IR 05000346/1986032
| ML20207S537 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 03/11/1987 |
| From: | Defayette R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20207S534 | List: |
| References | |
| 50-346-86-32, NUDOCS 8703190644 | |
| Download: ML20207S537 (41) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-346/86032(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: December 1,1986, through January 31, 1987 Inspectors:
P. M. Byron L. Kelly D. C. Kosloff J. P. Smith R. W. Cooper T. Stetka A. W. DeAgazio L. Valenti J. A. Isom R. Westberg M. R. Johnson L. E. Whitney L. Kanter P. R. Wohld
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Approved By:
R.
eFa t
Reactor Projects Section 2B Da'te
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Inspection Summary Inspection on' December 1, 1986, through January 31, 1987 (Report No.
50-346/86032(ORP))
Areas Inspected: Routine, unannounced team inspection by resident and regional inspectors of licensee action on previous inspection findings, Davis-Besse course of action program, startup activities, ombudsman program, training, operational safety, maintenance, surveillance, Licensee Event Reports, events, allegations, licensee response to RIII Davis-Besse study group report, and emergency preparedness.
Results: Of the thirteen areas inspected, no violations or deviations were identified in twelve areas. Two violations were identified in the area of operational safety (failure to follow procedures, Paragraphs 7.b.2, 7.b.3 and 7.b.5; and an LC0 violation, paragraph 7.b.4).
0703190644 870313 PDR ADOCK 05000346 PDR G
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DETAILS 1.
Persons Contacted a.
Toledo Edison J. Williams, Jr., Senior Vice President, Nuclear
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D. Shelton, Vice President, Nuclear D. Amerine, Assistant Vice President, Nuclear
+*L. Storz, Plant Manager
+*S.' Smith, Assistant Plant Manager, Maintenance W._0' Conner, Staff Consultant
+*R. Flood, Acting Assistant Plant Manager, Operations
+*E. Salowitz, General Superintendent, Outage and Program Management
+*L. Ramsett, Quality Assurance Director
+*M. Stewart, Nuclear Training Director J. Wood, System Engineering Manager
+*R. Cook, Compliance Supervisor
+*P. Hildebrandt, General Director, Engineering
- B. Carrick, Engineering Manager
+*D. Haiman, General Manager, Engineering
+*P.' Anthony, Technical Support, Engineering
- J. Dillich, Technical Support, Engineering
- J. Miller, Technical Support, Engineering F. Swanger, Operations D. Stephenson, Senior Licensing Specialist L. Young, Licensing, Fire Protection J. Haverly, Fire Protection J. Moyers, Quality Verification Manager
+*D. Briden, Chemistry and Health Physics S. Zunk, Ombudsman D. Harris, Manager Quality Systems
+*J. Sturdavant, Licensing Principal
b.
NRC
+*P. Byron, Senior Resident Inspector
+*D. Kosloff, Resident Inspector R. Cooper, I&E A. DeAgazio, NRR J. Isom, I&E M. Johnson,.I&E L. Kanter, RIII L. Kelly, NRR J. Smith, I&E T. Stetka, RII L. Valenti, EG&G L. Whitney, I&E P. Wohld, RIII R. Westberg, RIII
- Denotes those personnel attending the January 9, 1987, exit meeting.
+ Denotes those personnel attending the February 8, 1987, exit meeting.
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The inspectors also interviewed other licensee employees, including members of the technical, operations, maintenance,-I&C, training, health physics, and nuclear materials management department staffs.
'2.
-Licensee Action'on Previous Inspection Findings a.
~(Closed) Unresolved item (346-85025-04):
"Inoperability of the Control Room Emergency Ventilation System (CREVS)." This item was escalated to a violation in Inspection Report NO. 50-346/85040.
This unresolved item is closed.
b.
(0 pen) Violation (346/85040-04):
" Inadequate Test Control for Control Room Emergency Ventilation System." System modifications have been made and Test Procedure TP 850.75 was performed to verify system operability. Part of the testing was observed and the completed test was reviewed as part of the System Review and Test Program.
Technical specifications-(TS) require that the CREVS cooling'
capacity keep the control room temperature less than 110 F.
This item will remain open because neither the monthly nor 18 month surveillance tests verify the' CREVS cooling capacity under maximum load conditions (for example, during the hottest summer months).
Also, the inspector determined that the TS surveillance requirements do not require that all safety functions of.the system be tested.
c.
(0 pen) Violation (346/85030-02): This violation had six examples; A, B, C, D, E and F.
The. inspectors reviewed the licensee's corrective actions for example C, errors in valve designations in ASME pump and valve Inservice Test-(IST) Program review. The licensee developed a program to review the IST program, identify deficiencies and correct those deficiencies. The inspectors reviewed the documentation of the licensee's corrective action for this example of the violation and the corrective action appears to be adequate. Example C of this item is closed. The corrective actions for examples A, B, D, E, and F will be reviewed in future inspections.
No violations or deviations were identified in this area.
3.
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, letter.
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The inspectors reviewed the COA and identified 33 commitment categories requiring NRC review. These commitment categories were given special tracking numbers.
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 the June 9,1985, loss of feedwater event.
Each commitment category includes one or more specific commitments which have been assigned a Licensee Commitment Tracking System (LCTS) identifier.
The licensee commitments reviewed below list this LCTS number.
All commitment categories below were closed based upon satisfactory review of a sample of the licensee's completed commitments. Selected post-restart items will be reviewed during future inspections.
a.
(Closed) Item (346/RY-000-01):
Verification that new management personnel have qualifications required by ANSI 18.1.
The inspectors selected several new management personnel and compared the information in their training records with the qualifications required by ANSI 18.1.
No deficiencies were noted. This item is closed.
b.
(Closed) Item (346/RY-000-02), C0A II.B.1:
Restructuring and Strengthening of the Nuclear Mission and C0A II.B.3: Maintenance Improvement Program.
(1) (Closed) LCTS No. 2122: Assign responsibility for Quality Assurance (QA) review of procedures to a dedicated group to remove this collateral responsibility from the present audit group. The licensee met this commitment by establishing a Quality Systems Section within the QA division. The licensee-documented this action in Memo HA 86-0453 dated May 14, 1986, and on the Division Organization Chart which was approved on February 14, 1986. The Quality Systems Supervisor position is described in Section 1.0, Revision 9, of the Nuclear Quality Assurance Manual. This item is closed.
c.
(Closed) Item (346/RY-000-04), C0A II.B.1:
Increase and Relocate Staff.
(1) (Closed) LCTS 1413: Add 230 positions to the site staff. The permanent size of the site staff has been increased from 699 to 1093 which exceeds this commitment. This item is closed.
d.
(Closed) Item (346/RY-000-06), C0A II.B.1:
Improve Control of Contractors. Additional inspection of this subject was documented in Inspection Report No. 50-346/86014 under Performance Enhancement Program Item A-1 (346/RP-88001).
(1) (Closed) LCTS 2225: Engineering will acquire additional staffing to strengthen internal engineering capabilities and reduce dependence on outside consultants.
The inspectors have verified that the licensee has increased the engineering staff and has reduced its dependence on outside consultants.
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- (Closed) Item (346/RY-000-07), C0A'II.B.1. -Configuration Management.
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Program.
.(1).(Closed) LCTS;1383 and 1737: Devel'op a plan for the
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organization and structure of a Configuration Management Program (CMP). 'The licensee. issued the plan'on December 2, 1985, and the Davis-Besse Nuclear Power Station CMP Manual,
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Revision 0, was issued on. September 1,1986. This item is closed.
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(2) (Closed)'LCTS 1385
.In those cases where-vendor instruction
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manuals are used to support maintenance activities, each must
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receive'a technical review and be' approved prior-to each use.
The licensee.is in the process.~of reviewing each technical manual.. Unapproved technical manuals are not used to support
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maintenance activities, i
f.
(Closed) Item (346/RY-000-08), C0A II.B.1:
Improve Training Facilities.
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' (Closed) LCTS 1406:
Install a plant-specific simulator. The (1)
licensee has issued a purchase order to CAE Electronics for
construction of a plant-specific simulator. The simulator is currently scheduled to be ready for training on May 1, 1989.
This item is closed.
g.
(Closed) Item (346/RY-000-09), C0A II.B.3: Maintenance Facilities Improvements.
(1) (Closed) LCTS 1395: The inspectors verified that the office spaces in the newly constructed Personnel Support Facility are
in use. Although the new heavy shop equipment has not yet been
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installed, some of the shop spaces are in use and the facility appears to be ready for equipment installation. This item is
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closed.
h.
(Closed) Item (346/RY-000-10), C0A II.B.3:
Improve Maintenance.
i (1) (Closed) LCTS 1391: The program for identification and
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ordering of spare and repair parts has been defined and will be implemented prior to restart.
Procedure No. NMP-NP-403,
" Spare Parts / Materials," was issued for use on June 30, 1986.
This item is closed.
(2) (Closed) LCTS 1750: Maintenance Work Orders (MW0s) that may affect plant performance will be completed before restart or will be scheduled commensurate with their significance.
Region III verified that this action was taken. This item is closed.
(3) (Closed) LCTS 1758: A procedure which improves controls for in-storage preventative maintenance will be implemented.
Nuclear Engineering Procedure No. NEP-070 was issued and it adequately addresses this deficiency. This item is closed.
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(Closed) Item (346/RY-000-11), C0A IV.B.2.1: Reassignment of Performance Enhancement Program (PEP) and Systematic Assessment of Licensee Performance (SALP) Response Activities. The licensee has prioritized the remaining open PEP and SALP response items. The inspectors have reviewed the licensee's prioritization and it appears appropriate. The inspectors will continue to followup on all open items in this area based on the previously assigned tracking numbers. This item is closed.
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(Closed) Item (346/RY-000-12), COA IV.C.2.2: Decay Heat Removal
' Improvement Program.
(1) (Closed) LCTS 1325 and 2723: The pressure switch set points for auto transfer of Auxiliary Feedwater suction from condensate storage tank to service water will be increased from 2 to 5 psig.
The licensee increased the set point to 5 psig and later modified the commitment (LCTS 2723) to readjust the set point back to 2 psig. These actions were completed. This item is closed.
(2) (Closed) LCTS 1340, 1342, 1459, 1465 and 1466: Modify Steam and Feedwater Line Rupture Control System (SFRCS) before restart:
(a) Modify SFRCS logic to prevent the undesirable isolation of the main steam lines and main feedwater lines when Steam Generator (SG) low level conditions are sensed.
(b) Filter the SG low and high level SFRCS actuation signals to prevent spurious actuations caused by pressure transients.
(c) Provide a seal-in circuit and dedicated manual reset for the SFRCS full trip control room annunciator.
(d) Increase cooling for the cabinets housing the SFRCS electronic power supplies.
The documentation examined for this commitment included the related MW0s and Bechtel Safety Analysis BT 15721 which evaluated the effect of separating high and low level SFRCS i
trip signals. High level will isolate the steam generator and initiate AFW.
