IR 05000346/1986023

Insp Rept 50-346/86-23 on Aug-Sept 1986.Violation Noted: Failure to Promptly Identify & Correct Equipment Deficiencies

ML20213E189
Person / Time
Site:	Davis Besse
Issue date:	11/04/1986
From:	Jackiw I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20213E153	List: IR 05000346/1986023 ML20213E151 ML20213E177
References
50-346-86-23, IEB-86-002, IEB-86-2, NUDOCS 8611130045
Download: ML20213E189 (8)

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U.S. NUCLEAR REGULATORY COMISSION

REGION III

Report No. 50-346/86023(DRP)

Docket No. 50-346 License No. NPF-3 Licensee: Toledo Edison Company Edison Plaza, 300 Madison Avenue Toledo, OH 43652 Facility Name: Davis-Besse 1 ,

Inspection At: Oak Harbor, OH Inspection Conducted: August 1 through September 30, 1986 i

Inspectors: C. Byron osl ,f [ ,

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Approved By: ! . c iw, Chiefs 4& w /

Reactor Projects Section 2B

1. -dl6 Date Inspection Summary Inspection on August 1 through September 30, 1986 (Report No. 50-346/86023(DRP))

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Areas Inspected: Routine, unannounced inspection by resident inspectors of licensee action on previous inspection findings, licensee event reports, IE

Bulletins, operational safety, maintenance, surveillance, ombudsman program, emergency preparedness, security, and regional requests.

l Results: Of the eleven areas inspected, no violations or deviations were identified in nine areas, one violation was identified in the area of LERS l and followup of previous inspection findings (failure to promptly identify and correct equipment deficiencies).

8611130045 861105 PDR ADOCK 05000346 C PDR

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DETAILS 1. Persons (ontacted Toledo Edison J. Williams, Jr. , Senior Vice President Nuclear D. Shelton, Vice President Nuclear D. Amerine, Nuclear Mission Assistant Vice President L. Storz, Plant Manager T. Myers, Nuclear Safety and Licensing Director

• P. Hildebrandt, Nuclear Engineering Group Director G. Grime, Nuclear Security Director

• S. Smith, Assistant Plant Manager, Maintenance M. Schefers, Information Management Director W. O' Conner, Assistant Plant Manager, Operations L. Ramsett, Quality Assurance Director

• D. Harris, Quality Systems Supervisor J. Fay, Nuclear Engineering General Manager D. Briden, Chemistry and Health Physics Superintendent S. Jain, Nuclear Safety Manager M. Stewart, Nuclear Training Director R. Peters, Nuclear Licensing Manager J. Wood, Nuclear Plant Systems Director R. Flood, Technical Support Manager J. Stotz, Technical Support Group

• R. Cook, Senior Licensing Specialist E. Salowitz, Planning Superintendent

• J. Michaelis, Operations Superintendent

• G. Bradley, Nuclear Specialist NRC

• P. Byron, Senior Resident Inspector

• D. Kosloff, Resident Inspector

• Denotes those attending the October 2, 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 Findings (Closed) Unresolved Item (346/86012-02): Seismic Qualification of IE Electrical Cabinets Not Maintained. On January 10, 1986, the licensee issued Surveillance Report No.86-022, which identified missing door bolts on safety related Cyberex cabinets, a deficiency. The equipment items involved were the essential battery chargers, inverters, rectifiers and electrical distribution panels Y1, Y2, Y3, Y4, D1P, DIN, D2P and D2 Because the bolts had been missing since the plant was licensed on April 22, 1977, this is a failure to promptly identify a deficiency and

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is considered an example of a violation (346/86023-01) of 10 CFR 50, Appendix B, Criterion XVI, " Corrective Action." The missing bolts were required to maintain the seismic qualification of the equipment. The licensee corrected the deficiency on April 12, 1986. Since the deficiency was identified on January 10, 1986, the correction of the deficiency was not prompt and this is an example of a violation (346/86023-01B) of 10 CFR 50, Appendix B, Criterion XVI, " Corrective Action."

On April 22, 1986, the licensee issued Surveillance Report No.86-170, which identified that the Silicon Control Rectifier (SCR) balance potentiometers in the safety related Cyberex rectifiers and battery chargers did not have their settings locked with locking compound, a deficiency. The locking compound is required to maintain the seismic qualification of the equipment. Because the locking compound had been missing since the plant was licensed on April 22, 1977, this is a failure to promptly identify a deficiency and is considered an example of a violation (346/86023-01A) of 10 CFR 50, Appendix B, Criterion XVI,

" Corrective Action." The licensee corrected the deficiency on May 5, 1986. Since the deficiency was identified on April 22, 1986, and the corrective action required was simple and straightforward, the correction of the deficiency was not prompt and this is an example of a violation (346/86023-01B) of 10 CFR 50, Appendix B, Criterion XVI, " Corrective Action."

