IR 05000346/1985039

Insp Rept 50-346/85-39 on 851209-860213.Violations Noted: Failure to Comply W/Tech Specs 3.6.2.2 Due to Original Design Deficiency & 3.5.2 Due to Inadequate Surveillance Procedures

ML20138B674
Person / Time
Site:	Davis Besse
Issue date:	03/13/1986
From:	Dunlop A, Ring M, Rich Smith, Vandenburgh C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20138B657	List: IR 05000346/1985039 ML20138B651
References
50-346-85-39, NUDOCS 8603250131
Download: ML20138B674 (14)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-346/85039(DRS)

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: Decembe 9,1985 through February 13, 1986 i

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Inspectors:

Wh C.A.VanDenb6 9-15-fk Date c A. Dunlop, M b -l3 -r&>

h R. Smith

5 -o-#b 1 "

Approved By: M. Ring, Chief 'b- s il,-4 Test Programs Section Date Inspection Summary Inspection on December 9, 1985 through February 13, 1986 (Report No. 50-346/85039(DRS))

Areas Inspected: Special announced inspection by two regional, one headquarters, and three contractor inspectors to review licensee action on previous inspection findings; followup on Licensee Event Reports; review the SRTP System Review Reports; perform SRTP test procedure review; perform SRTP test procedure witnessing; and perform SRTP test results review. The inspection involved 741 inspector-hours onsite and 41 inspector-hours in office by six NRC inspectors, including 85 inspector-hours onsite during off-shift ,

Results: Of the six areas inspected, five violations were identified in Sections 3.a 3.b, 3.c, 3.d, and 3.e of the report. In addition, eight open items and one unresolved item are documented in the body of the report which require action by the licensee and the NRC or bot PDR ADOCK 05000346 G PDR

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DETAILS Persons Contacted Toledo Edison

• L. Storz, Plant Manager S. Smith, Assistant Plant Manager, Maintenance

• O' Conner, Assistant Plant Manager, Operations

• L. Ramsett, TED Quality Assurance Director 0. Mavro, SRTP Manager

• J. Ligenfelter, SRTP Coordinator B. Zemenski, SRTP Test Manager P. Hildebrandt, IPRC Chairman S. Batch, JTG Chairman

• S. Piccolo, JTG Member

• T. Bloom, Licensing Staff J. Stotz, Technical Support Group NRC

• Rogers, Senior Resident Inspector

• D. Kosloff, Resident Inspector

• C. VanDenburgh, RIII Inspector A. Dunlop Jr. , RIII Inspector

• R. Smith, I&E

• L. Valenti, EG&G

• Denotes those personnel attending the February 13, 1986 exit intervie The inspectors also interviewed other licensee employees, including members of the technical, operations, maintenance, I&C, and training department staf . Open Items (Closed) Open Item (346/85036-01): This item concerned the description of the System Review and Test Program (SRTP) Coordinator's ;

responsibilities and the Independent Process Review Committee's (IPRC)

concurrence requirements in SRTP-001, 002 and 006. Revisions 3, 1,- l and 1 to these documents respectively, provide these requirement <

This item is close l

! (Closed) Open Item (346/85036-02): This item concerned the review of '

SRTP-002 in that'there were no requirements to identify discrepancies in the licensing basis, to ensure the list of system functions will be inclusive of the Chapter 15 Safety Analysis, and to require the source of system functions to be documented. Revision 1 to SRTP-002 provides these requirements. This item is close (Closed) Open Item (346/85036-03): This item concerned the lack of provisions in SRTP-008 to identify which sections of a test procedure could be released for partial performance. Revision 2 to SRTP-008 provides these requirements. This item is close I

