IR 05000346/1987001

SALP Rept 50-346/87-01 for Nov 1986 - Dec 1987.Overall Performance Acceptable

ML20148E917
Person / Time
Site:	Davis Besse
Issue date:	12/31/1987
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20148E899	List: IR 05000346/1987001 ML20148E893
References
50-346-87-01, 50-346-87-1, NUDOCS 8803280030
Download: ML20148E917 (43)

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SALP 6 SALP BOAR 1 REPORT

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NUCLEAR REGULATORY COMMISSION

REGION III

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 50-346/C7001 Insnection Report N Toledo Edison Company Name of Licensee Davis-Besse Nuclear Power Plant Name of Facility November 1, 1986 through December _311_1987 Assessment Period l

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8803280030 800321 PDR ADOCK 05000346 O DCD

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SUMMARY OF RESULTS This assessment period covers the time period from November 1, 1986 (prior to initial criticality following the extended outage after the June 9, 1985, event), through December 31, 1987, and is labelled as SALP 6. The extended outage was labelled as SALP 5, but because of the nature of the work being done, no SALP ratings were assigned to that report; it was a chronological discussion of major site activities during the outag Therefore, the comparisons made in this SALP 6 report are with SALP 4 which covered plant operations from April 1,1983, through Auoust 31, 198 '

The licensee's performance has improved from SALP 4 to SALP 6. Whereas there were five Category 3 ratings in SALP 4, there was only one Category 3 rating in this assessment period (in fire protection). No areas declined in ratings, and the number of Category 1 areas incressed from two to four. Plant operations improved and plant availability, which is a reflection of plant maintenance, also increased. The licensee expended considerable resources for such things as higher salaries, a new maintenance shop facility and a reactor control room simulator. The plant operations staff continues to be a strength of the facility and performed well considering the length of time the plant had been shut down and the numerous changes to equipment and procedure A number of key middle and upper level management positions were vacated during the assessment period. With one exception these positions were filled with fully qualified personnel in a timely manner and the changes did not appear to detract from the progress in improving performance at l Davis-Besse. However, the NRC is sensitive to the potential disruption which can result from significant changes to the management team. In addition, continuing concerns exist regarding staff morale and !

engineering support. The NRC will continue to monitor the licensee's ;

performance carefully in these area I I

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Rating.SALP 4 Ratin Functional Area Period Period (gSALP This6)*** Plant Operations 2 2 Radiological Controls 1 1 Maintenance 3 2 Surveillance 2 1 Fire Protection 3 3 Emergency Preparedness 3 2 Security 2 1 Outages 1* 1 Quality Programs and Administrative Controls Affecting Quality 3 2 r Training and Qualification fiect'venris 3 2 Engineering / Technical N/R** 2 Support Lice sing Actirities 2 2 i

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• This functional area was titled "Refueling" during the SALP 4 perio **This functioral area was not rated (it is a new functional area for i SALP6).  !

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• • • SALP 5 was an informational report to cover the extended outage ,and

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functional areas were not rate l

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IV. PERFORMANCE ANALYSIS Plant Operations l Analysis

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The licensee's perfonnance .in the functional area of plant

operations conducted bywas the evaluated by considering(b) a special auginented(a) ro resident inspectors;  !

team inspection and (c) a special operational safety team inspection conducted by regional, headquarters, and contract personnel. Plant availability was approximately E4% for the 12 month period following reactor startu Five violations (four Severity Level IV and one Severity Level V)

were identified in this area during this assessment period. They involved isolated events and were not indicative of progranaatic problem Of tha six reactor trips involving rod motion during the assessment period, two can be attributed to errors made by operations personnel. The first - a trip from 15% power on the first day of operations following the 18-month outage - was caused, in part, by inadequate commur.ications between reactor operators and testing personnel who recoved a component, thus causing a feedwater transient. Althougn the operators responded properly to the transient, the reactor tripped during recovery operations. The other trip caured by operations personnel (late in the assessment period) was similar to the first one. Poor communication during an operator turnover was involved, and the trip occurred during recovery operations from the initiating even Four events attributed to activities in this area required thi submittal of licensee event reports (LERs). three of which involved, at leact in part, personnel error. The fourth LER was for a reactor trip caused by a lightning strik The licensee's corractive actions were timely and appropriate for each even In general, operat, ors personnel performed well considering

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the length of time the plant had been shut down and the numerous changes to equipment and procedure Their response-to the six trips at pcwer that occurred during this assessment period were excellen l l

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Several events early in the assessment period indicated a lack of attention by reactor operators. In addition to the perscnnel errors that led to the submittal of the LERs noted above, a reactor operator failed to turn on a blue status light which is used to warn control room personnel that one train of the auxiliary feedwater system was temporarily out of servic Also, the suction valve to the motor-driven .feedwater pump was inadvertently shut while the pump was operating during an oJtage, damaging the pump. Two of the personnel error events were identified and corrected by alert shift crews coming on duty. Individually, none of these . items was of major safety significance, but taken as a whole they indicated that the licensed staff was not paying close enough attention to detai Improvements were noted during the period and no events caused by inattention to detail occurred during the latter part of the perio Although the rumber of licensed senior reactor operators (SR0s)

is now s .fficient, inse'ficient shift staffing was a major weakness during the first half of the assessment period. As a result of insufficient staffing, SR0s. worked e.wisive overtime hours (at times, more than that specified by NRC policy and Technical Specification requirements) to cover shifts. About midway through the assessment period, a shift superviscr (SR0)

who had routinely been working 12-hour (plus turnover) rotating

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shifts was found dozing in his chair while on dut Licensee management had been aware of the shortage of staff and had plai.ned to increase the numbsr cf SR0s before this event; however, it Has not until after the individual was found dozing that some staff SR0s were assigned to shift duties to relieve the overtime burtien on the four active shift supervisor Licensee management later requested NRC a:sistance in expediting license examinations to help resolve the problem. Eight SR0s and four reactor operators were licensed toward the end of the assessnent perio The number of nonlicensed operations staff [ equipment operators (E0s) and auxiliary operators (A0s)] is more than adequat Approximately nine E0s and A0s are routinely assigned to a shif Only two are required by the Technical Specifications. In general, the E0s and A0s are knowledgeable, qualified, and well traine ,

I The top three management positions in the operations ,

' organization were vacated during the assessment period. The l Assistant Plant Manager-0perations resigned his position very I early in the period, and the position was quickly filled by one of the licensee's long-term employees. In the middle of the assessment period both the Operations Superintendent and the Operations Supervisor requested to be relieved of their dutie Both were returned to shift supervisor duties. The position of Operations Superintendent, which has not been filled is being l covered by the Assistant Plant Manager-0peration The

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licensee has designated an individual, who is currently in SR0 license training, to fill the position after he acquires his SR0 license; this is scheduled for May 198 The position of Operations Supervisor is currently filled by a contracto Filling these latter two positions with permanent staff should facilitate better teamwork in the operations organizatio Staff morale at Davis-Besse continuus to be of concern to the NR The operations staff is dissatisfied with management's style and concept of operations. The issue appeared to become worse with the change in management after the June 1985 loss-of-feedwater event and persisted throughout the assessment poriod. Management is aware of this issue and has taken steps to resolve it. Recently, the resident inspectors have noted an improvement in operator morale. There is no evic'ence thet the issue has affecteu the safe operation of the facility, and all operators interv'ewed stated that given a reactor event they would take whatever action was required to prctect the health and safety of the public. All performance data ano licensee documentation substantiate thi Management's involvement in ensuring quality was mixed. The management changes noted earlier may have cor:tributed to reduced management oversight earlier in the assessment period. A few cases were observed of inadequate reviews of logs and records and inadequate log keeping. Insufficient reviews of work requests before the packages were submitted to the shift supervisor was identified as a weakness because it increased the administrative burdens on the shift supervisor and detracted from his other duties. Corrective actions were initiated prior to the end of the assessment period. In spite of this and of management's lack of action on the staffing issue that i contributed to morale problems and to the excessive need for i overtime early in the assessment period, the performance of the 4 operstions staff was good. After the two problems were brought l to management's attention midw:y through the period, management  !

took corrective actions. Its involvement now i's improve Management's approach to resolving technical issues from a

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safety standpoint was generally conservative, and its respense to NRC initiatives was prompt and thoroug '

Housekeeping requires more attentio The more accessibic areas have been cleaned and painted, but less accessible areas still

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need work. The licensee plans to make a major effort in the next assessment period to finish cleaning the plan ,

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area. The licensee's performance was rated Categ,ory 2 during the SALP 4 period.

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Non B. Radiological Controls Analysis The licensee's performance in the functional area of radiological controls was evaluated by considering the results of three ia - sns by regional specialists and observations by the .e inspector ,

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Enforcement history in this functional area remains very goo No violations were identified during this assessment perio Major staffing and organizational changes were made in this functional area during this assessment period. The most significant changes were separation of the Chemistry and Health Physics Department into two separate departments, the raassignment of the former :iead of the Chemistry and Health Physics Department to a corporate position, and the resignation of the former Health Physics Cupervisor. The long-term effect of these changes on the quality of the licensee's radiological controls cannot yet be determine The personnel assigned to tha vacated and newly created positions resulting from these changes appear well qualified for their new responsibilities. A short-term weakness resulting from the changes is the diminished experience level of testers assigned to radiclogical control duties. Also, as a result of promotion, the first-line chemistry supervisory position is vacant; this weakens the professional review of analytical dat The licensee is actively recruiting and training additional testers and expanding the staff of technical and professional personnel to increas9 support for the operational radiological control and chemistry progra, Management involvement in assuring quality remains apparen In response to audit findings, the licensee has initiated a program designed to further formalize and standardize radiclogical control and chemistry program >3 improve equipment and facilities, and increase technical support arJ oversight capabilities. One area requiring additional management attention is the timeliness of modifications to postaccident sampling gaseous monitoring

systems and sample piping.

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l . The licensee has responded well to NRC initiatives as is shown l by improved airborne effluent monitor calibrations, improved l routing of airborne sampling lines, changes in software to l quantify effluents more accurately, and a commitment to improve reporting of effluent data by including lower limit of detection (LLD) values where appropriat The licensee's approach to resolving technical issues has been good. The licensee continues to show evidence of prior planning and well-implemented ALARA practices. Total doses for 1986 and 1987 were 124 and 59 person-rem, respectively. These annual doses continue to be very low and are indicative of continued good exposure and chemistry controls. There has also been a continuing effort to reduce total contaminated areas and contamination concentrations within such area The volume of low-level radioactive waste generated and shipped was lower than the average for U.S. PWRs. Liquid and gaseous radwaste releases were only a small fraction of Technical Specification limit No transportation incidents occurred during the assessment period. The performance of radiological confirmatory measurement comparisons declined somewhat since the last assessment period. Of the 8 disagreements out of 77 comparisors, 4 were corrected immediately. The quality control program for the counting room has been improved by implementation of improved procedures and programmatic oversight by a chemistry forema . Conclusion This licensee's performance is rated Category 1 in this are The licensee's performance was rated Category 1 during the SALp 4 perio . Board Recommendations Non C. Maintenance Analysis The licensee's performance in the functional area of maintenance was evaluated by considering the results of routine inspections conducted by the resident inspectors and several inspections conducted by regional inspectors, an operational safety team, a maintenance team, an auxiliary feedwater (AFW) system team, y and an augmented inspection team. The areas examined included followup activities with regard to previous inspection findings; completed maintenance work orders; completed facility change request packages; items deferred for completion until after restart from tne June 9, 1985 event; material condition of the

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. plant and status of the maintenance backlog; material condition cf the AFW system; station administrative maintenance controls; work in progress; and equipment problems that led to a reactor l tri j Two violations (Severity Level IV) were identified during this assessment period. They were not of major safety significance, nor were they indicative of a programmatic weaknes Six events l attributed to this area required the submittal of LERs. Of these i events four were caused by personnel error, one by a component l failure, and one by a procedural inadequac I

Af ter the June 9,1985 loss-of-feedwater event, the licensee !

instituted a major program to improve toe material condition of i the plan Management reviewed incompleted work periodically to l ensure that maintenance important to safety was completed before restart. Although many less significant work items were deferred l iltil after restart, work priorities were established and I adequate staffing was provided to allow the maintenance staff to keep pace with normal operating cycle work while reducing the I backlog of uncompleted maintenance items. Aggressive management l required supervisors to take personal responsibility for timely i and correct completion of maintenance activities. Lack of responsibility and accountability previously was identified as a weakness at Davis-Bess !

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The licensee is developing a comprehensive preventive 1 maintenance (PM) program and is increasing the scope of the !

program to include more balance-of plant equipment. Complete l development of the PM program is coupled to the configuration I management program (see Section K, "Engineering / Technical l Support"), which is scheduled for completion by the end of ,

the sixth refueling outage. The licensee has implemented a I computerized PM scheduling system to facilitate adherence to l the program. Management holds the staff accountable for timely I completion of PM activities and gives appropriate attention to !

the PM program, l During the first half of the assessment period, the licensee occasionally bypassed work control procedures to perform a tas In two instances, management personnel directed that minor plant modifications be made without using the facility change request process. In another instance, an engineer made minor adjustments to a system without using a maintenance work order (MWD). It ;

appears that the licensee has corrected this weakness because !

no such instances were identified during the latter part of the

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Management is involved in the control and quality of maintenance activities. Before the December 1986 restart cf the unit, the licensee performed extensive reviews of items deferred for completion until after restart and had, with minor exceptions, properly classified them. While some problems were identified in the quality of work packages submitted to the shift supervisor as noted in Section IV.A of this report, MW0s were '

generally very detailed in describing work performed and were a significant improvement in comparison to MW0s reviewed in 1984 and 1985. Problems were resolved generally in a conservative and technically sound manner, and NRC questions and requests for information were responded to in a timely, complete, and thorough fashio At the daily plan-of-the-day (P00) meeting, the licensee discusses current lists of equipment concerns. The lists briefly describe problems, identify the responsible shop, give estimated completion dates of work, and provide brief comment Significant problems are discussed openly with the responsible shop representative available to identify and resolve any schedular perturbation About midway through the assessment period, the Assistant Plant Manager-Maintenance resigned. The position was immediately filled by a person promoted from within the maintenance organization. Although the full effect of the change cannot yet be determined, the new Assistant Plant Manager-Maintenance is qualified to fill the position and is aggressively involved in maintenance activitie Early in the assessment period, the licensee completed a new shop facility building and consolidated most maintenance staff and shops in that location. Many services had been spread throughout the facility in temporary buildings. The consolidation has improved internal communications among plant service groups. The building also contains dedicated space for specialized tasks, such as snubber testing, which previously were done outside the protected area. In general, the consolidation has enhanced maintenance activities, i l

At the beginning of the assessment period, there were more l than 2200 open non-outage MW0s. This number has gradually decreased, and at the end of the assessment period, was about 1200 indicating that the licensee is applying the necessary resources and effort to reduce the maintenance backlo The licensee has directed a great deal of attention to performing maintenance tasks in a timely manner. This is demonstrated by l the reduction in the percentage of MW0s that are more than 90 days old (from 65% to 40%) during the assessment period. In addition, 1870 of 1872 preventive maintenance activities were completed on schedul .

. Once the plant was operating, weaknesses were identified that inhibited the licensee's ability to perform maintenance activities in an optimcl fashion. The most significant weakness was a continuation of a :hronic shortage of spare parts. The licensee developed an onsite procurement staff to speed delivery of needed material that is not immediately available. Also, onsite stock was increased for some readily identified categories of materials. However, long-term progress in this area depends on the completion of the licensee's configuration management program, predictive maintenance program, and obsolete equipment upgrading program. The licensee expects to complete the long term programs by early 1990. Sustained commitment of resources is required for these programs to succee Overall staffing levels were adequate throughout the assessment period, although the licensee relied on heavy use of contract personnel. This was necessitated by the large backlog of maintenance work. Training is scheduled in advance, and all maintenance personnel are assioned to a training shift. When a shif t is in training, it 'is nc,t assigned any other work activitie Each shop h n a training foreman to help supervise and coordinate training, and workers are assigned to training councils to help ensure training is relevant to normal work assignment The licensee has established a "continuous service" maintenance policy, which ensures that a minimum maintenance crew is on site at all time This policy supports continuous work activities for the completion of any work that will restore safety equipment (required by Technical Specifications) to operability. In such cases, the H40s are kept in distinctit 2 folders that must be handcarried through the documentation cycle until the equipment is restored to operability. Management also controls such work by using detailed work planning charts. Such charts are also used for jobs that are complex or have been delayed in the pas The licensee has decreased reliance on "skill-of-the craft" maintenance by substantially increasing the number of procedure This approach has been applied to balance-of plant equipment as wil as to safety-related equipment. Management has been more vigilant in ensuring that procedures and properly reviewed vendor manuals are used in the conduct of maintenance activitie However, there have been inconsistencies in the use of field procedures and on occasion, management personnel have directed that work be performed without adherence to all relevant procedure .

. During the latter part of the assessment period, the plant j tripped from full power and several pieces of equipment failed during the event and the recovery period. As a result of the multiple equipment failures, an augmented inspection team was dispatched to the site to investigate the incident. The team found no major programmatic maintenance deficiencies. Restart was authorized with the provision that maintenance priorities be reassessed. The licensee reviewed its program and made only l minor changes in priorit '

Two additional team inspections were performed as a result of this tri An operational safety team focused on plant operations, but also identified two minor weaknesses in the ,

maintenance program. A maintenance team inspection focused on !

the material condition of the plant. This team walked down systems, reviewed outstanding MW0s, and interviewed personne The team concluded that the material condition of the plant was acceptabl It also concluded that the licensee's efforts since the June 9,1985 loss-of-feedwater event have resulted in a better functioring Maintenance Department aided by good planning and coordination and complete work package . Conclusion The licensee's performance is rated Category 2 in this functional area. The licensee's performance was rated a Category 3 during the SALP 4 perio . Board Recommendations Non D. Surveillance Analysis The licensee's performance in the functional area of surveillance was evaluated by considering the results of routine inspections conducted by the resident inspectors

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and portions of an inspection conducted by the operational safety tea No notices of violation were issued for the functional area of surveillance during this assessment period. A minor weakness was identified in that two local level instruments used for TS surveillance criteria were not included in a periodic calibration program. In the surveillance area, five events required the submittal of LERs; of these events, only one was caused by personnel erro The events were not of major safety significance, and in each case the licensee's corrective action was timely and appropriate. The aggressive action in regard to

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the Static-0-Ring (SOR) pressure switch failure is especially commendabl Not only did the licensee send personnel to the vendor's site, but it also suggested to and convinced the vendor to issue a 10 CFR Part 21 reoort on the failures. In addition, following the completion of satisfactory main steam isolation valve (MSIV) testing during the plant heatup, the licensee conducted additional testing beyond the scope of the surveillance test requirements to ensure the adequacy of MSIV operation. This additional testing identified discrepanctes in the operations of these valve The routine monthly and quarterly surveillance testing program is well managed by the licensee and management is strongly involved. A list of upcoming tests is published daily and discussed as necessary at the morning staff meeting. The list is divided by responsible organization and list the earliest date the surveillance can be performed, a desired date, and the latest date it can be done. It also provides a comment space

. for the explanation of any abnormalities such as why a test will be late. During the last 12 months of the assessment period (January 1 through December 31,1987),8903 Technical Specification surveillance tests were performed and none were late. Surveillance procedures are well written and provide adequate guidelines to technicians and operator A problem that the licensee had before the long outage was that not all Technical Specification surveillance requirements were incorporated into surveillance procedures. To correct this, the licensee began a Technical Specification Verification Program (TSVP) in May 1986. Phase I of the TSVP, completed before restart, verified that all Technical Specification surveillance requirements are specifically addressed by procedures. Phase II of the TSVP, scheduled to be completed in early 1989, includes a review of all remaining Technical Specification sections, a review of all other pertinent licensing documents (e.g., Updated Safety Analysis Report and Safety Evaluation Report), a detailed programmatic review of all Technical Specification implementing procedures, a field verification of surveillance tests and implementing procedures, and a review for clarity to be integrated with the NRC Technical Specification Improvement Progra Staffing in the surveillance area is ample. Many tests are conducted by licensed and unlicensed operators (SR0s, R0s, EOs, and A0s) who are assigned on a rotating basis to a training and test shif This provides a ready list of qualified people to conduct the tests, and helps maintain experience and familiarity with a system for these personnel when they are on an operating shif ,

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. Conclusion The licensee's performance is rated Category 1 in this functional area. The licensee's performance was rated Category 2 during the SALP 4 perio . Board Recommendations Non E. Fire Protection Analysis The licensee's performance in the functional area of fire protection was evaluated by considering one fire protection programmatic inspection of limited scope performed during the assessment period. Also considered were general inspections performed by the resident inspectors; these consisted of observations made during plant tour Enforcement history was not good. While no major violations were identified, five Severity Level IV violations were identified during this assessment period. One of these involved four examples of a license condition violation including a recurring problem regarding fire wrap integrity. An observation also was made during an unannounced fire drill that deficiencies existed in fire brigade leadership, fire brigade training, and adherence to plant emergency procedure Management involvement in assuring quality was mixed. Positive evidence was shown by its response to concerns raised to the Ombudsman that some contractor fire watches had falsified their time cards. Followup interviews by the Ombudsman revealed that some fire watches also had been observed sleeping on duty. The licensee therefore terminated the contractor and took aggressive action to correct many of the deficiencies which required the fire watches. This action resulted in reducing the total number of fire watches from 16 to 2, and both of these are TED personne However, closer supervision of the fire watch program could have prevented the problems from occurring in the first place. The licensee is also invest gating several instances of recent fire watch deficiencie The licensee's approach to resolving technical issues from a safety standpoint was generally adequate although during the programmatic review considerable discussion was devoted to concerns about potential enforcement actions rather than on corrective actions necessary to resolve identified deficiencie .

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Also, there were numerous nuisance alarms which plagued the facility and which may have led to complacency by the reactor operators. For uample, in one fire drill verbal instructions given to the plant operator by the control room operator to investigate o postulated fire appeared to express the need for only a non-emergency type of response. Plant staff indicated that this may have been a result of the complacency. The licensee is investigating the cause of the nuisance alarm Historically, the licensee paid insufficient attention to the requirements of 10 CFR 50, Appendix R, and as a result many of these requirements were insufficiently implemented at the start of the assessment period. The licensee expended a great deal of effort during the period to determine those actions which were necessary to meet the requirements. These efforts included inspection of approximately 13,000 fire barrier penetrations and 640 barriers, in addition to walking down all of the fi.re doors, fire dampers, fire detectors and suppression systems. Of the fire barrier penetrations, 2,500 were identified as requiring rework. The licensee has completed approximately 85% of this rework. Approximately 80% of the high-priority fire dampers were replaced during this assessment period. While these efforts are laudable, significant work remains in other areas before the licensee fully meets Appendix R requirement The licensee generally submits required reports of events in a timely manner. During this assessment period only one report was lata. This was an isolated case and was of minor safety significanc The licensee's fire protection staff was considered adequate although most of the staff were contractor personnel. This was necessitated by the amount of work necessary to bring the plant into compliance with fire watch and Appendix R requirement Early in the assessment period a key Fire Protection Engineering position was open but has been filled with a qualified individua The licensee significantly reduced the amount of scaffolding in the plant before restart. However, the amount of scaffolding increased as the assessment period progressed. This is not a good practice because, in addition to being a combustible hazard, the scaffolding also creates a potential sprinkler head spray pattern obstruction. During the programatic inspection an in-plant tour noted 8 of 14 areas having sprinkler systems installed in an area where sprinkler head spray patterns appeared to be obstructe These concerns are heightened if the scaffolding is allowed to be left in-place for extended period .

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With the exception of the scaffolding discussed above, the amount of combustible materials located-in the plant is minimal, and the licensee has been diligent in maintaining a low level of such material . Conclusion The licensee's performance is rated Category 3 in this are The licensee's performance was rated Category 3 during the SALP 4 perio . Board Recommendations Phile the Board recognizes that the licensee expended considerable resources in this area during the assessment period, much work remains to be completed before all of the Appendix R requirements are met. Implementation of the corrective actions must be improved. In view of this both the NRC and the licensee must continue to closely monitor these effort F. Emeroency Preparedness Analysis The licensee's performance in the functional area of emergency preparedness was evaluated by considering routine inspections conducted by the resident inspectors and three inspections (two routine and one exercise) conducted by regional inspectors. ,

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Enforcement history in the area of emergency preparedness was goo No violations were identified in this area during this assessment perio Management involvement in ensuring quality was very goo Nu weaknesses were identified during the 1987 exercise. The exercise scenario was challenging, and a great variety of objectives were successfully met. The majority of participants had not participated in the previous exercise. Tracking systems were effectively used to track corrective actions on drill and exercise critique items and independent audit findings. The licensee, in conjunction with State and county officials, provided emergency preparedness training to school officials and their staffs working within and near the emergency planning l zone. The licensee gave significant support to State and county officials in the development, training, and successful exercising of new and revised offsite emergency plans. The licensee has been working with these officials in addressing concerns expressed by an emergency evacuation review team in a January 1987 report to the Governor of Ohio,

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The licensee's approach to resolution of technicai issues from a safety standpoint was adequate. NRC concerns on revised emergency action levels were adequately addressed in a timely manner, as were procedural and equipment concerns regarding offsite agency notifications following an emergency declaratio Two unannounced off-hour staff augmentation drills were held during the .latter part of the assessment period to address concerns expressed by resident inspectors. Nonnally in these -

drills the emergency response personnel'do not report to the site but only acknowledge that they received a notification to'

repor In these two drills the emergency personnel actually responded to their emergency duty stations. Some problems were identified in the first drill which were corrected before the second drill. The licensee has procured three suitable vehicles for its field survey teams and has upgraded its public notification (siren) system with remote interrogation capability to improve system reliabilit Staffing and training of the licensee's emergency. organization were adequate on the basis of the performances during the 1987 exercise and a review of records. Training adequacy was also evidenced by the correct classification of actual emergency plan activations during this SALP period and by the timely ano adequate notification of offsite officials on these occasion The emergency planning staff grew substantially in numbers and expertise during the previous SALP period. Several changes to the staff's structure and methods of operation have increased its effectiveness during the present SALP period. However, the key positions of Emergency Planning Manager and lead Onsite Emergency Planner, plus several staff positions, became vacant during this SALP period. Licensee management promptly replaced both supervisors and does not plan to decremse the size or responsibilities of its emergency planning staf I Conclusion I

The licensee's perfcrmance is rated Category 2 with an !

improving trend in this area. The licensee's performance was i rated Category 3 during the SALP 4 perio l 1 Board Recommendations None, i

G. Security Analysis i

The licensee's performance in the functional area of security was evaluated by considering the results of one special and two routine inspections conducted by Region III security ;

inspectors and inspections by resident inspector '

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Although six violations (one Severity Level III, four Severity Level IV, and one Severity Level V) were identified in the area of security, none resulted in direct safety problems. Furthermore, once the violations were identified, they were promptly reported '

and appropriate imediate and long-term corrective actions were taken, thereby demonstrating management's support and commitment to ensuring the quality of the security program. Toward this ;

end, preventive actions should also be taken to ensure that such ;

violations do not recu '

The identified violations were notable because they were caused l when nonsecurity personnel violated security requirements. The Severity Level III violation involved penetrations of security barriers and the subsequent failure to adequately protect the l penetrations. Because of inaccessibility, some penetrations ,

existed as long as 45 days before they were identified by !

security personne l Management increased its involvement to ensure quality since ,

the SALP 4 period and is considered good. Management's support I of the security program was very notably demonstrated through ;

modifications of security equipment, such as completaly upgrading l a major alarm station, including a new computer system, and by !

the increased staffing of the security organization. Corporate !

and security management had recognized weaknesses in those two l areas and initiated comprehensive and timely action. Management i attempts to ensure quality through an excellent security information dissemination program to plant employee The program .

has heightened security awareness among most employees and has l resulted in increased reporting by nonsecurity personnel of I security infractions. Support was also evidenced by management's aggressive role in correcting most security violations. However, ;

continued corporate and plant management vigilance is required :

to reduce the frequency of access control violations caused by nonsecurity personne The licensee's approach to resolving technical issues is goo Its comprehensive and timely corrective actions in regard to

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specific security violations have demonstrated a sound grasp of the underlying security issue The licensee's responsiveness to NRC initiatives was goo Before this SALP reporting period (1986), NRC concerns and the licensee's analysis of its problems resulted in the installation of a new security computer system and the relocation of the protected area fence to provide a more reliable security syste The licensee's reporting of events was a strength, and demonstrated a definite improvement over the previous assessment period when 14 reports were issued, 2 of which were late. During the assessment period, the licensee reported 11 security event .

Of these, 5 were computer failures that occurred in a 90-day period and were corrected. The licensee kept Region Ill personnel well informed with timely and accurate report .

Staffing in the security area was ample. The structure of the security organization changed to satisfy company and regulatory security requirements more effectively. The department staff was expanded, and security officer staffing levels were increased. The changes have resulted in more effective program administration, improved communications, reduced overtime for the security force, and increased morale among officer Security force training has been c,ood, and improvements have been made in the effectiveness of the security organization since the previous assessment period. Although the program has not been reviewed in its entirety, the strong overall performance of the security force provided a gauge of the

. effectiveness of the training. None of the security violations were the result of deficiencies in security force trainin The improved reporting of events was, in part, the result of effective training, which enables security officers to better recognize security problem . Conclusion The licensee's performance is rated Category 1 in this are The licensee's performance was rated Category 2 during the SALP 4 perio . Board Recommendations Non Outages Analysis The licensee's performance in the functional area of outages was evaluated by considering the results of routine inspections conducted by the resident inspectors. No violations were identified in this functional are At the beginning of the assessment period, the licensee was completing the outage that began on June 9, 1985, and its efforts were directed toward restart of the reacto Uncompleted work was reviewed frequently to ensure that tasks required for restart were performed. This outage ended on December 22, 1986, when the reactor was restarted. One other significant outage (33 days for maintenance) occurred during the assessment period. In addition, one 11-day and two short (2-4 days) maintenance outages occurred during this perio .

_ _ . _ _ _ _ _ - _ . _ _ _ _ . _ _ . - - - _ _ _ _ _ _ _ - _ _ _ . _ _ - _ - - - _ _ . _ _ _ _ - _ _ - - - . - - - _ _ _ _ _ _ . - _ - _ _ . - _ _ _ _ _ - _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ - . _ _ - _ - - - -

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During the restart effort, the staff met weekly with the

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Senior Vice President-Nuclear, at which time significant restart and outage is3ues were discussed and individuals responsible for the work and the schedules were held accountabl Outages were well managed and received aggressive management attention. The licensee has an organization with ample staff dedicated to this effort that is headed by a General Superintendent for Outage and Program Management who reports to the Plant Manager. Work is planned, ranked, scheduled, and done according to the schedule, thus providing good work contro Although a planned maintenance outage was extended because of emergent work, effective management limited the length of the unplanned extensio So that resources are used optimally during forced outages, the licensee maintains lists of work that must be done during outages of various duration The licensee has scheduled a 6-month refueling outage commencing on March 11, 1988. It had been scheduled prior to this date but the outage planning group recognized that the Engineering Department could not support the original date and therefore rescheduled it. Planning and work scheduling appear to be adequate. The timeliness of engineering packages and the resultant availability of materials are areas that appear to need additional effor . Conclusion o

The licensee's performance is rated Category 1 in this functional area. This functional area was titled "Refueling" ,

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during the SALP 4 period, and the licensee's performance at that time was rated Category j Board Recommendations None, l j

1. Quality Programs and Administrative Controls Affecting Quality

Analysis The licensee's performance in the functional area of quality programs and administrative controls affecting quality is evaluated by assessing two related but separate area The first is the licensee's management activities aimed at achieving quality in overall plant operations. As such, strengths and weaknesses identified in other functional areas were reviewed to determine if common attributes could be identifie In addition, licensee initiatives to mainttin or improve the overall quality of operations were considere .

The second area is the effectiveness of the licensee's independent quality organizations. This includes the quality assurance organization as well as other organizations that independently review licensee activities to identify r,roblems for corrective action Overall management involvement in ensuring quality has been excellent, and management has been aggressive in solving problems. This is evidenced by the large expenditure of resources for such things as higher salaries, the new personnel shop facility building, spare parts, and a reactor control room simulator. Further evidence is the high level of support provided for NRC special inspections such as those for the dozing shift supervisor, and for the reliability of the auxiliary feedwater system. Another example is the licensee trip assessment team which was assembled shortly after the September 6, 1987, recctor trip. The team investigated and

, evaluated the causes of the trip and of the several equipment failures, conducted an excellent evaluation and provided timely assistance to the NRC augmented inspection team (AIT)

that was dispatched to the site shortly after the trip. In fact, because of its rapid investigation and evaluation, it saved the AIT considerable time in describing the sequence of events and equipment failures. There is every evidence that this management involvement will continu ,

,

The licensee has implemented many management controls to ensure I quality and to resolve technical issues from a safety standpoin Examples are the following:

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l A monthly nuclear group performance indicator repor :

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A weekly report listing performance indicators related to regulation *

Daily plan-of-the-day meetings during which problems, scheduled work, and status of required items are discussed and responsible individuals are held accountable for effort *

Weekly tours of the plant by division directors, during '

which general conditions and observations are recorde *

Backshift tours of the plant by operations and security managemen Planning and scheduling of work. Work is not released until needed material is availabl *

Weekly meetings with the vice president (alternating between directors and the staff). Current issues are discussed, including schedules, material, and staffin *

Improved communications with the NRC such as increased management and staff interactio .

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Despite the number of good management programs, a number of issues remained open at the end of the assessment period:

Operator morale The number of licensed SR0s in the Operations Department

Intraorganizational and interorganizational communication Implementation of the spare parts program Housekeeping in out-of-the-way areas Design engineering support Management / staff stability The licensee's independent quality oversight organizations was evaluated by considering routine inspections by the resident inspectors, three inspections by regional specialists, and-several team inspections. Enforcement history in this area was excellent (no violations were identified).

The licensee has shown several strengths in this area:

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QA has become more assertive with regard to accepting corrective actions for Potential Conditions Adverse to Quality (PCAQs),

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the technical knowledge of QA audit teams has improved substantially through auditor qualification and increased use of consultants and loan personnel as technical specialists,

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corrective action programs in general are administratively I well founded to identify, track, and correct a wide range l of problem j l

After discussions with the NRC, the licensee increased the l number of quality assurance (QA) field observations so that '

more activities could be reviewed than under an audit program alone. A program also was initiated s' reduce the nun. Jr of open audit finding reports including taking actions to close the oldest of such reports. Both efforts have been. effectiv The QA organization has been aggressive in assisting engineering and other plant personnel by sending inspectors to vendors'

facilities to observe testing. Staffing is adequate in this are ,

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During the SALP 5 assessment period, the licensee consolidated multiple deficiency-reporting programs into one Potential Condition Adverse to Quality (PCAQ) Program. This program has several advantages over the earlier programs. It ensures that the shift supervisor is aware of deficiencies soon after they are identified. PCAQ reports are reviewed for reportability

,

daily; corrective actions are assigned; and the reports are tracked to ensure corrective actions are timely. Although the program is evolving and has been revised, it appears to be successful because deficiencies are generally identified, reported, and corrected-in a timely manner. However, the number of open PCAQ reports is increasing and this trend needs to t e reverse . Conclusion The licensee's performance is rated Category 2 in this functional area. The licensee's performance was rated Category 3 during the SALP 4 perio . Board Recommendations Non J. T. airing and Qualification Effectiveness Analysis The licensee's performance in the functional aras of training y-and qualification effectiveness was evaluated by considering, one inspection specifically related to training conducted  ;

during this assessment period. This functional area was als) '

i evaluated by considering the resident inapectors' and regional  !

inspectors' observations and review of plant activities and events related to the training and qualifications of personnel; involved. No violations were identified in the area of training and qualification effectivenes Observations and review of plant activities and events indicated ? ;

that personnel were properly trained and oualified and that '

!

LERs involving personnel errors were not due to programmatic s  !

deficiencies in the training progru In addition, a training '

program for 10 CFR 50.59 evaluations,' developed by the Independent l Safety Evaluation Group, appears to bc excellen , i The licensee's responsivi: ness to NRC initiatives has been adequate. Although the licensee uses an offsite simulator for operator training, it began a praject in August 1986, to build a plant-specific simulator on sit The project is on schedule and the simulator is expected to be ready for training in "g May 198 (N , -

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. The licensee has implemented a new, rather comprehensive training program for the Chemistry Department and the Health Physics Department. The program was accredited by the Institute of Nuclear Power Operations (INP0) and will provide ongoing training. This program will involve up to 20% of available work hcurs for those with the least experience and trainin The training includes selected plant systems and _a Qual Card program. Extra staffing is being provided to etcommodate the training program. The separation of the chemistry and health physics groups required an intensive program to qualify radiological control and chemistry testers in order to provide coverage nn all shift Training facilities include well-equipped laboratories for maintenance, chemistry, and health physics training. The licensee uses a training-shift concept for maintenance and operations personnel to ensure that personnel are available for scheduled training. Under this concept, one maintenance shift is always in trainin The maintenance staff has assigned a training foreman for each discipline to coordinate and supervise personnel in training. Training councils have been established to provide technicians an opportunity to suggest modifications to the training program based on their :

fields of kncwledge or needs. For the operations personnel, I the fifth shift is used for surveillance testing and trainin The training staff is adequate and includes several experienced maintenance technicians, unlicensed operators, and licensed operators. This is a substantial improvement from the SALP ano assessment perio ss u The licensee has received INP0 accreditation for all recognized training programs and is certified as a full member of the National Academy for Nuclear Trainin len cenior reactor operator (SRO) and six reactor operator i> (RO) candidates took license examinations during the assessment

, period. Of, the cantiidates 75% received ooerator licenses; two s candidam 'in each group were not successful. Indicative of

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, the rnponsiveness to plant problems, the training department has plans to have 14 SRO and 2 RO candidates take the next license exwination in May 1988, and approximately 10 SRO candidates take the exam in Augus+ 1988. The additional licensed SR0s will gin tne licenseo more flexibility in its str W ng. . ConcluAirs The licensee's i.erformance is ratec' Category 2 in this functional arec.' The licerroe's performance was rated

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Category'.b6 bring SALP 4 perio , 8

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• Board Recommendations Non . Engineering / Technical Support A'ialysis The licensee's performance in the functional area of engineering / technic 31 support was evaluated by considering the results of routine inspections conducted by the resident inspectors cnd three inspections conducted by a regional ir.w eeto The three inspections conducted by the regional inspector were performed to follow-up concerns raised in previous assessment periods on the licensee's response to NRC Office of inspection and Enforcement (IE) Eulletin 79-14, "Seismic Analysis for As-Built Safety-Related Piping Systems." Licensee efforts in this area were generally thorough and effective. During the assessment period, the licensee continued to improve its engineering capabilities and was aggressive in identifying problems in regard to work performed in its first attempt to respond to IE Bulletin 79-14. The licensee approached the analysis of identified hardware and design deficiencies in a well-organized manne The licensee is in the process of decreasing its dependence on architect and engineering (A&E) technical support and, as a result, has doubled its engineering staff since June 9, 198 The transition caused some design engineering work to be delayed, especially as it relates to course-of-action (C0A) comitments and to the System Review and Test Program (SRTP).

A few chronic problems that exist in the engineering / design area appear on the surface to be maintenance problems. One is the problem with leaking steam admission valves on the at,xiliary feedwater system and another is the problem with SOR pressure .

switches. The licensee is taking adequate corrective measeres i in regard to these issues until permanent design changes can be )

made. Furthermore, especially in the case of the 50R switches, '

the licensee has taken aagressive corrective actions and sent j three employees to the vendor's factory to discuss the failure i mechanism and to observe switch disassembly and testing of similar unit Two examples of insufficient engineering review were apparent l during the assessment period. A butterfly valve was not functioning as designed, and the licensee did not have spare parts to repair i The temporary engineering solution was l to rotate the valve body. The valve still did not function i properly because the engineers apparently did not understand i the effects of the dynamic forces on the disc. Another !

28

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example was the modificatiori to alleviate a pressure buildup in a low pressure system caused by a leaking check valve. The licensee failed to account for the effects of nitrogen that comes out of solution when the coolant's pressure is reduce On the positive side, the licensee appointed a task force to determine the failure mechanisms involved in the sten, of the main stear. safety valve. Originally it was believed that the failure mechanism was material failure. The task force concluded that the stem bent because the stem forces were greater than accounted for in the design and the forces were not halance The licensee also appointed a task force to study air-operated valves during the assessment perio The Engineering Division is divided into four principal groups:

system engineering; performance engineering; nuclear engineering; and desigr, engineering. Configuration management and tire protection projects also are the responsibility of the Engineering Divisio The systems engineering group is responsible for providing day-to~ day engineering support for the plant. Early in the assessment period, this group moved to new offices adjacent to the plant, thus making it easier for the engineers to become involved with p ant operation on a daily basis. The performance of this group has improved during the assessment period. The plant personnel rece:ve full support in solving technical problem Configuration management was a major engineering activity during the assessment period, and the results of this activity are goo The predominant activities were verification of vendor technical manuals, development of system descriptions, assembly of an equipment data base, and development of operational schematic diagrams. Physical wglkdowns of systems were performed to cLtain and verify data. The walkdowns were completed during the assessment period, and the remaining effort is scheduled to be completed by the end of the next assessment period. At the completion of this effort, the licensee will have an accurate graphic and written description of the as-built condition of the plant. A computerized listing of all documentation affecting hardware will be maintained. This will ensure that any hardware changes will be reflected in the applicable documentation. The licensee's efforts in this area should result in better control of plant equipmen The design engineering group has the largest backlog of work because of COA commitments, changes required by the (RTP, and previously ccmpleted modifications that had not been closed ou The changes offected by this backlog of work will be implemented by the end of the sixth refueling outage. The group's effort to reduc 4 the back ag and the progress it has made are good, but the amount of work as well as the routine design changes required to support the plant has placed a large burden on this grou This large backlog delayed the initiation of the fifth refueling outag )

. .

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, Management problems at the beginning of the assessment period l were numerous in the design engineering area. For example, work was not always placed in p*iority order, the support provided to meet pla?t operational needs was weak, and there were occasional failures to meet schedules. These problems appear to have been caused by managers who lacked sufficient operarional experience, and by a constant change in managenient personnel. There were three design engineering directors during the assessment period, two of whom were contractors. Furthermore, many of the design engineering managers below the director level also were contractors. Changes made during the period, however, appear to have improved the situ: tion although it is too soon to make a firm determination. These changes involved appointment of a TED employee as director of the design engineering group and replacement of all but two contractor personnel by TED personnel as design engitieering manager The restructuring of the organization during the assessment period by the addition of a Design Engineering Manager with a strong design management background enabler the head of the Department to deal more effectively with administrative duties. This change occurred near the end of the assessment period but appears to be effective. The establishment of an Engineering Services Depar tment during the latter part of the assessment period should ensure that tne Engineering Division has better control over ;ts commitments and wor Early in the assessment period, the NRC identified, and the licensee recognized, weaknesses in the areas of engineering analyses and root-cause analyse During the assessment period, the licensee took significant actions to correct the weaknesses; improvement in these areas has been significan The licensee developed a training course on root-cause ;

analysis that may be beneficial to other licensee The licensee also improved procedures and standards for l performing 10 CFR 50.59 evaluations. The procedures require that peuple who prepare evaluations be formally trained and qualifie Qualification is based on the results of a written i examination. An audit., conducted by an NRC Project Manager, l revealed that 10 CFR 50.59 evaluations generally are of high

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quality, l

Epineering personnel also have supported licensing activities by i preparing high-quality submittals and understanding operational I event J l

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• Conclusion The licensee's performance is rated Category 2 in this functional area. The licensee's performance was not rated in this area during the SALP 4 perio . Board Recommendations Non L. Licensing Activities Analysis The licensee's performance in the functional area of licensing activities was evaluated by considering the following activities during the assessment period: the submittal of more than 16 license applications, a Commission briefing, plant restart effcrts, followup of an allegation that a licensed operator slept onshift, and actions in regard to several other plant-specific and generic issues requir ng NRC review and approva i Specific licensing actions considered in this evaluation are identified in Section V, "Supporting Data and Summaries."

Management involvement in ensuring quality in this area was extensive and included substantial personal participation by top management officials in several major activitie The most notable examples of top-management involvement are the Commission meeting of November 21, 1986, to authorize restart; the licensee's efforts leading directly to restart of the unit in late December 1986; and the addressing of the issuas raised by the Governor of Ohio (and the Governor's emergency evacuation review team) as a result of the Chernobyl j acciden With respect to license applications, a steady improvement j in the quality cf the sifety evaluations and no significant 1 hazards consideration analyses has been noted for the perio Previously, the presentations were of poor quality and difficult to understand; the submittals are now clear, thus making it easier for the NRC staff to review them. Especially ,

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notable in this respect is the application submitted on October 9, 1987 requesting extencion of the date then the

emergency diesel generator surveillance was due. This application was outstanding in the quality and amount of detail provided to support the request. In the past, such i applications frequently were not conservativ ,

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Another area in which significant improvement has occurred is the communication of information on plant events to the NRC Prcject Manager. Previously, considerable time elapsed before the licensee's licensing personnel provided this information to the NRC Project Manage The licensee's approach to the resolution of technical issues from a safety standpoint was generally very good and a steady and significant improvement in this area has been noted since the SALP 4 perio The licensee has maintained close communications with the NRC staff on significant safety issues at Davis-Besse such as fire protection and enhancement of feed-and-bleed capabilit The licensee has been responsive to NRC initiative Information required to be submitted before restart of the plant was submitted in a timely manner and the technical content was adequate to support an NRC decision to permit restart without unnecessary delay. After restart, several required license amendment applications and special studies identified in the restart safety evaluation report were submitted on or before the dates specified by the NRC staf The staff is reviewing submittal The Technical Specificatic.is for the motor driven feedpump, which had been issued, were fully responsive to the staff's requirement The licensee has sionificantly improved communications with the staff with regard to the operational status of the plant, including operational events as mentioned previously. A daily plant status report is telecopied to the NRC Project Manager each morning, alerting him to any developing issues that may need followup actio While preparing for an audit of 10 CFR 50.59 evaluations, the NRC Project Manager discovered that the licensee had not been preparing and submitting an annual report summarizing changes made pursuant to 10 CFR 50.59 as required by the regulation A notice of violation (Severity Level V) was issued. Another audit, recently completed by the Project Manager on this same issue, revealed that the licensee has revised the procedure for preparing such evaluations to provide for the annual repor The latest report was submitted on July 31, 1987. The report is timed to coincide with the annuel revision of the Updated Safety Analyses Report (USAR) and covers the c.hanges discussed in the USAR revision. No other violations were identified in this functional are ,

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~The licensee substantially has increased the permanent staffing of the Licensing Department since the event of June 9, 1985, and the present size and quality of the department appear to be sufficient to maintain an ample level of performance. The impraved staffing has resulted in improved quality and timeliness of submittals. Also, during the assessment period, the previous Licensing Manager resigned. He was replaced by a new employee who spent a two week overlap period with the former manage There has been no observed detrimental affect on licensing submittal . Conclusion The licensee's performance is rated Category 2 in this functional area. The licensee's performance was rated Category 2 during the SALP 4 perio . Board Recommendations None,

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, V. SUPPORTING DATA AND SUMMARIES Licensee Activities The assessment period at Davis-Besse began while the ' plant was in a maintenance outage following the loss-of-feedwater event of June 9, 1985. The licensee continued its corrective actics ind system upgrades. On Decemoer 3, 1986, preparations for reactor restart began as Davis-Besse entered Mode 4. The reactor became critical on December 22, 1986. During the remainder of the assessment period, power was slowly increased, followed by routine power operatien for extended periods except for a few short outages and power reduction Significant outages / major events that occurred during this assessment period are summarized belo Significant Outages / Major Events December 22-26, 1986 - On December 22, 1986, the reactor became critical, but it tripped because the water level in one steam generator was low. On December 24, the reactor became critical again and the generator was synchroni:ed to the grid marking the completion of the unit outage that began on June 9, 198 The generator output breaker then tripped because of an improperly installed negative phase sequerae trip device. On December 25, the generator was synchronized to the grid. On December 26, the generator was taken off the line so that a main turbine control valve could be repaired.- After these repairs were completed, the generator was again synchronized to the grid, January 1-3, 1987 - The reactor tripped because of a main feedwater pump failure and remained shut down untii recair$

were completed on the main feedwater pump turbin . March 13-17, 1987 - The reactor tripped when feedwater flow to one steam generator was lost. The unit was restarted af ter a leaking main steam safety valve was replace . March 20, 1987 - The plant operated at 100', power for the first time since March 198 . May 8-June 14, 1987 - The unit was shut down so that leaking presturizer valves could be repaired and other maintenance could be don Significant outage activities included replacement of pressurizer code safety valves, Valve RC-11 (isolation valve for the power-operated relief valve), all four reactor coolant pump seals, and the bearing on the No. 2 auxiliary feed pump. Tne motor-driven feedwater pump, core flood che k Valve CF-30, and six turbine bypass valv.,

were repaire l -

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. August 21-23, 1987 - The reactor tripped after lightning struck a transmission line in the gri It was restarted after personnel investigated the insident and made the necessary repair . September 6-16, 1987 - The reactor tripped after a feedwater flow transmitter failed. It was restarted after personnel investigated several unrelated equipment failures and made the n.ecesthry repair . December 7>9, 1987 - The teactor tripped as a result of low instrument air pressure, It was restarted after personnel investigated the incident and made the necessary repair Seven rasctor trips were reported during this assessment; of these six occurred at more ?.han 15fs power and one occurred with no rod movemen Five of the seven trips were due to personnel errors r pror? dural ir. adequacies anti two trips were due to mechanical / component problems. The piant experienced nine engineered safety feature actuations during the assessment perio Inspection Act:vities During this assessment period, 30 inspection reports were issue Major or significant inspection activities are listed below in Paragraph 2, "Special Inspection Summary." Inspection Data Facility Name: Davis-Pesse Docket No: 50-346 Inspection Reports No: 86022, 86027, 86030, 86032, 86033,

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87002, 87004 through 87011, 87013 through 87018, 87021 ,

through 87028, 87030, and 8703 !

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Table 1 Number of Violations for Each Severity Level Functional Areac I II III IV V 1 Plant Operations 1* 4 1 l Radiological Controls  ; Maintenance 2  ; Surveillance '

1. Fire Protection 5 Emergency Preparedness Security 1 4 1 4 Outages Quality Program and Administrative Controls l Affecting Quality

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. Training and Qualification Effectiveness Engineering / Technical Support .

L, Licensing Activities 1

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III IV V TOTALS 2 T3 3

• This Severity level III violation was identified during 1985, and the notice of violation was issued during this SALP perio . Special Inspection Summary A team inspection was c',nducted December 1, 1986 through Janua ry 31, 1987 to review the course-of-action (COA)

program startup activities, the ombudsman program, and training and operational safety items (Inspection Report .

No. 346/86032). The licenseo participated in its annual emergency preparedness exercise witn the State and local organizations on April 30, 1987. NRC representatives observed these activities, An augmented inspection team (AIT) inspection was conducted September 8-11, 1987 to review the circumsta.nces related to the reacter trip and subsequent equipment probiems that occurred on September 6, 1987 (Inspection Report No. 346/87025). An operational safety team inspection was conducted September 28 through October 9, 1987 to exacine and review activities relating to piant operations, maintenance, surveillance and testing, safety, quality assurance, a corrective action being taken (Inspection Report' i N]. 346/87024). l

, Ar, NRC team inspection was conducted on October 5 and 6, 1987 to examine and review activities and records relating to the operation and reliability of the auxiliary feedwater pump turbines (Inspection Report No. 346/87031). A maintenince team inspection was conducted November 2-6, 1987 to examine the material condition of the plant by performing system walkdowns, examining records, and interviewing personnel (Inspection Report No. 346/8/030).

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C. Investigations or Allegations Review  ;

During this SALP period,14 allegations were identified and 7 allegations were closed out. One allegation made in a previous SALP assessment period was also closed out during this assessment period.

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. D. Escalated Enforcement Actions Notices of a Severity Level I and two Severity Level III

[ violations and a civil penalty for $450,00t were issued during '

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the previous assessment period for circumstances related to

- the June 9, 1985 loss-of-feedwcter event. The licensee paid the mitigated civil penalty on March 14, 1987 (Inspection Report No. 346/85030, Enforcement Cass No. EA-85-107). , Notice of a Severity Level III vio!ation r.nd a mitigated civil penalty in the amount of $25,000 were issued to the licensee on December 15, 1987 for f ailure to maintain the integrity Li a vital area barrier. The licensee paid the civil penalty on January 18, 1988 (Inspection Report Ne. 346/87028, ;

Enforcement Case No. EA-87-219, and Enforcement Notice i

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No. EN-87-106).

E. Licensee Conferences He,1d Ouring Assessment Period November 18, 1986, site - A management meeting was conducted with licensee representatives to review and discuss the 3tatus of major issues and plant readinass for restar . February 27, 1987, regional office - A nanagement meeting-was ccnducted with licensee representatives to discuss the corrective actions for interdepartmental communication problems and the lack of plant awareness (desc*'hed as c lack of attention to details). l June 15, 1977, regional office - A special mi.iagement meeting was conducted eith licensee representatives to discuss organizational :hanges~at Centerior and their effect on Davis-Bess . June 16, 1987, regional office - A management meet'ng was conducted with licenset representatives to dir:'iss the status of the plant and its modification . July 21, 1987, regional office - A management meeting was

conducted with licensee representatives to discuss the changes cnd improvements to the Davis-Besse quality assurance progra . July 30, 1987, site - A tour of the facility and a management meeting was conducted with licensee representatives to di? cuss Davis-Besse's performance enhancement program.

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. 7 August 26, 1987, regional office - A management me_eting wa? conducted with licensee representatives to discuss the licensee's proposal for an unshielded technicai support center (TSC) to be built within the protected are . August 28, 1987, regional office - A management meeting was conducted with licensee representatives to discuss shift management concepts at the plan . September 15, 1987, headquarters - A major managerrent meeting was conducted with licensee representatives, regional management, and other NRC representatives to discuss the issues relatina to the startup of the

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Davis-8 esse Nuclear Power Station and C0A coamitments in regard to the events related to the reactor trip on September 6, 198 . November 13, 1987, headquarters - To review tha licensee's planned work for the fifth refueling outage and the need to reprinritire certain program . November 19, 1097, regional office - An enforcement conference was held with licensee representatives to discuss the incident during which physical security barriers were inadvertently breached (Enforcement Case No. EA 87-219).

12. December 4, 1987, site - A management meeting was conducted with licensee representatives to review operational activities at the facilit . December 12, 1987, regional office - A management meeting was conducted with licensee representatives to discurs general topics related to plant operations at Davis-Bess Confirmatory Action Letters (CALs)

A CAL was issued to the licensee on September 9, 1987. The letter I confirmed a telephone conversation of September 8, 1987, concerning restart from the reactor trip and subsequent equipment malfunctions ,

en September 6, 1987. It confirined licensee commitments to l determine the causes of the event, take appropriate corrective actions, and evaluate its emergency procedures immediately. An s

augmented inspection team investigation was activated at that tim i

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G. A Review of Licensee Events Reports and 10 CFR 21 Reports Submitted by the Licensee CFR 21 Reports No 10 CFR 21 reports were issued by the licensee for Davis-Besse during this assessment perio , Licensee Event Reports (LERs)

Facility Name: Davis-Besse Docket Number: 50-346 LER Numbers : 86043, 87001 through 87015,87501(security),

and 87V00 (voluntary report).

Sixteen LERs were written for event; that occurred during this assessment period. An analysis and event.cause comparisons are shown in Table 2 below:

TABLE 2 Event Cause Comoarisons Basic Causes SALP 4 SALP 6 Personnel Errors 18%(13 63%(10 ;

Procedure Inadequacies 4% (3 12% (2 Equipment / Component 45%(32 12% (2 Design Discrepancies 23%(16) 6% (1 External 3% 6% 1 Other 7% 0% 0 Totals 100%(71) 100%*(16)

• Numbers do not equal 100, due to rour. din LERs were issued during this assessment period at a rate !

of 1.3 LERs per month, a large decrease from 4.1 LERs per I

, month during the SALP 4 assessment perio Note: The LER information in this Section was derived from a review of LERs performed by NRC Staff and may, or may not completely coincide with the licensee's single approximate

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cause assignments. In addition, the table is based on assigning one cause code for each LER and may not correspond to a

the identification of LERs addressed in the Performance Analysis Section (Section IV) where multiple cause codes may be assigned to each event.

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H. Licensing Activities Site Visits and Meetings .

March 19, 1987 Meeting with Information Management staff to discuss optical storage of record March 31, 1987 Observe various aspects of annual EP dril Visited Lucas and Ottawa County EOC with representative of the Attorney General (Ohio).

April 23,1987 Meet with licensee's Vice President, Nuclear to discuss plant status and schedules (at Bethesda).

April 29-30, 1987 Attend public meetings by Governor's task

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force and FEMA E June 16, 1987 Discuss with corporate management plant status and outage schedule (at Region III).

June 24, 1987 Initiate audit of 10 CFR 50.59 evaluations and discussions relating to licensing action statu June 26, 1987 Discussions with corporate management related to plant status and schedules (atBethesda).

July 27-29, 1987 Human Factors review of operator morale and environmental conditions in control room are Complete 1.0 CFR 50.59 revie October 5-9, 1987 Special AFW reliability assessment / inspectio . Commission Meetings l November 21, 1986 Review plant status and decision on I authorization for restar l Schedule Extensions None requeste . Exemptions Granted  !

l Eleven requests for technical exemptions for fire protection l pending revie l

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r

. 5. License Amt.,e.nents Issued

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Amendment No. 96, Revised AFW system surveillance December 22, 1986 requirement Amendment No. 97 Revised EDG surveillance February 10, 1987 requirements to reduce cold, fast start Amendment No. 98 Revised CNRB reporting and February 18, 1987 advising relationships and revised some organizational titles.

Amendment No. 99 Revised CNRB membership February 19, 1987 qualification ,

Amendment No. 100 Revised station battery March 12, 1987 surveillance requirement Amendment No. 101 Corrected a clerical erro March 16, 1987 Amendnent Mo. 102 Reduced to three (from four)

April 3, 1987 the number of EDG load sequencers l required to be operabl j i

Amendment No. 103 Added requirements for the l September 2, 1987 motor-driven feed pum Amendment No. 104 Revised reporting requirements September 8, 1987 for iodine spikes in the reactor e.colan '

Amendment No. 105 Extended surveillance due date i December 8, 1987 for ac source . Emergency / Exigent Technical Specifications ,

, l Amendment No. 102 Decreased the number of EDG load 1 April 3,1987 sequencers required to ba l operable. Required to correct an error in the specification . Orders  !

! None issue !

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