IR 05000346/1986005

Insp Rept 50-346/86-05 on 860105-0303.Violations Noted: Failure to Return Components to Storeroom After Maint Work Order Completed & Jul 1984 & 1985 Annual FSAR Revs Failed to Reflect Extensive Facility Mods

ML20203K071
Person / Time
Site:	Davis Besse
Issue date:	04/18/1986
From:	Jackiw I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20203K024	List: IR 05000346/1986005 ML20203K020 ML20203K043
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.3, TASK-1.D.2, TASK-2.B.1, TASK-2.E.1.2, TASK-2.F.2, TASK-2.K.2.08, TASK-2.K.2.09, TASK-2.K.2.11, TASK-2.K.3.01, TASK-2.K.3.05, TASK-3.D.3.4, TASK-TM 50-346-86-05, 50-346-86-5, NUDOCS 8604300312
Download: ML20203K071 (38)

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U.S. NUCLEAR REGULATORY COMMISSION REGI0ti III Report No. 50-346/86005(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, Unit 1 Inspection At: Oak Harbor, OH Inspection Conducted: January 5 through March 3, 1986 Inspectors: W. G. Rogers P. M. Byron D. C. Kosloff B. L. Burgess C. D. Anderson D. S. Butler J. K. Heller Approved By:

&a I. K Jack w Chief tw

- //- 84 Re'actorfroje,ctsSection28 Date Inspection Summary Inspection on January 5 through March 3, 1986 (Report No. 50-346/86005(DRP))

Areas Inspected: Routine, unannounced inspection of previous inspection findings, Licensee Event Reports (LER), operational safety, Interim Performance Enhancement Program, Performance Enhancement Program, Systematic Assessment of Licensee Performance corrective actions, TMI Action Items, maintenance and management meetin Special inspection by resident and regional inspectors of licensee actions identified as a result of the root cause investigation of malfunctioning equipment during the transient of June 9,1985. The inspection involved 593 inspector-hours onsite by seven NRC inspectors including 95 inspector-hotirs onsite during off-shift Results: Of the ten areas inspected, no violations or deviations were identified in nine areas and two violations were identified in the area of followup of previous inspection findings (improper control of excess material and failure to update the Safety Analysis Report - Paragraph 2).

8604300312 860418 PDR ADOCK 05000346 G PDR

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DETAILS 1. Persons Contacted Toledo Edison J. Williams, Jr., Senior Vice President, Nuclear

• T. Murray, Nuclear Mission Assistant Vice President

• L. Storz, Plant Manager

• S. Smith, Assistant Plant Manager, Maintenance W. O' Conner, Assistant Plant Manager, Operations L. Ramsett, Quality Assurance Director J. Ligenfelter, Operations Engineering Manager M. Stewart, Nuclear Training Director R. Peters, Nuclear Licensing Manager

• Cook, Senior Licensing Specialist J. Wood, Mechanical and Structural Engineering Manager

• J. Byrne, Quality Assurance Auditor J. Michaelis, Operations Superintendent R. Flood, Technical Support Manager E. Salowitz, Planning Superintendent T. Bloom, Senior Licensing Specialist

• J. Hirsch, Special Programs Manager

• D. Wilczynski, Configuration Management Program Manager

• J. Lietzow, Nuclear Specialist II

• D. Siferd, Technical Support Engineer

• J. Syrowski, Training Programs Manager

• J. Stotz, Technical Support Group

• C. Hengge, Nuclear Safety

• T. Myers, Nuclear Licensing and Safety Director

• D. Amerine, A< sistant Vice President Nuclear

• P. Hildebran<.t, MPR Consultants NRC

• Rogers, Senior Resident Inspector

• D. Kosloff, Resident Inspector B. Burgess, Project Inspector D. Butler, Regional Inspector J. Heller, Resident Inspector C. Anderson, Resident Inspector

• P. Byron, Senior Resident Inspector

• Denotes those personnel attending the February 28, 1986, exi The inspectors also interviewed other licensee employees, including members of the technical, operations, maintenance, I&C, training, health physics and nuclear materials management department staf L

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2. Licensee Action on Previous Inspection Findings (Closed) Open Item (346/82021-14): The licensee has developed load tables for both emergency diesel generators. The tables were issued as controlled Drawings E-1042 and E-104 (Closed) Violation (346/84001-05): Failure to use controlled drawings during the performance of I&C maintenance activities. The licensee has removed field use, information only drawings from all shops. Training was conducted on Generic Guidance Memorandum SPO-1, " Alpha Drawings, Information Only Drawings and Uncontrolled Drawings." The use of uncontrolled Nuclear Safety-Related drawings for field maintenance is prohibited. This item is close (Closed) Violation (346/84012-02): Failure to return spray shields to their required condition following maintenance activitie The inspector performed an auxiliary ouilding tour and determined that some spray shields were not properly installe This situation was brought to the attention of the Plant Manager and the Assistant Plant Manager -

Maintenance jointly, who acknowledged that recently performed environ-mental qualification equipment walkdowns had identified similar problem In response to these noted deficiencies, the licensee revised the written guidance on spray shield restoration, incorporated administrative controls concerning spray shield restoration into the preventative maintenance work order system and committed to perform spray shield inspections of appropriate rooms upon completion of maintenance activities in that room prior to startup from the current outage. The inspector will monitor these additional corrective actions as an open item (346/86005-01) and perform another auxiliary building tour to verify that spray shields are being adequately maintained upon completion of the licensee's corrective action (Closed) Unresolved Item (346/84019-07): Updating of the Safety Analysis Report (SAR). The inspector reviewed the condition described and found it to be accurate with respect to licensee modifications to the pressurizer code safety relief valves (valve relocation, removal of related discharge piping to the quench tank, adding short lengths of discharge piping to each valve, capping the new discharge piping with rupture disks, and adding a drain line from the new discharge piping to the quench tank). The last of these modifications, FCR 82-083, was completed July 30, 1982 and none of the above changes were reflected in the July 1984, SAR annual revision. The inspector also determined that a description of modifications to the service water ventilation system under Facility Change Request (FCR)81-054 was not incorporated into the SAR in the time period specified in 10 CFR 50.71(e). The ventilation system was modified (installation of fans, rearrangement of air flow patterns and installation of automatic fan start circuitry) during the refueling outage of 1984 and an acceptance test completed on September 11, 198 However, SAR Subsection 9.2.1, " Service Water System," and Section 9.4, " Air Conditioning, Heating, Cooling, and Ventilation Systems,"

do not provide a discussion or a single failure analysis of the installed

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ventilation system. FCR 81-054 is not considered closed in the licensee's FCR system. Presently, the last supplement, 16, remains outstandin This supplement entails field verification of relay settings shown on a relay setting shee Failure to update the SAR is considered a violation (246/86005-02) of 10 CFR 50.71(e)(4). The cause of the update failures was untimely closeout of completed FCRs and an improper trigger point for identifying required SAR updating. The licensee's program for updating the SAR was based on the engineering administration department (EAD)

receiving completed FCRs and EAD would issue a memo to the licensing department to incorporate the FCR into the SAR where appropriate. The inspector determined that this program did not account for partially completed FCRs (the rest of the FCR deferred until sometime in the future) and any FCR closeout package rejected by EAD for inadequate documentation which did not receive an expeditious followup by construction personnel to rectify the discrepancie The licensee has now established an FCR closeout project to resolve discrepancies identified by EAD and ensure a more timely review and closeout of completed FCRs. The licensee intends to resolve the backlog of FCRs by the end of the next refueling outag (Closed) Unresolved Item (346/84019-13): Shift turnover checklist The inspector reviewed the licensee's turnover process and determined that it met the intent of NUREG-057 (Closed) Unresolved Item (346/84019-19): Failure to return excess material to the warehouse. The inspector determined that the conditions identified in Inspection Report No. 84019 were not in accordance with the licensee's administrative controls on material established by AD1847.00, " Station Materials Control." A Static 0-ring pressure switch (Serial No. 78-8-2584), found in the instrument and control (I&C) shop office on August 23, 1984, had been issued for performance of maintenance work order (MWO) 1-84-1449, which was completed May 29, 198 A solenoid valve (Serial No. 32-8490), found in the I&C storage space on August 23, 1984, had been issued for no specific MWO on January 5,1981. A limit switch (purchased under Purchase Order Q 66983A), found in the I&C storage spaces on August 23, 1984, had been issued for performance of MWO IC 104-81 which was completed on January 11, 1982. The inspector discussed this situation with the Assistant Plant Manager for Maintenance who stated that after the IER 84019 finding, the Quality Assurance Department had identified similar problems with shelf life item The inspector rtviewed the corrective action associated with the quality assurance shelf life issue, determined that they were not sufficient to correct the problem identified in IER 84019, and so informed the Assistant Plant Manager for Maintenanc The Assistant Plant Manager responded with corrective action which would provide adequate resolution of the problem and prevent recurrence. This involved inventory of all in plant storage locations and removal of all excess material from these locations by April 1, 198 The fact that excess material was not being returned to the warehouse within 30 days after the job completion date as stated in Paragraph 9.1 of AD1847.00 is considered a violation (346/86005-03)