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d. (0 pen) Open Item (346/85036-04): This item concerned SRTP-003 in that problem report documentation in some cases did not appear to be adequate. Specifically, the description, cause/ consequences and recommended actions were incomplete; there is little or no documentation on problem reports of their resolution, reason for changing a Required for Restart (RR) item to a Not Required for Restart (NRR) item, or reason for deleting a NRR item; and the list of documents reviewed was incomplete in that sources listed on the problem report did not appear in the applicable section of SRTP-003 Exhibit 1. The inspectors have reviewed the approved System Review Reports (SRRs) and conclude that a portion of this item can be close The review process and revisions to SRTP-004 have in general improved the description, cause/ consequences and recommended action sections of the system problem reports; therefore, the first portion of the open item can be considered closed. A resolution section which has been added to some of the problem reports is also an improvement, but this has not eliminated the concern that many RR and NRR problem reports have been completely deleted from the SRR or had their classification changed from RR to NRR without documenting the reason in the SR For example, a review of the Reactor Coolant, High Pressure Injection, Decay Heat Removal, Containment Spray, Emergency Ventilation, Contain-ment Air Cooling and Makeup and Purification SRRs indicates that a total of ten RR items and 46 NRR items were deleted or had their classification changed without explanation or documentation. Further licensee action is required to resolve the second portion of this open item. The final concern followed by this open item involved the SRTP-003 requirement to list the unique document number for each report reviewed in the appropriate section of Exhibit 1 of SRTP-00 If no documents exist or no documents were reviewed for a particular type of document then this fact is required to be stated in the section for that document type. This was not done in all case Eight SRRs were reviewed and four of these had no entry under one or two of the document types listed in Exhibit Further licensee action is required to resolve the final portion of this open ite e. (0 pen) Open Item (346/85036-05): This item concerned the classification of problem reports identified in the system review process into three categories: RR, NRR, and Category 3. The inspector was concerned that the screening guidelines and the final disposition of these problem reports are not documente Revision 3 to SRTP-001 renames " Category 3" reports as " Third Category" and indicates that IPRC may place some problem reports in this classi-fication to be further evaluated in the long term. Problem reports placed by IPRC in this category will be submitted under separate cover to the SRTP Coordinato The inspector remains concerned that not only are the screening guidelines for " Third Category" problems not specified, but documentation of these problem reports will not be provided for review. Without documentation and justification for the disposition of all problems identified in the review process, the effectiveness of the SRTP becomes questionable. Action is required by the licensee to ensure that each problem identified in the review process is evaluated, dispositioned and adequately documente _ _ _

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3. Licensee Event Reports Followup

$ Through direct observations, discussions with licensee personnel, and t review of records, the following event reports were reviewed to determine that reportability requirements were fulfilled, immediate corrective action i was accomplished, and corrective action to prevent recurrence had been 1 accomplished in accordance with technical specification !

i (0 pen) LER 85-022, Inadequate Post-LOCA flow to Containment Air i Cooler (CAC) Units. During the review of the Service Water (SW)

!~ system as part of the SRTP, it was determined that only one of two i

independent trains of CAC would provide the required cooling during

] post-LOCA conditions. The report stated that Technical Specifica-

tion 3.6.2.2 which requires at least two independent containment cooling units to be operable had been violated and that this con-dition had existed since original startup. Two trains of SW supply cooling to the three CAC units. Upon receipt of an Safety Features Actuation Signal (SFAS) actuation signal, two of the three CACs will

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start in low speed. An original design deficiency exists in that the SW cooling water supply to the non-running CAC is not isolated in the l! post-LOCA condition. This results in shared SW flow to the running and non-running CAC and therefore less than design SW flow and

, cooling to the operating CAC. The design problem continued to exist j because the surveillance tests written to satisfy the technical a specification requirements do not ensure that adequate SW flow is available to the CACs. This LER will remain open pending verifi-

! cation of the licensee's actions to revise the surveillance procedure

[ to ensure adequate SW flow is available to each CAC. This condition l has existed since the plant entered Mode 3 on July 24, 1977 and was

] identified by the performance of the SRTP on November 30, 1985.

