure to initiate a test deficiency list summarizing the malfunctions which occurred while performing the tes The missed boron sample appeared to have been an isolated occurrence and did not indicate a programmatic deficiency. An intra-company memorandum was issued from the operations engineer clarifying the use cf the test deficiency list on June 20, 198 The licensee modified procedure ST 5013.03 to allow documenting the boron sampling in the reactor operator's log. The procedure step referenced in the modification was'not correct and the data sheet for logging boron sampling did not reference the appropriate action step in the body of the procedur These clerical errors have been identified to the licensee for resolution. This item is close (Closed) Open Item (346/85017-02): Use of WD-40 on GE reactor trip breakers. The licensee revised MP 1405.05, "480V Type AK Reactor Trip Breaker Maintenance and Testing," to exclude the use of WD-40 to revitalize the. grease lubricating the circuit breakers. This item is close (Closed) Violation (346/85018-01): Failure to establish fire watches as required by the Technical-Specification The inspector verified that the appropriate security procedure had been revised instructing the security supervisor to inform the shift supervisor when the security / fire protection computer is out of servic This item is close (Closed) Violation (346/85018-02): Failure to monitor the condition of piping in auxiliary feedwater pump room No. 2 during the operation of the startup feedwater pump. The licensee has installed another startup feedwater pump which does not require operator observation of the pipin Also, the inspector confirmed that operations personnel were briefed on this situation. This item is close a (Closed) Violation (346/85018-03): Failure to maintain reactor power below Technical Specification requirements. The inspector confirmed that the feedwater flow transmitter was replaced; a
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generic guidance memorandum was issued; PT 5131.02, " Verification of Computer Calculations," performance' frequency was increased to weekly; PT 5131.02 was-upgraded to add heat balance inputs for comparison and additional comparisons were added to ST 5030.01,
"RPS Heat Balance." This item is close b (Closed) Open Item (346/85020-02): The cause of main feedwater pump trip The inspector reviewed the licensee's calculations on the main feedwater pump trips and determined that the overspeed trip was the most logical. This item is close c (Closed) Open Item (346/85020-04): The breaker that supplies electrical power to containment vacuum breaker valve, CV5078, was found open. The licensee investigation consisted of consultation with the FBI, NRC Region III security and interviews (formal and informal) with personnel who had access to the area. The licensee could not determine a cause for the open breaker. This item is close d (Closed) Unresolved Item (346/85022-03): Presence of startup strainers in safety-related piping systems. This condition was a violation. However, since it was discovered by the licensee, prompt and comprehensive corrective action was taken, the condition was reported in accordance with 10 CFR 50.73, no corrective action to a previous violation ~would have identified the presence of the startup strainers and the licensee determined through engineering analysis that the presence of the strainers would not have kept the systems from performing their safety function, a violation will not be issued. _This decision is consistent with 10 CFR 2, Appendix C,
" General Statement of Policy and Procedure for NRC Enforcement Actions." This item is close e (Closed) Unresolved Item (346/85022-06(DRS)): _ Externally generated electrical noise was observed at the input to both source range nuclear instrumentation channels. The licensee has addressed the noise problem in Action Plan 158. Corrective action will be implemented through the-Licensing Commitment Tracking System, LCTS ID No. 1562.~ Based on the licensee's commitment, this item is close f (Closed) Open Item (346/85025-17): Modify procedure SP 1106.06 to provide guidance on using auxiliary boiler steam to run the-auxiliary feedwater pump turbines. The procedure was revised to assure care is used in precluding water hammer when using auxiliary bciler steam. This item is close No violations or deviations were identifie . Licensee Event Reports Followup Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine
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that reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had-been accomplished in accordance with technical specification (Closed) LER 83-09 and Revision 1, Failure to close containment isolation valve CV5010 (Closed) LER 84-14, Leakage of containment isolation valves found by local leak rate testin (Closed) LER 85-17, Overpressurization'of the No. 1 steam generator on the secondary side. Review and inspection-of the licensee's corrective actions for this event will be performed under violation 346/85025-1 (Closed) LER 85-20, Inoperable Diesel Fire Pum No violations or deviations were identifie . Operational Safety Verification The inspector observed control room operations, reviewed applicable logs and conducted discussions with control room operators during the months of November, December and January. The inspector verified the operability of selected emergency systems, reviewed tagout records and verified proper return to service of affected component Tours of the reactor, auxiliary and turbine buildings were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks and excessive vibrations, and to verify that maintenance requests had been initiated for equipment in need of maintenance. The inspector by observation and direct interview verified that the physical security plan was being implemented in accordance with the station security pla The inspector observed plant housekeeping / cleanliness conditions and vei ified implementation of radiation protection controls. During the months af November and December, the inspector walked down the accessible portions of the service water and emergency d'esel generating systems to verify operabilit These reviews and observations were conducted to verify that facility operations were in conformance with the requirements established under technical specifications, 10 CFR, and administrative procedure No violations or deviations were identifie . Interim Performance Enhancement Program (IPEP)
Paragraph 10 of Inspection Report No. 85025 reported the status of IPEP actions in' fourteen IPEP areas. During November, December and January the inspector continued his review of the IPEP, reviewing three area .
