IR 05000346/1986027

Insp Rept 50-346/86-27 on 861001-1130.No Violations or Deviations Noted.Major Areas Inspected:Licensee Action on Previous Insp Findings,Tmi Action Items,Review of Work Items Deferred Until After Restart & Maint & Surveillance

ML20207F517
Person / Time
Site:	Davis Besse
Issue date:	12/31/1986
From:	Defayette R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20207F493	List: IR 05000346/1986027 ML20207F491
References
TASK-2.B.1, TASK-TM 50-346-86-27, NUDOCS 8701060104
Download: ML20207F517 (19)

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U.-S. NUCLEAR REGULATORY C0pWISSION

REGION III

Report No. 50-346/86027(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: October 1 through November 30, 1986 Inspectors: P. M. Byron .

D. C4 Kosloff J. M. Ulie N. C. Choules G. R. Klingler L. Whitney Approved By:

24 /h. JF R. DeFayette, Chief i/

/2 /dH 8/,

Reactor Projects Section 2B Date '

Inspection Summary Inspection on October 1 through November 30, 1986 (Report No. 50-346/86027(DRP))

Treas Inspected: Routine, unannounced inspection by resident inspectors of licensee action on previous inspection findings, TMI action items, review of work items deferred until after restart, seismic monitoring instrumentation, operational safety, licensee event reports,' maintenance, surveillance, Commissioner visits, and management meeting Results: No violations or deviations were identifie .

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DETAILS 1. Persons Contacted Toledo Edison

+J. Williams, Jr., Senior Vice President, Nuclear

+ Amerine, Assistant Vice President, Nuclear

• +L. Storz, Plant Manager

• S. Smith, Assistant Plant Manager, Maintenance

1. +W. O' Conner, Assistant Plant Manager, Operations

+E. Salowitz, General Superintendent, Outage and Program Management

1. • +L. Ramsett, Quality Assurance Director

• Stewart, Nuclear Training Director

+J. Wood, System Engineering Manager

1. • R. Cook, Compliance Supervisor

1. +P. Hildebrandt, General Director, Engineering

1. • +P. Anthony, Technical Support, Engineering

• F. Swanger, Operations

• +D. Stephenson, Senior Licensing Specialist B. Carrick, Engineering Manager J. Lammon, Senior Reactor Operator

1. L. Young, Fire Protection

1. W.-Nissen, Fire Protection Coordinator

1. A. VanDenabeele, Nuclear Projects

1. M. Murtha, Nuclear Engineering Department

1. J. Fay, Engineering General Manager

1. G. Patrissi, Fire Protection

1. J. Haverly, Fire Protection

1. J. Moyers, Quality Verification Manager NRC

1. • +P. Byron, Senior Resident Inspector

1. • +D. Kosloff, Resident Inspector

• R. DeFayette, Region III

1. J. Ulie, Region III

+N. Choules, Region III G. Klingler, NRR

1. Denotes those personnel attending the October 29, 1986, exit meetin + Denotes those personnel attending the November 14, 1986, exit meetin * Denotes those personnel attending the December 4, 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 staff.

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2. Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (346/85007-06): Resolution of Audit Finding Report (AFR) 1327-6 which was subsequently upgraded to Corrective Action Report (CAR) 06-03 regarding traceability of materials listed on maintenance work orders (MW0s). Engineering had completed their review of an audit of traceability of parts listed on MW0s and no problems were identified. The Quality Assurance Department had closed CAR 86-03 after verification of the corrective action. This item is close (0 pen) Open Item (346/85028-01): Allegation No. RIII-83-A-0029-01:

Test data did not exist to support penetration seal fire resistance capability, including test data to show that six inch silicone foam (BISCO) fire barrier penetration seals are rated for three hour After reviewing four test reports related to penetration fire seals, the inspector had concerns with three of the reports. In addition the inspector had a general concern that no documentation was available to show that the BISCO tast reports were reviewed by the licensee for theii applicability to the as-installed plant penetration fire seals. On October 18, 1986, in a telephone call between Region III management and licensee management, it was discussed that this item be resolved prior to plant restart from the current outag Consequently, the licensee initiated resolution of this item with NRR including the submittal of fire test reports by letter dated June 25, 1986, to justify the adequacy of fire barrier penetration seals installed in the plant. Based on NRR's review of these fire test reports, certain penetration seal assemblies could be considered acceptable pending clarification of a number of issue The remaining seals were determined not to conform with Appendix A to BTP APCSB 9.5-1 guidelines and are considered degraded in accordance with plant technical specification As a result, a telephone conference call between the licensee's staff and their consultants, NRR, and Region III was conducted on September 9, 1936. The licensee's staff confirmed that, in accordance with the action statement of the plant technical specifications, fire watch patrols had already been implemented on a plant-wide basis for these and other fire protection concern On October 28 and 29, 1986, a regional based fire protection inspector visited the site to verify adequate implementation of the fire barrier technical specification action statement. The inspector, accompanied by licensee staff and their contractors, toured the plant, including radiologically controlled areas, and observed six plant areas with a continuous fire watch in place and other plant areas being patrolled hourly.