l Failure to comply with Technical Specification 3.6.2.2 due to an

original design deficiency is a violation (346/85039-01).

i (0 pen) LER 86-001, Inadequate SW Building Ventilation. During the

. review of problem reports on the SW system as part of the SRTP, it

was determined that the as-built configuration of the SW Pump Room-Ventilation System was inadequate to provide the required ventilation design flows during post-LOCA conditions. The report stated that 4 Technical Specification 3.7.4.1 which requires two independent SW j trains to be operable had been violated and that this condition had i existed since 1983. Facility Change Request (FCR)81-054 was'imple-mented on November 29, 1984 to upgrade'the dilution pump to function as a backup SW pump to meet Appendix R. dedicated shutdown criteri FCR 81-054 required the addition of a wall that cut one of the two SW

! Pump Room Exhaust Vents in half. This resulted in only a small f amount of air being drawn through the SW Pump Room and limited the

! cooling capabilities of the SW Pump Room Ventilation System. The

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licensee has determined that had the design post-LOCA' heat loads'been produced with an outside temperature of 95 degrees, the ventilation system could not have removed the heat from the SW Pump Room which would have resulted in a failure of the SW Pumps and a loss ~of SW

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supply'to safety-related. load The root cause of this occurrence is an inadequate technical review of the modification to the ventilation system including the lack of post modification testin This LER will remain open pending verification of the licensee's actions to improve the cooling and air flow characteristics in the SW Pump Room. This condition has existed since FCR 81-054 was implemented on November 29, 1984 and was identified during the performance of the SRTP on December 12, 198 Failure to comply with Technical Specification 3.7.4.1 is a violation (346/85039-02).

c. (0 pen) LER 86-002, Emergency Diesel Generator (EDG) Air Start System pressure inadequate. During the review of the periodic testing re-quirements of the EDG System as part of the SRTP, it was determined that preoperational Test Procedure (TP) 0410.01.1, performed August 11-17, 1976, had not shown that the EDGs could start five times with a single air receiver pressurized to 200 psig. The report states that this is a condition which is outside the design basis of the plan Section 8.3 of the Updated Safety Analysis Report (USAR)

indicates that the air receivers have sufficient capacity to start the EDG five times. The normal operating range for the air receivers is 200-250 psig. TP 0410.01.1 verified the capability of each of the air receivers to start the EDG five times from an initial pressure of 250 psig. However, the operating procedure for the EDG, SP 1107.11,

" Diesel Generator Operating Procedure," stated that the EDG would be operable if the air receiver pressure is greater or equal to 200 psig. Since TP 0410.01.1 had not performed the five starts at the air receiver's minimum acceptable pressure setpoint of 200 psig, the original design basis for the EDGs had not been demonstrated by testing. The licensee identified that the root cause of this occurrence was the lack of an adequate technical review in that the wrong EDG air receiver setpoint was being used for EDG operabilit On December 10, 1985, confirmatory testing of EDG 1-2 air start system was performed to prove the 200 psig operability setpoint. The EDG started four times and as such was unsuccessful in starting five times as required. EDG 1-2 was then subsequently successfully tested at a starting pressure of 210 psig for each air receive EDG 1-1 will be tested during its maintenance outage prior to restar This LER will remain open pending verification of this testing and subsequent equip-ment modifications and setpoint changes required by these increased l pressures. Davis-Besse technical specifications do not address the l

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requirement for five starts of the EDG, therefore the Technical Speci-fication Limiting Condition for Operation (LCO) was not violated; however, the possibility exists that the EDGs would not have performed ,

their intended safety function under certain conditions. This condi- I tion has existed since the plant entered Mode 3 on July 24, 1977 and was identified during the performance of the SRTP on December 10, 198 . - __ . - _ - .