Low level will initiate AFW only. The low level will be a common input with RCP monitor and the high level input will be independent. MW0s were examined which document the completion of the changes to SFRCS logic for Items a and d.
Item c is the same as LCTS 1459. NRR is satisfied these modifications have been made. These items are closed.
(3)
(Closed) LCTS 1376 and 2789:
Suction valves to the CST must be locked in the open position with power removed (Page 3-51).
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NRR reviewed the licensee's documentation of these actions, consisting of completed MW0s, made an inspection and observed the locks installed on the valves. NRR is satisfied that this commitment has been met. This item is closed.
(4) -(Closed) LCTS 1451: The normal alignment of the motor driven feed pump (MDFP) will be from the condensate storage tank to the auxiliary feedwater (AFW) system. The licensee issued procedure SP 1106.28.02 which states that the MDFP will be-lined up to the AFW prior to exceeding 40% power. This item is closed.
(5) (Closed) LCTS 1459:
Licensee will add seal-in to SFRCS control room annunciators. NRR reviewed completed MW0s which documented the addition of seal-in circuitry for the control room annunciators for the SFRCS. NRR is satisfied that this commitment is met. This item is closed.
(6) (Closed) LCTS 1468: SFRCS logic is to b' modified to prevent isolation of AFW flow to both SGs. A review of the MW0s relating to this item shows that the logic changes have been made. SFRCS logic will be tested under TP 850.71. This item is closed.
(7) (Closed) LCTS 1565: Additionai testing will be done to verify the transfer setpoint on low CST volume.
NRR has reviewed the licensee's documentation of this item, consisting of completed
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MW0s, and is satisfied that the commitment has been met. This
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item is closed.
(8) (Closed) LCTS 1724: All licensed individuals and STAS must pass a written examination to ensure a complete understanding of the loss-of-feedwater analysis and the relationship of this analysis to emergency procedure EP 1202.01. This item was closed by the inspection documented in Section 3.q.(2) of this report (LCTS 1478).
(9) (Closed) LCTS 2595 and 2596:
Procedures are to require monitoring the temperature of the MDFP discharge piping.
SP 1106.28 on the motor-driven AFW pump to be approved by the licensee and implemented, and training to be completed before plant restart from the current shutdown.
NRR has reviewed the licensee's documentation of these actions, consisting of SP 1106.28, Revision 1, and training attendance records on these commitments. NRR is satisfied that the commitments have been met. This item is closed.
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(Closed) Item (346/RY-000-13), C0A IV.C.3.2: Analyses Related to the June 9, 1985, Event.
(1) (Closed) LCTS 2227: Perform a structural analysis of the steam generator and reactor vessel. The licensee submitted the analysis which was performed by B&W in C0A IV.C.3.2.
This item is closed.
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(Closed) Item (346/RY-000-14), C0A II.C.5: Control Room Improvement Program.
(1) (Closed) LCTS 1271: A reassessment of priority and schedule for implementing corrective actions related to significant human engineering discrepancy (HED) items identified in the Detailed Control Room Design Review (DCRDR). The inspectors'
review revealed that HED items required to be performed prior to restart appeared to be adequately resolved. More detailed information is presented in Item (5) below. This item is closed.
HED items scheduled for completion during future refueling I
outas s will be reviewed as part of the DCRDR inspection l
process.
(2) (Closed) LCTS 1400: The SFRCS manual actuation switches will be rearranged prior to restart. The inspectors verified the SFRCS manual actuation switches had been rearranged. This item is closed.
(3) (Closed) LCTS 1695: Other procedural problems that are identified will be documented and examined for human factors considerations by the DCRDR review team and included in the remaining.spects of the DCRDR effort. Davis-Besse Procedure AD 1805.00, " Procedure Preparation, Review, Approval and Revision," Step 6.3.2, provides a checklist (Attachment 8) for review in this area. This item is closed.
l (4) (Closed) LCTS 1703:
Each Facility Change Request (FCR) will be reviewed by a human factors specialist to make sure that it fulfills the recommended design change and does not introduce
new human factors problems. A procedure for independent human l
factors review of FCRs is in place.
It forms the basis for I
revision of Toledo Edison procedures. This item is closed.
k (5) (Closed) LCTS 1973, 1976, 1978, 1985, 1987, 1990, 1993, 1994, t
1997, 2603, 2604, 2605, 2606: These LCTS items have been closed by the following HED solutions.
(a) HED 9.2.001: The licensee was to provide additional operator training to control room operators related to SFRCS actuation identification.
Licensee memorandum of
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October 7, 1986, Simon to Strout, KB86-0803, stated that training has been completed. NRR has reviewed the licensee's documentation of this action, including a summary of training provided, and is satisfied that interim corrective measures have been met. This item is closed.
(b) HED 9.2.033: The licensee was to provide relabeling enhancements and remove spare controls on SFAS incident Level 4 group and provide additional training to control
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room operators on existing systems including modifications to AFW. The licensee's memorandum dated October 7, 1986, Simon to Strout, KB86-0803, stated that training has been completed. NRR has reviewed the licensee's documentation of this item, including a summary of training provided, and is satisfied that interim corrective measures have been met. An inspection of SFRCS panel' confirmed removal of the spare controls and relabeling. This item is closed.
(c) HED 9.2.020: The licensee was to conduct a study based on good human factors guidelines to establish appropriate interim labeling fixes prior to restart.
Licensee memorandum of October 15, 1986, Simon to Strout, KB86-082, stated that labeling enhancements have been completed.
The licensee's human factors staff rated this commitment as partially satisfied (interim corrective solution acceptable) in the Post Implementation Verification of September 25, 1986.
The licensee's documentation of this action included Essex Corporation's " Report on the Interim Study for Labeling Enhancements to be Implemented Prior to Restart," August 8, 1986.
NRR has reviewed the licensee's documentation, made an inspection of labeling enhancaments, and is satisfied that interim corrective measures on this action have been completed. This item is closed.
(d) HED 5.1.006: The licensee was to confirm that corrective actions to the wide range makeup flow scale range were implemented in the control room.
Licensee memorandum dated October 7, 1986, Simon to Strout, KB 86-0803, stated that these corrective actions have been met. The licensee's human factors staff rated this commitment as fully satisfied in the Post Implementation Verification of September 25, 1986. NRR has reviewed the licensee's documentation of these actions and is satisfied that the commitment has been met. An inspection of the control room verified the modifications were made. This item is closed.
This HED consists of 3 items: wide-range makeup flow scale-range expansion, a new wide-range AFW indicator, and expansion of the Reactor Coolant System (RCS) wide-range pressure indicator. There is a conflict in Appendix D of NUREG 1177, the Safety Evaluation Report (SER)
regarding the schedule for the RCS wide-range pressure indicator modification. The SER states on Page 9 (Appendix D) that the RCS change will be completed prior to startup, but states on Page 78 that this will be implemented as part of the Regulatory Guide 1.97 require-ments for the three items in HED 5.1.006.
The RCS wide-range indicator modification is the least " safety-
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~ ignificant" item..Therefore, NRR considers 'that s
addressing-this item in the fifth refueling outage is acceptable. This item is closed.-
'(e).HED6.1.012: The-lice'nsee was-to ensure that corrective actions being-implemented in the control room.made use of good human factors guidelines. The licensee's.
documentation of this item included the labeling enhancemer.ts study (HED 9.2.020), and memorandum ~ dated-October 7, 1986, Simon to Strout, KB 86-0803, stating that these actions have been completed. NRR has reviewed the licensee's documentation on this action, made an inspection of some_ control room modifications, and is satisfied that this commitment has been met. This item is closed.
(f) HED 5.1.007: The licensee.was to conduct training to ensure that operators were aware of the potential for the present High Pressure Injection (HPI) meters to fail onscale. 'The licensee provided as required reading for operators, OR-Q86-10 " Pointers on Meters Do Not Fail Offscale," and the HED. NRR has reviewed the licensee's documentation of this action-and is satisfied that interim corrective measures have been met. This item is closed.
(g) HED 9.2.004: The licensee was to incorporate-solution to.
improve ICS reliability (related controls and displays not located together) into procedures and training. The licensee's documentation of this action included the FCR~
for design change,-training log on design change, and required reading for operators OR 086-10, April 28, 1986.
NRR has reviewed the licensee's documentation for this item and is satisfied that th? commitment has been met.
This item is closed.
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(h) HED 9.2.006: The licensee was to provide improved i
labeling for the Safety Features Actuation System (SFAS)
l trip pushbuttons.
The licensee's human factors staff rated this commitment as partially satisfied (interim
corrective action is acceptable) in the Post Implementa-
tion Verification of September 25, 1986. NRR has reviewed the licensee's documentation on this action and is
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l An inspection of the control room verified the changes i.
were made. This item is closed.
i (1) HED 9.2.005: The licensee was to provide interim labeling
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enhancements for ICS input select switches, and to provide
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the NRC with inputs which describe how the instrument and control characteristics were considered in development of i
interim present hardware fixes to the control boards.
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licensee's human factors staff rated this commitment as
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fully satisfied in the Post Implementation Verification of October 2, 1986..The licensee's. documentation included a copy of their report dated August 8, 1986, " Interim Study for Labeling Enhancements to be Implemented Prior to
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Restart." NRR has reviewed the licensee's documentation on this action and-is satisfied that the commitment has been met. This ite.n is closed.
(j) HED 5.1.009: The licensee was to install: interim labeling enhancements for the AFW pump indicators,-correct wide range indication and meter scale deficiencies associated with makeup flow indication, and provide the NRC with inputs which describe how the instrument and control
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characteristics were considered in the development of the interim or permanent hardware fixes applied to the control boards. The licensee's human factors staff rates these interim corrective actions as fully acceptable in the Post Implementation Verification of September 25, 1986, and October 14, 1986 NRR has reviewed the licensee's
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documentation of this action, made an inspection of implemented corrections,- and is satisfied that interim corrective actions have been made.
(k) HED 9.2.028: The licensee was to ensure that training and procedures addressed any impact of using wide range scale for indicating feedwater flow during startup conditions.
The licensee's memorandum dated October 7, 1986, Simon to
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Strout, KB 86-0803, stated that operator training had been completed. NRR has reviewed the licensee's documentation of this action, including a summary of training and-required reading provided, and is satisfied that this commitment has been met.
This item is closed.
(1) HED ?.2.047: The licensee was to resolve the potential for operator confusion between Decay Heat Pump /HPI Pump mimic relationships by providing labeling modifications.
The licensee's human factors staff rated this action as
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fully satisfied in the Post Implementation Verification of September 26, 1986.
NRR has reviewed the licensee's documentation of this action, inspected the completed modifications, and is satisfied that this commitment has been met. This item is closed.
(m) HED 4.1.004: The licensee was to develop labeling enhancements for demarcation of controls on Panels C-5703 and C-5705. The licensee's human factors staff rated this action as par, ally satisfied (interim corrective solution acceptable) ir he Post Implementation Verification of September 27, 86.