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The inspector examined several completed fire watch patrol log sheets (attachments to Administrative Procedure AD 1810.00.8) used to document implementation of the fire watch patrol program. The inspector's examination of implementation of AD 1810.00.8 included interviews with fire watches which determined that the fire watches were knowledgeable of their fire watch responsibilities and dutie Consequently, the NRC staff determined that implementation of fire watch patrols in areas containing the degraded fire seals in accordance with the action statement of the plant technical specifications would provide adequate compensatory protection until the fire seals conform with Appendix A to BTP APCSB 9.5-1 guidelines. The licensee's remedial resolution removes this item as a restart restriction. Final resolution of this issue is being discussed with NR The licensee's staff did not identify any other previously opened items as ready for closur No violations or deviations were identifie . Davis-Besse Course of Action In an August 14, 1985, letter, the NRC requested that the licensee, pursuant to 10 CFR 50.54(f), furnish the NRC with its plans and programs to resolve NRC concerns related to the June 9, 1985, loss of feedwater event and other concerns listed in the letter. To meet the requirements of 10 CFR 50.54(f), the licensee developed the Davis-Besse Course of Action (C0A) and submitted it to the NRC as an attachment to a September 10, 1985, lette The inspectors reviewed the C0A and identified 33 commitment categories requiring NRC review. These commitment categories were given special tracking numbers. Each commitment category includes one or more specific commitments which have been assigned an LCTS identifier. Items assigned tracking numbers RY-000-01 through RY-000-20 are general commitment categories. Items assigned tracking numbers RY-100-01 through RY-100-13 address commitments made to correct conditions discovered during completion of the action plans for equipment that malfunctioned during the June 9, 1986, loss of feedwater even (0 pen) Item (346/RY-000-02), C0A II.B.1: Restructuring and Strengthening of the Nuclear Missio (1) (Closed) LCTS No. 1410: "A cognizant engineer from the new system engineering department will be assigned to each system to handle maintenance problems, preventive maintenance, regulatory concerns, quality problems, conditions adverse to quality, surveillance, testing and design modifications."

Licensee memo IF 86-0137, dated February 14, 1986, states that effective January 1, 1986, the Systems Engineering Division has been staffed. Contract personnel were assigned to augment the

.o permanent' staff. : Licensee memo NES-86-0141, dated August 28,

1986, lists Nuclear Plant System Engineering Assignments (Rev. 2). The inspectors verified that Systems Engineers were performing the functions described. This item is close (2)- (Closed) LCTS No. 1412: One foreman in each shop will be assigned specific responsibilities for training. Licensee Administrative Procedure AD 1844.16, " Training and-Qualification of Maintenance Personnel," dated March 12, 1986, and licensee organization chart, dated August 8, 1986,

established the required training positions. This item is close (3) (Closed) LCTS No. 2209: "The-personnel administrator will be included in the Assistant Vice President's staff." The

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licensee's position description for the job title, " Personnel

, -Administrator" dated October 21, 1985, and organization chart dated August 8, 1986, includes the Personnel Administrator in

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the Assistant Vice President's staff. The inspectors verified that-the Personnel Administrator was performing the functions described. This item is closed.

I (4)- (Closed) LCTS No. 2213: The Assistant Vice President will 3 concentrate his attention on security, personnel, and

[ administration. The licensee met this commitment in the job position description issued on October 21, 1985, for the job title, " Assistant Vice President, Nuclear." This item is close (5) (Closed)LCTSNo.2214: " Establish assistant plant manager, maintenance; assistant plant manager, operations; and an overall planning department." The licensee established the positionsofassistantplantmanager, maintenance (October 21, 1 1985), assistant plant manager, operations (October 21,1985),

and general superintendent outage and program management (April 23, 1986) for a planning department. The inspectors have observed all three individuals functioning in their respective positions. This item is close (6) (Closed) LCTS No. 2217: "The Training Department will report to vice president, nuclear." The licensee established the job title, " Nuclear Training Director" reporting to the Senior Vice President, Nuclear on October 21, 1985. This item is close (7) (Closed)LCTSNo.2218: "Vice president, nuclear will be relocated to the site." Licensee memo NLM 86-318 dated July 14, 1986, establishes a permanent work station on-site in the Davis-Besse administration building. The inspectors verified the existence and use of this work station. This item is close '