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The lack of a suitable test program to verify the adequacy of the original design and therefore the operability of the system is a violation (346/85039-03).

d. (0 pen) LER 86-004, SFAS Testing of High Pressure Injection Valve During the review of the periodic testing requirements of the SFAS as part of the SRTP, it was determined that current testing does not actuate High Pressure Injection (HPI) valves HP-2A, HP-2B, HP-2C, and HP-20 from a SFAS test signal as required by Technical Specification Surveillance Requirement 4.5.2. Technical Specification 3. requires that two Emergency Core Cooling Systems (ECCS) subsystems be operable. Surveillance Requirement 4.5.2.e.1 requires a verification at least once every 18 months while shutdown that each automatic valve in the flowpath actuates to its correct position on a safety injection test signa Surveillance Test (ST) 5031.07, " Integrated SFAS Test,"

currently strokes these valves with the control room handswitches onl Although the SFAS logic is tested in ST 5031.07 and ST 5031.01, "SFAS Monthly," the valves do not receive a periodic signal from the SFAS logic directl The root cause of this occurrence is an inadequate technical review of the procedures utilized to implement the surveil-lance requirement This LER will remain open pending the verifica-tion of the licensee's actions to modify the surveillance procedure This condition has existed since the plant entered Mode 3 on July 24, 1977 and was identified during the conduct of the SRTP on December 14, 198 Failure to comply with Technical Specification 3.5.2 due to inadequate surveillance procedures is a violation (346/85039-04).

e. (0 pen) LER 86-007, CAC Fan running backward During the performance of post modification testing on the CAC System required in the performance of the SRTP, it was determined that CAC fan 1-1 was running backward in low speed. The report states that this is a violation of Technical Specification 3.6.2.2 which requires at least two independent containment cooling units to be operable. During the performance of TP 850.31, "CAC Damper Test," on January 4, 1986, CAC fan 1-1 was found running backward in the low speed mode of operatio The fan ran in the correct direction in high spee CAC fans run in high speed during normal plant operation to provide containment cooling and automatically start in low speed upon receipt of an SFAS signal. The likely cause of reverse rotation is due to swapping two of the three motor leads on the low speed motor during previous maintenance activities. A review of the Maintenance Work Orders (MW0s) performed since original startup testing has identified 51 maintenance activities involving the CACs, of which five could have resulted in the incorrect reconnection of the motor lead These records however, do not contain sufficient information to identify when the fan was incorrectly reconnected. The earliest activity occurred on March 28, 1977 and the latest on July 18, 198 ST 5063.02, ensures operability by verifying at least once per 18 months that each unit starts automatically on low speed on receipt of a SFAS signal. Although STs have existed since the original startup testing, ST 5063.02 does not record sufficient data to l

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determine the direction of fan rotatio On January 11, 1986, the motor leads were connected properly and the fan rotation was verified visuall The inspector has requested that the licensee revise this

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LER to reflect the effects of inadequate SW flow to the CACs, previously identified in LER 85-022, on the analysis of this occurrenc The licensee has committed to provide this analysis by February 28, 198 , This LER will remain open pending verification of the licensee's l actions to include fan rotation verification in the surveillance procedure and to revise this LER to address the effects of inadequate

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SW flow. The root cause of this occurrence is inadequate technical review and post maintenance testing as well as inadequate technical surveillance procedures. This condition could have existed since the performance of the first MWO on March 28, 1977 and was identified

during the performance of the SRTP on January 4, 198 Failure to comply with Technical Specification 3.6.2.2 is a violation i

(346/85039-05).