NRR reviewed the licensee's documentatior, this action, inspected the completed modifications, and is satisfied that interim corrective measures have been met. This item is closed.
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(n) HED 9.2'.043: The licensee was to ensure that control room operators were thoroughly trained on the design change arrangement and that labeling conformed to good human
'l factors' guidelines. The licensee's human factors staff-
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rated this action as partially satisfied (interim corrective solution acceptable) in the Post Implementation Verification of October 10, 1986. NRR has reviewed the ifcensee's documentation of this action and is satisfied that the interim corrective actions have been met. This item is closed.
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(Closed) Item (346/RY-000-15),-C0A II.C.6 and C0A IV.C.4.1.3, Shift-Technical Advisor (STA).
(1) (Closed) LCTS 2228: ' Change STA shifts to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The inspectors verified that the STA shifts are 12 or 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> shifts. This item is closed.
(2) (Closed) LCTS 2299: STA's will have Senior Reactor Operator (SRO) licenses by January 1,1987. This is'a post-restart commitment. The licensee, with concurrence of NRR, extended this commitment date and has projected an estimated completion date of January 1,1988. This item is closed. The revised commitment, open item (346/86032-01(DRP)) will be reviewed in a future inspection.
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.(Closed) Item (346/RY-000-16), COA II.C.7: System Review and Test Program.
(1) (Closed) LCTS 1930: Review the radwaste gas system oxygen monitor. The radwaste gas system oxygen monitor was reviewed
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in a July 2,1986, Gaseous Radwaste System Review and Test Report (Rev. B). This item is closed.
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(Closed) Item (346/RY-000-17), COA IV.C.3.1: Analysis of High Pressure Injection and Make Up Systems Cooling Adequacy.
(1) (Closed) LCTS 2261: Perform analysis of HPI/MU cooling adequacy. The review of this analysis was reviewed in Section 4.3 of the Safety Evaluation Report, NUREG-1177.
This item is closed.
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(Closed) Item (346/RY-000-18), C0A II.C 3: Evaluation of Single Failure Effect on Engineered Safeguards Systems.
(1) (Closed) LCTS 1739 and 2152: Modifications to provide electrical independence between redundant Safety Features Actuation System (SFAS) instrument channels. NRR examined the documentation relating to this commitment.
Facility Change Request (FCR) 85-0177 proposed modifications to eliminate the shared power returns for the SFAS instrument channels.
Maintenance Work Orders 2-85-0177-01 through 11 document changes made to the system. NRR is satisfied the modifications have been made. This item is closed.
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(2) (Closed) LCTS 2172 and 2173: Testing to assure electrical separation and isolation of SFAS. The licensee's documentation indicates testing for FCR 85-0177A was performed August 2, 1986, in accordance with TP 850.19. The documentation also shows (memo from Joint Test Group to J. Michaelis, et al, October 1, 1986) that the test results were evaluated and accepted by the Joint Test Group. This item is closed.
(3) (Closed) LCTS 2171:
Surveillance Test (ST) 5031.03 to be performed af ter SFAS modifications and monthly thereafter, including SFAS sensor commons testing, to detect degraded voltage conditions. The licensee's memorandum of October 3, 1986, Wond to Strout, NES 86-0178, stated that required testing had been jerformed, results evaluated and accepted. NRR has reviewed the licensee's documentation of this action and is satisfied that the commitment has been met. This item is closed.
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(Closed) Item (346/RY-000-20), COA II.C.4: Review of Operations Procedures and Training.
(1) (Closed) LCTS 1473: The emergency prc.edures (EP) will be reviewed before restart to ensure clarity and explicitness where significant actions are required. NRR has reviewed the
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licensee's file on this commitment which documented that a review of the emergency procedures was completed and problems of explicitness identified and modified in EP 1202.01.03. NRR is satisfied that this commitment has been met. This item is closed.
(2) -(Closed) LCTS 1478: All licensed operators will be trained on the results of loss-of-feedwater analyses and the revised procedures for lack of heat transfer. The licensee's file on this item included a sample attendance sheet for training on loss-of-feedwater analyses. The licensee's memorandum of May 30, 1986, Simpkins to Licensing, stated that a written exam has been taken by Shift Technical Advisors (STA) and licensed operators following training. NRR has reviewed the licensee's documentation of this action and is satisfied that the commitment has been met.
This item is closed.
(3) (Closed) LCTS 1479: Revision to EP 1202.01 will be included in the' training program. The licensee's file on this item documents that training on EP 1202.01, Revision 3, was conducted between March 31, 1986, and May 7, 1986. NRR has reviewed the licensee's documentation of this action and is satisfied that the commitment has been met. This item is closed.
(4) (Closed) LCTS 1480: Hands-on training for resetting the trip-throttle valve and overspeed trip mechanism during a simulated accident will be a requirement for all plant
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operators and licensed personnel. This item requires that the plant be in Mode 3.
Region III verified that the required training was obtained by all plant operators and licensed personnel prior to transition into Mode 2.
The verification included actual observation of training. This item is closed.
(5) (Closed) LCTS 1481: Operators will be trained on the functioning of valves AF 599 and 608, including any modifica-tions.
Licensee memorandum of May 19, 1986, Simpkins to Licensing, stated that restart training on AF 599 and 608 was completed. The training covered control circuit and operation of the valves. NRR has reviewed the licensee's documentation of this action and is satisfied that the commitment has been met. This item is closed.
(6) (Closed) LCTS 1482: Operators will be trained on proper actuation of the Steam and Feedwater Line Rupture Control System for all combinations of actuations, before restart.
The licensee's memorandum of May 19, 1986, Simpkins to Licensing, stated that training on this item has been completed. NRR has reviewed the licensee's documentation of this action and is satisfied that the commitment has been met. This item is closed.
(7) (Closed) LCTS 1486:
Licensee will provide additional operator training before restart to discourage premature reduction of steam system pressure. NRR reviewed documentation relating to this item. Documentation indicated that simulator Phase I restart training, which included this action, was completed January 15, 1986. Documentation included attendance sheets for Phase I.
This item is considered closed.
(8) (Closed) LCTS 1488:
Emergency procedures will be modified to include specific criteria to indicate lack of heat transfer requiring the initiation of makeup /high pressure injection cooling.
NRR has reviewed EP 1201.01.03 and is satisfied that required modifications have been implemented. This item is closed.
(9) (Closed) LCTS 1489 and LCTS 1493:
Errors in EP 1202.01 will be corrected before restart. On June 9, 1985, Table 1 of EP 1202.01 contained errors. NRR reviewed Table 1 of EP 1202.01.03, and concluded that the errors have been corrected. This item is closed.
(10) (Closed) LCTS 1490 and 1491:
FP 1202.01 will be reviewed before restart with regard to tne adecuacy of existing control room instrumentation. Licensee memorandum dated October 18, 1985, O' Conner to Wideman, stated that the licensee has completed the required review. Maintenance Work Orders (MW0s)
reviewed by NRR document that improvements to instrumentation have been completed. Although two MW0s require final testing
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to be closed, NRR considers this commitment closed since the required improvements have been implemented.
(11) (Closed) LCTS 1492:
Licensee will add guidance to SP 1106.06 regarding circuitry and control logic for valves AF599 and AF608. Temporary Modification Request (T-MOD) 9688 identified the appropriate changes to be made to SP 1106.06.24. The T-MOD was reviewed and found to satisfy the commitment.
Later the inspectors reviewed SP 1106.06.25 and verified that the T-MOD had been incorporated into the procedure. This item is closed.
(12) (Closed) LCTS 1494:
Specific criteria to determine when to transfer Auxiliary Feedwater Pump suction from Service Water to the condensate storage tanks will be added to procedures.
T-MOD 9688 identified the criteria to be added to SP 1106.06.24 to satisfy this commitment. The criteria were reviewed and found acceptable.
The inspectors later verified that the -T-MOD had been incorporated into of SP 1106.06.25. This item is closed.
(13) (Closed) LCTS 1495: Add verification of Main Steam Isolation (MSIV) status to emergency procedure supplementary actions.
NRR reviewed EP 1202.01.03, and is satisfied that the required MSIV status verification has been implemented. This item is closed.
(14) (Closed) LCTS 1499: Train all licensed personnel and STAS on the revised emergency notification procedure. The licensee memorandum of May 30, 1986, Simpkins to Licensing, stated that a written exam has been taken by STAS and licensed operators following training. The licensee's file on this item included a sample attendance sheet for training on revised procedure notification.
NRR reviewed documentation of this action and is satisfied that the commitment has been met. This item is closed.
(15) (Closed) LCTS 1505:
Each of four zone operators will be provided a key ring with a locked-valve key.
NRR has reviewed Administrative Procedure AD 1839.02.03, and is satisfied that zone operators are required to have a locked-valve key. This
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item is closed.
(16) (Closed) LCTS 1721, LCTS 1722, LCTS 1723: AD 1839.00 governing conduct of shift operations will be revised before restart to assure an SR0 will remain in control room once an SR0 has assumed duties of Procedure Director until relieved by another SRO.
Requirement to be included in requalification program.
NRR reviewed AD 1839.00.15, and is satisfied that SR0 procedures meet the commitment. Also, included in the licensee's documentation of this item is an attendance sheet for training on AD 1839.00.15 for operator requalification, completed May 7, 1986. This item is closed.
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(17) (Closed) LCTS 1725:?,0perating hvorience Assessment activitics identified in AD 1839.04 will be Assumed by the Operation Ergireering Cepartment and consolidated with transient (
assessment act wi'.ies.
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The inspectors r6 viewed plant-procedures OPE-001, Revision 0,
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" Operating Experience' Assessment Program-Review Operating '
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Experience," and /01939.04.10, " Shift Technical Advisor."
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ON-001 assign!gesponsibilityfortheoperatingexpeqience assessment progam to the Operations Assessment Supprvisor who
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is within-thegDperations Engineering Department.
Included in
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r this procadurb is\\the review of transient assessment reports
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and transfent assessmera program, reports. AD 1839.04 describes N
the shifttechnical adiisor's resp;nsibilities with respect to the operating experience lassassment progren.
Implementation of this 'prograa will be verl?ied, on a samplinr, basis, through the routineinspectionprcg-am.]Thisitem1,5 closed.
(18) (Closed) LCTSi1933: Ope;atingl Experience Assessment Program
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procedures based on operatiocs' engineering standards will be
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in place,by June 1986. Cfhe inspectcrs reviewed procedure 0PE-011; Revision 0, dated August 4, 1986, which is the
Operating Experience Assessment Program procedure. Although
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issued late, the procedure satisfjes the commitment. This item is closed.
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(19) (Closed) LCTS 1934: The Operating Experience Assessment
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s Program will add additional topics co the current program.
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The Operating S perience Assessment Program Procedure, OPE-001,
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Revision 0,. dated August 4, 198E, requires assignment of plant-applicable operating e parience issues to cognizant individuals for evaluation ar.d action, if warranted.N An overall coordinator tracks thi progress of all reports received for review or evaluation. The procet'ure covers a number of
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different operating experiency source documents which appear
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to be sufficient to ensure adtquate review of both interr M and external operating experience;, Also. Procedure AD 1839.04.10, allows the STA the option of acquiring othe techthcal
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information to screen for operating experience applicability.