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(8) (Closed) LCTS No. 2219: "Vice president, nuclear report to the CEO." Licensee letter to H. Denton dated January 2, 1986, states that the senior vice president, nuclear will report to the CEO. This item is clost (9) (Closed) LCTS No. 2220: "All but nuclear services director reports to vice president, nuclear." The licensee closed this item as C0A APP. V.B.1.1. Since then, nuclear services is no longer a department. Information management, special projects, and environmental and emergency preparedness reports to the Assistant Vice President. The licensee met this commitment in the position description for the Information Management Director (July 14,1986) and organization chart (April 20, 1986) which described the position reporting to the Assistant Vice President, Nuclear. This item is closed, (0 pen) Item (346/RY-000-02), C0A II.B.3: Maintenance Improvement -

Progra (1) (Closed) LCTS No. 2210: Increase Instrument and Control shop foreman to worker ratio to approximately 1 to 7. The licensea has met its commitment as indicated by its organization chart dated August 8, 1986. This item is close (2) (Closed) LCTS No. 2211: Increase Electrical shop foreman to worker ratio to approximately 1 to 6. The licensee has met its commitment as indicated by its organization chart dated August 8, 1986. This item .s close (3) (Closed)LCTSNo.2212: Increase Mechanical shop foreman to worker ratio to approximately 1 to 10. The licensee has met its commitment as indicated by its organization chart dated August 8, 1986. This item is close <

(4) (Closed) LCTS No. 2221: " Assign training councils for each discipline." The licensee satisfied this commitment in Administrative Procedure AD 1844.16.0, Attachment 10, which establishes shop training councils. This item is close (5) (Closed) LCTS No. 2222: " Develop ' training shift' concept to assure that designated individuals are assigned for specific lengths of time totally devoted to training." The licensee established this requirement through Administrative Procedure AD 1844.16. " Training and Qualification of Maintenance Personnel," Section 6.4.1. This item is close c. (Closed) Item (346/RY-000-03), C0A II.B.1, LCTS No. 1419: Establish definitive position descriptions for each Toledo Edison employce at Davis-Besse, including a description of exactly what work that person is responsible for performing. The licensee interpreted tnis commitment to include only non-union represented employees. The inspectors have reviewed Volumes 2 through 4 of the Nuclear Mission Policy and Organization Manual which contain definitive position descriptions. This item is close .

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d. .(0 pen) Item (346/RY-000-04), C0A II.B.1: Increase and Relocate Staf (1) (Closed) LCTS No. 1409: "Most nuclear mission personnel and material support personnel .are.being moved to the site and all corporate engineering staff will be relocated to the site."

The licensee has completed the move of nuclear mission, material support personnel, and engineering from corporate headquarters to the site. This item is close (Closed) Item (346/RY-000-05), COA II.B.1, LCTS No. 1408: " Salary adjustments will be made to make TED truly competitive in recruiting talent and maintaining stability." This item is identical to PEF Plan B-2 and was closed in Inspection Report 50-346/86005, therefore this item is close (0 pen) Item (346/RY-000-08), C0A II.B.1: Improve Training Facilitie (1) (Closed) LCTS No. 761: " Reactor simulator will be purchased and operable by December 31, 1986." This is a SALP item and has been superseded by LCTS 1406. This item is close (2) (Closed) LCTS No. 1405: " Provide a greatly expanded training facility with electrical, chemistry, mechanictl, and I&C o laboratories." The four laboratories have been completed and i

available for use since January 6, 1986. The inspectors have

! observed the use of the training laboratories and the expanded training facility. This item is close (3) (0 pen) LCTS No. 1406: " Provide a site specific simulater."

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' The inspectors verified that the licensee had an active contract in place for the construction of a site specific simulator. This item will remain open until the simulator is

operational (currently projected for early 1989). (0 pen) Item (346/RY-000-10), C0A II.B.3 and Appendix III.2

Improve

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Maintenance.

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(1) (Closed) LCTS Nos. 1387 and 1388: "Results of the review of all plant systems will be used to improve the quality and effectiveness of the preventive maintenance program. Ongoing

reviews of the results of testing, corrective maintenance, and

preventive maintenance will provide information to upgrade the

preventive maintenance program." Licensee memo NES-86-10004

dated November 4, 1986, documents that the licensee reviewed 34

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systems as part of the System Review and Test P:ogram (SRTP).