On May 12, 1986, the licensee issued Deviation Report No.86-107 which identified missing door bolts on the safety related Emergency Diesel Generator control cabinets, a deficiency. The bolts were required to maintain the seismic qualification of the equipment. Since the bolts had been nissing since the plant was licensed on April 22, 1977, this is a failure to promptly identify a deficiency and is considered an example of a violation (346/86023-01A) of 10 CFR 50, Appendix B, Criterion XVI,

" Corrective Action." Once the deficiency was identified it was promptly correcte No other violations or deviations were identifie . Licensee Event Reports Followup Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine that reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had been accomplished in accordance with technical specification (0 pen) LER 86-11: Essential Instrument AC Power Seismic Unqualified Cabinets. The licensee has experienced problems with maintaining seismic qualifications of Cyberex class 1E electrical equipment. LER 86-11 was issued March 27, 1986, to document that Cyberex inverters, rectifiers, battery chargers and essential power distribution cabinets were found with all door bolts missing. The bolts were required to maintain seismic qualification _ _ _ _

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The licensee determined on April 22, 1986, (Surveillance Report'86-170)

that the SCR balance potentiometers in Cyberex battery chargers and rectifiers did not have a locking compound required for seismic qualificatio Deviation Report (DVR)86-098 was issued on May 5, 1986, documenting the discrepancy. Later inspection by the licensee identified missing bolts on emergency diesel generator control panels. The licensee documented this discrepancy on DVR 86-107 on May 12, 1986. Both items are reportable under 10 CFR 50.7 Since both problems are related to seismic qualifications, the licensee chose to report them by revising LER 86-011. However, as of September 30, 1986, the revision had not been issued. This LER will again be reviewed for closure when it is revise (0 pen) LER 86-15: Seismic Qualification, Domestic Water Line in Battery Room A and B. On February 19, 1986, the inspectors notified the licensee that domestic water lines directly over three of the six Class IE station battery chargers apparently were not seismically qualified. The licensee later found that spray shields shown on design drawings had not been installed on the battery chargers to protect them from potential water leakage from the seismically unqualified water lines. The licensee also found that if the lines would have broken and sprayed the chargers there was a potential for serious degradation of the station's 1E electrical system. Because the spray shields had been missing since the plant was licensed on April 22, 1977, this is a failure to promptly identify a deficiency and is considered a violation (346/86023-1A) of 10 CFR 50, Appendix B, Criterion XVI, " Corrective Action." Once the deficiency was identified, it was promptly corrected by the license No other violations or deviations were identifie . IE Bulletin For the IE Bulletin listed below, the inspectors verified that the written response was within the time period stated in the bulletin, that the written response included the information required to be reported, that the written response included adequate corrective action commitments based on information presented in the bulletin and the licensee's response, that licensee management forwarded copies of the written response to the appropriate onsite management representatives, that information discussed in the licensee's written response was accurate, and that corrective action taken by the licensee was as described in the written respons (Closed) IEB 86-02, Static "0" Ring (SOR) Differential Pressure Switche The licensee determined from a document review that they have no Model No.102 or No.103 SOR differential pressure switches in safety related applications or in non-safety related applications as defined in 10 CFR 50.49(b). The inspectors also verified through the licensee's EQ program that neither model SOR switch was used in safety related applications, or in non-safety related application No violations or deviations were identifie ___________________________________ _____________ _ _ _ _ .

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5. Operational Safety Verification The inspector observed control room operations, reviewed applicable logs and conducted discussions with control room operators during the months of August and Septembe 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 viLrations and to verify that maintenance requests had been initiated for equipment in need of maintenanc The inspector by observation and direct interview verified that the physical security plan was being implemented in accordance with the station security pla The inspectcr observed plant housekeeping and cleanliness conditions and verified implementation of radiation protection controls. During the months of August and September, the inspector walked down the accessible portions of the Station Battery and Emergency Diesel Generator 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 While in the control room, the inspectors cbserved that operators did not repeat back verbal orders as required. The lack of repeat backs occasionally resulted in confusion during the September 23, 1986, Emergency Preparedness dril The licensee issued Generic Guidance Memorandum P0L-21, " Verbal Communications ' Repeat Back of Orders'," on April 2,1985, to improve plant communications and reduce errors. The operators failed to follow this procedure. The inspectors have discussed their concerns with the licensee. The licensee has initiated corrective actions including a procedure revision, emphasis to the operators by plant management and increased training. Tkts is an Open Item (346/86023-02).