Five violations were identifie No other violations or deviations were identified.

s 4. SRTP System Review Reports The inspectors reviewed the SRRs and associated Appendix A, Test Review Reports,which document the results of the system reviews, the corrective actions plans, the implementation schedule of corrective actions, the list of system functions and the associated testing required to demonstrate these functional capabilities. The review verified that the implementation schedule for the corrective action plans was consistent with the guidance of SRTP-004, that the system functions identified as "important to safe plant operation" were consistent with the USAR and the Davis-Besse Nuclear Power Station Licensing Safety Evaluation Report NUREG 0136, and that sufficient testing was identified to demonstrate the functional capabilities of the system in the anticipated modes of operatio The licensee has provided an approved SRR for each of the 31 systems

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listed in Attachment 1. Although the inspectors' review of these reports is ongoing, the inspectors have identified the following concerns with respect to the systems included in the scope of the SRTP and the list of system functions identified in the SRRs developed in accordance with SRTP-004, The SRTP implementing procedures define a program which, if properly i implemented, can demonstrate and document that the " Systems Important to Safe Plant Operation" are capable of functioning as intended. In addition to these 31 systems identified in Attachment 1, Toledo Edison (TED) has also identified four additional systems which will receive a " supervisory review" very similar to the SRTP process, but j with a narrower scope of documentation revie These additional systems are listed below and in Attachment (1) Gaseous Radwaste System (2) Post Accident Sampling System

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(3) Fuel Handling Ventilation System (4) Miscellaneous Containment Isolation Valves The verification that these systems receive a " supervisory review" similar in nature to the SRTP will be followed as an open item (346/85039-06). The SRRs developed in accordance with SRTP-004 identify the functions considered important to safe plant operations. The inspectors have reviewed this list for each of the 31 systems listed in Attachment 1 and have satisfactorily resolved their comments with respect to this list with the exception of the following concern (1) The Makeup and Purification System functions identified in the approved SRR dated December 3, 1985 did not specifically address the function of letdown isolation on a high temperature signal to mitigate a letdown line pipe brea TED committed to revise the USAR to clarify what systems and system functions are assumed to mitigate a letdown line pipe break discussed in USAR Section 15.4. This action will be followed as an open item (346/85039-07).

(2) The Anticipatory Reactor Trip System functions identified in the approved SRR dated November 18, 1985 did not specifically address the interlock function that prevents reset before the initiating signal has cleared. Verification of the proper operation of this interlock during system testing will be followed as an open item (346/85039-08).

(3) The Control Rod Drive System functions identified in the approved SRR dated December 2, 1985 did not specifically address the reactor runback to 15 percent power. Runbacks are addressed in the Integrated Control System (ICS) functions identified in the approved SRR dated November 14, 1985; however, the ICS SRR does not designate the runback function as a safety functio In addition, the Main Steam System functions identified in the approved SRR dated December 3, 1985 did not address the function of the turbine bypass. TED committed to revise the USAR to update the discussion provided in Section 15.2 on the turbine trip analysis to indicate that the Anticipatory Reactor Trip System provides the mitigating functions and delete the discus-sion concerning reactor runback and turbine bypass as mitigating functions. This will be followed as an open item (345/85039-09).

(4) The Control Room Normal and Emergency Ventilation System functions identified in the approved SRR dated December 3, 1985 did not address the function of control room isolation on Auxiliary Building high radiatio TED agreed to include this functio The inclusion of this item will be followed as an open item (346/85039-10).

The inspectors are concerned that to date only two of 31 Test Review Reports (SRTP-009 Appendix A Reports) are available for review. With so few Test Review Reports available for review, an evaluation as to the