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The acilons to-be inspected in the future are associated with vendor manual control, 12-5(1-3). The results of the inspector's review are summarized below:
Area Number 6 - Station Operations 06-1(01) Commitment: Complete a review of procedures and-correlate them with the Updated Safety Analysis Report (USAR).
Status: An April 30, 1985, letter from R. P. Crouse, Toledo Edison (TED), to J. G. Keppler, NRC Region III, documented that this review is expected to be completed by July 1, 1987. In their response to the August 1985, 10 CFR 50.54(f) letter the licensee stated that the correlation would be performed in the annual USAR revie IPEP action RP-06011 remair,s ope (02) Commitment: Have Bechtel complete write-up of system design functional requirement for the safety related
. Heating Ventilation and Air Conditioning (HVAC)
system Status: The licensee has closed this item by issuing Action Items 06-1(07), " Issue Bechtel system design functional requirements for safety related HVAC," and 06-1(09), " Identify and communicate to cognizant procedure individuals the procedures requiring modification due to review of the functional requirements for safety-related HVAC."
This IPEP action (RP-06012) is close (03) Commitment: Have Babcock and Wilcox (B&W) complete writing of system design bases descriptions for the Emergency Core Cooling System (ECCS), Reactor Protection System (RPS) and Makeup (MU) Syste Status: The licensee has received the system descriptions and they will be documented in item 06-1(08),
" Review and comment on B&W drafts for the system design basis description for the ECCS' MU and RPS."
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This IPEP action (RP-06013) is close (04) Commitment: Retain a consultant to begin updates af system auxiliary diagrams (SAD) and establish a program to control SADs and SSD Status: The licensee schedule for closeout is December 198 IPEP action RP-06014 remains'ope (05) Commitment: Generate Safe Shutdown Logic Diagrams (Appendix R).
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Status: The licensee stated that the Safe Shutdown Logic Diagrams have been generated and are controlled-n-
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documents. _The inspector has reviewed the diagrams and verified that they are controlle This IPEP action (RP-06015) is close (06) Commitment: Establish a procedure requiring a Shift Supervisor to obtain approval from station management prior to action for any abnormal ~ plant arrangemen Status: The licensee implemented this requirements in Standing Order 39 on March 27, 19Es. The licensee voided Standing Order 39 and incorporated the instructions in AD 1839.00. This IPEP action (RP-06016) is close (07) Commitment: Issue Bechtel system design functional requirement for safety-related HVA Status: The licensee transferred this action to 06-1(09).
This IPEP action (RP-06017) is close (08) Commitment: Review and comment on B&W drafts for the system design basis description for the ECCS, MU and RP Status: The original draft reports were not acceptable and the program was discontinued. Preparation of system descriptions is now included in the Configuration Management Progra This IPEP action (RP-06018) is close (09) Commitment: Identify and communicate to cognizant procedure individuals the procedures requiring modification due to review of the functional requirements for safety-related HVA ~
Status: The licensee has closed this item based on making revisions to HVAC.related procedures. Generically, revising procedures as the~ result of a review of functional requirements is now part of the configuration Management Progra This IPEP action-(RP-06019) is close Area Number 7 - Maintenance 07-1(01) Commitment: Conduct an organizational review of the maintenance departmen Status: The maintenance department was reorganized so that maintenance supervisors reported directly to the maintenance enginee Staff personnel were added to the department. Administrative responsibilities
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for facility Change. Requests were reassigned to the facility modification department (FMD).