As stated above, repeat backs reduce misunderstandings, which in turn reduces errors. This was highlighted on September 24, 1986, when an Equipment Operator (EO) observed a circuit breaker position indicating flag in mid position and requested permission from the Reactor Operator (RO) to operate the breaker control switch to match the flag with the breaker indicating light. The R0 granted permission and the E0 opened breaker AD 110, deenergizing essential bus D-1 and stopping decay heat pump 1- EDG 1-2 started and reenergized bus D-1. It is likely that if the R0 and E0 had used repeat back communications procedures, one of them would have realized that AD 110 was shut, providing power to bus D-1, and should not have its control switch put in the open positio _ _ _ _ _ _ _ _ _ _ _ _

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On September 25, 1986, Decay Heat (DH) System valve DH 13A failed closed, stopping flow in DH loop #2 and valve DH 14A could not be opened from the control room. The operators restored DH flow by starting the pump in DH loop #1. Valve DH 13A had failed on several earlier occasions. On September 29, 1986, a leak developed in the threads of a small pipe connected to DH pump #1. DH loop #1 was isolated to stop the leak. At this time, DH loop #2 was inoperable due to the problems with valves DH 13A and DH 14A. However, since the valves would function, DH loop #2 was placed in service. The inspectors will review the results of the licensee's. investigation of the equipment failures. This is considered an Unresolved Item (346/86023-03).

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 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 rela * vi equipment maintenance which may affect system performanc The following maintenance activities were observed / reviewed:

Installation of Station Batter Removal of Service Water (SW) Pump 1-1. The inspectors noted that some small parts removed from the pump were stored in the pump room in an apparently uncontrolled manner. This will be an Unresolved Item (346/86023-04) while the inspectors continue their inspection of the licensee's procedures for storage of parts removed during maintenanc No violations or deviations were identifie .

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. Monthly Surveillance Observation The inspectors observed technical specifications required surveillance testing on the Safety Features Actuation System (SFAS), ST 5031.07,

" Integrated SFAS Test", verified that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that limiting conditions for operation were met, that removal and restoration of the affected components were accomplished, that test results conformei with technical specifications and procedure requirements and were reviewed by personnel other than the individual directing the test, and that any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personne The inspectors also witnessed portions of the following test activities:

ST 5075.01, Service Water Monthly Test ST 5084.02, Station Battery Service and Capacity Test No violations or deviations were identifie . Ombudsman Program The licensee implemented an ombudsman program on September 17, 198 The program was put in place to accept concerns from individuals who believe ,

resolution of previously identified concerns to be inadequate, or those who desire to maintain anonymity. The ombudsman was set up to supplement existing reporting methods, not replace them. The ombudsman is a Toledo Edison employee who reports directly to the Senior Vice President, Nuclear. The inspectors have reviewed Nuclear Mission Procedure, NMP-AV-124, " Nuclear Group Ombudsman Program", issued September 17, 1986, and noted that the program is not part of the Quality Assurance progra The procedure contains mechanisms which elevate safety concerns. The inspectors informed the Vice President, Nuclear, and the Ombudsman of the need to notify the NRC of concerns involving wrongdoing. The inspectors will evaluate the effectiveness of the ombudsman program in a later inspectio No violations or deviations were identifie . Emergency Preparedness The licensee held an Emergency Preparedness drill on September 23, 198 The drill scenario included offsite radiological releases, enabling county and state participation. The resident inspectors observed the licensee in the control room, satellite Technical Support Center (TSC)

and the TSC. The drill was also observed by Region III inspectors. The observers concluded that the licensee's drill was successful but noted several areas for improvement. The drill will be documented in more detail in Inspection Report No. 8602 No violations or deviations were identifie _ _ _ - _ - _ - - _

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10. Security A licensee employee violated visitor escort procedures on August 5, 1986, by leaving visitors, three NRC inspectors he was escorting, out of his sight. The escort proceeded ahead of his visitors and the visitors did not know where their escort had gon A security officer observed the unescorted visitors and took them to their escort. The visitcrs were unescorted for less than one minute. This is an Unresolved Item (346/86023-05) pending further inspection by Region III security inspector No violations or deviations were identifie . Regional Request The inspectors reviewed a manufacturer's 10 CFR 21 report, dated July 25, ,

1986, concerning Static "0" Ring (SOR) pressure switches. The report listed nine switches which had been ordered by the licensee but none of these switches were Models No. 102 or No. 103 that were identified in IEB No. 86-02 (see Paragraph 4 of this inspection report). The inspectors reviewed two licensee Potential Condition Adverse to Quality reports that identified six of the switches installed in the plan The other three switches had not been installed and were being controlled by two Supplier Deviation Reports. The licensee's corrective action is still in progress and this will remain an Open Item (346/86023-06) until the inspectors can review the licensee's corrective actio 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. Unresolved items disclosed during the inspection are discussed in Paragraphs 5, 6 and 1 . 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 5 and 1 . Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1)

throughout the period of the inspection 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 repor