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adequacy of the test program as well as a specific definition of the tests required prior to restart cannot be mad TED has committed to provide an approved Test Review Report for each system by February 28, 1986. The inspectors will continue to monitor the licensee's progress in developing the Test Review Reports in future inspection No violations or deviation were identifie Five items were identified which require further action by the license . SRTP Test Procedure Review The inspectors reviewed the following technical specification required surveillance testing, periodic testing, and one-time performance testing which were utilized to verify the functional operability of the system This review verified that the TPs adequately demonstrated the functional capabilities of the system in their anticipated operating conditions to the maximum extent practicable, were reviewed and approved by the appro-priate management personnel, and contained appropriate acceptance criteri TP 850.01, " Reactor Protection System Time Response Calculation" TP 850.02, "EDG Full Load Rejection" TP 850.03, " Motor Driven Feed Pump Acceptance Test" TP 850.04, "EDG Governor Electric Noise Test" TP 850.08, " System Air Compressor Sequencer Checkout" TP 850.09, " Clean Waste Tank Low Level Alarm Test" TP 850.10, " Detergent Waste Drain Tank 1-1 Low Level Alarm Functional Test" TP 850.11, " Miscellaneous Waste Drain Tank 1-1 Alarm Functional Test" TP 850.12, "13.8KV Bus A&B Lockout Test" TP 850.16 "CAS Relocation Fire Protection" TP 850.28, " Containment Air Cooling Fan Overload Test" TP 850.31, " Containment Air Cooler Damper Test" TP 850.36, "EDG Room Temperature Alarms" TP 850.37, "EDG Air Start System Test" TP 850.38, "EDG Refueling Surveillance Test" TP 850.40, "Incore Detector Testing" TP 850.41, " Component Cooling Water CRD Booster Pump Trouble Alarm" TP 850.50, " Auxiliary Feed Pump Overspeed Test" TP 850.59, " Component Cooling Pump Room Ventilation" TP 850.60, " Main Feed Pump Turbine Drain System" TP 850.77, " Motor Driven Feed Pump Run-In" TP 850.78, "EDG Diesel Oil Tank High Level Alarm" TP 850.84, " Makeup Valves Air System Integrity Test" TP 850.93, " Fire Protection / Radiation Monitor Alarm" TP 850.97, "EDG 1-1 Control Circuit Fire Isolation Test" TP 850.96, " Auxiliary Feed Pump Room Ventilation Test" TP 850.98, "EDG Governor Control Test" TP 851.04, "HVC Low V Switchgear Fan C133 Acceptance Test" ST 5016.02, " Fire Protection System Electric Pump Weekly Test" With respect to the review of TP 850.97, the inspector had the following concern. Procedure AB 1203.26 has not been revised to include the new disconnect switch in the event of a control room fir This will be followed as an open item pending the revision to this procedure (346/85039-11).

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No violations or deviations were identified. One item was identified which requires further action by the license . SRTP Test Procedure Witnessing The inspectors observed the following technical specification required surveillance testing, periodic testing and one-time performance testing

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which were performed to verify the functional operability of the system This review verified that the testing was performed in accordance with approved procedures, test instrumentation was calibrated, limiting condi-tions for operation were met, removal and restoration of the affected components were accomplished, and that deficiencies encountered during the performance of the procedure were adequately documented and resolved prior to proceedin TP 850.01, " Reactor Protection System Time Response Calculation" TP 850.03, " Motor Driven Feed Pump Acceptance Test" TP 850.07, " Functional Test of System Air IA Control Valves" TP 850.08, "SA Compressor Sequencer Checkout" TP 850.12003, "480V Unit Substation Live Transfer" TP 850.12004, "13.8 KV Bus A&B Lockout Test" TP 850.23, " Containment Spray 57% Valve" TP 850.28, " Containment Air Cooling Fan Overload Test" TP 850.31, " Containment Air Cooler Damper Test" TP 850.37, "EDG Air Start System Test" TP 850.38, "EDG Refueling Surveillance Test" TP 850.59, " Component Cooling Pump Room Ventilation Test" TP 850.60, " Main Feed Pump Turbine Drain System" TP 850.77, " Motor Driven Feed Pump Run-In" TP 850.78, "EDG Diesel Oil Tank High Level Alarm Test" TP 850.84, " Makeup Valves Air System Integrity Test" TP 850.98, "EDG Governor Control Test" TP 851.04, "HVC Low V Switchgear Fan C133 Acceptance Test" ST 5016.02, " Fire Protection System Electrical Pump Weekly Test"