Administration and management'of contract labor were assigned to FM These changes took place prior to management changes in the summer of 1 This IPEP action (RP-07011) is close (02) Commitment: Implement Management By Objective program within the maintenance departmen Status: This IPEP action (RP-07012) is closed as it was included in' PEP plan E/SP-9 and will be monitored as Open Item 346/RP-9962 (03) Commitment: Monitor and control the implementation of the Davis-Besse Maintenance Management System (DBMMS).
Status: DBMMS has been implemente Five conversion units are in place and functional, enhancing the flexibility of the system. This IPEP action (RP-07013) is close (04) Commitment: Revise Maintenance Procedure AD1844.0 Status: The procedure was revised on March 31, 198 Training on the procedure was conducted in'the spring of 1984. This IPEP action (RP-07014) is close (05) Commitment: Define the role of the maintenance planning grou Status: The maintenance planning group was expanded into the planning department defined in the current ~
revision to-AD1844.02, " Control of Work." This IPEP action (RP-07015) is close (06) Commitment: Evaluate'and correct deficiencies in the quality circle progra Status: The major factor affecting quality circle performance was determined to be untimely response to quality circle recommendations. The maintenance engineer increased his involvement in quality circle activities in an attempt to improve responses to recommendations. The program was later abandoned when new management personnel were hired in the summer of 198 This IPEP action (RP-07016) is close (07) Commitment: Evaluate preventative maintenance progra Status: The evaluation determined that a full time coordinator was necessary. This position has been
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established and filled. Further evaluation is being performed as part of the licensee's response to the 10 CFR 50.54(f) letter. Therefore, this-IPEP action (RP-07017) has been superseded by the "
10 CFR 50.54(f) response and is considered close (08) Commitment: Track commitments _within the maintenance departmen Status: Commitments are tracked by a clerk who reports to the plant services manager. The clerk was knewledgeable of her responsibilities in this are However, the clerk works three days a week and when she is not present no one perforns her function. Also, the clerk's position description does not include commitment tracking. The fact that commitment tracking is being accomplished is adequate to close this IPEP action (RP-07018).
However, the inspector will monitor the licensee's response to the deficiencies noted above as an Open Item (346/85037-04).
07-1(09) Commitment: Conduct an evaluation of the plant cleanliness inspection progra Status: The licensee has supplemented the inspection program with a dedicated cleanup crew. Additional painting and insulation activities were implemente This IPEP action (RP-07019) is close (10) Commitment: Conduct a review and possible revision of the job observation progra . Status: The licens'ee is evaluating the necessity for AD 1844.08 since the requirements of this procedure have been included in AD 1844.00 and Attachment 9 of AD 1844.00. - This IPEP action (RP-07110) is close (11) Connitment: Monitor activities of the water treatment task forc Status: The water treatment task force has completed its review, provided recommendations for correcting the problems identified and.has disbanded. This b IPEP action (RP-07111) is closed.
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07-1(12) Commitment: Determine the training needs for the shop and staff personne Status: Shop personnel needs have been determined and training has been. scheduled. The licensee is now determining the staff training need This IPEP action (RP-07112) is closed. Determination of staff training needs will be monitored as an Open Item (346/85037-05).
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07-1(13) Commitment: -Quality Assurance (QA) to conduct an audit of maintenance work orders to determine if they were properly classified as safety related or non safety-related.
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Status: QA performed audit 1157 in this area. Minimal problems were. identified and the audit was closed on January 10, 1985. This IPEP action (RP-07113)
is close Area Number 12 - Engineering p 12-1(01) Commitment: Complete changes to AD 1848.0 Status: -The procedure was revised on April 11, 198 This IPEP action (RP-12011) is close (02) Commitment: Implement corrective. action in the drawing control process to ensure that alpha drawings accurately
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reflect as-built condition Status: All alpha drawing walkdowns were complete All alpha drawings except those with multiple Facility Change Requests issued against them have been verified to be "as-built." This IPEP action (RP-12012) remains ope ~12-1(03) Commitment: Have engineering services complete and reverify .