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Preventive maintenance program impravements identified, as a i

result of the reviews, were classified as short-term or

long-term items. These items will be incorporated into the preventive maintenance program as part of the ongoing review

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and feedback program delineated by Preventive Maintenance Procedure AD;1844.01 and NEP-070. These procedures'also provide a continuing review for upgrading and. improving the preventive maintenance program. Region III also continues to review the SRTP and document this review in inspection reports dealing exclusively with the SRTP. The licensee is deve. loping a predictive maintenance. program to trend equipment parameters and. identify additional preventive maintenance measures intended to extend equipment life.and identify spare parts

requirements. This item will be reviewed in the future by the

. normal inspection process. This item is close (2) (Closed).LCTS No. 1742: "A position! description for the-training foreman is being developed and will be formally implemented by November 30, 1985." The licensee prepared a position description for the position of " Station Services -

Training Foreman" (January 15,1986) which completes the licensee's commitment. This item is close (3) .(Closed) LCTS No. 1743: "The procedure writers' guide and administrative controls for procedure development, review and approval will be completed by December 31, 1985." ~The licensee met its. comitment by issuing a. Procedure Writers' Manual

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-approved April 14, 1986, and Procedure AD 1805.00, " Procedure Preparation, Review, Approval and Revision," (Rev. 26) approved April 7,1986. This item is close (4) (Closed) LCTS No. 1745: "TED will implement a 7-day-per-week, 24-hour-per-day maintenance shift coverage. This shift work will comence with entry into Mode 4." Licensee memo dated April 18, 198G, (File'No. CC 12.1) documents that the maintenance department implemented a 7-day-per-week, 24-hour-per-day maintenance shift coverage commencing April 14, 1986. The licensee has met its commitment and this-item is close (5) -(Closed) LCTS No. 1746: "All maintenance personnel are being trained on the requirement of new position description Training will be completed by November 30, 1985. The licensee

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trained people on position descriptions by having them read their position descriptions and sign a memo documenting that it had been done. The inspectors reviewed the documentatio This item is close (6) (Closed) LCTS No. 1747: " Maintenance department training schedule which establishes maintenance training shifts will be approved and issued by Novem'>er 30, 1985." Licensee memo

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M85-86 and MA 86-0006 dated December 5, 1985, and January 24, 1986, respectively, transmitted copies of the maintenance long-term training shifts. This item is close _ .. . ._ __ _ _ ___ _ _ _ _ _ . _ _ _ _ _ . _ ..

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.(7) (Closed)'LCTS No. 1751: "The controlling procedure for the Preventive Maintenance Program has been revised to formalize PM identification, scheduling...." The licensee issued Temporary

' Modification Request (TMR) T-10416 (March 13,1986) .to  :

Administrative Procedure AD 1844.01.06. The inspectors

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' reviewed the TMR and the licensee met its commitment. This item is close (8)' (Closed) LCTS'No. 1755: "The program to improve plant i cleanliness will be completed by March 31, 1986." Licensee

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memo dated October 24, 1986, (File No. DSM-86-00047) states-

' .that the program to improve plant cleanliness is a program which will last for the balance of the-life of the plant; however, Phase I of the work is completed and Phase 2 is

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scheduled to be complete by the end of the fifth refueling outage, currently scheduled to end April 28, 1988. The-licensee has met its commitment and this item is close (9) (Closed) LCTS Nos. 2114 and 2115: " Develop a Nuclear Mission  !

i- Procedure (NMP-DS-206) ' Request for Assistance,' that contains ;

i mission-wide requirements in this area. After NMP-DS-206 is i issued, Station Administrative Procedure AD 1844.14 will be revised (or--superseded) as appropriate." The licensee issued r Nuclear Mission Procedures, NMP-DS-206 on June 30, 1986, and

' cancelled Administrative Procedure AD 1844.14 " Request for '

j Engineering Assistance," on September 2, 1986. This item is closed, i

j (0 pen) Item (346/RY-000-12) (Closed) C0A IV.C.2.2: Decay Heat

Removal Improvement Program.

=(1) (Closed) LCTS No. 1457: " Additional decay heat removal task

' force (DHRTF) recommendations related to SFRCS are under consideration and may, result in additional changes being made."

The DHRTF made additional recommendations which will result in system modifications. The inspectors reviewed the DHRTF final

} report dated October 15, 1985, and noted the additional  ;

l recommendation This item will be reviewed in the future by

the normal _ inspection process. This item is close (2) (Closed) LCTS No. 1720

"The control room will-have the

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capability to manually start the motor driven feedwater pump

!- (MDFP)." Licensee memo M-480N dated June 20, 1986, included a copy of Test Procedure TP 850.03, step 7.6.1 which verified the MDFP could be started from the control room. The inspector witnessed the MDFP being started from the control room. This

item is closed.