, With respect to TP 850.01, the inspector witnessed the changing of filter capacitors and the Reactor Protection System response time calculations in accordance with FCR 85-0103 for Channel 3. One discrepancy was noted during the performance of the FC The Acceptance Card description for the new filter capacitors did not agree with the description in the procedure. The part numbers were the same but the value of the capacitors did not agree. This was identified by the personnel performing the FCR and resolved prior to installatio There are no further concern With respect to TP 850.03, the inspector witnessed that the mini-recirculation line from the motor-driven feed pump to the Deaerating Storage Tanks would not pass the required flow. The licensee's Engineering Department is investigating this discrepanc Licensee investigation of a failure of the minimum recirculation

valve to fully open following a reduction in the system flow during the Phase I test has determined that the strainer basket was not installed. The licensee is presently investigating methods to

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t prevent similar occurrences in the futur This item will.be

, followed as a open item pending the completion of the licensee's investigation (346/85039-12).

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! With respect to TP 850.08, the inspector witnessed testing to verify j proper operation of the air compressors sequencer. The test was stopped once because of an incorrect pressure value in Step 7.1.4

which resulted in compressor No. 2 starting before its expected

! value. A procedure change was implemented; however, during the reperformance the compressor again started before anticipated. The

licensee is investigating. The licensee's resolution will be re-viewed with the results package.

l With respect to TP 850.12003, the inspector witnessed.the transfer of

{ each 480 volt unit substation. During the performance, some expected

, alarms were not received. The inspector verified that test defi-j ciencies were initiated for evaluation as require No additional

concerns were note .

i With respect to TP 850.12004, the. inspector noted that the test had i an apparent typographical error in supporting procedure SP 1107.06 j which resulted in the wrong alternate supplies being listed for j Substations E2 and E3. This was identified by the test personnel j and the correct supplies were utilize The error in SP 1107.06 was j reported to the shift supervisor for correction. The inspector also i noted that the test was delayed due to a broken roll pin in the i electrical breaker discovered in Step 6.2.9 of PT 5103.02, "13.8KV Bus B Lockout Test." Investigation determined-that the broken pin j was a common nail. This item will be followed as an unresolved item ,

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pending the licensee investigation into the use of non-nuclear material in the repair of safety-related equipment (346/85039-13).- >

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' With respect to TP 850.23, the inspector noted that the test was

reperformed to verify some questionable differential pressure

! readings. The licensee is evaluating this data. The resolution

will be reviewed with the results package.

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' With respect to TP 850.28, the inspector witnessed Section 7 which obtained data on the CAC Fans when they are switched from high to low speed in an attempt to determine why they had been receiving an overload signal. No overloads were noted during the test and no i additional concerns were identified.

3 With respect to TP 850.31, the inspector witnessed the running of i one combination of two CAC fans in low speed with the dampers in their normal open position and then with the dampers held full ope More flow was obtained with the dampers held open, but the flow rate was not sufficient to meet the acceptance criteri The test data is being evaluated by the licensee and will be reviewed with the results package.

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. With respect to TP 850.37, the inspector had the following comments:

(1) As required by the procedure, the operator started EDG 1-2 by depressing the " idle start" pushbutton and secured the EDG by depressing the " normal shutdown" pushbutton. This procedure was inadequate in that after the EDG shutdown, it would imme-

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diately restart itsel The test leader attempted to secure the EDG using the same method with identical results. The EDG was then secured using the " emergency stop" pushbutton. It was determined that the TP was incorrect and an additional step was required to depress the " idle release" pushbutton prior to the

" normal stop" pushbutton. A Temporary Modification (T-MOD) was issued to the procedure to include this additional ste (2) The TP was performed to verify that the EDG 1-2 would start five consecutive times from a single air receiver charged to an initial pressure of 200 psi The EDG failed to start on its fifth attempt using air receiver 1-2-1. A revision was issued to the procedure to increase the initial pressure to 210 psi The EDG then successfully started five times from air receiver 1-2- The EDG was then tested with air receiver 1-2-2 charged to an initial pressure of 210 psig. The EDG again failed to start five time Troubleshooting determined that the air line oil lubricator was not functioning properl Following correc-tive maintenance, the EDG was successfully tested with an air receiver 1-2-2 pressure of 210 psig. The inoperability of the