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This item is closed.
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-(Closed) Item (346/RY-100dl), COA IV.C.1.1, Actions Plu 1A, IB, and IC: Overspeed Trip of the Auxijiary Feedwater Pump Turbine t
(AFPT).
(1) (Closed) LCTS 1331: Maintain all steam lines from the steam generators to the AFPT at full temperature and pressure by keeping the cross-connect isolation valves open. NRR reviewed the licensee's file on this commitment which documents in Valve Verification List A of procedure SP 1106.06.25, that valves MS 106A and 107A are to be open and MS 106 and MS 107 are to be closed. The inspectors verified this lineup by in plant observations.
This item is closed.
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(Closed) Item (346/RY-100-02), C0A IV.C.I.1, Action Plan 10:
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, f, Auxiliary Feedwater Pump Turbine (AFPT) Overspeed Trip and Throttle f
- (T&T) Valve Problem.
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! (1) (Closed) LCTS 1219 and 1226: Eight corrective actions related I
to the AFPT throttle valve. The eight corrective actions proposed are:
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(a) Modify the appropriate procedures to reflect the proper
reset sequence for the overspeed trip mechanism (OTM).
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(b) Modify the testing procedures to ensure that the T&T valve and 0TM are reset after testing.
(c) Provide operator training on the theory of operation for
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the OTM and T&T valve.
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(d) Provide hands-on-training in the proper resetting of the
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OTM and opening of the T&T valve with a minimum steam pressure of 800 psi.
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p{ 4 (e) Design and install local position indication of the OTMs
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and position indication of the T&T valves.
(f) Post simplified operating instructions near the T&T valves.
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(g) Paint the yoke of the T&T valve, the latch-up lever,
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trip yoke, and connecting rod (for both AFPT) yellow to distinguish this equipment as important to the operation of the overspeed trip (in addition, the manual trip level will be painted red.)
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(h)
Improve communication for the equipment operators between
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both pump rooms and the operators in the control room.
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' NRR examined documentation relating to item "a."
The documentation shows the commitment is met by Temporary t
Modifications (T-MOD) to Procedures SP 1106.06.24 (Auxiliary
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Feedwater (AFW) operating procedure); ST 5071.01 (AFW monthly fj test),ST 5071.02 (AFW system refuel test); and PT 5150.01.
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These modifications should be included in subsequent revisions
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- i [, f of these procedures.
Item "a" is closed.
k NRR examined the T-MOD added to ST 5071.04, "AFW System Channel s
Functicnal Test." The modification insures proper reset of the
- y-T&T and OTH.
The T-MOD should be incorporated into subsequent
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revision of the procedure.
Item "b" is closed.
Licensee memorandum of May 19, 1986, Simpkins to Licensing, stated that Phase II and Phase III training had been completed, meeting item "c" requirements. NRR has reviewed documentation
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of this action and is satisfied with the action taken.
Item
"c" is closed.
Item "d" is the same as RY-000-20, COA IV.C.4.1, LCTS 1480.
Item "d" is closed.
NRR examined the corrective measures taken to resolve items e, f, g, and h.
Local position indication, posted instructions, and painting of portions of the mechanism to improve the operators' ability to distinguish important components were all observed by NRR. The relocation of communication equipmcnt for the equipment operators was also observed.
NRR is satisfied that items e, f, g, and h have been addressed as proposed.
These items are closed.
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(Closed) Item (346/RY-100-03), C0A IV.C.I.1, Action Plan 5: Steam and Feedwater Line Rupture Control System (SFRCS) Trip and Main Steam Isolation Valve (MSIV) Closure.
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(1) (Closed) LCTS 1340:
Establish a new electronic filter setting for steam generator (SG) water level transmitters and test for proper calibration and response time. NRR has examined the
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maintenance work orders relating to this item.
The documenta-tion establishes that new filter settings for all channels were made and tested for response time. NRR is satisfied that this (
commitment is completed. This item is closed, u.
(Closed) Item (346/RY-100-04), C0A IV.C.1.1, Action Plan 8: Main Feedwater Pump Turbine (MFPT) Control System Failure. This item is closed based on the inspection documented in Inspection Report No. 50-346/86027.
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(Closed) Item (346/RY-100-05), COA IV.C.I.1, Action Plan 9A and 98:
Turbine Bypass Valve (TBV) Actuator Failure. This item is closed based on the inspection documented in Inspection Report Nc. 50 >c 16027.
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(Closed) Item (346/RY-100-06), C0A IV.C.1.1, Action Plan 16: Main Steam Header Pressure Anomalies.
(1) (Closed) LCTS 1518: Main Steam Header Pressure Control Modules No. 4-3-4 and No. 4-3-6 in the integrated control system (ICS)
string controlling AVV-2 will be replaced. The inspectors observed work in progress and reviewed documents and determined that these modules had been replaced. This item is closed.
(2) (Closed) LCTS 1624: Modifications to Main Steam Safety Valve (MSSV) piping to provide adequate support. NRR examined the completed MWO relating to this item.
NRR further observed the additional support installed on the main steam lines near the MSSVs. This item is closed.
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(3) ~(Closed) LCTS 1584 and LCTS 1648: The excerpt from AP 16 that describes step No. 3 contains two separate but related activities. These are:
(a) Ensure proper functioning of alarm Points Z961 and Z969 that provide position status for Atmospheric Vent Valves (AVV).
(b) Determine other limit switches that may affect the
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operation of the AVVs.
Investigate and troubleshoot to ascertain proper operation.
The licensee's breakdown of the above commitments shows that LCTS 1648 covers item 1 alone; however, it further states that other limit switches which may affect operation (of the alarm points, but not the AVVs) will be determined.
This portion of LCTS 1648 applies to Item 2 above, but incorrectly translates the action as applying to the alarm points rather than the AVVs.
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The licensee's statement of LCTS 1584 is overly generic in that it is not clear that it specifically covers item 2 above--that is, determining which limit switches affect AVV operation and verifying proper operation.
Based on the above discussion, this issue is closed under LCTS 1584 and reopened under open item (346/86032-02(DRP))
until the licensee can prove that closure included the determination required in Item 2 above.
Currently, the closure package does not substantiate that the licensee investigated anything other than the AVV alarm Points Z961 and Z969.
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LCTS 1648 is closed based on the inspector's review of completed Facility Change Request No. 86-0332 as recorded by completed MW0's 2-86-0332-02 (October 25, 1986) and 2-86-0332-01 (October 25,1986).
These MWO's modified wiring to applicable limit switches to resolve discrepancies that existed between computer valve position status and control panel status lights for the AVV's.
(4) (Closed) LCTS 2071:
Evaluate Rapid Feedwater Reduction (RFR) control setpoints. The Licensee has evaluated the RFR setpoints and decided that 4600 RPM is proper.
However, physical testing in Mode 3 or higher may change this decision.
This item is closed.
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(Closed) Item (346/RY-100-07), C0A IV.C.1.1, Action Plan 18:
Startup Feedwater Valve SP-7A.
(1) (Closed) LCTS 1284: Train operators on Steam and Feedwater Line Rupture Control System power supplies. The inspectors verified that this training had been completed. This item is closed.
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(Closed) Item (346/RY-100-08), C0A IV.C.1.1, Action Plan 26:
Auxiliary Feedwater (AFW) System Suction Transfer.
(1) (Closed) LCTS 1326 and 2723: Add time delay to actuation of AFW suction transfer and pressure switch setpoints for automatic transfer to service water (SW) to be set at 2 psig.
The inspectors reviewed Facility Change Request (FCR)
No. 85-0155 and its associated maintenance work order (MWO-85-0155). The FCR added ten-second time delay relays and reset the pressure to 2 psig. The work was completed during November 1986. Test Procedures TP 850.48, 850.53, and 851.06 were the verification tests for FCR 85-0155.
Region III inspectors reviewed the completed test packages.
The testing demonstrated that the equipment performed as designed. These items are closed.
(2) (Closed) LCTS 1327 and 1328: AFW strainer changes. NRR examined the MW0s relating to the removal of the strainers in the suction lines ahead of each AFW pump. The documentation indicated that the strainers were removed.
The mesh size of the strainer in the common suction line was increased to No. 6 wire. The mesh was previously No.12 wire. Thus, the opening size has been increased from 0.060 inch to 0.120 inch. There remains some testing to complete the MWO related to this item.
Test verification will be accomplished as part of the SRTP inspection. This item is closed.
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(Closed) Item (346/RY-100-09), C0A IV.C.1.1, Action Plan 27: Main Steam Valve, MS 106. This item is closed based on the inspection of items related to (346/RY-100-10).
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(Closed) Item (346/RY-100-10), C0A IV.C.1.1, Action Plan 12:
Auxiliary Feedwater System Containment Isolation Valves (AF599 and 608).
(1) (Closed) LCTS 1250: Adjust the limit switch bypass setting of AF-599 and 608 to a value of 20% of full stroke in the open direction as measured from the point of valve disc movement.
Test data reviewed by the inspector indicated that the bypass setting for both valves meets the 20% criteria. This item is closed.
(2) (Closed) LCTS 1252:
Issue Maintenance Procedures (MP) to provide proper instructions for corrective maintenance, for setting limit and torque switches on type SMB Limitorque valve operators, and to test Limitorque operators using the Motor Operated Valve Analysis and Testing System (M0 VATS). This action was completed on August 7, 1985, upon issuance of MP 1410.32.03, and MP 1411.05.01. The inspector verified satisfactory completion of this item previously as documented in Inspection Report No. 50-346/85037(DRP), Paragraph 12.h.
This item is closed.
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(3) (Closed) LCTS 1251: Adjust the torque switch setpoint in the open direction to the maximum value that will still preclude valve damage. The inspector observed that the licensee has obtained valve structural limits from the valve manufacturer, Velan, and has set the open torque switch at 3.75 for AF 599 and 608 in observance of these limits (which corresponds to a limiting valve stem thrust of approximately 35,000 pounds).
This item is closed.
(4) (Closed) LCTS 1253: Verify that valve data and measurements used for stress and unseating torque calculations are correct based on field measurements of valve dimensions used in calculations.
Valve stem data was obtained by Maintenance Work Order (MWO)
No. 1-85-3534-15.
The valve orifice diameter was obtained from a vendor drawing.
In spite of an increased confidence in the valve dimensions, however, actual seating and unseating thrust forces measured to the valve stem under differential pressure conditions were considerably higher than calculated. M0 VATS test signatures indicate that the valve seat friction component, calculated to be 11,136 pounds at 1425 psid, was approximately twice that during differential pressure (dp)
testing. This anomaly was unnoticed during open stroke testing because the torque switch is bypassed during the application of a dp and the valve operator was capable of approximately 75,000 pounds thrust at motor stall torque conditions. However, the higher than expected friction caused a premature torque switch opening (prior to final adjustment) on closing against full dp from the motor driven feedwater pump.