' (0 pen) Item (346/RY-000-14), C0A II.C.5, Control Room Improvement Program l

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(Closed) LCTS No. 548: Steam and Feedwater Line Rupture Control System (SFRCS) controls not located and arranged to support emergency task sequence. Facility Change Request 85-0015 was issued by the licensee to rearrange switches, install protective shrouds and relabel switches. The work was completed on November 5, 1986 and verified by the inspector on November 18, 1986. This item is close (0 pen) Item (346/RY-000-16), C0A II.C.7: System Review and Test Progra (1) (0 pen) LCTS No. 1428: " Corrective actions for problems with plant systems slated for long-term resolution will be identified after startup." The licensee has not completed action on this item and it will :emain as an open item (346/86027-01(DRP)).

(2) (Closed) LCTS No. 1429: " Plant system problems requiring short-term corrective action. The proposed resolution will be developed by the System Review Groups (SRG)." The licensee has addressed this comitment in Section D of Procedure SRTP-001, "Systen Review and Test Program Administrative Control Procedure," and in steps 1 and 2 of Procedure SRTP-004,

" System Review Evaluation and Corrective Action Development."

This item is close (3) (Closed) LCTS No. 1430: "The System Review Groups will evaluate each identified problem against an established set of criteria to determine the significance of the problem and, therefore, whether short-term or long-term corrective action is required." The licensee has adequately addressed this comitment in Procedure SRTP-004. This item is close (4) (Closed) LCTS No. 1435: " Concerns identified by the System Review Groups will be documented and proposed test outlines for newly required testing will be created." Procedure SRTP-006,

" Preparation of Test Outlines for System Review and Test Program," is the licensee's administrative control to fulfill this commitmen This item is close (5) (Closed) LCTS No. 1436: "The Independent Process Review Committee (IPRC) will review the identified concerns and concur with the need for additional testing if appropriate. The IPRC will evaluate the proposed test outline and conceptually approve the testing, as appropriate." Procedure SRTP-001, Section E, defines the duties of the IPRC and satisfies the commitment. This item is close (6) (Closed) LCTS No. 1437: "After the newly generated test requirements are conceptually approved, the System Review Group will initiate the development of new or revised surveillance tests which will be processed in accordance with existing i 10

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procedural program." Licensee memo NES-86-0150 dated

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September 5, 1986, lists the new or revised tests required b the SRTP.~ This item is closed.

(7) (Closed)LCTSNo.1440: "The System Review Group (SRG) will

evaluate the scope of surveillance testing that currently

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' the' testing for completeness and adequacy of testing with respect to design basis conditions." Section E of Procedure

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surveillance testing for adequacy. This item is close (8)

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(0 pen) LCTS No. 1522: " System Review and Test Program activity will also integrate the generic implications information from event investigations to assure appropriate consideration is

, given these factors in the power ascension test program." The

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licensee has committed to have this item completed sixty days after restart. Thisisanopenitem(346/86027-02(DRP)).

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C0A II.C.7 is also addressed in Section 3.4 of NUREG 1177 and the

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licensee's program was found to be~ acceptable. Region III also continues to review the SRTP and document this review in inspection l . reports dealing exclusively with the SRTP.

, (0 pen) Item (346/RY-000-18), C0A II.C.3: Evaluation of Single Failure Effect on Engineered Safeguards Systems.

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(Closed) LCTS No. 1516: "TED is reviewing-the Reactor Protection f,

. System (RPS) and Engineered Safeguard-Features Actuation System (SFAS) for similar single failure susceptibilities." The

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licensee's analyses of the RPS and SFAS was included in Appendix

C.3.3 of the C0A. The NRC review of the licensee's analyses is .

. documented in NUREG-1177, Section 3.3. This item is closed, e (0 pen) Item (346/RY-000-20),COAII.C.4, Review of Operations

Procedures and Training.

(1) (Closed) LCTS No. 1864: "TED's ATOG procedures will be revised

to require the use of the incore detectors." The inspectors l reviewed Emergency Procedure EP 1202.01.03, "RPS, SFAS, SFRCS l Trip on SG Tube Rupture" (the AT0G procedure) and verified that the required revision had been made. This item is closed.

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(2) (Closed) LCTS No. 2738: " Complete annual requalifichtion

, examination prior to entry into Mode 2." Licensee memo NTD-86-03003 dated November 7, 1986, states that-the annual i

requalification examinations for 1986 have been completed and

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attached the scores for reactor operators and senior reactor

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requalification examinations was audited by an inspection l team lead by a Region III inspector. This item is closed.