EDGs as a result of a failure to start five times.from an initial air receiver pressure of 200 psig is discussed in detail in Section 3.c of this repor With respect to TP 850.78, the inspector witnessed Section 7 of the test which demonstrated that the modification on the EDG fuel oil storage tank alarm systems had deleted the high level alarm and that the low level alarm continued to operate properly. No concerns were

, identifie With respect to ST 5016.02, the inspector witnessed the successful completion of the weekly surveillance with the exception that the fire pump discharge relief valve which provides a minimum flow path was found leaking after the pump was secured. The inspector verified that there is an outstanding MWO on this problem. The inspector also

noted that Technical Specification Surveillance Requirement 4.7.9. incorrectly specifies that the fire pump should maintain the fire suppression pool to a pressure less than or equal to 95 psi The correct values should be greater than or equal to 95 psi This item

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will be followed as_an open item pending licensee investigation (345/85039-14).

No violations or deviations were identifie Three items were identified which require further action or evaluation by the licensee, NRC or bot .

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. SRTP Results Review The inspectors reviewed the following TP to ensure that the licensee is performing an adequate evaluation of test results; to ensure that all test data is either within previously established acceptance criteria or that deviations are properly documented and evaluated; and to verify that test results are reviewed, evaluated and approved by appropriate management personne TP 850.78, "EDG Diesel Oil Tank High Level Alarm Test" No violations or deviations were identifie . Open Items Open items are matters which have been discussed with the licensee, which

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will be reviewed further by the inspectors, and which involve some action on the part of NRC or licensee or bot Open items disclosed during the

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inspection are discussed in Paragraphs 4.a, 4.b.(1), 4.b.(2), 4.b.(3),

4.b.(4), 5.a, 6.b, and . Unresolved Items 4 An unresolved item is a matter about which more information is required in order to ascertain whether it is an acceptable item, an open item, a deviation, or a violation. One unresolved item disclosed in the inspection report is discussed in Paragraph . Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1)

throughout the month and at the conclusion of the inspection and summarized the scope and findings of the inspection activitie The licensee acknowledged the findings. After discussions with the licensee, the inspectors have determined there is no proprietary data contained in this inspection repor Attachment: Systems Important to Safe Operation

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b ATTACHMENT 1 SYSTEMS IMPORTANT TO SAFE OPERATION Group 1 Reactor Coolant System High Pressure Injection Core Flooding System Decay Heat Removal and Low Pressure Injection Containment Spray System Containment Emergency Ventilation Containment Air Cooling and Hydrogen Control Makeup and Purification System Group 2 Electrical 125/250 VDC (Includes Battery Room H&V)

Electrical 4.16 KV System (13.8/4.16KV Transformers Electrical 480V Distribution (Includes Inverters and Required Transformers)

Electrical 13.8 KV System (Includes Startup and Auxiliary Transformers)

Emergency Diesel Generators (Includes "Q" Fuel Oil Tanks and Diesel Room Ventilation)

Instrument AC Power (Includes Inverters and Required Transformers)

i Group 3 Anticipatory Reactor Trip System Control Rod Drive System Incore Monitoring (Includes Core Exit TC)

Reactor Protection System Steam Feedwater Rupture Control System Safety Features Actuation System Integrated Control System Security System Group 4 Control Room Normal and Emergency H&V System Station and Instrument Air-Station Fire Protection Component Cooling Water System Service Water System Group 5 Auxiliary Feedwater System Main Steam Steam Generator System Main Feedwater System ADDITIONAL SYSTEMS FOR SUPERVISORY REVIEW Gaseous Radwaste Post Accident Sampling Fuel Handling Ventilation Miscellaneous Containment Isolation Valves