the field change notice (FCN) log in accordance with newly instituted procedure Status: The FCN log was reverified and a QA audit confirmed its accurac This IPEP action (RP-12013) is close (04) Commitment: Have Bechtel furnish any drawings found to be missing as a result of the TED drawing log revie Status: The drawings have been received and are being filed. This IPEP action (RP-12014) is close (05) Commitment: .Have engineering services prepare a list of missing vendor drawings; forward the list to Bechtel for them to furnish the missing drawing Status: -The list has been sent to Bechtel and acted upo A discussion with cognizant licensee personnel revealed that the licensee has received the drawings or. identified them as irretrievabl This IPEP action (RP-12015)_is close (06) Commitment: Expedite efforts of station personnel and nuclear facility engineering personnel to close Facility Change Requests (FCR).
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Status: -148 FCRs have been closed out since January 1, 1985. The licensee's actions in this area'are
. continuin This IPEP action (RP-12016) remains ope (07) Commitment: Quality Assurance (QA) review and close out Audit
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Finding Report (AFR) 581-1 and Corrective Actio Request (CAR) 81-0 Status: The AFR and the CAR were closed on February 17, 198 This IPEP action (RP-12017) is close (08) Commitment: Designate a qualified group to periodically assess the adequacy of the controlled document distribution proces Status: -This assessment was first assigned to the Nuclear Safety Department but has since become a.part.of the QA audit process. This IPEP action (RP-12018)
is close (09) Commitment: Computerize the drawing log Status: The drawing logs have not been computerize Through discussion with licensee management th inspector determined that the logs will be computerized during the first quarter of 198 This~IPEP action-(RP-12019) remains ope (10) Commitment: Review the methods and procedures used for closeout and updating of drawing Statusi The review was performed.and_ procedure NFES-032,
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" Drawing Control," was issued as a result. This APEP action (RP-12110) is close (11) Commitment: Form an engineering administration departmen Status: This department has been established and is recognized in the Quality Assurance Manual and the Nuclear Facility Engineering Manual. This IPEP action (RP-12111) is close ' 12-1(12) Commitment: Make organizational adjustments'to properly manage the drawing control are Status: Two people were temporarily assigned to the drawing control area. These changes were determined to be insufficient and IPEP action 12-1(11) was generated. This IPEP action (RP-12112) is close _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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12-1(13) Commitment: Form a team to walk down a select number of completed Facility Change Requests (FCR).
Status: The team was formed and walkdowns of ten FCRs were performed. Minor discrepancies were noted and no more walkdowns were considered necessar Thi .IPEP action (RP-12113) is close ~12-1(14) Commitment: Verify the status of.all open FCR Status: The activity was completed. The licensee has since computerized the tracking system for maintaining the status of any FCR. -This IPEP action (RP-12114) is close (15) Commitment: Issue a memo to recall outdated control logic diagrams from the statio Status: The control logic diagrams were changed from
" controlled as-built" to "information only" drawing, until the drawings were corrected and reissued. This IPEP action (RP-12115) is close (16) Commitment: Instruct the architect-engineer to update the control logic diagram Status: -The logic diagrams were updated by FCR 84-10 Following the implementation of FCR 84-108, the logic diagrams were returned to the " controlled as-built" statu This IPEP action (RP.-12116) is close (17) Commitment: Issue a special order outlining new controls for alpha drawing Status: Special Order 32-3 was issued on July 31, 1984, to-control alpha drawing. The order was renumbered SPO-1 on April 2, 1985, during implementation of PEP action plan E/SP-6. . Controls on alpha drawings have been established and this IPEP acticn (RP-12117) is closed. Progress has been made in reducing the number of alpha drawing Elimination of remaining alpha drawings.through the FCR process is considered an Open Item (346/85037-06).
'12-1(18) Commitment: Write program for computerizing the drawing log Status: The program has been written and its use is projected for the first quarter of 198 This IPEP action (RP-12118) is close No violations or deviations were identifie .