Hence, the valve did not fully close.
The licensee has increased the close torque switch setting and performed testing to assure that the valves will close.
This item is closed.
Because of the high thrust measurement, however, the licensee plans to open both of the valves for a physical inspection during the next refueling outage. This inspection and evaluation of the valve material condition will be considered an open item (346/86032-03(DRP)) pending the completion of the licensee's activity and NRC review.
i (5) (Closed) LCTS 1254: Verify the adequacy of limit switch and
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torque switch adjustments during valve operation.
The limiting operational differential pressure condition for AF-599 and AF-608, according to functional requirements evaluated by the licensee, is now considered to be 1425 psid.
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l The valves initially failed their closure tests because of valve disc friction forces approximately twice that calculated at 1425 psid. However, final testing after closure torque i
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switch adjustment shows that both valves will open and close against 1480'psid with a demonstrated margin in operator capability. This item is closed.
(6) (Closed) LCTS 1255:
Review system design and operating parameters to ensure that a design differential pressure of
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1050 psig is adequate to ensure proper operation of AF-599 and AF-608 upon activation by a Steam and Feedwater Line Rupture Control System (SFRCS) signal. As indicated in LCTS 1254 above, the licensee considers 1425 psid the credible limiting dp and has assured the operability of both valves by instrumented tests in both the open and close directions at pressures above 1425 psid. This item is closed.
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(7) (Closed) LCTS 1256:
Issue procedures for preventive maintenance on Limitorque operated valves. Maintenance Procedure (MP) 1411.06, " Preventive Maintenance for Type SMB and SMC Limitorque Valve Operators," has been in place since November 1985. The inspector reviewed proposed Revision 1 of the procedure.
It includes periodic testing at the motor control center (using M0 VATS, Inc. equipment), performing necessary lubrication, lubrication inspections, and general physical inspection including a verification of proper operation with the handwheel.
While the procedure appears to be adequate, the inspector informed the licensee's staff that it might be beneficial to add a check for valve packing leaks and a check on the grease relief valve condition to the procedure. The licensee indicated that this would be considered. This item is closed.
(8) (Closed) LCTS 1257:
Review surveillance and post-maintenance test procedures to determine if this testing or portions thereof can be performed at expected operational differential pressures. This review has been completed and is documented in a licensee memorandue to D. Stephenson from E. Caba, dated September 15, 1986. The licensee is now rewriting existing procedures to include dp testing.
For Valves AF-599 and AF-608, specifically, Test Procedure (TP) 850.09 is being revised to include valve stroking under flow and differential pressure conditions, and will be re-designated as a Surveillance Test Procedure.
Administrative Procedure (AD) 1844.11.01, " Post Maintenance Testing Requirements" (with Temporary Change T-10217),
specifies Post Maintenance testing requirements. While dp testing may not be practical during plant conditions that exist post maintenance, comprehensive MOVATS testing is prescribed for any maintenance evolutions that could significantly impact motor-operated valve operability. This item is closed.
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(9) '(Closed) LCTS 1258:
Institute training for maintenance
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on Limitorque valve operators, operation of MOVATS ~ test equipment and analysis of M0 VATS test data.
Inspection Report-No. 50-346/85037(DRP),.Page 24, reports the results of inspection:in this area and indicates satisfactory completion of this item. This item is closed.
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(10) (Closed) LCTS 1259:
Issue. corrective maintenance procedures for type SMC Limitorque operators. This item was satis-
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factorily completed with the issuance of Maintenance Procedure
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(MP) 1411.07, " Maintenance and Repair of Limitorque Valve Operators Type SMC-04." This item is closed.
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(11) (Closed) LCTS 1260: Adjust limit switch bypass contacts based on valve disc movement. The inspector determined that these
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-activities have been completed. When the onset of disc motion could not be determined from the MOVATS signature, the limit switch bypass contacts were set to a value of 25% of full open stroke as measured from the point of valve stem motion. The
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inspectors consider this fully adequate to meet the intent of this item. This item is closed.
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i (12) (Closed) LCTS 1261:
For all safety-related valves, set the
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torque switch to the maximum in the open direction. The inspectors determined that this activity has been completed.
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This item is closed.
-(13) (Closed) LCTS 1262:
Issue maintenance procedures to provide instructions for corrective maintenance and testing of all Limitorque operators. This item was complete as reported in Inspection Report No. 50-346/85037(DRP), Page 24. This item is
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closed.
-(14) (Closed) LCTS 1263: Verify that calculations used in adjusting Limitorque. operator torque switches are correct based on field
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measurements of valve dimensions used in calculations.
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Measurements were. verified; however, diagnostic testing was done to assure that stem thrust requirements stated by the
i vendors for design operating conditions would be met at the final torque switch settings.
Hence, the settings were not dependent on calculations based on valve geometry. This item is closed.
(15) (Closed) LCTS 1264: Review preventive maintenance for Limitorque operated valves. While the licensee's program will continue to develop in this area, the inspector considers the licensee's review of the program and ongoing activity in this area adequate to address the item.
This item is closed.
(16) (Closed) LCTS 1265:
Review post-maintenance testing and
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surveillance testing procedures to ensure they reflect operational requirements. The licensee has completed this i-
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item by the same activity used to close LCTS 1257. This item is closed.
(17) (Closed) LCTS 1266: Train personnel who maintain and test Limitorque operated valves..This item was completed by the same licensee activity reported in the closure of LCTS 1258.
This item is closed.
(18) (Closed) LCTS 1267:
Investigate other types of valve actuators at Davis-Besse to ascertain whether similar problems could exist. There are no other valve motor-operators on site for safety-related valves'other than provided by Limitorque. This item is closed.
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(Closed) Item (346/RY-100-11), C0A IV.C.I.1, Action Plan 10:
Review of the Operation of the Power Operated Relief Valve (PORV).
(1) (Closed) LCTS 1238, 1239, and 1240: Stroke test PORV at reduced pressure and at full pressure. This item was revicwed by the SRTP inspection program.
This item is closed.
(2) (Closed) LCTS 1241:
Confirmation of PORV operability, PORV control circuit repair, replace PORV control circuit signal monitor. MWO 1-85-2049-02 replaced signal monitor PSHLRC02 with a new module; the MWO was completed on November 22, 1986.
This item is closed.
(3) (Closed) LCTS 1236: Add acoustic monitor PORV flow indication lights to the control panel and identify PORV position. The inspectors observed the lights in the control room and reviewed completed MW0s 2-85-0171-01 (November 25,1985),2-85-0171-04 (November 20, 1985), and 2-85-0171-02 (November 19,1986).
This item is closed.
(4) (Closed) LCTS 1237:
Identify PORV solenoid position indicator as PORV solenoid position indication. The inspectors observed the new tag (SOL POS IND) in place in the control room and reviewed the Post Implementation Verification sheets. This item is closed.
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(Closed) Item (346/RY-100-12), C0A IV.C.1.1, Action Plan 15A:
Source Range Nuclear Instrument (NI), Channel 2.
(1) (Closed) LCTS 1534:
Replace connectors at penetration.
The inspectors observed this work in progress and reviewed MWO 2-85-0184-01 which documented completion of the connector changeout. This item is closed.
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(2) (Closed) LCTS 1540: Replace blue ribbon connector for source range high voltage power.
The inspectors reviewed MWO 1-85-2890-00, completed December 7, 1985, for replacement of the subject connector.
This item is closed.
(3) (Closed) LCTS 1541:
Replace source range NI-2 amphenol penetrations with new CONAX penetrations. The inspectors observed work in progress and reviewed MWO 2-85-0184-02 completed on December 14, 1985, which accomplished this change. This item is closed.
(4) (Closed) LCTS 1542: Address current requirements for source range discriminator and high voltage settings.
Temporary Modification T-9605 resolved procedural technical inadequacies.
This item is closed.
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(Closed) Item (346/RY-100-13), C0A IV.C.1.1, Action Plan ISB:
Source Range Nuclear Instrument (NI), Channel 1.
(1) (Closed) LCTS 1550:
Replace containment penetration. The inspectors reviewed this work in progress and reviewed MWO 2-85-0184-01 completed December 14, 1985, which accomplished this change. This item is closed.
(2) (Closed) LCTS 1551:
Inspect, clean or replace all cable connectors from the detector to the Reactor Protection System cabinet. The inspectors reviewed this work in progress and
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l reviewed MWO 1-85-3289-00, completed December 14, 1986, which i
accomplished this work. This item is closed.
(3) (Closed) LCTS 1552: Revise or prepare new procedures for installing triaxial cable connectors. The inspectors reviewed a temporary change to maintenance procedure MP 1410.24 which
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included the needed information. The inspector reviewed a later revision of MP 1410.24 and found that the needed information had been deleted and is now included in MP 1700.98.
This item is closed.
(4)
(Closed) LCTS 1557:
Replace source range NI-2 amphenol penetrations with new CONAX penetrations. The inspectors reviewed this work in progress and reviewed MWO 2-85-0184-02, completed December 14, 1986, which accomplished this change.
This item is closed.
(5)
(Closed) LCTS 1560:
Revise IC 2002.04 to address current requirements for source range discriminator and high voltage (
settings. Temporary modification T-9605 resolved the technical inadequacies. This item is closed.
No violations or deviations were identified in this area.
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4.
Startup On December 22, 1986, the licensee operated the reactor for the first time since June 9, 1985. The licensee entered Mode 2 (startup) at
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1:52 a.m. and Mode 1 (power operation above 5%) at 9:11 a.m.
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inspectors observed criticality and noted that the startup went smoothly.
During Integrated Control System (ICS) testing, the reactor tripped at 15% power at 10:15 p.m. on December 23, 1986. A feedwater flow startup control valve (SP7A) closed causing a Steam and Feedwater Line Rupture Control System (SFRCS) actuation on steam generator low water level.
The SFRCS actuation caused an Anticipatory Reactor Trip System (ARTS)
trip of the reactor.
Following the plant trip the inspectors determined the status of the reactor and. safety systems by observation of control room indicators and discussions with licensee personnel concerning plant parameters, emergency system status and reactor coolant chemistry. The inspectors verified the establishmer,t of proper communications and reviewed the corrective actions taken by the licensee. All systems responded as expected; however, due to the low decay heat level in the core, the cool down rate exceeded the B&W recommendations but did not exceed technical specification requirements.
The licensee's post trip evaluation revealed that SP7A closed due to a procedural error and an erroneous signal from unisolated test equipment.
The licensee's corrective action included changes in control of testing and troubleshooting activities and revisions to test procedures.
The reactor was restarted at 10:11 a.m. on December 24, 1986. The generator was synchronized with the grid at 8:37 p.m.
An improperly wired negative phase relay tripped the main generator output circuit breaker at 8:38 p.m.
The generator was again synchronized with the grid at 10:15 a.m. on December 25, 1986. The inspectors observed the reactor restart and generator synchronizations.