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. (0 pen) Item (346/RY-100-02), C0A IV.C.I.1: Action Plan 1 Auxiliary Feedwater Pump Turbine (AFPT) Overspeed Trip and Throttle (T&T) Valve Proble (Closed) LCTS No. 1248: Institute a semi-annual preventative maintenance (PM) item to clean and lubricate the AFPT T&T valve and the overspeed trip mechanism (OTM). The inspectors reviewed Maintenance Procedure MP 1401.23.01, "AFPT Governor, Governor Valve, and Trip Throttle Valve Maintenance," and determined that the procedure adequately addressed the lubrication of the T&T valve and OTM of each AFPT. The procedure did not address the cleaning aspect of the commitment. The inspectors discussed this deficiency with the licensee. The procedure is currently being revised and will include the cleaning requirements. The inspectors also reviewed a PM General Information Inquiry from the Davis-Besse Maintenance Management System (DBMMS) for AFPT-1-2 Trip Throttle Valve and noted that it contained a cleaning requirement. This item is close (0 pen) Item (346/RY-100-04), C0A IV.C.1.1: Action Plan 8, Main Feedwater Pump Turbine (MFPT) Control System Failur (1) (Closed) LCTS No. 1280: Replace and calibrate failed circuit board. The inspectors reviewed the completed maintenance work orders (MWO) used to replace calibrate and test the circuit board. The inspectors observed the successful testing of the MFPT after the licensee replaced and calibrated the failed circuit board. This item is close (2) (Closed) LCTS No. 1281: Replace solenoid valve cover plate bolts. The inspectors reviewed the completed MWO used to replace the bolts. This item is close (3) (Closed) LCTS No. 1282: Repair MFPT oil leaks. Maintenance personnel inspected the system and identified those leaks which needed to be repaired. The leaks were repaired by MW0s 1-85-3507-01, 1-85-3499-02, 03, and 08. This item is close (4) (Closed) LCTS No. 1283: Modify hydraulic system. The inspector verified that Facility Change Requests (FCR) 860055 and 860273 were completed. These FCRs eliminated two causes of spurious startups of the standby hydraulic oil pump. The completed modifications were tested by test procedure TP 850.61 which was reviewed by the NRC SRTP inspection team. This item is close (5) (Closed) LCTS No. 1285: Increase accuracy of MFPT speed indication. This was accomplished by calibrating the MFPT controller speed circuit. This item is close .

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(6) (Closed) LCTS No. 1286: Increase computer ti.ne scan rate for MFPT speed and MFP discharge pressure. The licensee increased the time scan rate for MFPT speed and determined that the time scan rate for MFP discharge pressure was sufficient. This item is close (7) (Closed) LCTS No. 1287: Modify MFP high discharge pressure trip circuit. The circuit was modified by adding a time dela This item is close (8) (Closed) LCTS No. 1288: Modify MFP high discharge pressure trip circuit. The circuit was modified by adding a time dela This item is close (9) (Closed) LCTS No. 1289: Modify MFP high discharge pressure trip circuit. The circuit was modified by adding a time dela This item is close (10) (Closed) LCTS No. 1290: " Evaluate the need for checking the rapid feedwater reduction (RFR) target speed setpoint calibration once every refueling outage." The licensee determined that the RFR target speed setpoint was calibrated every refueling outage in accordance with Preventative Maintenance Procedure PM 1804. The calibration was last completed April 28, 1986. This item is close (0 pen) Item (346/RY-100-05 , C0A IV.C.1.1:

Turbine Bypass Valve (TBV)) Actuator Failure. Action Plan 9A and 98,

-(1) (0 pen)LCTSNo.1244: DevelopPreventativeMaintenance(PM)

program to inspect all six TBV during the next two refueling outages. This action is not required until the next refueling outage and will be an open item (346/86027-03(DRP)).

(2) (Closed) LCTS No. 1245: Repair failed TBV-and actuato Maintenance Work Order (MWO) Nos. 1-85-1942-15 and 16 were issued to reinstall the actuators and rebuild the valve tri The inspectors observed the work done on the TBVs. The MW0s were closed March 13, 1985, and November 12, 1985, respectively. This item is close (3) (Closed)LCTSNo.1246: Install new steam traps and new drain valves. MWO 1-85-1942-09 was issued to install new steam traps and new drain valves. The inspectors observed the installation of the traps and valves. The MW0s were closed October 2, 198 This item is close (4) (Closed) LCTS No. 1247: Revise plant procedures to minimize the potential for water hammer. The inspectors reviewed Plant Procedure PP 1102.02.23 and noted that Section 6.4 ensures drains are unisolated and open to prevent water hammer and that the valve lineup sheet includes the proper valves. The

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J inspectors reviewed Plant Procedure PP 1102.10.15 and noted that Section 4.2.8.2 requires the main steam startup drains be opened. This item is close (0 pen) Item (346/RY-100-11),C0AIV.C.1.3,ActionPlan10,Reviewof-the Operation of the Power Operated Relief Valve (PORV).