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of 10 CFR 50 Appendix B Criterion II. The licensee's Nuclear Quality Assurance Manual lists ANSI N18.7-1972 as a standard committed to in Chapter 2. This ANSI standard requires control of materials and components necessary for plant maintenance and modificatio Procedure AD1847.00 partially establishes these material control Based on the corrective action designated by the Assistant Plant Manager for Maintenance, the inspector considers that no response to the violation need be given and has no further questions regarding this issue. Followup on these corrective actions will be a part of the routine inspection progra (Closed) Open Item (346/84020-03): Replacement of a c-clamp with welds on the control room emergency ventilation system. The field work to accomplish this FCR has been completed. The inspector observed FCR completion during the FCR walkdown on January 21, 198 (Closed) Unresolved Item (346/84028-03): Ground water presence in safety-related conduit located in the miscellaneous waste monitor tank room. The inspector discussed this situation with regional personnel who stated that this conduit could remain in that condition without degradation to the electrical cabl (0 pen) Open Item (346/84028-06): Establishment of a maintenance procedure to perform disassembly of the reactor coolant pump cover. The procedure will be generated Lc. 'e it is necessary to remove the pump cover. The procedure will incorporate the requirements of IEB 82-0 (0 pen) Open Item (346/84028-07): Method used to perform magnetic particle or liquid penetration inspections of reactor coolant system threaded fasteners. The licensee plans to change the appropriate maintenance procedures to incorporate the required inspection Discussion with the Assistant Plant Manager - Maintenance established that the inspection requirements will be issued prior to disassembly of the affected reactor coolant system pressure boundary threaded fastener (0 pen) Open Item (346/85003-06): Implementation of ventilation ductwork corrective action The inspector reviewed the nonconformance report disposition and the attached 10 CFR 21 evaluation form associated with the ventilation ductwork. The inspector noted that the 10 CFR 21 evalua-tion form concluded that this condition was 10 CFR 21 reportabl The inspector requested the licensee to provide an explanation as to why the

"other" block of the LER form did not indicate that this LER was reportable under 10 CFR 2 (Closed) Unresolved Item (346/85003-10): Vendor manual control during maintenance activities on an emergency diesel generator air regulato The condition observed by the inspector was another example of Violation 85001-02. The corrective action provided in response to this violation adequately addressed the proble r

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(Closed) Open Item (346/85003-11): Adequacy of the control room emergency ventilation system. The concerns raised by this open item have been superseded by the violations identified in special Inspection Report No. IER 85040, a report currently in the NRC review and approval proces (Closed) Unresolved Item (346/85003-12): Drawing error The inspector identified the errors to the licensee and they were corrected. Due to the small number of errors found the inspector considered that a programatic trend was not established and this matter is considered close (Closed) Open Item (346/85004-03): EVS transmitter facility change for freeze protectio The inspector observed that the freeze protection device had been installed under Facility Change Request 84-20 (0 pen) Open Item (346/85004-07): Safety Features Actuation System power supply commons. The licensee has issued Facility Change Request 85-177 to separate the power supply common (Closed) Unresolved Item (346/85010-02): A surveillance was being performed without the latest revision of the surveillance procedur Subsequent reviews showed that the surveillance procedure was an advance copy of a procedure that had been approved by the onsite review committee. During reviews of the unresolved item, the inspector expanded his reviews to include control of procedures used for maintenance. The inspector reviewed AD 1844.02.01, " Control of Work (MWO)" and AD 1838.00, " Surveillance and Periodic Test Program." AD 1838.00 requires the shift supervisor to ensure that tests are performed utilizing the latest revision of written test procedure Interviews with a shift supervisor revealed that all surveillance procedures are issued from his office file These files are reviewed weekly to assure the latest revision is in the files. In addition, the " Test and Procedure Index" which is updated daily, is reviewed when a surveillance procedure is issued. Interviews with Document Control Group (DCG) personnel revealed that revisions to procedures used to perform maintenance work orders (MWO) are identified by use of a Work Search Program and the DCG compute Once a MWG is identified as needing a procedure revision, the Lead Shop General Foreman and Foreman are responsible to assure the revision is incorporate Based on his review, the inspector determined that this was an isolated case and that adequate steps were taken to prevent recurrenc (0 pen) Unresolved Item (346/85016-04): Adequacy of Main Steam Isolation Valve (MSIV) testing. The licensee issued a new surveillance procedure, ST 5031.20, " Main Steam Isolation Valve Response Time Test," to test the closure capability of a MSIV via the A/B solenoids and C/0/E solenoids separately. Adequacy of MSIV surveillance testing completed before the new procedure was issued has yet to be determined. Without this determina-tion a decision as to whether a violation existed cannot be mad (Closed) Unresolved Item (346/85017-01): This item by the Vendor Inspection Branch included four examples that may form the basis for a violation. The individual examples and status of each are listed belo E

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Example 1: The vendor for the turbine driven auxiliary feedwater pumps issued a notification dated February 3,- 1984, advising that the trip / throttle valve could malfunction under certain condition The vendor recommended replacement of a spring in the trip / throttle valve. Paragraph 6.c of Inspection Report No. 85007 states "the spring in question had not been replaced at the time of the inspection and there were no records at Davis-Besse to indicate that the notification had been received or evaluated by the addressee."

Status: The licensee confirmed that the vendor notification had not been received. The licensee requested and received a copy of the notification on July 19, 1985. The notification was reviewed per the licensee's requirements for vendor supplied information (Reference: Licensee File 0274B). This example is close Example 2: Davis-Besse has fire dampers supplied by three different vendors; however, the Fire Damper Maintenance Procedure (MP 1405.07)

references only one vendor. In addition, a Ruskin fire damper was found to have an "S" hook installed backwards, with the open loop towards the blades. Ruskin had published information advising that a backward "S" hook may prevent proper closing of the dampe Status: The licensee has revised the Fire Damper Maintenance Procedure to include all fire dampers (reference: Licensee File CC12.1 and T-9150 to MP 1405.07). This part of Example 2 is close The inspector was unable to find documentation that the licensee had addressed the question of the backwards "S" hook. This was discussed with Site Licensing Engineering. The Licensing Engineer agreed to initiate paperwork to have this portion of Example 2 reviewed. Proper installation of the "S" hook will be tracked as Open Item (346/86005-05).

Example 3: The report documented some inadequacies in the Station Administrative Procedures for controlling vendor supplied informatio Status: The licensee review of this example documents that the requirements were covered by Nuclear Facilities Engineering Department Procedures (NFEP). The licensee revised the Station Administrative Procedures to reference the appropriate NFEP (Reference: Licensee File CC12.1 and T-Mod 9389 to AD 1848.02). This example is close Example 4: The vendor for the emergency diesel generators routinely issues Maintenance Instructions (MI) and Power Pointers (PP) to its i customers. The inspector found that the licensee was not aware of i

these; however, the Diesel Generator Maintenance Specialist did have

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some mis and PPs obtained when he attended vo' dor training classe The documents that the Maintenance Specialist had were not controlled, and therefore, reviews for applicability could not be verified.

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l Status: The licensee has ordered a new vendor manual which is being reviewed per Nuclear Engineering Department Procedure 041, " Vendor Manuals." In addition, as stated in Example 3 above, the licensee has revised Station Administrative Procedures to reference appropriate Engineering Department Procedures to assure vendor supplied material is reviewed (Reference: Licensee Files 02298 and CC12.1). This example is close Conclusion: Example 2 pertaining to improperly installed "S" hooks for Ruskin Dampers is still outstanding and will be tracked as an open ite The review did not indicate the need for enforcement actio (Closed) Unresolved Item (346/85017-03): GNB battery racks. Facility Change Request (FCR)85-078 modified the racks by placing tempered Masonite between the racks and the batteries to assure that the appropriate gap is maintained. The licensee's safety evaluation of FCR 85-078 stated that in the "as-found" condition the batteries had been operabl (Closed) Unresolved Item (346/85022-04): Flood retention capacity of BISCO fire seals. Following the inspector's identification of a problem with the flood protection properties of BISCO seals, the licensee generated a surveillance report on the subjec The inspector reviewed the disposition of the surveillance report which indicated that removal of the BISCO and grouting of the holes was an acceptable solutio Based on discussion with the personnel involved in the disposition the inspector understood that there was not a test report that subjected the seal to the same head of water that would be present given the worst flooding scenario for that seal. The inspector further ascertained that the design control process that allowed this to occur was the subject of current audit findings. The licensee has planned to walkdown all fire penetrations prior to startup and evaluate them for a number of hazard The inspector verified that the holes in question had been grouted and considers this unresolved issue closed. However, an unresolved item shall be generated (346/86005-06) with resolution contingent upon adequate corrective action in response to the audit findings, proper performance of the fire barrier walkdown and adequate evaluation of the fire barriers for hazards other than fire. The inspector noted that the controls for holes drilled in safety-related walls appeared to be minimal from the standpoint of hazards other than fire until the grout or BISCO is installed. The inspector will follow the licensee's initiatives in establishing more formal controls in this area as an open item (346/86005-07).

(Closed) Unresolved Item (346/85022-08): Failure to follow the jumper and lifted wire administrative procedure. The concerns identified with this unresolved item were escalated to a violation as identified in IER 8503 (Closed) Unresolved Item (346/85022-09): Inadequate testing of an auxiliary feedwater flow meter. The concerns identified with this unresolved item were escalated to a violation as identified in IER 8503 __ -__ _____ _ _ _ _ _ _ _ _ _ _ _

t (Closed) Unresolved Item (346/85022-10): Limiting condition for operation exceeded on auxiliary feedwater flow. The concerns identified with this unresolved item were escalated to a violation as identified in IER 8503 (Closed) Unresolved Item (346/85022-11): Improper procedure format used for calibration of auxiliary feedwater sonic flow indicator The licensee generated ST5071.06, " Auxiliary Feedwater Control-0-Tron Flow Meter Calibration," and incorporated this procedure into the surveillance test matrix as noted in AD1838.00, " Surveillance and Periodic Test Program."