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6. TMI Action Items (Closed) 1.A.1.1 Shift Technical Advisor (STA)
The inspector reviewed the records associated with the initial STA qualification program. The records supported'the qualification of the individuals reviewed. The inspector performed a comparison between the recommended guidance of NUREG-0737 for a STA qualification program and the licensee's qualification progra Good agreement between the two documents was note No violations or deviations were identifie . Monthly Maintenance Observation Station maintenance activities of safety related systems and ccmpnnents 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 performed prior to returning components or systems to service; quality'
control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were implemented; and, fire prevention controls were implemente 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: Modification of the reactor protection system (RPS) filtering circuit for reactor coolant system (RCS) flow as required by Facility Change Request (FCR)85-010 While observing the Instrument and Control (I & C) mechanics replace two .015 ;rofarad capacitors in an RPS Channel 2 RCS flow conditioning module the inspector noted that ".015 microfarad" was marked on the Q-accept tag for the replacement capacitors. FCR 85-0103 required a .15 microfarad capacitor. The manufacturer's part number on the tag was for the proper par The inspector requested the licensee verify a 10% sample of the capacitors with the same part numbe Verification of capacitance with a certified meter demonstrated that the capacitors were .15 microfarad as required. The Q-accept tag was corrected. After the modification was completed response time was tested and found to be within the Technical Specification limi .
The inspector reviewed the entire FCR work package, b. Calibration of the No. 2 Emergency Diesel Generator (EDG) Model FAX ALNOR replacement pyromete While reviewing vendor calibration procedure VM 6100.30, Revision 0, the inspector became concerned with the pyrometer internal resistance and lead resistance of the thermocouples. The measured resistance of each thermocouple was approximately ten ohms. The replacement pyrometer had an internal resistance of three ohm The pyrometer presently installed in EDG No. 2 had an internal resistance of ten ohms. The I&C Mechanic promptly informed his foreman of the part discrepanc The inspector found that a pyrometer (TI 20177) with incorrect internal resistance (three ohms) had already been installed on September 17, 1985 on EDG No. It is the responsibility of the originating organization to ensure administrative procedure AD 1846.00.05, " Requisition of Materials and Services" has been correctly implemented. The procedure requires the Bill of Material (BOM) be reviewed for technical adequacy prior to approval. In addition, the receipt inspector did not substantiate the component was was nonconformin The error made on the 80M was carried unnoticed through installation and acceptance of the component in declaring the pyroneter operabl The procurement, receipt, and installation of an incorrect component in a safety-related system is a violation (346/85037-07) of 10 CFR 50, Appendix B, Criterion IV, " Procurement Document Control,"
for not providing adequate procurement instructions; and Criterion XV,
" Nonconforming Materials, Parts, or Components," for the receipt and installation of the incorrect componen The licensee has ordered two new pyrometers with the correct internal resistance and issued nonconformance report 85-2783 to document the proble The three ohm pyrometer installed on EDG No. 1 does not affect EDG operability and the pyrometer is providing temperature indicatio c. Calibration of No. 1 Core Flood Tank leve During the calibration the inspector noted that it was difficult to read the level indicator with sufficient accuracy to meet the indicator acceptance criteri The inspector recommends that I & C review the analog output devices and adjust the input values to the string calibration so the calibration points fall on major divisions of the output device d. Rewiring of the Integrated Control System Main Feedwater block valve interlock circuitry as required by FCR 85-022 The inspector. observed rewiring of portions of the interlock circuitry and verification of the wiring list against controlled drawing. Testing will be performed late .