During the startup the inspectors observed inconsistencies in the relative performance of operations personnel on different shifts. The inspectors have discussed these observations with the licensee and it is taking steps to improve shift consistency. This is an open item pending review of the corrective actions (346/86032-04).
The licensee experienced main turbine steam flow control valve vibration while operating at 40% power. The control valves are normally operated using full arc admission, with all four valves moving in unison.
The throttling of the steam flow by the partially open control valves causes
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steam line vibrations. The vibration caused steam leaks when two of four unused pressure taps broke off the main steam lines. The vibration also caused the control wire lugs for the valves to break off at the terminal boards. The licensee sought and received concurrence from the turbine vendor (General Electric) to operate the control valves in the partial arc admission mode to reduce vibration.
In partial arc admission one of the control valves is disabled in the shut position while the remaining three valves control steam flow to the turbine. This action coupled with increasing power to 51% reduced vibration.
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On January 1,1987, main feedwater pump turbine (MFPT) 1-1 tripped causing an ARTS trip of the reactor and an SFRCS actuation on steam generator low water level.
Examination of the MFPT revealed a failed bearing in the MFPT front standard.
Following the plant trip the inspectors determined the status of the reactor and safety systems by observation of control room indics. ors and discussions with licensee personnel concerning plant parameters, emergency system status and reactor coolant chemistry. The inspectors verified the establishment of proper communications and reviewed the corrective actions taken by the licensee. All systems responded as expected. The turbine trip appears to have been caused by high shaft vibration releasing the mechanical overspeed device. The bearing failed due to reduced oil flow caused by a
. restriction (a drain plug) in the oil line.
Licensee records indicate that the drain plug could not have been placed in the oil line after 1984.
The licensee restarted the reactor on January 2, 1987, and synchronized the generator to the grid the next day.
On January 2,1987, the licensee initiated a conference call with NRR to discuss keeping the motor driven feedwater pump (MDFP) lined up to the main feedwater (FW) system while operating the plant above 40% power with only one MFPT. This is a deviation from a commitment which requires the MDFP to be lined up to the auxiliary FW system above 40% power. The licensee stated that keeping the MOFP lined up to the main FW system would allow the MDFP to be started quickly enough to prevent an unnecessary S7RCS actuation upon loss of the MFPT. NRR agreed with the proposed operating line up. After the conference call the inspectors requested that the licensee document the deviation with a letter to NRR.
This action will remain an open item (346/86032-05(DRP)) pending review of the letter. On January 25, 1987, MFPT 1-1 was restored to service and the MDFP was lined up to the Auxiliary FW system.
The licensee plans to test plant response to loss of the MFPT's on February 9,1987, by tripping one MFPT with the plant at full power and then tripping the second MFPT after the plant is stabilized. The ARTS will then trip the reactor and the SFRCS will be actuated due to loss of main FW. This is a deviation from the previously planned high power turbine-reactor trip.
The licensee plans to send the operators who will perform the test to the B&W simulator _in Lynchburg, Virginia, to gain experience on the plant response to the planned transient.
In addition, the operators will cbserve plant response to several different scenarios which could occur during the test.
The plant was operating at 58% power with one MFPT at the end of the reporting period.
No violations or deviations were identified in this area.
5.
Ombudsman The inspectors reviewed the Ombudsman's files for three concerns which the licensee believed to be either safety and/or quality related. Two of the concerns are described in Paragraph 12, " Allegations," and the
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third concern related to contract employees being kept on site because of friendship rather than ability.
The review revealed that the investigations appeared to be thorough and the conclusions were supported by the documentation.
No violations or deviations were identified in this area.
6.
Training The inspectors questioned the licensee as to the involvement of requalification proficiency watch standers during the shift. The inspectors asked if the watch standers were observers or participants.
The response indicated that most proficiency watch standers were observers. The inspectors were concerned that observation is not an effective method for maintaining proficiency. Additional discussions were held with the Plant Manager, the Assistant Plant Manager -
Operations, and training personnel.
The licensee considered the inspectors' concern to have merit.
The proposed changes to 10 CFR 50.55 requirements including increased time for watch standing will result in the licensee scheduling requalification watches. The scheduling of proficiency watches will allow the licensee to better control proficiency watch activities. The licensee plans to have the proficiency watch standers on the watch bill with the regular shift members overseeing their activities so that they will get more hands-on experience and accountability. This is an open item (346/86032-06(DRP)).
On December 11, 1986, INPO certified six training programs at Davis-Besse, making the plant a branch member of the National Academy for Nuclear Training. The six training programs accredited were Mechanical Maintenance Personnel, Electrical Maintenance Personnel, Instrument and Control Technician, Non-licensed Operator, Reactor Operator, Senior Reactor Operator / Shift Supervisor. The licensee has submitted Self-Evaluation Reports to INPO for the remaining four programs; Technical Staff and Management, Chemistry, Shift Technical Advisor, and Health Physics.
INPO has scheduled a site visit on July 20, 1987, to continue the accreditation process for the remaining programs.
No violations or deviations were identified in this area.
7.
Operational Safety Verification (71707)
a.
The inspectors observed control room operations, reviewed applicable logs and conducted discussions with control room operators during the period from December 1,1986, through January 31, 1987. The inspectors verified the operability of selected emergency systems, reviewed tagout records and verified proper return to service of affected components. Tours of the reactor building, auxiliary building, water treatment building, service water intake structure, and turbine building 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.
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The inspectors, by observation and direct interview, verified that the physical security plan was being implemented in accordance with the station security plan.
I The inspectors observed plant housekeeping and cleanliness conditions and verified implementation of radiation protection controls. During the inspection, the inspectors walked down the accessible portions of the Auxiliary Feedwater and Reactor Protection systems to verify operability. While walking down the Reactor Protection System th inspector found a class 1E conduit with its colored identificatian tape obscured by paint. The inspectors' review of the licensee's corrective action for verifying that future painting does not obscure conduit identification and that any conduit identification previously obscured is restored is considered an open item (346/86032-07(DRP)).
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 procedures.
b.
The inspectors have noted several operational weaknesses and potential violations during the reporting period.
Each item by itself had minimal safety significance. However, collectively, they indicate potentially significant problems relating to control of the plant.
(1) On December 15, 1986, the licensee declared main steam isolation valve (MSIV) MS 101 inoperable at 6:30 p.m.
because it failed to shut in less than five seconds as required by the Technical Specification (TS). The shift supervisor declared MS 101 inoperable and listed TS Limiting Condition for Operation (LCO) 3.7.1.5 (MSIV) as being applicable but did not list TS LCO 3.6.3.1 (containment isolation valves) as also applicable because he apparently was unaware of it.
The inspector asked the licensee if TS LC0 3.6.3.1 also should be listed as applicable. The licensee later informed the inspector that it was and entered this TS LCO action statement in the unit log. TS LCO 3.6.3.1 is more restrictive than TS LC0 3.7.1.5.
(2) On December 10, 1986, at 9:45 p.m. the licensee declared the containment air cooler (CAC) service water discharge valve, SW 1357, inoperable.
SW 1357 is also a containment isolation valve. This action placed the unit in the action statements for TS LCO's 3.6.2.2 and 3.6.3.1.
Both action statements were entered in the unit log and on the equipment status board.
TS LCO 3.0.4, which prohibits Operational Mode (mode) changes, was also applicable.
Later, the licensee correctly determined that SW 1357 had always been operable and at 9:00 a.m. on January 8,1987, made an entry in the unit log stating that the December 10, 1986, entry had been in error. However, during
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the time the valve was considered inoperable the licensee made seven mode changes. Once the valve was declared inoperable, mode changes were prohibited.
The retroactive declaration of operability did not remedy the seven incorrect mode change decisions. Plant Procedure PP 1102.01.20, dated October 20, 1986, " Pre-Startup Checklist," includes a ~ List C for each mode listing the requirements of the Technical Specifications that are to be fulfilled prior to entering that mode.
Item 43 of List C of the Mode No. 3 Hot Standby Checklist requires verification that the Containment Isolation Valves, TS 3.6.3.1, are operable. On December 20, 1986, the licensee took the unit-to Mode 3 even though SW 1357 was considered inoperable. On six more occasions from December 22, 1986, through January 3, 1987 mode changes were made under the same circumstances.
These are examples of violations (346/86032-08(DRP)) for failure to follow a procedure.
(3) From December 7 through 16, 1986, a contractor performed a Surveillance Test (ST 5035.01) on the meteorological tower.
During the surveillance, equipment was found to be inoperable and was also rendered inoperable by the testing. The shift supervisor was not notified of these conditions. Section 6.8.3 of Administrative Procedure AD 1839.00.15, " Station Operations," dated June 18, 1986, requires that any person discovering a component that is inoperable must report this to the Shift Supervisor. This is an example of a violation (346/86032-08(DRP)) for failure to follow a procedure. As a result of this lack of communication, the licensee failed to enter the appropriate TS LCO action statement. The shift supervisor became aware of this while reviewing the completed surveillance test and wrote Potential Condition Adverse to Quality (PCAQ) 86-0651 documenting the incident.
(4) On January 7, 1987, the Containment Radiation Level Monitor for channel one of the Safety Features Actuation System (SFAS) was inoperable and the channel one SFAS Containment High Radiation trip module was tripped as required by TS LCO 3.3.2.1 action statement nine. At 11:52 p.m., while performing Surveillance Test Procedure ST 5031.04.15, " Containment Radiation Monitor Input to SFAS Refueling Period Calibration," dated April 29, 1986, an Instrument and Control (I&C) technician erroneously placed the Test Trip Bypass Switch (TTBS) in the " Containment Radiation" position. Once this action was taken the unit was no longer in compliance with TS LC0 3.3.2.1 action statement nine and the licensee wcs required to meet the requirements of TS LC0 3.0.3.
TS LC0 3.0.3 requires that when an LC0 is not met, except as provided in the associated action requirements, action shall be initiated within one hour to place the unit in at least hot standby within six hours, at least hot shutdown within the following six hours and cold shutdown within the subsequent
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twenty four hours, as applicable. However, the failure to comply with TS LCO 3.3.2.1 action statement nine was not identified until about 8:20 a.m. the following day and the position of the SFAS TTBS was changed to restore the unit to compliance with TS LC0 3.3.2.1 action statement nine.
For eight hours and twenty eight minutes the unit remained at power with no actions taken to place the unit in hot standby.
.This failure to comply with TS LC0 3.0.3 is a violation (346/86032-09(DRP)).
This violation' occurred because the I&C technician did not correctly follow steps 5.6 and 6.2 of ST 5031.04.15.
Step 5.6 of ST 5031.04.15 directs the I&C technician to obtain one SFAS cabinet door key if the SFAS channel is under an action statement; and one SFAS cabinet door key and one TTBS key if the SFAS channel is not under an action statement. Although the SFAS was in an action statement the technician obtained both keys from the shift supervisor. Step 6.2 of ST 5031.04.15 directs the_ technician to place the TTBS in the " Containment Radiation" position if the channel is not in an action statement. However, as indicated, the SFAS channel was in an action statement and yet the technician placed the TTBS in the
" Containment Radiation" position.
It is the inspector's_ opinion that if Step 5.6 of ST 5031.04.15 had been worded differently, the probability of this type of violation would have been diminished.
(5) On January 20, 1987, the inspectors noted that the unit log and reactor operator's log both had a 3:30 p.m. entry indicating that an Auxiliary Feedwater (AFW) System was inoperable.
System Procedure SP 1106.06.26, dated December 2, 1986,
" Auxiliary Feedwater System," requires the operator to turn on the " Manual System Bypass" blue indicating light whenever any condition which causes the AFW system to depart from its normal operational status. The illumination of this blue light serves as a reminder and indication to the operator that the system is in an inoperable status.
At about 3:40 p.m. the inspector noted that the Manual System Bypass indicating light for the AFW system was not on and that the system was not listed as inoperable on the. Equipment Status Board. This is an example of a violation (346/86032-08(DRP))
for failure to follow a procedure. The inspector asked the l
Reactor Operator (RO) at the R0's desk why the blue light for (
the AFW systems was not on.
The R0 stated that he thought both AFW systems were operable.
The R0 called the Shift Supervisor and asked him the status of the AFW systems. The R0 then informed the inspectors that one AFW system was inoperable, turned on the appropriate blue light and entered the status of the AFW system on the Equipment Status Board. The RO's awareness of plant conditions was inadequate.
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.The above examples illustrate that the licensee is not always. aware of plant conditions or applicable technical specification action
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statements..The-licenseeLrecognizes this and subsequent to the
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_ reporting period requested a management meeting with Region III to discuss the problems and corrective actions. The results of.
this meeting will be reported in the next inspection. report.
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On January 20,'1987, the licensee experienced a dropped control rod (7-3) due to a' fuse failure. The' fuse was replaced and the rod returned to service..The inspector verified adequate shutdown-margin was maintained.
d.
'The inspectors reviewed two Administrative Procedures, AD 1839.00.15, " Station Operations," and AD 1839.05.03, " Shift Turnover," during the inspection period and noted discrepancies in both procedures. ~Section.5.6.6 of AD 1839.00 requires the shift supervisor to maintain the unit log and equipment status board.
Section 6.5.1 of AD 1839.05 requires the shift supervisor to review the unit log and-Section 6.5.6 requires him to review the blue status lights on control room panel C5717 prior to assuming the '.
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shift. There is no requirement in AD 1839.00 for anyone to maintain i
the _ blue status lights and there is no requirement in AD 1839.05 for-anyone to review the equipment status boards prior to assuming the shift.
Section 5.7.9 of AD 1839.00 requires the assistant shift supervisor to maintain either a reactor operator's or senior reactor operator's i
(SRO) license. -However, Section 6.1.1 states that the assistant shift supervisor will have an SR0 license.
The inspectors have discussed these and other discrepancies with the licensee. The licensee stated that the 1839 series of
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administrative procedures would be reviewed'and revised as necessary. This is an open item.(50-346/86032-10(DRP)).
Sections 5.6.13 and 6.15 of AD 1839.00 require the shift supervisor to perform detailed unit tours at a minimum frequency of three
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times per week and record the tours in the unit log. The inspectors'
review of the unit log did not reveal any entries for shift supervisor tours for two-thirds of the reporting period. The inspectors discussed their observation with the licensee. _The inspectors later reviewed the unit log from January 21 through 30,
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1987, and still could find no entries for shift supervisor tours.
This observation was again discussed with the licensee. Subsequent
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to the reporting period, the inspectors have observed that shift i
supervisor tours were being recorded. This is considered to be an
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i open item (50-346/86032-11(DRP)).
Two violations were identified in this area.
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8.
Monthly Maintenance Observation (62703)
The inspectors are concerned about the indiscriminate use of temporary mechanical modifications (TMMs) to circumvent the more formal methods of changes. TMMs are used to perform minor mechanical modifications.
TMMs are documented on TMM log sheets as described in Administrative Procedure AD 1823.00.17, but the changes are not documented on other applicable documents, i.e., drawings and procedures. The inspectors have observed that temporary modifications frequently become semi permanent or long term ar.d have a high potential of not being properly documented. The inspectors have concluded that TMMs may have been used to circumvent the facility change request (FCR) process which requires changes to be documented in both drawings and procedu...
In addition, the inspectors have noted that historically the licensee had utilized jumpers, lifted leads and TMMs as a normal way of doing business to expedite completion of work. The licensee is currently making a concerted effort to reduce the number of jumpers and lifted leads but has not addressed TMMs. The inspectors have discussed their concerns with the licensee. This is an open item (346/86032-12(DRP)) pending the inspectors' review of the licensee's response.
Station maintenance activities on safety-related systems and components listed below were observed to ascertain that they were conducted in accordance with approved procedures, regulatory guides and industry codes or standards and in conformance with technical specifications.
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 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 implemented.
Work requests were reviewed to determine the status of outstanding jobs and to assure that priority is assigned to safety-related equipment maintenance which may affect system performance.
The following maintenance activities were observed:
Replacement and calibration of Auxiliary Feedwater System low pressure switches.
- Troubleshooting and repair of Main Steam Isolation Valve.
- Troubleshooting and repair of Main Feedwater Pump Turbine 1-1.
- Nuclear instrumentation amplifier gain adjustment.
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Following completion.of maintenance on the Auxiliary Feedwater, Main Steam, and nuclear instrumentation systems, the inspectors verified that these systems had been returned to service properly.
No violations or deviations were identified in this area.
9.
Monthly Surveillance Observation (61726)
The inspectors observed technical specifications required surveillance testing on the Control Room Emergency Ventilation System, ST 5076.06,
" Control Room Emergency Ventilation System Train 2 Service Water Flow Adjustment," and the Reactor Protection System (RPS), ST 5030.02, "RPS Monthly Functional Test," and verified that:
testing was performed in accordance with adequate procedures, test instrumentation was calibrated, limiting conditions for operation were met, removal and restoration of the affected components were accomplished, test results conformed with Technical Specifications and procedure requirements and were reviewed by personnel other than the individual directing the test, and any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personnel.
The inspectors also witnessed portions of the following test activities:
ST 5042.02 RCS (Reactor Coolant System) Water Inventory Balance
ST 5076.05 Control Room Emergency Ventilation System Train 1 Service Water Flow Adjustment.
No violations or deviations were identified in this area.
10.
Licensee Event Reports Followup (92700)
Through direct observations, discussions with licensee personnel, and review of records, the following event report was reviewed:
LER 87-003, Service Water Valve Incorrectly Declared Inoperable During Mode Changes.
Further discussion of this issue can be found in Paragraph 7.
11.
Followup of Events (93702)
During the inspection period, the licensee experienced several events, some of which required prompt notification of the NRC pursuant to 10 CFR 50.72. The inspectors pursued the events onsite with licensee j
and/or other NRC officials.
In each case, the inspectors verified that the notification was correct and timely, if appropriate, that the licensee was taking prompt and appropriate actions, that activities were conducted within regulatory requirements and that corrective actions would prevent future recurrence.
The specific events are as follows:
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12-23-86 - Reactor trip resulting from testing.
- 01-01-87 - Reactor trip resulting from loss of Main Feedwater Pump.
- 01-12-87 - Both trains AFW declared inoperable due to testing and maintenance of SOR pressure switches.
Because of previous problems with SOR switches at another Region III site several months ago, further investigation was conducted on this last item.
Review of SOR Pressure Switch Failure On January 7, 1987, while performing Surveillance Test, No. ST5071.13,
" Functional Test of Auxiliary Feedwater Pump Turbine (AFPT) 1-1," Valves MS106 and MS106A did not'close when Pressure Switches PSL106A and PSL106C were vented, as called for by Steps 5.4.1 through 5.4.9.
The licensee declared AFW train No. 1 inoperable, entered T.S. 3.7.1.2, and authorized immediate action maintenance to replace the failed switches.
These switches were environmentally qualified (EQ) static-o-ring switches manufactured by SOR, Inc. The Model Number, 6TA-B4-NX-CIA-JJTTX6, indicated that the switches were in the standard configuration for a SOR EQ switch, which included an Ethylene Propylene Rubber (EPR) o-ring and a Kapton Polyimide primary diaphragm.
On January 12, 1987, with train No.1 of the AFW system already inoperable, the licensee intentionally removed the second train from service to verify the operability of it's SOR switches. With both trains technically inoperable, the licensee declared an unusual event.
The surveillance testing verified that the system was operable and the unusual event was terminated and the train was returned to service.
On January 13, 1987, SOR representatives were onsite with replacement switches. These switches differed from the failed switches in that they had stainless steel primary diaphragms. The hypothetical failure mode was the formation of a gas bubble between the layers of the diaphragm material caused by the migration of ammonia across the first layer of the Kapton diaphragm after a period of exposure to the feedwater.
It was believed that the formation of this bubble between the layers caused the setpoint to shift. At Davis-Besse,-ammonia is added to the FW system to control the pH of the water. Hydrazine also becomes a source of ammonia because hydrazine reacts with oxygen to form ammonia and water.
The replacement switches with stainless steel diaphragms will not be affected by ammonia.
A region based inspector arrived onsite on January 14, 1987 to follow up on the SOR switch failures and to review the licensee's actions relative to this event.
a.
Documents Reviewed (1) Potential Condition Adverse to Quality (PCAQ) Report, No.87-005,
"No.1 AFW Train, PSL 106A and PSL 106C," dated January 7,1987.
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(2) PCAQ Report, No. 87-0011, "No. 2 AFW Train, PSL 107A, 1078, 107C, and 107D," dated January 9, 1987.
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(3) Specification No. 12501-M-3670, " Technical Specification for Operational' Pressure Switches (Q Listed)," Revision 4.
(4) Facility Change Request, No. 85-0143, "SOR Pressure Switch Changeout" Revision B.
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(5) Safety Evaluation for FCR No. 85-0143, Revision B.
(6) Request for Purchase, No. MR 270841, "SOR Pressure Switches,"
dated January 14, 1987.
(7) Request for Purchase, No. MR 239989, "SOR Pressure Switches,"
dated October 18, 1985.
(8) Evaluation of Environmental Conditions From Auxiliary Feedwater Pump Turbine Steam Supply Line Ruptures," Report No. 02-0140-1334," Revision 1.
(9) Calibration Records for SOR Pressure Switches PSL 106/107 A through D, dated January 17, 1987 through January 22, 1987.
b.
Results of Inspection On January 14 and 15, 1987, the inspector reviewed the technical specification for operational safety-related pressure switches, the
related PCAQ reports, the field change package to install the new switches, the related purchase requests, and calibration records.
The inspector interviewed selected personnel about the switch failures and reviewed the sequence of events. The inspector also met with the SOR representatives, licensing personnel, and Davis-Besse EQ personnel.
The inspector's review of the purchase requests indicated that SOR, Inc. supplied exactly what the licensee ordered. This was an EQ switch with a Kapton primary diaphragm. Although Kapton's intolerance to ammonia had previously been recognized by the chemical industry, it was not known to the nuclear industry. This potential generic problem will be the subject of an Information
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Notice currently being prepared by the Office of Inspection and Enforcement.
The inspector's review of the EQ of the failed switch and the proposed replacement indicated that the new switches were identical to the ones originally qualified for use at Davis-Besse, with the exception of the stainless steel primary diaphragm. The inspector reviewed the similarity analysis prepared by the licensee to establish the EQ of the system in its present configuration and
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No violations or deviations were identified during this inspection.
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'12.1 Allegations
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Closed AMS-RIII-86-A-0178
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Region III received an allegation that feedwater system problems on:
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June 2,1985, were similar to problems which ~ occurred on June 9, _1985;-
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that senior Toledo Edison management was informed of the June 2 event and directed the plant be returned to service and. threatened to fire
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'the. senior individual on shift;-and that the NRC resident inspectors'
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statement that the events were not similar was questionable.
With respect to the issues of similarity of the events and whether the resident inspectors conclusion was correct, both e' vents involved the main feedwater pumps (MFP) and therefore are "similar" on that basis.
l However, the root:cause of _the June 2,.1985, MFP trip -(and of the April 24,1985-trip) was improper adjustment of the MFP rapid feedwater reduction circuitry which is part of the integrated control circuitry.
e The root cause of the June 9, 1985, MFP trip.was a failed electronic component.in the _ speed sensing circuit causing the. output voltage to
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indicate "0" speed at all times. The " demand" part of the control i-circuit was requesting higher speeds'on the MFP so that flow would equal i-demand but, because of the failed component, the indicated speed (e.g.,
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higher flows) would not vary from "0."
The end result was a trip of the
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On this basis the events are-n'ot similar. One involves-an improper adjustment of one circuit and the other involves a failed component _in-an unrelated circuit.
Furthermore, the failures of the MFPs on April 24
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and June 2, occurred after reactor trips because the rapid feedwater
reduction circuitry functions only after such events, and the failure on June 9, occurred prior to the reactor trip and in fact was an initiating
event of the trip.
i The remaining _part of the allegation' relates to the interaction of the
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Toledo Edison Chai.rman of the Board and the shift supervisor. The I
alleger stated that the Chairman of the Board was pressuring the shift i
supervisor-to return the unit to service on June 2, 1985 and that the-senior individual on shift called the Chairman of the Board at home. It is further alleged that the Chairman of the Board threatened to fire the
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-senior individual on shift if the unit was not returned to service. The
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chronology of operations shows that the plant tripped about 6:00 a.m. on June 2,1985, and was not restarted until 2:45 a.m. on June 4,1985. Some of this is discussed on Page 3-2 of NUREG-1154, " Loss of Main and i
Auxiliary Feedwater Event at the Davis-Besse Plant on June 9,1985" where it states:
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"Since April 1985, there had been control problems with both main i
feedwater pumps. Troubleshooting had not identified nor resolved i
the problems.
In fact, a week earlier, on June 2, 1985, both feedwater p
pumps tripped' unexpectedly after a reactor trip. After some additional l
troubleshooting, the decision was made not to delay startup any longer, i
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. pump trip, if it occurred again. As a precaution,- the number two main
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feedwater pump was_ operating in manual control to prevent it from '
tripping and.to ensure that all main feedwater would not be lost should
the reactor trip.
Some operators were uneasy about going up to power with problems in the
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feedwater: pumps,.but they complied with the decisions made by their management."
_The resident _ inspectors interviewed the shift supervisors who had been on duty on. the two shifts of June 2,1985, subsequent to the one of the -
L reactor trip (which occurred at 6:05 a.m. on June 2) and asked if they had called the Chairman of the Board on that day and whether_they had been
pressured to restart the reactor.
Both of the shift supervisors denied
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they had called or spoken to him and one in particular was emphatic in
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stating he would_not call the Chairman of the Board at any time, but would call plant management if he had problems.
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i He further stated that_if such a. call were made it would be logged in the
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. operations. log. The inspectors reviewed the logs for that day and found i
no such entry. The inspectors also note that both of these shift
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supervisors still work at Davis-Besse, one as a shift supervisor and the
'other.as the operations superintendent.
Based on this information, this allegation was not substantiated and is j
closed.
No violations or deviations were identified in this' area.
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13.
Licensee Response'to RegionIII Davis-Besse Study Group Report In March 1986, the NRC Region III Study Group completed a broad review of r
the history of the licensee's regulatory performance. The purpose of the
review was to determine what problems have existed and how these problems were handled by the NRC and Toledo Edison, or if they were not addressed, to identify an appropriate course of action.
Section III of.the report, " Observations and Findings," provided details of.the study group's concerns identified during its review. Region III evaluated those items and concluded that corrective action regarding most
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of the items had been initiated or completed.
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A May 30, 1986, letter from Region III transmitted the Study Group report j
to the licensee and requested that the licensee provide corrective
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actions for five items in the report.
The licensee's corrective actions were documented in two letters from the
licensee to Region III; Serial No. 1-674 dated October 13, 1986, and Serial No. 1-678 dated November 7, 1986.
The five items requiring corrective actions are listed below with a summary of the licensee's response and inspection status.
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a.
(Closed) Item III.A.4, LCTS 2545 and 2277: Continuing problem with ventilation boundary and fire door closing and latching mechanisms.
Licensee letter. Serial No.1-674, Item III.A.4, provides a plan for repairing and maintaining fire and ventilation boundary doors and balancing ventilation air flow. This item is closed.
Satisfactory and timely completion of the plan will be followed as an open item (346/86032-13(DRP)).
b.
(Closed) Item III.A.5, LCTS 2280:
Recurrent problems maintaining nitrogen pressure in electrical containment penetrations.
Facility Change Request (FCR)84-104 has been approved for implementation during the next refueling outage (February 1988). This modification will provide a continuous nitrogen supply. This item is closed.
Completion of FCR 84-104 will be followed as an open item (346/86032-14(DRP)).
c.
(Closed) Item III.0, LCTS 2279:
Improper use of lifted leads and jumpers, and five events with multiple component failures that occurred before the June 9, 1985, event.
Corrective action for incidents involving improper use of lifted leads and jumpers is discussed in the response to Item III.E.3.
Licensee letter Serial No. 1-674, Item III.D, Part 2, describes the programs the licensee has in place to evaluate multiple failure events. The licensee's program will be periodically reviewed by the inspectors as part of
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the regular inspection program. This item is closed.
d.
(Closed) Item III.E.1, LCTS 2278: Significant number of technical specification violations due to inoperable equipment and failure to complete surveillances.
Licensee Letter Serial No.1-674, Item III.E and III.E.1 described the licensee's corrective actions. The inspectors have observed examples of the corrective actions and they appear to be effective. This item is closed.
e.
(Closed) Item III.E.2, LCTS 2542:
Improper control of valves.
Toledo Edison Letter Serial No. 1-674 describes the corrective actions the licensee has taken to properly control valves. The inspectors have observed the implementation of the corrective actions and the actions appear to be appropriate and successful.
This item is closed.
f.
(Closed) Item III.E.3, LCTS 2279 and 2544:
Improper removal of equipment from service and failure to follow jumper and lifted wire (J&LW) procedures.
Licensee Letter Serial No.1-674, Items III.E and III.E.3 described the licensee's corrective actions.
The licensee's corrective actions to prevent improper removal of equipment from service appear to be appropriate; however, during the period of the report, equipment was improperly removed from service (see Paragraph 7, Operational Safety Verification). The inspectors will continue to evaluate the licensee's corrective actions in this area in conjunction with review of the licensee's response to violation (346/86032-08(DRP) identified in Paragraph 7.b.(3).
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The licensee's corrective actions included actions already taken as well as plans to improve AD 1823.00, " Jumper, Lifted Wire and Temporary Mechanical' Modification Control," and provide additional training on AD 1823.00. The number of J&LW's and temporary mechanical modifications (TMM's) is being tracked by the licensee and, in nuclear safety systems, safety evaluations are written for J&LW's and TMM's before the affected system may be declared operaole. The inspectors verified that AD 1823.00 has been revised.
The. inspectors will continue to follow the licensee's corrective actions in this area as open item (346/86032-15(DRP)) due to concerns discussed in Paragraph 8, Maintenance.
g.
(Closed) Item III.E.4., LCTS 2543: Repetitive violations of
fire protection procedures, including open fire doors, improperly sealed fire barrier penetrations, inadequate fire watches, and inoperable equipment.
Licensee letter Serial 1-678, Attachment 2, Item III.A.4, Response, and Item III.E.4, Response "a," described the licensee's corrective actions to prevent improperly opened fire doors. The inspectors consider the licensee's planned corrective action adequate. Attachment 2, Item III.E.4, Response "b,"
described the licensee's corrective action to repair and prevent improperly sealed fire barrier penetrations. The inspectors consider the licensee's planned corrective action adequate. The inspectors have observed numerous fire barrier penetration seals that have been replaced or improved. Satisfactory completion of the corrective actions in this area will be reviewed in future inspections during the review of open items (346/85028-01) and (346/86005-05). Attachment 2, Item III.E.4, Response "c," described the licensee's completed and planned corrective action to assure fire watches are adequate and timely.
The completed corrective action was previously reviewed and documented in Inspection Reports No. 50-346/85037 and No. 50-346/86006.
The corrective actions for repeated examples of inoperable equipment were discussed in Item "f" above. This item is closed.
h.
(Closed) Item III.F., LCTS 2276:
Provide corrective actions to address repetitive procedural violations, inadequate management controls and inadequate corrective action.
Licensee Letter Serial No.1-674, Item III.F., describes steps taken to address deficiencies and improve performance in management and programmatic problem areas. This item is closed.
No violations or deviations were identified in this area.
14.
Emergency Preparedness On January 19, 1987, high winds caused localized flooding near the site.
All access to the plant was temporarily blocked due to barricades placed on State Routes 2 and 19. On the morning of January 20, 1987, the inspectors found that some barricades were still in place, although the flooding had subsided. Also, on the morning of January 20, 1987, the licensees employee access information telephone recording advised callers
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to take an alternate route to the site. The alternate route included State Route 19, which was still barricaded. During later discussions with the licensee, the licensee stated that State Routes 2 and 19 had been barricaded by the State of Ohio at appropriate intersections in accr.rdance with the state's normal procedures. The inspectors requested Region III specialists to investigate this matter (346/86032-16).
No violations or deviations were identified in this area.
15. Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. Open items disclosed during the inspection are discussed in Paragraphs 3, 4, 6, 7, 8, 12, 13, and 14.
16.
Exit Interview (30703)
The inspectors met with licensee representatives (denoted in Paragraph 1)
on January 9 and February 8,1987, and informally throughout the inspection period and summarized the scope and findings of the inspection activities. The inspectors also discussed the likely informational content of the. inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not identify any such documents or processes. s proprietary. The licensee acknowledged the findings of the inspection.
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