(0 pen) Open Item (346/85025-10): Establish a maintenance procedure for emergency diesel generator governor replacement. The licensee is preparing procedure, MP 1700.84, addressing governor replacemen This procedure is scheduled to be completed prior to restar (Closed) Open Item (346/85025-15): Revise ST 5031.06. The surveillance test was modified on January 24, 1986, by temporary modification 1011 (0 pen) Violation (346/85025-18): Steam Generator (SG) No. 1 was overpressurized during auxiliary feedwater pump testing. After the overpressurization, a required engineering analysis of the SG was not performed as required prior to overpressurizing the SG a second tim The inspector reviewed the licensee response dated January 21, 1986, (Serial No. 1-608) and verified the following:

• Changes to procedures AD 1803.00, " Safety Tagging," AD 1839.00,

" Station Operations" and ST 5071.01, " Auxiliary Feedwater System Monthly Test" were mad * Meetings were conducted with Operations Department personnel to discuss the event, event findings, and corrective actions take The following items remain open but are scheduled for completion prior to startup:

• Complete training sessions on positioning Limitorque operated valves. As of February 13, 1986, six operators remained to be traine * Complete review of procedures that have a potential for overpressurizing the steam generators to assure they have provisions to provide a vent pat (0 pen) Open Item (346/85025-19): LER updating. The inspector has noted that the licensee is updating old LERs in a much more timely fashion and more resources are being applied in this are However, the inspector noticed that future corrective actions being identified in LERs generated in 1986 did not have completion dates assigned. The inspector discussed this situation with the Station Review Board Chairman who stated that the

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SRB had noted this condition also. The SRB chairman stated that the SRB would review all LERs generated in 1986 and ensure that completion dates were identifie Performance of this review is required for closure of

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this open ite (0 pen) Open Item (346/85025-24): Incorporate licensing and training procedures into the correct manuals. The licensing procedures have been incorporated into the Nuclear Safety and Licensing Division Procedures Manual and the training procedures still require incorporation into a training division procedures manual. In addition, the QA manual needs to be changed to reflect these division level procedure manual (0 pen) Open Item (346/85037-01): Multiplexer change out per FCR 84-08 The licensee has scheduled change out of all four conversion cabinets at a rate of one cabinet per refueling outage. The four cabinets which comprise the multiplexer are used to modify field instrumentation input to a signal that can be utilized by the plant compute (0 pen) Violation (346/85030-01): Failure to meet single failure criteri The inspector discussed the licensee's rebuttal of Section E of the Notice of Violation. The inspector was told that the steam line break analysis included a failure of the turbine stop valves to close as the single active failure. The licensee stated that including a failure of valve AF599(608) to reopen following repressurization of the good steam generator was a failure beyond the design bases of the facility. Since the original license conditions of the facility allow the turbine stop valves to be considered as the single active failure, then it appears that the design does meet IEEE 279. The licensec did state that the major thrust of the analysis of a steam line break was to assure i containment integrity by determination of the maximum pressure generated

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inside containment during this accident.

i Following the discussion of this analyzed condition the inspector identified a discrepancy between the analyzed condition for the steam

, line break and the Technical Specifications. Specifically, the analysis assumes a one second closure of the turbine stop valves. However, the

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Technical Specifications require a response time of less than or equal to five seconds for the closure of the turbine stop valves. This is the same response time as the main steam isolation valves. Therefore, if the i

turbine stop valves were to close in the maximum Technical Specification time, both steam generators would blowdown below the actuation pressure for SFRCS. If the single failure was taken to be valve AF599(608)

inability to open, then the auxiliary feedwater system would be prevented from fulfilling its safety function. The inspector's review of numerous surveillance records on the turbine stop valves revealed that the stop valves were closing within the accident analysis time of one secon Further discussion of the discrepancy between the accident analysis and the Technical Specifications is provided in Paragraph 14 of this report.

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k 3. Licensee Event Reports Followup Through direct observations, discussions with licensee personnel, and ,

review of records, the following event reports were reviewed to determine that reportability requirements were fulfilled, immediate corrective e action was accomplished, and corrective action to prevent recurrence had been accomplished in accordance with technical specification (Closed) LER 81-35 and Revision 1: Determination that the containment .

purge and exhaust valves would not operate as designe (Closed) LER 82-51, Revision 1 and Revision 2: Loss of 43VDC power supply in SFRC (Closed) LER 83-20 and Revision 1: Failure of Valve RC 240 to clos .

(Closed) LER 83-32 and Revision 1

Auxiliary feedwater flow transmitter j power supply inadvertently turned of (Closed) LER 85-06: Failure of control rod drive E-3 to meet trip tim P No violations or deviations were identifie . Operational Safety Verification

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The inspector observed control room operations, reviewed applicable logs and conducted discussions with control room operators during the months ,

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of January and February. The inspector verified the operability of

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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

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inspector by otservation 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 verified implementation of radiation protection control During the

months of January and February, the inspector walked down the accessible portions of the 250VDC electrical distribution system and emergency

diesel generating systems to verify operabilit During the 250VDC electrical distribution walkdown the inspector noticed

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that a domestic water pipe was installed above Battery Chargers DBC-2P, DBC-2N and 08C-1N. Therefore, the water line spanned battery chargers for both trains of the 250VDC system. The inspector read the USAR Section 3.6. 2.7.2.4, " Domestic Water System," and could not determine if this water line had been analyzed for pipe failure in a seismic event.

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The inspector brought the situation to the attention of the licensee who isolated water in the line by shutting a manual valve outside of the battery charger room and initiated a deviation report to investigate compliance of the line with appropriate design criteri This item is unresolved (346/86005-08) pending inspector review of the licensee's deviation report result During a tour of the auxiliary building the inspector observed the newly installed control panels for the control room emergency ventilation system (CREVS). Based upon these observations the inspector questioned whether the design control measures used for installation of the panels took into account the water lines which run over the top of the panel The inspector notified the licensee of the condition and the licensee is investigating the design of the panels to determine if they can withstand water spra This matter is considered unresolved (346/86005-09) pending further review of the design proces The inspector also reviewed some of the licensee's deviation reports (DVR) for the fall of 1985. The inspector noted that a DVR stated that a completed facility change request (FCR) had invalidated the single failure design of the auxiliary feedwater (AFW) and steam and feedwater line rupture co: trol system. The FCR had changed the position of a normally closed AFW valve. The DVR was marked as reportable under 10 CFR 50.73. No report was made because the licensee had later determined that the single failure design was not invalidated. The inspector requested the licensee to provide detailed justification as to why the condition was not reportable. This item will remain unresolved (346/86005-13) until the inspector can review the licensee's detailed justificatio On January 31, 1986, a mild earthquake was experienced at the site. The earthquake was not of sufficient magnitude to activate the licensee's active seismic monitoring system. Indications recorded by the licensee's passive monitoring system were consistent with the magnitude of the earthquake. The magnitude of the earthquake was verified by independent monitoring facilities. The inspector verified that the licensee's response to the event was appropriate. The inspector also performed an immediate independent partial walkdown of the plan These reviews and observations were conducted to verify that facility operations were in conformance with the requirements established under the technical specifications and administrative procedure No violations or deviations were identifie . Monthly Maintenance Observation Station maintenance activities of safety-related systems and components 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 maintenance which may affect system performanc The following maintenance activities were observed / reviewed: Modification of the No. 1 Emergency Diesel Generator (EDG) Air Start System as required by Facility Change Request (FCR)85-004 l Adjustment of No. 1 EDG air start system pressure regulator as required by FCR 85-004 Troubleshooting and replacement of computer incore detector channel point relay car Rewiring of Component Cooling Water Pump Room Vent Fan 1-2 intake damper Hydromotor actuato Modification of the Safety Features Actuation System (SFAS) power supply commons, as required by FCR 85-0177. Initial work was begun in Channel 1. The vendor, Consolidated Controls Corporation (CCC),

performed the changes according to the FCR package developed by CC The work was stopped when discrepancies were found between the FCR and the "as-built" configuration in the cabinet The licensee's Quality Assurance (QA) Department conducted audit No. 1524 of CC The licensee determined that 3echtel had revised CCC drawing S9N16-2 to reflect the "as-built" conditions in the cabinets. Bechtel issued a revision to 59N16-2 as 7749-E-30-25-12, Revision Bl. CCC did not have this current drawing revision when they prepared the required engineering changes. Audit Finding Report (AFR), No. 1525-1, was issued to require NFED to provide corrective actions to prevent recurrence of this type of proble Completion of the following corrective actions is an open item (346/86005-10): correct problem with CCC drawings; investigate and change other vendor drawing discrepancies; and revise current design interfacing procedure The licensee has issued supplement FCR 85-0177A. Licensee personnel have completed the wiring changes to SFAS Channels 1 and 3 and separation of power supply commons has been achieved. Work is continuing on Channels 2 and _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

. Calibration of the No. 2 EOG Jacket Cooling Water Heat Exchanger flow indicato Replacement of No. 2 EDG bearing temperature indicator TI 20178. A short was observed in bearing No. 9 thermocouple (TC). A maintenance I work order (MWO) was issued, however, exact location of the short was not found. A followup MWO was issued to install a spare T Post maintenance testing verified proper operation of the T Repair of damper CV 5009 air actuato Following completion of maintenance on the EDG, the inspector verified that the system had been returned to service properl No other violations or deviations were identifie . TMI Action Items

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(Closed) I.A.1.3.2, Minimum Shift Manning:

NUREG-0737 established new minimum shift manning requirements consisting of two senior reactor operators (one of which would be the shift supervisor), two reactor operators (RO), and two auxiliary operators for a single unit sit After the requirements were established in NUREG-0737, 10 CFR 50.54(m) was rev Ded to require that two senior reactor operators (SRO) and two R0s be present to meet minimum shift manning in any mode above cold shutdown. The inspector verified that AD 1839.00, " Station Operations" had been revised to require that two SR0s and two R0s be present in any mode above cold shutdow The inspector reviewed the licensee's shift roster and determined that the roster was in accordance with 10 CFR 50.54(m) and NUREG-073 The inspector reviewed Table 6.2-1 of the Technical Specifications and determined that the table was not consistent with 10 CFR 50.54(m). The inspector ascertained that the licensee had initiated a Facility Change Request (FCR) in 1983 to change Table 6.2-1 to require two SR0s. That FCR has yet to be submitted to NRR as a license amendment reques The inspector informed the licensee of the inconsistency and requested that the amendment request be submitted. The inspector informed the NRR Licensing Project Manager of the situatio (0 pen) I.D.2.2, Plant Safety Parameter Display (SPDS) Console Installation:

The inspector verified that the licensee had installed a system which utilizes process and computer inputs to generate graphs of select plant parameters. These graphs are displayed on cathode ray tubes located in the control room and the Technical Support Center. The resident inspector (DRP) inspection requirements have been met. A more detailed review of the plant safety parameter display console shall be done under a NRR site audit to be determined at a later dat _____ _ -

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(0 pen) I.D.2.3, Implementation of the Plant Safety Parameter Display Console:

, The inspector verified that the licensee had developed a procedure for the use of the SPDS. The procedure is SP1105.11, SPDS Operation Procedure. The inspector determined that the usability of the system was acceptable. A more detailed review of the plant safety parameter display

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console shall be done under a NRR audit to be determined at a later dat (0 pen) II.B.1.3 Establishment of Procedures for the Use of Reactor Coolant Vents:

The inspector reviewed emergency procedure EP 1202.01.02, "RPS, SFAS, SFRCS Trip or SG Tube Rupture," and determined that the sections on lack of heat transfer and inadequate core cooling provide direction on the use of the high point vent paths and the pressurizer vent paths. The inspector utilized (AT0G)-74-11255531-00, " Davis-Besse Abnormal Transient Operating Guidelines (ATOG);" Oconee AT0G 74-1123297-00 and TED letter (Serial No. 1106) to NRR of November 30, 1984. The letter identified differences between the two ATOG documents and differences between EP 1202.01 and the Davis-Besse AT0G. This item can not be closed until a determination is made on whether the reactor vessel head vent need be installed and confirmation that the present procedure guidance is adequate following vent testing at the Alliance Ohio test facilit (0 pen) II.E.1.2.2.c, Auxiliary Feedwater (AFW) Initiation and Flow:

The inspector reviewed documents and correspondence related to this NUREG-0737 item. Upon completion of this document review, the inspector determined that the following three areas required inspection: (1) Adequacy of the monthly functional testing of the Steam and Feedwater Line Rupture Control System (SFRCS); (2) Installation of a safety grade AFW flow indicator for each steam generator; (3) Establishment of surveillance testing procedures for the safety grade AFW flow indicators and the nonsafety grade AFW flow indicators in accordance with Technical Specification 4.3. The inspector determined that the SFRCS monthly surveillance testing was adequate with respect to the output relay contact Item 1 is considered closed. Inspections documented in IER 79019 and IER 85022 adequately reviewed the installation of the safety grade flow indicators. Item 2 is considered resolved. Item 3 shall be reviewed in a future inspectio Therefore, only Item 3 requires review and resolution for closure of TMI Action II.E.1.2. (0 pen) II.F.2. Inadequate Core Cooling Instrumentation:

The inspector reviewed the Reactor Coolant System (RCS) Hot Leg Level Monitoring System (HLLMS) instrumentation for computer display availability and computer power source reliabilit The licensee uses two separate computer systems. Each system can provide RCS HLLMS information to the Control Room operato The station computer, located

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in the Control Room, is powered from two unterruptible power supplies (UPS). The prime computer is located in the Technical Support Center and is powered from its own UPS, backed by a diesel generator unit. The redundancy, availability and use of high reliability power sources meet the intent of NUREG-0737 for computer display systems.

The inspector also compared the following surveillance tests (ST) to the licensee's Technical Specifications (TS):

• ST 5038.03.02 RCS Hot Leg Level Calibration

• ST 5038.04.03 RCS Hot Leg Level Monthly Test The STs fully meet TS requirement 4.3.3.6 and TS definitions for channel calibration (1.9) and channel check (1.10). The measuring and test equipment (MTE) met the accuracy requirements specified in the above STs.

The inspector reviewed the following drawings to ensure all changes had been incorporated:

• J-190 Revision OA, Sheet 1 Channel 1 Loop Diagram RCS DCN J-190-3 Hot Leg Level (LT-5448B)

• J-190 Revision 0A, Sheet 2 Channel 2 Loop Diagram RCS DCN J-190-4 Hot Leg Level (LT-5448A)

• J-190 Revision 0A, Sheet 3 Channel 1 Loop Diagram RCS HLLMS (TE-5450A, TE-5450B)

• J-190 Revision 08, Sheet 4 Channel 1 Loop Diagram RCS DCN J-190-5 HLLMS (TE-5450A, TE-5450B)

• J-190 Revision 0A, Sheet 5 Channel 2 Loop Diagram RCS HLLMS (TE-5449A, TE-5449B)

• J-190 Revision OB, Sheet 6 Channel 2 Loop Diagram RCS DCN J-190-6 HLLMS (TE-5449A, TE-54498)

• J-191 Revision OB, Sheet 1 Channel 1 Loop Diagram Nest Power Distribution

• J-191 Revision OB, Sheet 2 Channel 2 Loop Diagram Nest Power Distribution

• E-725 Revision 5 Block Diagram, Station Computer Systems Electrical Single Line Diagram; Davis-Besse Administration Building, Revision 5

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This item remains open pending the inspectors review of the licensee's void coefficient monitoring syste (Closed) II.K.2.8 Upgrade Auxiliary Feedwater System:

The inspector reviewed NUREG-0737 and determined that II.E.1.1 and II.E.1.2 of NUREG-0737 covered the actions associated with this ite The status of II.E.1.1 and II.E.1.2 is documented above. Any actions remaining on these items will be monitored and documented under the appropriate NUREG-number and therefore Item II.K.2.8 is considered close (0 pen) II.K.2.9 Failure Mode Effects Analysis on the Integrated Control System (ICS)

An ICS failure analysis documented by BAW-1564 contained six recommenda-tions. In correspondence dated January 9, 1980, March 25, 1982, and October 24, 1983, the licensee responded to NRR stating that some facility modifications would be performed as a result of the six recommendation Those modifications were: Additional pilot operating relief valve (PORV) and safety valve position indications would be provided under FCR 79-41 Electrical circuitry changed so that the PORV and pressurizer spray valve would close upon loss of power under FCR 80-05 Electrical circuitry changed so that pressurizer heaters deenergized upon loss of non-nuclear instrumentation under FCR 80-05 Electrical circuitry changed so that the letdown containment isolation valve would not close upon loss of non-nuclear instrumentation under FCR 80-07 Additional AC and DC power provided to the non-nuclear instrumentation 24VDC buses under FCR 80-09 Redundant AC power provided to the startup feedwater control valves, main feedwater control valves and the turbine bypass valves under FCR 80-23 Redundant power provided any instrument string which presented a given parameter required for cold shutdown that did not have anotter instrument string presenting the same parameter under FCR 80-10 Change the reactor coolant flow signal providing input into the integrated control system to an artificial signal under FCR 82-02 _ _ _ . - ._ . _ _ _ _ , - _ _ _ _

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The licensee response was considered acceptable by NRR in a safety evaluation dated April 5, 1982. The inspector performed a review and determined that the reactor coolant flow signal has been changed to an artificial 100% signal by FCR 82-023. Inspection of the FCRs which implemented the other commitments shall be the subject of future inspection (Closed) II.K.2.11 Upgrade Operator Drilling and Training:

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The inspector reviewed the licensee's administrative procedures for reactor operator training and requalification training. The inspector determined that classroom training on abnormal and emergency procedures is presented in the Pressurized Water Reactor Technology cours Recognition of degraded core cooling / inadequate core cooling guidelines and simulator training on small break loss of coolant and total loss of feedwater accidents is provided in the initial Reactor Operator Training program. The inspector determined that classroom training covered abnormal and emergency procedures and that simulator training included small break loss of coolant and total loss of feedwater accidents in each two year requalification cycl (Closed) II.K.3.1, Installation and Testing of Automatic Power-0perated p

Relief Valve (PORV) Isolation System:

NUREG-0737 stated that an automatic PORV isolation system would be required only if studies performed under NUREG-0737 II.K.3.2 confirmed that the system was necessary. On January 30, 1981, the licensee adopted the conclusions of the Babcock and Wilcox Owners Group generic report,

" Report on Power Operated Relief Valve Opening Probability and Justification for Present System and Setpoints." One of the conclusions was that an automatic PORV isolation system was not needed. In a-letter dated September 23, 1983, NRR agreed that the automatic system was not required. Based upon NRR's conclusions, this item is considered close (Closed) II.K.3.5 Automatic Tripping of Reactor Coolant Pumps:

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The inspector reviewed the appropriate documentation and the inspection requirements as stated in TI 2515/65. Following the issuance of Generic Letter 83-10, the licensee performed an analysis of small break LOCAs and the maximum assumed steam generator tube rupture to determine if a setpoint or criteria could be established for manually tripping the reactor coolant pump The licensee determined that loss of subcooling margin could be used as the criterion for manually tripping the reactor coolant pumps. Therefore, no automatic tripping system was installed and no inspection of that system for this item required. This item is close (Closed) III.D.3.4, Control Room Habitability:

NUREG-0737 required the licensee to assure that control room operators would be adequately protected against the effects of accidental release

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of toxic and radioactive gases and that the the nuclear power plant could be safely operated, or shut down, under design basis accident condition In a safety evaluation report dated June 30, 1982, NRR concluded that the control room habitability systems were acceptable without design changes being instituted. Two licensee submittals dated May 28, 1981, and March 16, 1982, were referenced as the licensee's position on this subject. The inspector reviewed these submittals and noted in the March 16, 1982, submittal that the licensee committed to change the appropriate station procedures to direct operators to isolate the Control Room Ventilation System in the event chemical contaminants are detected in the control room atmosphere. The inspector reviewed abnormal procedure AB 1203.14.05, " Toxic Gas and Liquid Release." The inspector determined that the personnel . actions section for a toxic gas release direct the shift supervisor, or assistant shift supervisor, to secure the Control Room Ventilation System and start the Control Room Emergency Ventilation System with the fresh air damper closed. If fumes from a toxic liquid release are sensed in the control room, the shift supervisor is directed to secure the fresh air damper to the Control Room Ventilation Syste No violations or deviations were identifie . SALP IV Commitments In the SALP IV report of December 6, 1984, the NRC requested the licensee to provide a written response stating the corrective actions that would be taken to improve performance in the areas of plant operations, maintenance, emergency preparedness, quality programs and training. The licensee responded in a letter dated February 4,1985, with supplemental information provided in a letter dated March 4, 1985. The two licensee letters reaffirmed the licensee's commitment to implement the Performance Enhancement Program (PEP) and identified other corrective actions in the deficient area The inspectors conducted a review and determined the status quo of a number of the licensee's corrective actions. The review included interviews with cognizant licensee personnel and familiarization with appropriate licensee documentation and correspondence. Status of a commitment action is provided under its appropriate functional area except PEP action plans which are statused in the succeeding section of this repor NOTE: The RP-XXXXX designator is a special tracking number assigned by the inspector to track licensee corrective actions associated with the IPEP, PEP, and the SALP IV report. Numbers beginning with 01 through 17 identify an IPEP action. Numbers beginning with 88 identify a PEP action plan not specifically committed to in the SALP IV response. Numbers beginning with 99 identify a SALP response action including PEP action plan General Management (Closed) Item (346/RP-99011): Establish a Management Review Task Forc The task force was formed, headed by the Vice President

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Nuclear, which reviewed the PEP and provided a report. Prior to the issuance of the report, there were significant management changes to the licensee's organizatio The new management established new priorities and methods for correcting the root causes identified in PE One of the inputs to that reprioritization was the task force report on PE The task force has since been disbande (Closed) Item (346/RP-99012): Establish senior management site visit This action was IPEP 04-1(01). A program was established and has been reinforced by the new managemen (Closed) Item (346/RP-99015): Establish a performance measures program in the Nuclear Mission. A program has been established which monitors 39 areas on a monthly basi b. Operations (Closed) Item (346/RP-99021): Administrative Procedure AD 1839.00,

" Station Operations," has been revised concerning the generation and documentation of valve lineups. Specifically, this revision provides increased guidance concerning the valve lineup of a system or component being removed from, or returned to, service. The guidelines are contained in various paragraphs of AD 1839.0 (Closed) Item (346/RP-9902?): Plant Procedure 1102.01, " Pre-Start Check List," was modified to impose increased requirements for valve lineup verification following an extended outag PP 1102.01.19, dated November 23, 1985, implements this requirement by requiring the Operation Engineer (now Assistant Plant Manager for Operations)

to evaluate the startup and specify the number of valve verifica-tions required prior to mode chang (Closed) Item (346/RP-99023): Administrative Procedure AD 1839.00 had been revised to reinforce control and accountability of procedure sign-off by requiring the use of initials rather than a check mar The requirement for use of initials was later moved to Paragraph 9.11 of AD 1805.00, " Procedure Preparation and Maintenance." It is acceptable to have the requirement in AD 1805.00 instead of AD 1839.0 (Closed) Item (346/RP-99024): The determination that a specific operations procedural step is not applicable must now be made by a Senior Reactor Operator (SRO) license holder. AD 1839.00.12,

" Station Operations," Section 5.2 implements this requiremen (Closed) Item (346/RP-99025): Establish tighter access control for the Control Room. The inspector verified that the licensee took the following initiatives to improve access control: enlarged the restricted zone which requires specific approval from a licensed operator to cross into; barred the equipment operators from the restricted zone; reduced the number of chairs to the minimum; moved

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hat racks to an area o'utside the Control Room; provided an office on the turbine deck,for the testing shift operators; moved the procedure files to th.e /dministrative Assistant's office; and, issued a memorandum jte all personnel regarding Control Room access.

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(Closed) Item (346/RP-99026): Encourage operator professionalis The following six specific actions were taken in this area:

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(1) Provide a new Test'ing Shift offic The inspector verified that a new testing,bffice has been established on the turbine floo (2) Expand the Equipment Operator Study Room. The inspector observed that the study room has been moved from the turbine building to a room just outside the emergency diesel generator rooms. The available space for study appears to have double (3) Remodel the Shift Supervisor and the Administrative Assistant Offices / The inspector observed thqt both offices have been remodeled.

(4) Provide new uniforms for all ope'rators. The inspector ascertained through discussion with select operators that new uniforms were provided the operator (5) Review the salary of the SRO qualified personnel on-shif As a result of a salary review, the licensee' established a significant differencerin base salary and bonus pay between reactor operators and senior reactor operator (6) Implement Maintenance By Objective (MBO). Implementation of MB0 will be monitored and statused under PEP Action Plan A-2 as Item (346/RP-99013).

(Closed) Item (346/RP-99027): Reduction of Control Room Nuisance Alarm The licensee committed to reduce the number of nuisance control room alarms and to maintain the number at a minimum. The licensee initially had a program to quarterly monitor the Control Room annunciators in the " alarm" condition. The mechanism to resolve these alarms was to issue a Facility Change Request (FCR),

Maintenance Work Orders (MWO) or a Request for Engineering Assistance (REA). Currently, ten (10) nuisance alarms require resolution prior to startup. Once these alarms are resolved, the Assistant Plant Manager for Operations expects a " Black Board" during power operation. At the exit interview, the inspector informed the licensee that two of the performance indicators that Region III monitors are the number of inoperable and continuously alarming Control Room annunciators at greater than 90% power, and the number of out-of-service tags in the Control Roo Therefore, the inspector shall monitor the success of the licensee's commitment to the blackboard concept in routine inspection effort .

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(Closed) Item (346/RP-99028): Procedure AD 1844.00, " Conduct of Maintenance," has been modified to require an experienced non-shift senior reactor operator (SRO) review all Maintenance Work Order This SR0 reviews the proposed work for potential impact on system operabilit Paragraph 6.1.4.5 of AD 1844.00 and Paragraph 6. of AD 1844.02 implement this requirement. This item is close (0 pen) Item (346/RP-99029): System by system USAR revie The licensee had started this review, however, following the June 9, 1985, transient the group was disbanded to support other effort The inspector identified that those design bases concerns which were being addressed by this group still need to be addressed. The inspector cited a specific example of a flow switch in the station ,

heating system, FIS 5222, which is taken credit for in Section  !

3.6.2.7.1.12 of the USAR to protect the control room emergency ventilation system from flooding. However, the instrument index does not identify this switch as safety-related and the setpoint index does not identify a specific flow at which this switch must actuate. This was the subject of a management meeting held on March 6, 1986, at the Davis-Besse sit (0 pen) Item (346/RP-99210): The licensee has established a goal of having only 23 lifted wire and jumper entries prior to startup from the current outage. These 23 entries are necessary for plant operations and cannot be removed without extensive plant modificatio On February 1, 1986, there were approximately 100 entries. This action will be considered closed when the number of entries is reduced to the established goal of 2 c. Maintenance (Closed) Item (346/RP-99031): Permanently fill the Maintenance Engineer position. The position has been filled and the job title elevated to the Assistant Plant Manager for Mainteranc (Closed) Item (345/RP-99032): Add four new foreman positions to the maintenance organization. Four people were promoted to an electrical, mechanical, I&C and general foreman positio (Closed) Item (346/RP-99033): Establish a corporate recruiting task force to recruit key personne The inspector interviewed the Assistant Vice President and ascertained that the task force exists and is being used to obtain the additional personnel mentioned in the licensee's response to the 10 CFR 50.54(f) lette (Closed) Item (346/RP-99034): Implementation of Management by Objectives (MBO) in maintenance. The implementation of MB0 mission wide is being monitored under PEP Action Plan A-2. Since maintenance M80 is a small subset of mission MBO, this item shall be closed and MB0 implementation shall be monitored under Iterr 346/RP-9901 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

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(0 pen) Item (346/RP-99036): Increase backshift coverage. Presently, the licensee is on continuous shift work. When the plant is returned to power, the licensee intends to provide two technicians per discipline with two supervisors for backshift coverag Closure of this item is dependent upon implementation of this coverage following restart from the current outag (Closed) Item (346/RP-99037): The Quality Circles concept was expanded in the spring of 1985. However, following the June 9th event and significant management changes in the maintenance area, the Quality Circles concept was abandoned. New management established post job critiques and training foreman positions to rectify the problems that quality circles were to addres (Closed) ltem (346/RP-99038): Require drawings and manuals to be controlled in the fiel Licensee responses dated February 4, 1985, and March 4, 1985, to the Systematic Assessment of Licensee Performance (SALP) Report (346/84-11) at Paragraph II.B.2 address strengthening of controls for use of control vendor manuals. The inspector's review of this area is discussed in the write-up for IPEP Action 12-5(02) located in Paragraph 9 of this repor (Closed) Item (346/RP-99039): A concern over the testing of modifications (FCR) prior to completion of the work was addressed by a change to AD 1845.03, " Facility Change Request Implementation."

This change specified that "all required work needed for system or equipment operability must be completed prior to conducting the related testing." The inspector requested the Assistant Plant Manager for Operations to provide further written guidance as to the type work that could be left outstanding and still not affect operabilit The Assistant Plant Manager stated that additional written guidance shall be provide (0 pen) Item (346/RP-99310): Reduce the Maintenance Work Order (MWO)

backlog. The licensee has performed 1385 of the 1855 outstanding work orders that existed on June 9, 1985. The licensee is also continuing their attempt to maintain control of the backlog of newly generated MW0 (0 pen) Item (346/RP-99311): Construct the Personnel Shop Facility (PSF). The PSF is currently under construction with the steel support structure erecte Emergency Preparedness (Closed) Item (346/RP-99041): Emergency Preparedness and Quality Assurance review the audit checklists. Inspectors reviewed this action, considered it satisfactorily resolved and documented the review in Paragraph 4.f of IER 8503 (Closed) Item (346/RP-99042): Establish an activity tracking syste Inspectors reviewed this action, considered it satisfactorily resolved and documented the review in Paragraph 4.b. of IER 8503 l

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(Closed) Item (346/RP-99043): Schedule the next exercise. The last exercise was scheduled for July 1985, and conducted on schedul This item is close (Closed) Item (346/RP-99044): Establish a Scenario Development Committe Inspectors reviewed this action action, considered it satisfactorily resolved and documented the review in Paragraph of IER 85038. This item is close (Closed) Item (346/RP-99045): Establish a Lead / Alternate EDO syste Inspectors reviewed this action, considered it satisfactorily resolved and documented the review in Paragraph 4.c of IER 85038. This item is l close (Closed) Item (346/RP-99046): Schedule table top exercises. Three table top exercises were performed on May 29, 30, and 31, 1985 and a more elaborate drill was performed on June 20, 198 (Closed) Item (346/RP-99047): Provide Controller Training classes prior to the next major scheduled exercise. Controller Training classes were given on June 18 and June 25, 198 e. Quality Programs (Closed) Item 346/RP-99051): Station Review Board (SRB) review of Nonconformance Reports which constitute nuclear safety-related temporary facility changes. The inspector reviewed the SRB charter and determined that Section 6.11 requires SRB review of all nonconformance report (Closed) Item (346/RP-99052): Establish controls so that safety evaluations are written on use-as-is and Repair Nonconformance

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Reports. Exhibit 1 of NFEP-060 has the appropriate informatio (Closed) Item (346/RP-99053): Modify AD1823.00, " Jumper, Lifted Wire, and Temporary Mechanical Modification Control Procedure,"

to require a written safety evaluation on nuclear safety-related jumpers and lifted wires. The inspector reviewed AD1823.00.14 and determined that the appropriate changes had been mad (Closed) Item (346/RP-99054): Update of design documents prior to Maintenance Work Order closeout. The inspector reviewed AD1845.04.00, " Facility Change Request Closecut," and determined that Enclosure 4 to the procedure addresses update of design document Also, Section 5.4, Steps 1 through 4 of AD1845.04 tie completion of the Enclosure 4 to Maintenance Work Order closur (Closed) Item (346/RP-99055): Establish a standing order on abnormal system configurations. The inspector determined that the standing order has been deleted and the information translated into AD1839.00,

" Station Operations." The inspector reviewed AD1839.00.12 and determined that, in Section 5.10 on equipment maintenance and

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Section 5.19 on removal from or return to service of a system or component, that the shift supervisor has been instructed to contact the operations superintendent when the shift supervisor is not certain when certain equipment affects operability. The licensee has developed a program to review all systems and identify operability requirements for applicable equipment in these system (Closed) Item (346/RP-99056): Implement a Surveillance Report System to identify potential quality concern The inspector verified through review of the Nuclear Services Division Procedures Manual, Nuclear Material Management Procedures Manual, Nuclear Facility Engineering Division Procedures Manual, Information and Records Management Procedures Manual, and Procurement Quality Assurance Instructions Manual that procedures were present which address reporting conditions adverse to quality under the Surveillance Report Syste The licensee has developed a mission wide procedure to identify and resolve potential quality concern (Closed) Item (346/RP-99057): Submittal of Audit Finding Reports for Station Review Board (SRB) review. The inspector reviewed the SRB charter and noted that Section 6.11 requires the SRB to review all Audit Finding Report (Closed) Item (346/RP-99058): Establishment of Audit Finding Report and Nonconformance Report resolutions as performance measure Performance Measure NM-201 was established concerning Audit Finding Report resolution and NM-202 was established concerning Nonconformance Report resolutio (Closed) Item (346/RP-99059): Attendance by the immediate supervisor of the audited area is required at QA exit interviews to ensure adequate management participation. QAI 4181, Revision 12 dated October 3, 1985, at Paragraph 7.4.3 requires, via memo from the Vice President, Nuclear, attendance of the direct supervisor being audited. If the direct supervisor is not available, the next level of supervision should be presen (Closed) Item (346/RP-99410): Control of cannibalization of spare part The inspector verified that AD1847.00, " Station Materials Control," Section 8.1 requires quality control's presence when equipment is cannibalized. The inspector determined that these controls are being adequately implemente (Closed) Item (346/RP-99591): QA Auditor Commensurate Training Progra This item involved the use of experienced technicians to provide expertise in the performance of QA audits. QAI 4185 was revised to allow qualification of technical specialists to perform QA audits. The inspector reviewed various audits performed by technical specialists and did not identify any concerns relative to the performance of these audit (0 pen) Item (346/RP-99592): Balance of plant quality assuranc This item shall be inspected in a future inspection perio _-

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(Closed) Item (346/RP-99593): Expanded Quality Assurance for General Orientation Training (GOT). This item is addressed as part of Open Item 346/84009-26; therefore, Item 346/RP-99593 is redundant and is close (0 pen) Item (346/RP-99594): Quality assurance training per division and/or department. This item shall be inspected in a future inspection perio f. Training (0 pen) Item (346/RP-99061): Write nuclear training procedure This item shall be inspected in a future inspection perio (0 pen) Item (346/RP-99062): Implement master training schedul This item shall be inspected in a future inspection perio (Closed) Item (346/RP-99063): Increase the size of the Training Department. This issue was identified originally in the diagnostic conducted by the Management Analysis Company (MAC) and documented in their report dated April 24, 1984. Since the identification of this issue, the training staff has tripled in siz Based on the inspector's review of the training organization, this item is close (Closed) Item (346/RP-99064): Significantly reduced self stud A program for development of self study has been provided by the Nuclear Training Department as guidance to the other divisions of the Nuclear Mission. For the nonlicensed operator, initial licensed

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operator and operator requalification programs, self study is

! controlled through the use of internal memoranda. Self study for the operators has been reduced from three days to a maximum of one and one-half day (Closed) Item (346/RP-99065): Improve licensed operator trainin The measures mentioned in the licensee's March and April response to the SALP involved preparation review, approval and analysis of operator exam and exam results. The inspector reviewed the applicable procedures and exam analyses and based on this review, this item is close (Closed) Item (346/RP-99066): Improve nonlicensed operator training using the Action Status Lis Non-operator training program improvements are being implemented through the use of the Action Status List. Milestones are generally accomplished within scheduled completion dates for specific program improvement (Closed) Item (346/RP-99067): Requalification Exam improvemen Training Department procedures NSP/NT-007 and NSP/NT-008 have been written to proceduralize the analysis of examinations and provide feedback for improvement of program identified weaknesses. The 1985 training schedule was developed based on knowledge weaknesses identified by analysis of 1984 exam weaknesse _ - _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ,

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(Closed) Item (346/RP-99068): Contractor lesson plans reviewed by the licensee. Training procedure NSP/NT-014, " Requirements for Vendor Instruction," requires review of vendor lesson plans prior to course delivery. Based on the inspector's review of this procedure, this item is close (Closed) Item (346/RP-99069): Contractor training evaluated by the licensee and students. Training procedure NSP/NT-014 requires student critiques for evaluation of vendor provided training and a random evaluation of vendor instructors in accordance with NSP/NT-00 (0 pen) Item (346/RP-99510): Accredit the licensee's training programs under the INP0 criteria. The last training programs are scheduled to be submitted for accreditation in late 1986. This item shall be closed upon the accreditation of all the licensee's training program (Closed) Item (346/RP-99691): Procedures for training staff evaluation of contractor trainin As discussed above, NSP/NT-014 requires random evaluation of vendor instruction in accordance with NSP/NT-009.

! No violations or deviations were identified.

l 8. PEP Action Plans I

During 1983, Toledo Edison (TED) and the NRC had a number of meetings to discuss diminishing performance of certain licensee activitie It was apparent that a coordinated, well designed improvement program was required to address the concerns. As a result of discussions and a survey of TED Nuclear Mission personnel, 16 " improvement categories" were identified encompassing specific areas of NRC concern and additional improvement areas identified by TED. Formal activities began in March 1984, and the program was submitted to the NRC on July 20, 1984. During the week of January 13, 1986, a team of three NRC inspectors attempted to review the PEP. During this review, the inspectors found that each PEP item was assigned a monitor. The monitor responsibility was to provide a monthly status of the assigned PEP item, noting any delays, assuring that computer scheduling was changed for overdue items, and to attach a statement or a copy of memorandum or reference to other documents that describe the results comprising completion of those implementation plan steps during the monthly report period. The inspectors reviewed the Implementation Flan Monitoring Package (IPMP) and it appears that the monitors functioned from February 1985 to September 1985. The inspectors found that work done prior to February 1985 was usually documented as complete and the dates noted on the computer printout; however, the appropriate reference for closeout was not made. For the IPMP completed from March to September 1985, some monitors provided the necessary information while others provided little or non Once the inspectors found that the IPMP were of little use, interviews were conducted with individuals assigned for each PEP item (the assigned individual was not

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the same as the monitor). The inspectors found that some individuals had created folders containing all of the information necessary to show how a PEP item was closed out. In other cases, the responsible individual had to search files, make phone calls or review the procedures index to find the information necessary to prove the item was closed. This form of record management can lead to lost informatio In addition, the inspectors were puzzled as to how the licensee was able to confirm that an item was indeed close At the exit interview, tne senior resident inspector informed the licensee that more complete and comprehensive files are required for those items currently open from the C0A, SALP IV, PEP and IPEP l commitment The licensee should assure that the appropriate management tools are in effect to assure the files show the appropriate paper path

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for close out of each item. This is aa Open Item (346/86005-11) pending establishment of those management control NOTE: The RP-XXXXX designators are defined in Paragraph 7.

, The PEP has changed in form from the initial program. Some of the items l

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have been incorporated in the Davis-Besse Course of Action (C0A) Progra Other steps have been completed. The following items are those that were reviewed by the inspectors during this inspection period: The A Plans (0 pen) Item (346/RP-99013): A-2, Integrated Approach to Goals, l Objectives and Strategic Plan. Approximately 40% of nuclear mission management personnel are working under the MB0 progra Continued efforts to increase this percentage shall resume following plant restar Presently, the licensee tracks MBO implementation progress under Performance Measure 6-NM 40 (Closed) Item (346/RP-88002): A-4, Management Styl The licensee established a written policy statement on this subjec Policy statement Pers.-2 embodies the licensee's management styl (Closed) Item (346/RP-88003): A-5, Provide Adequate Technical Expertise. This item was incorporated into plan A- The B Plans (Closed) Item (346/RP-88005): B-1, Merit Review Syste The licensee broadened the salary merit range which does not require submittal to the Salary Review Board for approval. A matrix was generated providing supervisor's with guidance in completing the merit revie (Closed) Item (346/RP-88006): B-2, Salary Administration Progra The salary structure was originally compared with industries from the local area. The licensee modified their salary comparisons to five nuclear utilitie Based upon the results of those comparisons

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the licensee made salary adjustments at the beginning of 1986 with an additional adjustment to take place in the beginning of 198 Also, new hire salaries were increase (Closed) Item (346/RP-88007): B-3, Qualifications - Position Description Questionnaires (PDQs). The licensee has generated

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completely new position descriptions for all nuclear mission personne (Closed) Item (346/RP-99612): B-5, Dedicated Personnel Unit to the Nuclear Mission. The licensee developed a new position under the Assistant Vice President Nuclear entitled " Personnel Administrator."

One of the duties stated in the position description is the coordination of wage and salary administration with active support from corporate personnel. The position has been fille (Closed) Item (346/RP-88010): B-7, Stress Managemen The licensee's training division developed a course on the causes and

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some actions that-can be taken to alleviate stress. This course was presented to the on-shift licensed operators in the summer of 198 i (Closed) Open Item (346/RP-88011): B-8, Employee Involvement /

Communications. The original plan was to develop a hands-on operational approach through a suggestion program with rewards, a survey and problem solving sub programs and a quality of work life employee involvement program. Following reevaluation by new management, these actions were considered impractical due to the availability of resources and past history with programs of this type. Two actions were substituted to improve communication The first was the issuance of a policy statement " Suggestions for Improvement" and the second was to improve the ratio of employees assigned to a supervisor, The C Plans (0 pen) Item (346/RP-99613): C/CM-1, Configuration Management. The Davis-Besse C0A, dated September 10, 1985, in Revision 4 dated November 16, 1985, committed to a configuration management proces 'Ep goals and objectives are:

• Determine the as-built configuration of the plant;

• Use the equipment data base to validate documentation;

• Use the equipment data base to help establish system descriptions which will be used for detailed design work and for the support of station activities;

• Establish a living data base; I

• Develop procedures to keep all validated data base information correc l

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The inspectors met with the Configuration Management Program Project

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Manager on December 18, 1985, to discuss the program. The manager provided the inspectors with a package dated December 2,1985, which consisted of:

• An overview of the plan;

• A flowchart of performance steps;

• A list of the Configuration Management Program Subtasks;

• A preliminary long range schedule.

In addition, the manager discussed the program and provided the following information:

• The system description for the High Pressure Injection System was being written by Babcock and Wilcox and will have been completed by February 28, 1986. This system description will be used as the guide for developing the remaining descriptions;

• Stone and Webster is currently performing a walkdown of all systems inside the containment and has a completion date of January 15, 1986;

• The walkdown teams will write observations to document their findings. The observations will be reviewed by cognizant plant personnel and then verified by Quality Assurance.

On January 7,1986, the inspector met with the project manager and Stone and Webster to discuss configuration managemen The inspector was informed that:

• Each system was subdivided into a manageable number of subsystems;

• Stone and Webster is preparing a walkdown package for each subsystem;

• Each walkdawn package requires verification of the mechanical, instrumentation, and electrical components for each subsystem;

• Each walkdown package was or will be performed by one two-man team (the individual teams are required to verify that data is correct);

• Problems found by the team will be documented by Surveillance Reports that are written by Stone and Webster and resolved by licensee (TED) engineers;

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• Stone and Webster was performing the first portion of Configuration Management - obtain the dat Stone and Webster provided the inspector with two complete walkdown packages (Service Water, from the containment penetration to containment air cooler 1-2 and Core Flood tank to the Reactor Vessel).

The inspector performed a walkdown of each package and found some minor discrepancies. The discrepancies were provided to the Project Manager on January 10, 1986, and discussed with licensee management at the exit interview for Inspection Report No. 8503 The inspector concluded that the program will provide useful information; however, there does not appear to be TED verification of the Stone and Webster data. The project manager stated that TED engineering personnel were not reperforming completed walkdown packages; however, TED QA was auditing the program. Additionally, TED engineers would validate data by comparison of the new data with previously obtained dat On January 16, 1986, the project manager informed the inspector that TED QA had issued a Stop Work Order for Configuration Management because of a discrepancy found with completed packages. The Project Manager stated the Stop Work was lifted after Stone and Webster retrained team members, assigned selected teams and committees to redo and/or verify a number of work package d. The D Plans (0 pen) Item (346/RP-990s., ;/06-1, quality Assurance (QA) Awareness Progra General Employee iaining has been revised including a 25 minute presentation on QA. All appropriate Division / Departments had initiated schedules for developing training on QA requirements and job related procedures. However, training was hindered by the June 9, 1985, event. Since then, a new QA Director has been appointed. The continuation of this PEP item is contingent on the policies and direction established by the QA Director. With the increase of personnel at the site, the inspector will continue to monitor the adequacy of the licensee's QA Awareness Progra (0 pen) Item (346/RP-99616): D/QA-2, Procedures Review Grou The action plan for this item involved the establishment of a dedicated QA Procedures Review Grou This item has been incorporated into the Course of Action to be accomplished in the normal course of business. With the appointment of the new QA Director, a specific QA procedure review group had not been establishe The licensee has proposed several organizational changes, but has yet to identify those specific actions to address the root cause of this PEP ite The inspector is monitoring the licensee's activities in this are The E Plans (0 pen) Item (346/RP-88016): E/SP-1, Hazardous Chemical Safet Prior to the development and implementation of this PEP item, there was no program for the control of hazardous chemicals at Davis-Besse. The major tasks yet to be completed are approval of Administrative Procedure AD 1813.00, Control of Consumable

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Materials, which is expected in February 1986, and then to comply with with the control program which is expected in late summer 198 The licensee plans on decreasing the number of consumables used onsite and, thus, will have to dispose of the other A list of Approved Consumable Materials is currently being developed by the Environmental Monitoring group which includes the Material Safety Data Sheet and an additional information sheet. The other activities associated with this PEP program, such as training, inspections, inventories, classifications, chemical tagging procedure development, and reference material gathering, have been completed. Some of these activities will continue, such as training and inspection This PEP item will remain open until all activities are complet (Closed) Item (346/RP-99628): E/SP-2, Shif t Technical Advisor (STA) l Assume Interim Emergency Duty Officer (EDO) Function. The STAS were '

given ED0 training in November of 1985. This training was to provide the necessary instruction to the STAS so they could help the shift

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supervisor in classifying emergencies. The EDO training has been incorporated into the training program for the STAS. The original intent of this PEP plan was to allow the STA to take over the role of the interim EDO. However, management modified the plan and the STA duties are consistent with the guidance provided by the NRC in the TMI Action Pla (Closed) Item (346/RP-99035): E/SP-3, Prioritize Non-outage Maintenanc The non-outage Work Prioritization Program is now in Paragraph 6.6 of Procedure AD 1844.02. An individual trained as a Senior Reactor Operator is responsible for assigning work priorities and the Operations Superintendent is responsible for review of assigned priorities (AD 1844.00, Enclosure 1); however, one individual who prioritizes maintenance work orders was unaware that the priori-tization program had become a part of the procedure. The inspector confirmed with the training division that this individual and other in his department were scheduled for training on the latest revision of AD 1844.02 upon its issue. The implementation of the program could not be reviewed due to the current extensive outage and infrequent use of the progra (Closed) Item (346/RP-99630): E/SP-5, Station Procedure Error Reduction Progra The licensee closed this item by memo dated November 18, 1985, by incorporating this PEP item with D/P-1 Nuclear Program Procedure The main thrust of E/SP 5 is the Qualif'ied Reviewer Program which will be reviewed with D/P-1. Following discussions and documentation review, the inspector has no remaining questions on the steps that were completed prior to the decision to incorporate with D/P- (Closed) Item (346/RP-99631): E/SP-6, Improve Generic Guidance Provided The Station Staff. The licensee reviewed all standing, administrative and special orders and from that review numerous orders were deleted or incorporated into procedures. The licensee

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included all orders still in existence into a generic guidance program and issued a controlled manual containing all these documents. The manual is entitled " Generic Guidance Program."

(Closed) Item (346/RP-99632): E/SP-8 STA Program Improvements. By memo dated June 4, 1985, the licensee closed this PEP item. The inspector spoke to the individual responsible for E/SP-8, reviewed the revised portions of Procedure AD 1828.21, Shift Technical Advisor Training Program, and reviewed E/SP-8 associated document The licensee was unable to locate the memo on the company policy for STA degree requirements. Further discussion on this matter revealed that confirmation of STA degree requirements was done verbally and no memo exists. However, subsequent to the licensee's closure of the PEP plan the position description on the STA was established requiring a degree. The inspector has no other concerns and considers this item closed; however, confirmation of the degree requirements should have been documented before the licensee considered this plan closed. This lack of documentation was discussed with the license (Closed) Item (346/RP-99633): E/SP-9, Maintenance MBO. This item shall be tracked under the Nuclear Mission MB0 implementation program, PEP plan A- (Closed) Item (346/RP-99634): E/SP-10 Determine the type of Permanent, Non-outage Backshift Coverage, if any, for I&C and Electrical Shops. See the inspector write-up on PEP plan E/SP-1 (Closed) Item (346/RP-99635): E/SP-11 Determine the type of Permanent Non-outage Backshift Coverage, if any, for Mechanical Maintenance and Station Services. These two items are treated together since they are the same except for the departments involved. The licensee was not able to produce the action plans or the documentation to show the closure of the three steps for each implementation plan. The inspector interviewed the responsible individual to ascertain that the steps of the program had been implemented in the Spring of 1985 which included a midnight shift along with the day shift. Following the June 9, 1985, Loss of Main and Auxiliary Feedwater Event, the decision was made to have continuous coverage and implementation occurred in November 1985. Though the documentation was not available, the inspector determined that E/SP-10 and E/SP-11 were implemented and then later expanded. The inspector has no further concerns about the completion of these two PEP items other than the lack of adequate program documentation and considers this item close (Closed) Item (346/RP-88018): E/SP-13 The environmental problems that resulted in degraded security computer reliability were corrected by the CAS relocation project. The relocation project was completed in January 198 The reliability of the new security computer will be monitored through the Safeguards Inspection Progra .

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(Closed) Item (346/RP-88019): E/SP-14 The performance of the security detection equipment could not be evaluated during the most recent Safeguards Inspection Report No. 50-346/86003(DRSS) because of ongoing acceptance testing for the new security computer. The licensee is continuing their evaluation of the equipment with vendor assistance. Security detection equipment performance will continue l to be monitored through the Safeguards Inspection progra F Plans None of the F plans were inspected during this inspection perio No other violations or deviations were identifie . Interim Performance Enhancement Program (IPEP)

Paragraph 10 of Inspection Report No. 85025 and Paragraph 5 of 85037 reported the status of IPEP in seventeen IPEP area During January and February, the inspector completed a review of the IPEP. The results of the inspector's review are summarized below:

Area No. 12 - Engineering 12-5(01) Commitment: Have Engineering verify that vendor manuals listed by station are availabl Status: This item (346/RP-12051) is closed based on the reviews that generated PEP interim Action 12-5(03).

12-5(02) Commitment: Establish a master file and a list of instruction manuals and develop a plan to identify controlled copie Status: Licensee files show that this item will be resolved by the Configuration Management Progra In addition, QA Audit Finding 1348-5 issued to the Station Maintenance Department on February 13, 1985, and closed December 31, 1985, documented that uncontrolled manuals were in use. The licensee revised AD 1844.00, " Control of Maintenance," and AD 1805.00, " Procedure Preparation and Maintenance," to control verification and approval of vendor manuals prior to us This item (346/RP-12052) is close (03) Commitment: Determine need/ availability of 5 manuals referenced in station procedures that could not be locate ,

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Status: By letter dated July 30, 1984, from T. D. Murray to L. A. Grime, the licensee documented that all vendor manuals referenced in station procedures have either been located, or their reference in station procedures have been delete This item (346/RP-12053) is close The inspector also performed followup reviews on some of the previously identified open IPEP actions. The result of those reviews is summarized below:

(Closed) Item (346/RP-06021): 6-2(01), ALARA FCRs. This interim action was to remedy any problems with Health Physics /ALARA projects receiving high enough priority by the Davis-Besse Work Scope Committee. In a memorandum dated December 2, 1985, the Nuclear Mission Vice President directed that all FCRs receive an ALARA cost / benefit ratio evaluatio Previously, only high budget modifications received such a review. A reprioritization of the ALARA FCRs, new and backlogged, is presently under way with a scheduled completion date of April 1, 198 (Closed) Item (346/RP-08013): 8-1(03), Training Diagnostic. The licensee contracted the performance of the diagnostic to MAC. Based on the diagnostic MAC made certain recommendations to correct the problems identified with the licensee having control over what corrective actions would be performe The inspector met with the licensee to discuss the status of the licensee's corrective actions related to the findings of the MAC training diagnostic. The inspector discussed the regulatory interest in the diagnostic and the need to address, point by point, the findings contained therein. The licensee explained that their progress

' in addressing the findings of the diagnostic were inherent with their effort to achieve INP0 accreditation. INPO accreditation is being tracked under Item (346/RP-99510). All training programs required to be accredited should be submitted by December 1986. Therefore, the majority of the diagnostic findings will be addressed by the first quarter of 1987. The licensee has committed to provide a resolution of the diagnostic or a justification for not addressing a diagnostic item by the end of the first quarter of 198 This commitment will be tracked as an Open Item (346/86005-12).

(Closed) Item (346/RP-08117): 8-1(17), Fill 13 Training Department Positions. The licensee has significantly increased the training department staff. All the training positions originally committed to have been filled except the STA instructo However, an individual has accepted the STA instructor position. With the acceptance of an individual as STA instructor this action is considered closed.

l (Closed) Item (346/RP-12025): 12-2(05), Update Logic Diagram The l inspector determined through record review that the logic diagrams had been updated.

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(Closed) Item (346/RP-12032): Correct Inconsistencies Between the SAR and Piping Class Sheets. The inspector determined through record review that the two documents had been reconcile No violations or deviations were identifie . Management Meetings i The ACRS subcommittee for Davis-Besse met on February 6, 1986, to review the draft Restart Safety Evaluation Report (SER). The licensee addressed the open issues and described their corrective actions. The staff accepted the licensee's corrective actions and reviewed the remaining open issue '

No violations or deviations were identifie . Corrective Action Plan Observations The licensee has developed corrective action plans for each trouble-i shooting action plan that had been developed to investigate the systems j which may have contributed to the abnormal behavior of equipment during the June 9, 1985, even The resident inspectors, with assistance from other Region III inspectors, observed portions of the work in progress i

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: No observations <

were made of corrective actions for this action plan during this

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inspectio Auxiliary feedwater (AFW) pump turbine and controls: The inspector verified the installation of a new gaitronics phone station near the No. 1 AFW pump turbine in accordance with FCR 83-011 Steam and Feedwater Rupture Control System (SFRCS): The inspector observed wiring checks in Steam and Feedwater Line Rupture Control System (SFRCS) cabinet C5762A to verify the as-built configuration and correct any drawing discrepancies. The results of the wiring checks indicated that some of the modules were incorrectly wire The licensee subsequently reported the deficient condition in ,

LER 86-009 as a Part 21. The inspector shall followup on the '

Part 21 in a future inspection.

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' Startup Feedwater Control Valve SP7A: No observations were made of corrective actions for this action plan during this inspectio Source Range Nuclear Instruments (NI-1 and NI-2): No observations were made of corrective actions for this action plan during this inspection.

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O t Turbine Bypass Valve (TBV) SP13A2: The inspector observed I&C mechanics prepare to implement FCR 85-0275, turbine bypass control improvement The FCR did not contain a wiring list, calibration information was not provided for applicable modules, and there was no mention of past FCR testing. The mechanics did not start the FCR and returned it with question Power Operated Relief Valve (PORV): No observations were made of corrective actions for this action plan during this inspectio Auxiliary Feedwater Valves AF 599 and AF 608: Results of observations made during this inspection period are documented in IER 86006, Steam line pressure discrepancies: No observations were made of corrective actions for this action plan during this inspectio Service Water valve controls for Auxiliary Feedwater (AFW) supply:

The inspector observed portions of FCR 85-0155, AFW pump 1-1 suction transfer from the Condensate Storage Tank (CST) to the Service Water, as implemented by MWO 2-85-0155-08. PSL 4928A was calibrated by Procedure IC 2700.13.00, " Plant Miscellaneous Pressure Switch Calibration." The data package for the pressure switch was complete and the head correction calculation was adequate. The I&C mechanics were qualified to perform the wor Valve MS 106: The activities related to this valve are the same as reported for item h. abov No violations or deviations were identifie . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations or deviations. An unresolved item disclosed during the inspection is discussed in Paragraphs 2 and . 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, 5 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 activitie The licensee acknowledged the findings. During the exit the inspector reiterated concerns over the inconsistency between the

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licensee's safety analysis and the Technical Specifications. The inspector cited two examples. The first example was discussed in i inspection report 85037 regarding the lack of Technical Specifications on !

the remote chlorine detectors even though they are taken credit for in the USAR, Chapter 15 analysis for a chlorine tank car rupture. The second example was the one second closure of the main steam turbine stop valves taken credit for in the steamline break analysis of Chapter 15 of the USAR. However, the time response required by Technical Specifications for the stop valves is less than or equal to five second Therefore, the Technical Specifications are not conservative with respect to the safety analysis. The inspector requested the licensee address these cases with s appropriate Technical Specification change requests. After discussions with the licensee, the inspectors have determined there is no proprietary data contained in this inspection repor ,

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