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The inspector reviewed the entire FCR work packag Following completion of maintenance on the reactor protection system, the in~spector verified that the system had been returned to service properl No other violations or deviations were note . Monthly Surveillance Observation The inspector observed technical specifications required surveillance testing on Station Battery 2P, ST 5084.02, " Station Battery Refueling Inspection and Discharge Tests," 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 activity:
ST 5032.14,- Instrument String Check of Gaseous Radwaste F1 ne of FV 1821 The instrument did not meet the acceptance criteria of the test and will be repaire No violations or deviations were identifie . IE Bulletin Followup For the IE Bulletins listed below, the inspector verified that the written response was within the time period stated in the bulletin, that the written response included the information required to be reported, that the written response included adequate corrective action commitments based on information presentation in the bulletin and the licensee's response, that licensee management forwarded copies of the written response to the appropriate onsite management representatives, that information discussed in the licensee's written response was accurate, and that corrective action taken by the licensee was as described in the written respons (Closed) IEB 79-24, Freeze Protectio No violations or deviations were identifie . Part 21 Followup (Closed) Part 21, Westinghouse Electrical Equi] ment
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During a Quality Assurance vendor audit of Westinghouse the licensee determined that some replacement electrical equipment did not have seismic certification documentation. The licensee replaced the unqualified equipment and performed followup audits on the vendor's corrective' action and found those corrective actions satisfactory as documented in audit finding reports 1186-1, 1186-2 and 1186- No. violations or deviations were identifie . Allegations In June 1985 an individual called the Region V NRC office and reported that he had been camping near Davis-Besse on. June 2, 198 He stated that he heard " unusual noises" in the early morning of June 2, and upon returning home to California developed a skin ras The individual suspected that the skin rash was related to the " unusual noises" that he had heard. The inspectors noted that at 0603 on June 2, 1985, the plant tripped causing a loud noise due to steam escaping from the secondary steam relief valves. The inspectors ascertained that there was no release of radioactivity associated with the plant tri The inspectors sent the NRC Region III office.a copy of the monthly progress report on environmental. testing for radioactivity. The July 26, 1985, report, prepared.by Teledyne Isotopes Midwest Laboratory, analyzes environmental samples. collected in the area by the licensee during the period from January through May of 198 A review of the report by regional inspectors revealed that only normal natural background radioactivity was present and that no levels of radioactivity were present that could have caused any measurable or sensible reaction by human tissu No violations or deviations were identifie . Corrective Action Plan Observations The licensee has developed corrective action plans for each trouble-shooting action plan that.had been developed to investigate the systems which may-have contributed to the abnormal-behavior of equipment during the June 9, 1985, event. The resident inspectors, with assistance from other Region III inspectors, observed portions of the work in progress
'and reviewed Facility Change Requests (FCR) during the inspection perio Listed below are the significant observations made by the inspectors for each corrective action plan: Main feedwater pump turbine (MFWPT) and controls: The inspector reviewed the documentation for the performance of FCR 85-0200 for modification of the rapid feedwater reduction (RFR) MFWPT speed setpoint. The inspector also observed rewiring of portions of the RFR circuitry in accordance with FCR 85-0200 and verification of the wiring with controlled drawing n .
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s Auxiliary feedwater (AFW) pump turbine and controls: The inspector observed installation of a pipe whip restraint required by FCR 85-016 The inspector observed the installation of a new Gaitronics phone station near the No. 2 AFW pump turbine in .
accordance with FCR 83-0118. The inspector observed installation of the new AFW pump turbine pneumatically operated steam admission valves required by FCR 85-014 Steam and feedwater rupture control system (SFRCS): The inspector observed installation of SFRCS cabinet cooling fans as required by FCR 84-0102.- .The inspector found that- the contractor performing the work had removed the SFRCS cabinet door hinge screws and mounted nylon clips to those screws to secure the fan wirin The inspector informed the Quality Control (QC) inspector that this condition could invalidate the seismic qualification of the doo The QC inspector stopped the work and had the contractor. return the door to its original condition. Engineering was notified that the FCR did not have instructions on how to secure the fan wiring in the SFRCS cabinet. The FCR was returned to engineering for revisio Startup feedwater control valve SP7A: No observations were made of corrective actions for this action pla Source range nuclear instruments (NI-l and NI-2): The licensee noted that NI-1 spikes when the Fan Failure Alarm goes on for the channel 2 Reactor Protection System cabinet. This phenomenon had not previously been observed and was not expected. The licensee is developing corrective actions for this malfunctio Turbine bypass valve (TBV) SP13A2: No observations were made of corrective actions for this action pla Power operated relief valve (PORV): A spare PORV was modified following flow testing. Full flow testing of the modified PORV at normal operating pressure and temperature provided satisfactory results. When the installed PORV was removed and modified the licensee determined that the valve disc spring was to short to shut the valve. This occurred even though the spring conformed with all applicable : specifications. The spring was replaced with a spring of adequate length. In the future when a PORV spring is ordered a minimum length will be specifie h. . Auxiliary feedwater valves AF 599 and AF 608: Troubleshooting activities for AF 599 and AF 608 are complete. Motor-operated Valve Analysis and Testing System (MOVATS) testing and other maintenance activities will continue until all safety-related motor-operated valves (MOV) have been addressed. Because of extensive troubleshooting to date by the licensee, the licensee's success identifying valve problems and root causes, and because of extensive review of these activities by Region III and Resident Inspectors, there is no need for further inspection to assure the adequacy of
- troubleshooting activities. There is, however, a continuing
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interest.in valve problem areas being identified and in the necessary corrective actions being performed. Hence, inspection will continue in these area Motor-Operated Valve Maintenance Procedures:
The inspector-reviewed the following procedures used for MOV maintenance, testing and adjustment:
MP 1410.32.04, " Testing of Motor Operated Valves Using MOVATS" MP 1411.04.01, " Maintenance and Repair ~of Limitorque Valve Operators Type SMB-000 and SMB-00" MP 1411.05.00, " Maintenance and Repair of Limitorque Valve Operators Types SMB-0 Through SMB-4" The procedures were found to be clearly ~ written and to properly address Limitorque motor-operator adjustment, maintenance and testing. Adjustment settings for torque and geared limit switches conform with plant engineering staff recommendations, and the settings are being verified and tested for adequacy during M0 VATS testing and test data evaluation for all safety-related MOV Documentation, including M0 VATS test curves, indicates-that AF 599 and AF 608 are set properly according to procedure. Other valves have also been reviewed for compliance of the valve settings with plant procedures and found to be properly se Motor-Operated Valve Maintenance' Training:
The inspector reviewed training requirements, records, classroom materials, shop training aids and on-the-job' traiairg for personnel allowed.to perform maintenance and MOVATS testing on safety-related MOV Records showed that. personnel performing MOV maintenance had completed the minimum classroom and on-the-job training. Classroom materials and shop training aids shewed that the licensee had a well-developed, formal program with " hands on" formal trainin The latest plant maintenance procedures are used in the training program to assure compatibility between training and maintenance, and to apply training department expertise to the improvement of procedures. Discussions with individuals developing the formal training lesson plans and providing training indicated that they were well qualified technicall Maintenance personnel performance in the plant, observed during MOV testing, indicated that the personnel were capable. However, the proficiency of some individuals.and maintenance efficiency needs improvement both for ALARA considerations and plant schedule concerns. Additional experience and maintenance scheduling efforts being initiated during the inspection period should improve these area L
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. Steam line pressure discrepancies: The inspector observed calibration of atmospheric vent valve (AVV) proportional-integrate Modules 4-3-4 and 4-3-6. A broken test jack was found on Module 4-3-4. The module was removed to the Quality Control hold area and it will be replaced later with a new modul The inspector observed testing of control room indication for the open and close limit switch on each AVV. Both AVV limit switches would not reset. A follow-up mainte1ance work order was written to adjust the limit switche Service water valve controls for auxiliary feedwater (AFW) supply:
The inspector reviewed the documentation for the performance of FCR 85-0155 for modification of the controls for the AFW pump suction transfer. The inspector verified procedures, DCNs and actions required by procedure changes had been implemented in the field for FCR 85-0090, AFW System Suction Valv Power was removed from the motor operators for valves FW 786 and FW 790. A lock and chain was attached to each valve and they were administratively controlled by PT 5186.06, " Locked Valve Verification Periodic Test." Valve MS 106: The activities related to this valve are the same as reported for item h. abov . Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspectors, and which involve some action on the part of NRC or licensee or both. Open items disclosed during the inspection are discussed in Paragraphs 2 and . Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)
throughout the period of the report and after the conclusion of the inspection and summarized the scope and findings of the inspection activities. The licensee acknowledged the findings. During the exit the inspector discussed with the licensee the current NRC interpretation on when an LCO action statement starts upon discovery of a missed surveillance test. The inspector discussed the licensee's Technical Specification 3.3.3.7 which deals with the chlorine detection system. The inspector informed the licensee that the set of chlorine detectors required to be operable by 3.3.3.7 does not include the detectors in the block house adjacent to the chlorine tank car. Section 15.4.8.3 of the Updated Safety Analysis Report assumes the block house detectors actuate to mitigate the effects of a chlorine tank car rupture by protecting the control room operators. The inspector requested that the licensee pursue this matter with NR After discussions with the licensee, the inspectors have determined there is no proprietary data contained in this inspection repor