(Closed)LCTSNo.1242: Procure an alternate PORV. The licensee purchased two Crosby PORVs, style HPV-SN, in August 1985. The valves are currently undergoing refurbishment at the vendor following testing at an offsite test facility. This item is close . TMI Action Items (0 pen) II.B.I.2: Install Reactor Coolant System (RCS) Vents. The inspector verified that the licensee has vent pathways in place from the high points of the pressurizer and both RCS loops. Technical Specification (TS) 3.4.11. addresses the operability requirements for the existing vent paths and TS 4.4.11 establishes the surveillance requirements for the existing vent paths. The surveillance requirements were implemented by Test Procedure TP 851.24, "RCS Vent Path Operability," which was reviewed and witnessed as part of the review of the System Review and Test Program (InspectionReport 50-346/86009). In the future the surveillance requirements will be performed under the direction of Surveillance Test ST 5031.1 This item cannot be closed until the installation of the reactor vessel head to hot leg' vent system is completed. The licensee plans to install this system during the next refueling outage (1988).

This schedule is consistent with an NRC interim exemption granted by a letter dated September 7, 198 (0 pen)II.B.1.3: Establishment of Proceduros for the Use of Reactor Coolant Vents. Procedures for the existing vents have been established; however, the licensee is having procedure validation testing done at an offsite facility. This item will remain open until the inspector reviews the testing documentation and reviews the procedures established for the reactor vessel head to hotleg vent syste No violations or deviations were identifie . Review of Items Deferred for Completion Until After Restart The licensee has many outstanding maintenance items which it had determined through various reviews were not required to be completed or closed out prior to restart of the plant. These items have been scheduled for completion at various times after restart including the next two refueling outages. The items included Facility Change Requests (FCRs), Work Requests (WRs), Maintenance Work Orders (MW0s), Deviation

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Reports (DVRs), Non-Conformance Reports (NCRs), Surveillance Reports (SRs), Jumpers and Lifted Leads, and items with a Potential Condition Adverse to Quality (PCAQ).

The inspectors reviewed the licensee's program and criteria for determining which items were required for restart and which could be deferred. Basically, any item affecting nuclear safety was required to be completed prior to restar The inspectors reviewed the deferred items to determine if they could have an effect on nuclear safety. The review consisted of reviewing lists of titles or short descriptions of items which had been deferred and picking items for further review which appeared to have the potential to affect nuclear safety. The vast majority of items reviewed did conform with the licensee's criteria for deferral until after restar The inspectors identified seven deviation reports (DVRs) (85-119,84-149, 85-144,86-030, 86-032, 86106,86-113), one WR (86-2987), and one MWO (1-86-1672-01) which appeared to require additional work or completion of~

corrective actions prior to restart. The licensee concurred with the inspectors' findings and was completing action on them prior to restar During the review of MW0s with the inspector, the licensee identified two MW0s (1-86-3022-00, and 1-86-3452-00) which were required for restart and had been inadvertently classified as not required for restar The inspectors' review of deferred items indicated the licensee has extensive reviews of deferred items and had, with minor exceptions, properly classified the No violations or deviations were identifie . Quality Assurance The licensee utilizes a Potential Condition Adverse to Quality (PCAQ)

report to document deficiencies and deviations. The PCAQ report includes a description of the deficiency, reportability review, initial review, root cause, proposed and actual remedial action, and corrective action taken to prevent recurrence. The inspectors review all PCAQs, including the licensee's root cause analysis. The review revealed that the licensee's root cause analyses need to be improved. The inspectors have discussed their concerns with the licensee. The licensee plans to initiate corrective action to improve the quality of root cause analyse This is an open item (346/86027-04(DRP)).

