IR 05000346/1986016

Insp Rept 50-346/86-16 on 860616-0731.Violations Noted: Failure to Control Overtime for Personnel Performing safety-related Work & to Carry Out Activities Re Quality in Accordance W/Procedures

ML20212P074
Person / Time
Site:	Davis Besse
Issue date:	08/27/1986
From:	Jackiw I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20212P050	List: IR 05000346/1986016 ML20212P046 ML20212P061
References
50-346-86-16, IEB-81-03, IEB-81-3, NUDOCS 8609020174
Download: ML20212P074 (9)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-346/85016(DRP) .

Docket No. 50-346 License No. NPF-3 Licensee: Toledo Edison Company Edison Plaza, 300 Madison Avenue

Toledo, OH 43652 Facility Name

Davis-Besse 1 Inspection At: Oak Harbor, Ohio Inspection Conducted: June 16 through July 31, 1986 Inspectors: P. M. Byron

- D. C. Kosloff P. R. Wohld Approved By: ie b,27-M Reaptor P ojects Section 2B Date

Inspection Summary Inspection on June 16 through July 31, 1986 (Report No. 50-346/86016(DRP))

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Areas Inspected: Routine, unannounced inspection by resident inspectors of licensee action on previous inspection findings, licensee event reports (LERs), operational safety verification, biofouling of cooling water heat exchangers, environmental qualification of limitorque motor valve operator wiring, monthly maintenance observation, strike activities, surveillance, service water pump maintenance, and followup on 10 CFR Part 21 repor Result: Of the ten areas inspected, no violations or deviations were identified in eight areas, one violation was identified in the area of the strike (failure to control overtime for personnel performing safety related work) and one violation was identified in the area of followup of previous inspection findings (failure to carry out activities related to quality in accordance with procedures).

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P B609020174 860827 PDR G ADOCK 05000346 PDR

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DETAILS Persons Contacted Toledo Edison ,

• J. Williams, Jr. , Senior Vice President Neclear D. Amerine, Nuclear Mission Assistant Vice President

• L. Storz, Plant Manager .

S. Sm'ith, Assistant Plant Manager, Maintenance M. Schefers, Information Management Director W. O' Conner, Assistant Plant Manager, Operations *

L. Ramsett, Quality Assurance Director

• M. Stewart, Nuclear Training Director R. Peters, Nuclear Licensing Manager J. Wood, Nuclear Plant Systems Director T. Bloom, Senior Licensing Specialist R. Flood, Technical Support Manager

• J. Stutz, Technical Support Group

• R. Cook, Senior Licensing Specialist B. Carrick, Nuclear Facility Engineering Director

• B. Beyer, Nuclear Projects Director E. Salowitz, Planning Superintendent P. Hildebrandt, Nuclear Engineering Group Director M. Fortel, Nuclear Licensing

• D. Stephenson, Senior Licensing Specialist

• J. Moyers, Quality Verification Manager

• J. Michaelis, Operations Superintendent

• J. Kasper, Maintenance / Mechanical' Superintendent

• S. Batch, System Engineer

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• J. Willard, Toledo Specification Surveillance Specialist

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• P. Byron, Senior Resident Inspector

• Kosloff, Resident Inspector P. Wohld, Region III Inspector

• Denotes those personnel attending the August 5, 1986, exit meetin 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 . Licensee Action on Previous Inspection Findi31 (Closed) Unresolved Item (346/86014-03). Section 1 of Administrative Procedure AD 1827.06, " Tornado", requires that the Toledo Edison load dispatcher notify the station that a tornado watch, or warning, exists for the vicinity of the station. Section 6.2 of AD 1827.06 states that Weather Bureau services are provided to the Toledo Edison load dispatcher

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by teletype and Section 6.3 states that Toledo Edison also maintains a radar weather surveillance system covering a 64 mile radius of Toled Davis-Besse is 21 miles from Toledo. The load dispatcher is the sole source of information for tornado watches or warnings listed in

. AD 1827.0 The licensee investigated this. event in response to the inspectors'

concerns and determined that the load dispatchers believed that Davis-Besse had the saae type of equipment as listed in Sections 6.2 and 6.'3 of AD 1827.06 and that it.was no longer necessary for them to contact the station. The load dispatchers were aware that notification had been made in_the past but did not know'if the policy was still in effect.. The licensee did not determine when the load dispatcher last notified the station of severe weather. The load dispatcher's failure to notify the station of the tornado warning on June 10, 1986,.is a Violation of

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. Technical Specification 6.8.1 (346/86016-01).

The licensee, by memo dated June 24, 1986,. requested that the load dispatchers notify Davis-Besse of severe weather information. This

- incident demonstrates the licensee's need to verify the adequacy of procedures that require support froin oatside the nuclear missio No other violations or deviations were identifie . Licensee Event Reports Followup Through direct observations, discussions with licsnsee personnel, and review of records,- the following event reports were reviewed to determina .

that reportability requirements were fulfilled,.immediate corrective action was accomplished, and corrective action to prevent recurrence ha been accomplished in accordance with technical specification (0 pen) LER 86-21: Inadequacies in Raychem Installations: .The licensee has identified 1150 electrical connections that require inspection. As of July 29, 1986, 504 connections had been inspected and 255 unsatisfactory Raychem installations have been identified.- The licensee has developed a test program to determine whether some of the identified unsatisfactory installations can be temporarily accepte The final test report is expected to be issued August 22, 1986.

(0 pen) LER 86-24

Inadequate Testing of Containment Isolation Valve Flanges. The inadequate local leak rate testing of the eleven valve '

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. flanges is considered an Unresolved Item (346/86016-02).

(0 pen) LER 86-25

Discrepancies between Technical Specifications and Installed Fire Detection. The four discrepancies identified are considered an Unresolved Item (346/86016-03).

f No violations or deviations were identified.

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4. Operational Safety Verification The inspector observed control room operations, reviewed applicable logs and conducted discussions with control room operators during the months of June and July. The inspector verified the operability of selected emergency systems, reviewed tagout records and verified proper return to service of affected component Tours of the auxiliary and turbine buildings were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks, and excessive vibrations and to verify that maintenance requests had been initiated for equipment in need of maintenance. The inspector by observation and direct interview verified that the physical security plan was being implemented in accordance with the station security pla The inspector observed plant housekeeping and cleanliness conditions and verified implementation of radiation protection control During the months of June and July, the inspector walked down the accessible portions of the Fire Water and 120 Volt AC Electrical systems to verify operabilit These reviews and observations were conducted to verify that facility operations were in conformance with the requirements established under technical specifications, 10 CFR, and administrative procedure No violations or deviations were identifie . Biofouling of Cooling Water Heat Exchangers The inspectors reviewed the licensee's response to INP0's Significant Operating Event Report (50ER) 84-01, "Bicfouling of Cooling Water Heat Exchangers", and held discussions with licensee personne The licensee performed an investigation in respunse to IE Bulletin No. 81-03 and determined that the Asiatic clam is a warm water species and could not survive in the temperature extremes of Lake Erie. The licensee uses closed cycle condenser cooling which does not provide thermal input to the lak They found no traces of the Asiatic clam in lake sediment samples and cooling system inspections in the vicinity of Davis-Besse. Thus, the licensee does not believe that 50ER recommendations 2, 3, and 4 are applicable. The licensee's engineering department considers that the present alarms for flow, pressure and temperature in the emergency core cooling systems room coolers, containment air coolers and the control room emergency ventilating system are sufficien Since no Asiatic clam fouling has occurred, the licensee's only action has been to request that Environmental Monitoring personnel observe preventative maintenance on the condenser, circulating water canal and the screen wash strainers. The licensee does not periodically inspect the fire protection system for biofoulin .

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The inspectors also reviewed the licensee's response to.IE Bulletin 81-03. . The licensee stated that they would prepare Preventative Maintenance. Work Orders to inspect piping in the fire protection, service water and component cooling water systems for clams and shell debris each fall after the peak breeding. seaso A licensee memo, dated July 21, 1981- requested the inclusion of this

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requirement in a new Surveillance Test,sST 5016.16, " Fire Protection

, System Flush". Reviews of ST 5016.16, Revision 3 (9/14/85) and

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Revision 4 (7/28/86) revealed no requirement to inspect for clams or debris. This is an Unresolved Item (346/86016-04). .

No violations or deviations were identified.- Environmental Qualification of Limitorque Motor Valve Operator Wiring The-licensee, as part of their Equipment Qualification (EQ) program, inspected the limit switch compartments of two Limitorque motor operators. Wires were identified that did not meet EQ requirement ~ Licensee Nonconformance Report (NCR) 85-1602 clocumented this findin Facility' Change Request (FCR)85-349 was then issued to inspect all safety related Limitorque operators and replace any wiring that could not

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be readily verified as qualifie The licensee's inspection of the 116 operators covered by the requirements of 10 CFR 50.49 identified 109 operators with wire that did not meet EQ requirements. The licensee was

. unable to provide documentation as to the qualification of most of the I

wire found.'.The licensee did not specifically document all the deviations as they replaced all wire found without adequate

2 documentatio The licensee has documented this finding as Potential Condition Adverse

, to Quality (PCAQ) No.' 86-0067. The PCAQ is currently being evaluated to determine if it falls under the requirements of 10 CFR 50.72 or 50.7 This is an Open Item (346/86016-05).

No violations or deviations were identifie . Monthly Maintenance Observation Station maintenance activities of safety related systems and components listed below were observed or reviewed to ascertain that they were

conducted in accordance with approved procedures, regulatory guides and

[: + industry codes or standards and in conformance with technical

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~ 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 or calibrations were i

performed prior to returning components or systems to service; quality

control records were maintained; activities were accomplished by

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. qualified personnel; parts and materials used were properly certified; radiological controls were implemented; and fire prevention controls were r implemente Work requests were reviewed to determine status of outstanding jobs and

'to assure that priority is assigned to safety related equipment maintenance which may affect system performanc The following maintenance' activities were observed / reviewed:

Installation of grilles for ventilation fans on Steam and Feedwater Line ,

Rupture Control System cabinet ,

.Reinsta11ation of. Service. Water Pump # 1- Replacement of electric motor on Service Water Strainer #1- Calibration of temperature switch for Service Water Pump room ventilation syste Following completion of maintenance on the Service Water system, the inspector verified that the system had been returned to .ervice properly.

No violations or deviations were identified.-

' Strike The strike which commenced June 2, 1986, was settled during the inspection, period. Members of Local 245 of.the International Brotherhood of Electrical Workers (IBEW) voted on July.11, 1986,fto ratify the licensee's-revised contract offer. Represented employees returned to work on July 14, 1986, and entered a re-entry program for approximately one week. The re-entry included training and required reading. The transition was orderly with no apparent problems.

i The inspectors reviewed the licensee's re-entry program and determined

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that it exceeded the requirements. The inspector's observations of various activities revealed that activities were being conducted ,

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satisfactorily and staffing met Technical Specification requirements.

- The Building Trades supported much of the outage work during the' strik The inspectors observed licensed operators and maintenance personnel l performing their duties and did not observe any whose job perfomance l- affected ~ safe operations of the plant; however, the inspectors wie

. concerned that some personnel'during the strike were working hours which were in excess of Technical Specification requirements. The ins'pectors requested that the licensee review their records 'to verify that no employee who performs a safety related function had exceeded Technical, Specification 6.2.3 requirements. Technical Specification 6.2.3 states in part " Adequate shift coverage shall be maintained without routine

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heavy use of overtime. The objective shall be to have operating

personnel work a normal 8-hour day, 40-hour week while the plant is

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operating. However,'in the event that unforeseen problems require substantial amounts of overtime to be used, or.during extended periods of shutdown for refueling, major maintenance or major plant modifications, on a temporary basis, the following guidelines shall be followed: 1) An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> straight, excluding shift turnover time. 2) An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24-hour period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any seven-day period, all excluding shift turnover tim Any deviation from the above gui' d elines shall be authorized by the Superintendent, his designee, or higher levels of management, in accordance with established procedures and with documentation of the basis for granting the deviation. Individual overtime shall be reviewed by Station Management to assure that excessive hours have not been assigne Routine deviation from the above guidelines is not authorized." ,

The licensee determined that between June 7 and July 11, 1986, 22 individuals worked at least one period in which they worked more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7 day period and 13 worked two periods exceeding 72 hou~ in a 7 day period. In addition, 15 individuals worked more than 24 hou na

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48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period at least once and the majority several times. Two individuals worked more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in a 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period in this time frame. Neither the plant manager or his designee authorized the overtime. The large number of deviations indicate that station management did not review individual overtime to assure excessive hours were not assigned. The above are a Violation of Technical Specification 6.2.3 (346/86016-06).

No other violations or deviations were identifie . Surveillance The inspector observed technical specifications required surveillance testing on the Fire Water System, ST 5016.02, " Fire Protection System Electric Pump Weekly Test" and verified that testing was performed in accordance with technically adequate procedures, that results were in conformance with technical specifications and procedure requirements and were reviewed by personnel other than the individual directing the test, and that any deficiencies identified during testing were properly reviewed and resolved by appropriate management personne The inspector also reviewed portions of the following test activity:

ST 5081.01, Diesel Generator Monthly Tes ,

-While perforniing Surveillance Test, ST 5081.01, Diesel Generator Monthly Test, on EDG 1-2 on July 11, 1986, the operator observed the room temperature was increasing. The operator also observed that the inlet

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damper, HV 5336A, was closed and the recirculation damper, HV 5336B, was open. This action is opposite to the desig The Diesel Room Ventilation System was declared inoperable and was documented in 7 -

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PCAQ 86-0133. The dampers were later placed in the proper position, the controller placed in the manual mode, and the system declared operabl Subsequent investigation by the licensee revealed that the'cause of the reverse action was a mispositioned switch in the Hydramotor Actuato The switch was found to be in the reverse position which resulted in reverse action. The Hydramotor Actuator for the EDG 1-1 dampers were operating properly. A revision to LER 86019 will be issue No violations or deviations were identifie . Service Water Pump Repair and Testing The inspector discussed activities related to installation and testing of Service Water Pump 1-1 and removal plans for Service Water Pump 1- Inservice testing was also di,scussed, including the use of clamp-on, ultrasonic flow meters and the use of a pump curve for reference value The licensee's activities and testing plans appeared fully acceptabl The inspector noted, however, that if the clamp-on flow meters do not meet the specific instrumentation requirements of Subsection IWV in Section XI of the ASME Boiler and Pressure Vessel Code, a relief request should be submitted to NR No violations or deviations were identified.

1 Followup on 10 CFR Part 21 The licensee experienced leakage problems with ITT General Controls Hydromotor Actuators which they believed could result in the actuator being inoperable. Region III was notified of a potential 10 CFR 21 by telecom on April 18, 1986. The licensee followed this with a written report on April 30, 1986. Subsequently it was determined that the leakage was not caused by manufacturing defects but by maintenance and testing ceficiencies and, thus, did not fall under the requirements of 10 CFR 2 The inspectors discussed their concerns regarding untimely reporting and the licensee is currently evaluating methods to improve their performance in this are No other violations or deviations were identifie . Management Meeting NRR and Region III management, with members of their staffs and an I & E representative, met with licensee management on July 22, 1986, to review the status of the licensee's restart and improvement programs in preparation for the July 24, 1986, Commission briefing. A tour of the facility preceded the discussions. The I & E representative received a detailed briefing in the problems relating to Raychem heat' shrink tubin No violations or deviations were identifie .

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13. Unresolved Items

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Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. Unresolved items disclosed during the inspection are discussed in paragraphs 3 and . 0 pen 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 bot Open items disclosed during the inspection are discussed in paragraph . Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1)

throughout the inspection period and at the conclusion of the inspection and summarized the scope and findings of the inspection activities. The licensee acknowledged the findings. After discussions with the licensee, the inspectors have determined there is no proprietary data contained in this inspection report.

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