No violations or deviations were identifie . Independent Safety Engineering Group (ISEG)

The ISEG initiated monthly meetings with the inspectors to keep them informed of its activities and to discuss any concerns the inspectors have. The ISEG performs a nuclear safety overview and audit functio The ISEG developed safety evaluation training and is in the process of developing training to cover Chapter 3, Design Criteria, of the Updated

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Safety Analysis Report. The inspectors were informed that the ISEG performed a safety system functional type inspection on the auxiliary

.feedwater-(AFW) system. The inspectors will be provided with the final

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repor The inspectors also informed the ISEG that they were concerned about root cause analyses; the effects of nonsafety-related equipment on safety equipment; methods of minimizing the probability of a_ station blackout, potential _ effects of cold temperatures on ventilation _ system functions; fire water system piping pressurization; and the effects of AFW exhaust steam en equipment in. the component cooling water pump roo No violations or deviations were. identifie . - . Seismic Monitoring Instrumentation The inspectors have reviewed the licensee's maintenance and surveillance data for seismic monitoring equipment and verified that all technical specification related surveillances are scheduled. The seismic system

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has been inoperable since August 24, 1986, and is awaiting a triaxial accelerometer. The required maintenance is scheduled pending receipt of parts. The_ inspectors reviewed completed maintenance work orders (MW0s)

to verify documentation of equipment failures. The inspectors observed-the seismic sensing device and observed that it did not show visible signs'of deterioration in containmen No violations or deviations were identifie . Licensee Event Reports Followup Through direct observations, discussions with licensee personnel, and review of records, the following event' report was reviewed to determine that reportability requirements were fulfilled, inanediate corrective action was accomplished, and corrective action to prevent recurrence had been accomplished in accordance with technical specification (Closed) LER 85-21. Revision 1: Safety Features Actuation System Output Module Testin '

The inspectors' earlier review of LERs revealed that the licensee's safety evaluations were weak and frequently did?not address the safety issues. The inspectors selected several LERs and requested that the Group Director of Nuclear Engineering review the selected LERs. The inspectors met with him after his review. He concurred with the

. inspectors' evaluation. The licensee initiated a corrective action program which included training, emphasizing the importance of adequate reviews and a higher level of management review. The Independent Safety Engineering Group (ISEG) developed an 8-hour training program for safety evaluations. All licensee personnel who perform safety evaluations were required to attend the training. In addition, personnel from other licensees have attended the training. The licensee has received requests from other utilities to allow them to use the training which has been video tape <

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The inspectors have observed an improvement in the quality of LER safety evaluations. The inspectors continue their discussions with the licensee to seek continuing improvernent in the licensee's safety evaluation No violations or deviations were identifie . Operational Safety Verification The inspectors observed control room operations, reviewed applicable logs and conducted discussions with control room operators during the months of October and November. The inspectors verified the operability of selected emergency systems, reviewed tagout records and verified proper return to service of affected component Tours of the reactor, auxiliary and turbine buildings were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks, and excessive vibrations and to verify that maintenance requests had been initiated for equipment in need of maintenance. The j inspectors by observation and direct interview verified that the physical security plan was being implemented in accordance with the station

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The inspectors observed plant housekeeping / cleanliness conditions and

', verified implementation of radiation protection controls. During the months of October and November, the inspectors walked down the accessible portions of the Service Water and Emergency Diesel Generator systems to verify operabilit ,

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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 deviatio ce 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 r

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Work requests were reviewed to detennine 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:

Reinstallation of Service Water Pump 1- Disassembly of Auxiliary Feedwater Pump Turbine Steam Admission Valv Repair of Decay Heat Valve DH 13 Following completion of maintenance on the Service Water Pump and the Decay Heat Valve, the inspector verified that these systems had been returned.to service properl '

No violations or deviations were identifie . Monthly Surveillance Observation The inspector observed technical specifications required surveillance testing on the Station Vent Radiation Monitor, ST 5032.02, " Radiation Monitoring System Channel Calibration" and verified that testing was performed in accordance with adequate procedures, that test-instrumentation was calibrated, that limiting conditions for operation were met, that removal and restoration of the affected components were accomplished, that test results conformed with technical specifications and procedure requirements and were reviewed by personnel other than the individual directing'the test, and that any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personne No' violations or deviations were identifie l 13. Commissioner Visits l Commissioner Asselstine and the Deputy Director, Division of Reactor

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Projects (DRP), Region III and members of their staffs met'with the

licensee on October 27, 1986, to discuss the licensee's readiness for .

t: restart and tour the plant.

i l Commissioner Carr and the Director, DRP, Region III and members of l their staff met with the licensee on November 5, 1986, to discuss the

! -licensee's preparations for restart and current problem areas. A tour

of the plant followed the discussion . Management Meetings 7 Region III, NRR, and IE senior management met with the licensee on

[ - November 18, 1986, to review the items remaining to be completed prior  ;

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to restart and other issues. A tour of the facilities followed the discussion *

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l 15. 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 disclosco during the inspection are discussed in paragraphs 3.J.(1), 3.j.(8), 3.o,(1), and . Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1)

throughout the month and at the conclusion of the inspection and summarized the scope and findings of the inspection 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 . . - _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ .