IR 05000346/1987004

Insp Rept 50-346/87-04 on 870201-0331.Violations Noted: Failure to Follow Tech Spec Action Statement & Failure to Provide Regulatory Required Rept

ML20214F279
Person / Time
Site:	Davis Besse
Issue date:	05/08/1987
From:	Defayette R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20214F265	List: IR 05000346/1987004 ML20214F262 ML20214F270
References
TASK-2.E.1.1, TASK-2.F.2, TASK-TM 50-346-87-04, 50-346-87-4, IEB-85-001, IEB-85-1, IEB-86-003, IEB-86-3, NUDOCS 8705260014
Download: ML20214F279 (16)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-346/87004(DRP)

Docket No. 50-346 Operating License No. NPF-3 Licensee: Toledo Edison Company Edison Plaza, 300 Madison Avenue Toledo, OH 43652

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Facility Name: Davis-Besse 1 , ,

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Inspection At: Oak Harbor, Ohio o

Inspection Conducted: February 1 through March 31, 1987 f

Inspectors: P. M. Byron

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D. C. Kosloff P. R. W h1 Approved By: e aye , ief // If ReactorProjectsSection Date'

i Inspection Summary ,

Inspection on February 1 through March 31, 1987 (Report No. 50-346/87b04(DRP))

Areas Inspected: Routine, unannounced inspection by resident inspectors of licensee action on previous inspection findings, operational safety, onsite followup of events, maintenanco, surveillance, Licenspo Fvent Re,norts, bulletins, plant trips, TMI items, fire protection, independent safety review, followup of performance enhancement program, quality assurance emergency preparedness, followup of Regional request, management meetin,g Results: Of the 16 areas inspected, no violations or deviations were identified in 14 areas. Two violations were identified in the areas of operational safety (failure to follow technical specification action statement, Paragraph 3) and quality assurance (failure to provide regulatory required report, Paragraph 14).

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8705260014 870508 .

PDR ADOCK 05000346 G PDR

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i l.- cPersons Contacted-

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. ToledolEdison Company

'+DD Shelton,lVice President, Nuclear -

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D. Amerine,: Assistant:Vice President, Nuclear

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'+*L.. Storz,~ Plant Manager

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+S.iSmith,--Assistant P.lant Manager,-Maintenance-

- . Jain, Independent Safety Engineering Director: >

W. O' Conner, Staff Consultant

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+*R.- Flood - Acting Assistant Plant' Manager, Operations +*E..Salowltz,GeneralSuperintendent,OutageandProgramManagement'

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2+*L. Ramsett, Quality-Assurance Director M.~' Stewart, Nuclear-Training Director i

• P. Hildebrandt, Engineering General' Director

+J.. Wood, Nuclear Plant Systems Director R.~ Cook, Acting Compliance Supervisor

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+ Honma, Compliance Supervisor

- B. Carrick, Design Engineering Director

7 g- +D.'Haiman, Nuclear Engineering General' Manager

[ ., < +*J.'Dillich, Technical Support, Engineering

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-J. Miller, Technical Support, Engineering- '

!, F. Swanger, Operations

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D. Stephenson,-Senior' Licensing Specialist

+L. Young,~ Licensing, Fire Protection-

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J. Haverly, Fire Protection

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+J. -Moyers, Quality Verification Manager

+*D. Briden, Chemistry and Health Physics General Superintendent

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S. Zunk O l D. Harris,mbudsmanManager Quality Systems

, +*J. Sturdavant, Licensing Principal s.

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l +*P. Byron, Senior Resident Inspector

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+*n, Kosloff, Resident Inspect e -

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• Denotes those. personnel attending the March 3, 1987, exit meeting.-

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4 Den'utes thosF personnel attending the April 3,, 1987, exit meeting.-

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2.' Licensee Action on Previous Inspection Findinas i

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a'. ..(Closed)UnrosolvedItem(346k5022-07): Valve MS106 wiring and f .,j torq0e switch problem! The licensee has successfully completed' J

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trouble shoottag'and correctin

jDifferentialprassuretesting,gwiringproblemsidentified., unction with the use of con;valve 4- diagnostic test aquipment,' has'slown that the valve torque switch'

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settings were cortect;- however, due to a' mechanical imbalance j' condition of.the saitch, the thrust developed at torque' switch trip

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was inadequate for closure of this valve at design differential pressur The licensee submitted a 10 CFR 21 deficiency repart on this finding February 3, 1987, indicating that the concern is generic with Limitorque valve operators. Final corrective action, using diagnostic test equipment, has been implemented to assure that MS106 sis operable, including the capability to close against full design differential pressure. This item is closed, (Closed) Open Item (346/85025-07): Motor operated valve (MOV)

closure thrust capability. The licensee has completed its evaluation of closure requirements and valve operator ca) abilities for all safety-related M0V's. Corrective action has aeen completed to assure that the valves will close when require The total effort involved wa:, much more ccmplex than expected at -

the beginning of the licensee's M0V Reliability Improvement Testing Program. "As-found" closure thrust was sometimes too high, exceeding

, either the valve or valve operator stress limits, or bot Sometimes the thrust was too low. Corrective actions involved an engineering

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evaluation of all aspects of valve programs from purchase requisition to maintenance and repair activities. Changes were made, as necessary, resulting in solutions individually determined and implemented for each valv Diagnostic testing and evaluation of the data for each valve

"as-left" has been completed by the licensee and has shown that all safety-related M0V's are now operable and capable of performing as designed. This item is close (Closed)OpenItem1346/85025-08): Post maintelance and surveillance testing, program development. This item is closed based on the inspection activities reported in Inspection Report No. 50-346/86032(DRP), paragraph 3, Items aa. (7), (8), and (13)

through (17). (Closed) Open Iten (346/85025-09): Completion of valve differential pressure testing. The licensee has completed its commitment for M0V differential pressure testin Problems identified by this testing have been corrected and all valves tested have now been shown capable of operation as require This item is closed No violations or deviations were identifie . Operational Safety Verification The inspectors observed control room operations, reviewed applicable logs and conducted discussions with control room operators during the months of February and Marc The inspectors verified the operabiiity of selected emergency systems, reviewed tagout records and verified proper return to service of affected components.

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Tours of the auxiliary, turbine, water treatment, and service water purgp buildings were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks, and excessive vibrations and to verify that maintenance requests had been initiated for equipment in need of maintenance. The inspectors by observation and direct interview verified that the physical security plan was being implemented in accordance with the station security pla The inspectors observed plant housekeeping and cleanliness conditions and verified implementation of radiation protection control The. inspectors found that plant housekeeping and cleanliness has improve However, the inspectors have occasionally found areas which fall short of the licensee's standards. Such areas are reported to the licensee and the conditions are quickly remedied. During the months of February and March, the inspector walked down the accessible portions of the Component Cooling Water (CCW) and Control Room Emergency Ventilation (CREV) systems to verify operabilit These reviews and observations were conducted to verify that facility operations were in conformance with the requirements established under technical specifications, 10 CFR, and administrative procedure On March 27, 1987, during the walkdown of the Control Room Emergency Ventilation (CREV) system, the inspectors found the airflow control damper partially closed. The Shift Supervisor was informed and he declared the system inoperable. The redundant CREV system was operabl Later that day the damper was opened and the system was successfully tested and declared operable. This will remain an unresolved item (346/87004-01(DRP) until the inspectors review the licensee's determination of the root cause of the improperly positioned dampe The Assistant Plant Manager-Maintenance and the Assistant Plant Manager-0perations met with the inspectors on February 10, 1987, to discuss the operational problems identified in Inspection Report No. 50-346/86032(DRP) and other similar event The licensee discussed its perception of the problems and its proposed corrective action. The inspectors discussed several of their observations with the license It appeared that poor communications between maintenance and operations was one of the largest. contributors. The licensee proposed that the continuous duty maintenance foreman attend the shift turnover briefing and in addition, tour the plant with the shift superviso The inspectors consider that this proposed change will improve communications between the two organization On March 25, 1987 with the plant operating at 100% power (Mode 1), the licensee took Emergency Diesel Generator (EDG) 1-1 out of service for maintenance at 7:20 a.m.. Technical Specification (TS) 3.8.1.1. requires that as a minimum two independent circuits between the offsite transmission network and the onsite class 1E distribution system and two-separate and independent diesel generators be operable. This requirement is applicable for Modes 1 through . . _

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Action Statement a. for TS 3.8.1.1. requires that with either an offsite circuit or diesel generator inoperable the operability of the remaining AC sources be demonstrated by performing Surveillance Requirement (SR) 4.8.1.1.1.a. within one hour and at least once per eight hours thereafter and by performing SR 4.8.1.1.2.a.4: within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. SR 4.8.1.1. requires that the offsite power sources be determined operable by verifying circuit breaker alignments and indicated power availabilit SR 4.8.1.1.2.a.4. requires that each diesel generator be demonstrated operable by verifying the diesel starts and accelerates to 900 rp EDG 1-2 was demonstrated to be operable in accordance with SR 4.8.1.1.2. at 1:00 p.m. The licensee demonstrated the operability of the offsite AC power sources by performing SR 4.8.1.1.1.a. at 7:45 a.m. on March 25, 198 The surveillance should have been reperformed at 3:45 p.m. on March 25, 1987. The surveillance was performed at 7:20 p.m. on March 25, 1987, three hours and thirty five minutes after the required tim The oncoming shift noted at 7:10 p.m. that SR 4.8.1.1.1.a. had not been reperformed. The surveillance was completed at 7:20 p.m. and both offsite AC sources were demonstrated to be operable. The shift supervisor issued Potential Condition Adverse to Quality (PCAQ)87-170 documenting the missed surveillanc TS 4.0.2. requires that a surveillance requirement be performed within the specified time interval with a maximum extension not to exceed 25%

of the surveillance interval. This would have allowed the licensee to perform the surveillance requirement of TS 4.8.1.1.1.a. no later than 5:45 p.m. TS 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 a mode in which the specification does not apply. The licensee did not start to shut the unit down within the required time thereby failing to take the action required by T This is a violation of TS 3.0.3. (346/87004-02 (DRP)).

The licensee utiliz.s a five shift rotation for operator This rotation requires ten licens( l SRO's. At the beginning of the inspection period, the licensee had 12 SR0 licensed operators on shift. The two licensed SR0's above the minimum required were performing reactor operator (RO)

duties. During the inspection period one of the operators who filled a required SR0 position went offshift which leaves the licensee with only one available SR0 above minimum requirements. The.next group of SR0 candidates will not sit for their license until August 1987. The licensee does, however, have SR0 licensed individuals who are not on shift and could be utilize The inspectors are concerned about the dearth of available onshift SR0 licensed operators and have discussed their concerns with the license The licensee plans to utilize the offshift SR0's if it is necessary to maintain minimum staffing requirement The inspectors consider this option to be less than desirable as it would adversely affect operations management and trainin This is an Open Item (346/87004-03 (DRP)).

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The licensee stated that-it shared the inspectors' concern and was

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making _an effort to increase the number of-SR0 licensed operator The licensee considers its solution to-be long ter '

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No other violations or deviations were identifie ~

Onsite Followup of Events at Operating Power Reactors (93702)

~ During the inspection period, the license'e 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 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:

l Potential Emergency Diesel Generator (EDG) Overload. The licensees' EDG system engineer identified a possible overload condition of EDG 1-1 during a surveillance test. The EDG manufacturer determined that the potential overload was not high enough to cause degradation ~of the EDG. However, the licensee partially disassembled the EDG in March to allow the vendor to inspect the EDG internals. The licensee's evaluation-of.the inspection determined that the EDG was not' degraded. This item will remain an Open Item (346/87004-04(DRP))'pending the inspectors review of the licensee's evaluation.

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. Dropped Control Ro The licensee found that the dropped rod was caused by a failed control rod drive power supply fus The licensee sent the failed fuse to the~ manufacturer for failure-analysis. The failure snalysis showed that the fuse had not

" blown," but that it had failed due to melted solder inside the fuse at the connection between the end of'the fuse and the fuse elemen Prior to the analysis the licensee suspected that the fuse caps had been causing fuse failures and had started a program to monitor fuseholders for high temperatures and modify fuse caps. The vendor determined that the melted solder was caused by a high resistance between the fuse and the fuse cap. The licensee installed different fuse caps supplied by the vendor. The licensee's efforts have reduced the incidence of dropped rod Main. Turbine Removed from Service Due to Small Steam Leak Unusual Event . Inoperable Safety Features Actuation System Sequence The licensee s immediate evaluation of the event revealed that the Technical Specification (TS) requirement that led to..the declaration of an Unusual- Event was overly conservative. While it was restc. jng and testing-the inoperable sequencer module the l

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licensee requested and received an emergency:TS: change to make the TS action 1 requirement consistent.with the safety significanc of the equipment conditio No violations or deviations were identifie '5; ; Monthly Maintenance Observation d

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Station maintenance activities of safety.related systems and components

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' listed below were observed or reviewed to ascertain that'they were-conducted:in accordance wi_th approved procedures, regulatory guides -

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and industry codes or standards and in conformance' with technical

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~ specifications.

o The following items were' considered during this review:: > the . limiting- ,

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conditions for operation were met;while components:or: systems were removed from service; approvais wereLobtained prior to. initiating the- ~

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. work; activities were accomplished using approved procedures'and were

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' 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.c fire prevention controls

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were implemente Work requests were reviewed to determine status of outstanding jobs

and to assure that priority is assigned to safety- related-equipment i maintenance which may affect system performance.

The following maintenance activities we're! observed or reviewed:

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Disassembly of a Main Steam Safety Valv ,

• Repair of a safety features actuation system power. supply l lea .

• Repair of Main Turbine Steam Leaks.

4 * Installation of Control Room HVAC Compressor;

• Repair of Main Feedwater Pump Turbine'.

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• Disassembly of a~ service water straine * Damaged Motor Control Center circuit breakers Following completion of maintenance.on the safety-features actuation,~

main turbine, and main feedwater; systems, the inspectors verified that

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the. systems had been' returned to service. properl No violations or deviations were identifie l

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The~ inspectors observed._ technical. specifications required' surveillance testing on the Safety _ Features Actuation System-(SFAS), ST 5031.01,.

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"SFAS Monthly Test", and the Reactor 1CoolantLSystem (RCS), ST35042.02,

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"RCS Water Inventory Balance," and verified that. testing was: performed:

o in accordance with~ adequate procedures, that: test: instrumentation was:  :

calibrated, .that limiting conditions..for-operation were met, that' removal

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and: restoration of the affected. components were accomplished, that test -

results conformed with technical specifications and procedure ~ requirements >

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and were reviewed by personnel'other.than the individual directing the

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test, and that any deficiencies ~. identified'during the testing were-

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properly reviewed and~ resolved by appropriate management: personnel.

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. .. . -i Licensee Event Reports Followup'  ;

Ths inspectors have had concerns regardingLthe quality.of LER safety /

engine ~eringLevaluations. This concerr. had been previously documente The-inspectors have observed an_overall improvement 1in the quality of-i these evaluations. The inspectors discussed with the licensee during the:

February-6,-1987, exit meeting-the advantages of anticipating question and having the evaluation address the questions. 'After the exit meeting ,

the . inspectors reviewed LER 87-02 and noted that its evaluation generated

- more questions-than it answered. The inspectors suggested to the'licensen ~

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that it review LER 87-02 and consider. comments-made in the exit. The- _

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. licensee informed the inspectors on. February 20,'1987, that the: Independent ~

. Safety Engineering Group (ISEG) had been-requested to review the evaluation ,

of several LERs including 87-02. -ISEG concluded that the reviews'did not:

, always answer all the questions and frequently raised more than were-

answered. It recommended that additional training ~be given to' evaluators i and the LER evaluations will be given an additional level of review. This~

is an Ope'n Item (346/87004-05(DRP)).

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I No violations or deviations were identified.- IE Bulletin Followup- l FortheIE~Bulletinlistedbelow,the^ inspectors _verifiedthatithe' written response'was within the time period stated.in the bulletin, that-the .

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written response-included the information required to be' reported,'that?

L the written response included adequate corrective action' commitments-E based on information presentation in.the bulletin and the licensee's-

response, that licensee management forwarded copies _of;the written; '

z response to the appropriate onsite management' representatives, that

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information discussed in the licensee's written' response _was acc0 rate, and that corrective action taken by the. licensee was as described in the written. respons (Closed) IEB 85-01, Steam Binding of Auxiliary Feedwater Pump (Closed) IEB 86-03, Potential. Failure of Multiple ECCS Pumps Due to Single Failure of Valve in Minimum Recirculation Flow Lin No violations or deviations were identifie . Plant Trips Following the plant trip on 03-13-87, the inspectors ascertained 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 chemistr The inspectors verified the establishment of proper communications and reviewed the corrective actions taken by the license The plant trip on high pressure was caused by a partial loss of feedwater (FW). The loss of FW was caused by a worker accidentally bumping into a local control switch for a main FW containment isolation valve. The control switch was located at a normal working. level (approximately forty inches above the floor) and did not have a protective cover. The licensee's short term corrective action was to idantify and temporarily protect all such switches located in high traffic areas. The licensee s long term corrective action is to provide permanent protective covers for all local control switches. This corrective action is in progress with suitable management attention and is_ considered adequate to prevent recurrence. Following the trip one of 18 main: steam safety relief valves (MSSV) did not reseat properly. The valve was replaced and the defective valve was disassembled and inspected. A required cotter key was.not found and the damage to the valve indicates that the-missing cotter ~ key probably-caused the valve to malfunction. An in place inspection of all other MSSV's showed that all had the required cotter key. The: licensee is preparing an evaluation of the malfunctioning valve. The inspectors consider this an Open Item (346/87004-06(DRP)) pending their review of the licensee's evaluatio All systems responded as expected, except for the MSSV, and the plant was returned to operation on March 17, 198 No violations or deviations were identified.-

10. Fire Protection The licensee learned through its Ombudsman Program in January 1987 that-some contractor personnel who performed firewatch duties had falsified )

their time cards. The allegation was substantiated by an~ investigation conducted by the licensee's security department. Several people were

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terminated on the basis of the investigation findings. .The licensee learned through the Ombudsman's interview of one of the terminated

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v b .1 4 employee's=thatlseveral fire watchstanders had.been1found asleep while

.on duty. The allegation also:statedithat licensee management was awaref .

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Lof the situation and 'had taken no action. 7The contractor'siemployees

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believed by.the 1ack of. strong disciplinary:actionLthat;the licenseel e

condoned sleeping on duty. -The securityidepartmenttexpandedLitsi ,

? - investigation to determine if the; allegations could be substantiate The11icensee through a review of contractor records;found that;several-

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fire watchstanders<had been disciplined by;the contractor forlbeing1

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asleep while.:on duty. The contractor had;not informed.the licensee .

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of this action.1 The licensee terminated the contract with the fire watch-

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contractor and:had the fire watches performed by other 'pers'onnel. The license took measures to reduce'the number of. fire watches by-accelerating.the implementation of.several Facility Change RequestsL-(FCR'S). -The licensee through a personnel error had an. additional-fire watch incident when~a continuous fire ~ watch for auxiliary building

stairwell'(AB3).was mistakenly replaced with an-hourly fire watch patrol on March 1, 198 Auxiliary Building Stairwells AB3 and AB3A both had Technical' Specification

'.' (TS) required continuous. fire watches. The' continuous-fire watch-on AB3 was relieved when stairwell.AB3A was restored to a condition that required- -

4 only an hourly' fire watch patrol. Stairwell AB3A was described to_the-i shift supervisor'in a manner that caused the shift supervisor to<believ :

, that Stairwell AB3 was being described. TheLshift supervisor then i  :::ictakenly directed the wrong cont.inuous fire-watch to be relieved.-

A relief fire watch identified the condition approximately-two and.-

one half hours after the incorrect placement of watchstanders.

t i TS 3.7.10 (fire barrier penetrations)-requires all fire barrier

[ penetrations in fire zone boundaries protecting safety related areas to be functional at all times. If not, theilicensee must establish a cont _inuous; t

! fire-watch within one hour or verify the operabil.ity of fire detectors on:

at least one side of a non functional _ fire barrier and establish an hourly ~.

fire watch patrol. All of the above examples of' inadequate fire watches will remain an Unresolved Item (346/87004-07(DRP)) pending completion of i the licensee's investigation and Region III's revie .

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No violations or deviations wer'e-identifie . Independent Safety Engineering Group (ISEG)

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Thi' inspectors continued their monthly meetings with members of the-licensee's ISEG. ~ Items that have a -potential impact _on' safety were 1 discussed, including results of: previous;ISEG reviews and studies.- ,

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Although some of the items discussed are not clearly encompassed in; -l

existing regulatory requirements the discussions may help develop; - 1 F insights: that lead to improving safe operation ofiths plant. - The i

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meetings provide a valuable opportunity.for' synergistic ~ inter _ action-between two groups whose primary responsibility is nuclear safety.

Significant items discussed are listed below:

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• Relstionship 'of. actual plant' room. temperatures . to room ' temperature .

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ranges-described in Section 9.4.2.1.1 of the Updated Safety _ Analysis

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Report <(USAR). sTheDinspectors stated:that a frozen fire-protection Lwater line.in the Service Water Pump. Building Lindicated that.the .

temperature had been lower than the 60 degrees-F. described in the'

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USAR ?The-ISEG plansito review the'potentialtsafety consequences

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of roomctemperatures outside:the ranges described:in~the' USA +

.  : Theiinspectoristatedthatthere:isLafpe'rception1thatISEG!is:not'-

totally independent. .The existing organizational structure of ISEG

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-and theLNuclear Engineering. Department reporting to the:same

' individual gives support to this perception. The inspectors'have(no .

evidence that the ISEG lacks independenc However,_the. inspectors believe:that the strength of.the. person in charge allows the ISEG to- '

. maintain;its. independenc The inspectors, stated that independence; based on organizational structure ~is preferable to that based oni

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personality. The inspectors _believe that despite.the strength;of:

the personality the potential for degradation of ISEG independence'

-still exist ' Reliabili_tyoftheDavis-Besseplantandlinstrumentlairsystems as related to studies that show that air: systems ca'n affect core'

melt probabilities. This issue is.related to unresolved safety.

issue-A-47 which NRR has not yet resolve .

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Completion of'a Failure Mode-Ef'fects Analysis of the direct' current

1E electrical syste ~ ~~

. Protection of safety related equipment from the effects-of { inadvertent ~

l fire protection system 1actuations.. The= system interactions 1 observed-

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during the Surrey plant feedwater line break were discussed. Th !

inspectors asked if the controls.on the licensee's established-

" spray shield" program will minimize interactions between'safetyL and non-safety system Increasing identified leakage from th'e_ steam volume of the!

pressurizer. During the inspection period-'the' leakage.from the-

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pressurizer gradually increased from about. 37 gallonsiper minute:

(gpm) to about .87 gpm. The inspectors discussed _the' issue-in

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relation to recent similar situations at~the Calvert-Cliffs and.

i the Turkey Point plants. The members of the ISEG stated that the'

! plant engineering staff was sufficiently addressing all safety) ,

. concerns related to this issue. The inspectors consider this an- -

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Open Item (346/87004-08(DRP)) and will review the work down by the

engineering staff-in a future. inspection.-

. Control Room HVAC System modification. The inspectors stated that the rapid replacement of an old.HVAC compressor was commendabl However, the replacement 1: activities appeared to be beyond the scope of the paperwork controlling the work. Considering the importance to safety of Control Room-HVAC_SystemsLin. light'of recent studies

[ linking control room instrumentation-failures to HVAC deficiencies, it i-

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shortly after the meeting',Lthe ISEG' reviewed.thessituationandLissued a.Petential Condition Adverse to Quality Report. The inspectors will'

review the resolution of this Open Item-(346/87004-09(DRP))jin . future: inspectio '

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Human-factors. The inspectors asked the.ISEG how it evaluated ~ subtle:

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human, factors concerns. EAreas'. discussed, included-improvement of

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communications-and teamwork, management training for SR0's, and

?metho'ds to mitigate the effects of mental fatigue of management-personnel whoLrepeatedly work excessively long hour '

No violations 6r deviations were' identified in this area.-

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12. :TMI' Items-

-(Closed) II.E.1.1.2, Long Term Modifications of the. Auxiliary Feedwater!  !

(AFW) System: l

.The. inspectors reviewed the Safety Evaluation Reportsi(SERs) of; August 3,

,. 1984;' February 21,.1984; May 9, 1985,:and-December 22, 1986. Twelve _

p shortLterm recommendations.(GS-1 through GS-8 and B.1 through'B.4), five-long term recommendations (GL-1 through GL-5), and;one evaluation of the -

design l basis for AFW flow requirements : encompass the scope of II.E.1.1'as -

presented in the SERs. The information provided in"the SERs indicated that only recommendations GS-2, GS-3, GS-6,- B.1, B.4,L and .GL-3 required

,

NRC inspection. Inspection results for all six recommendations were

~

, reported in Inspection Report No. 50-346/86012(DRP). Recommendation on GS-2, GS-6, B.4, and GL-3 required further inspection. The four ..

!. recommendations and the inspection results.for.each are presented belowi -

t i GS-2: The licensee should lock open single valves or multiple valves.

1 in series in the AFW system pump. suction piping and lock open

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, other single valves or multiple valves-.in series:that could 4-interrupt all AFW flow'. Monthly inspections.should be performed to verify that these valves ~are locked open.- These inspection should be included in Technical Specification (TS) surveillance -l requirement j

Status

The licensee's program for controlling AFW system valvesias -'

l described-in Inspection Report No. 50-346/86012(DRP). The; inspectors verified that the licensee has now changed its~TS,-

r adding TS Surveillance Requirement _4.7.1.2a.3, which-requires the monthly valve verification described in GS-2. -The'

.

I inspectors verified that ST 5071.14,'" Auxiliary Feedwater:

E Train .1-1 Monthly Valve Verification," and ST 5071.24, .

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" Auxiliary Feedwater Train 1-2. Monthly; Valve; Verification,"'

have been -issued to fulfill the TS! requiremen ~

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GS-6: The licensee should confirm flow path availability of an.AFW-i

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system flow train that has-been out ofiservice.to perform l periodic testing'or mainte_ nance-as.follows: . < +

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second. operator;to= independently verify the valve

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Status: This part of GS-6 was closed in Inspection Report -

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! No. 50-346/86012(DRP). -

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, . The licensee should propose TS t to: assure that,Lprior to

. plant'.startup:followingian extended coldishutdown,-a flow-E test is performed to verify the. normal. flow path from the- '

primary AFW system. water source to the steam generators.

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Status: The inspe'ctors verified that.TS Surveillance.

' ~ Requi>ement 4.7.1.2f., requires the flow test-y described. : This zitem'is close '

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B.4: Licensees'with~ plants'whichDrequire local' manual realignment

! -of. valves to' conduct periodic: tests on an AFW system' train'

r - with only one remaining AFW train available for' operation

should propose TS to provide that a dedicated individual, i ' who is-in communication with the control. room, would alignL the valves.in the AFW system from the test mode to'its-

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operational alignment ~

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Status: The inspector verified that a note for TS 4.7.1.2 includes'the-requirement stated:in the recommendation. The inspectors.also-reviewed ST 5071.22.00, " Auxiliary Feedwater Pump 1-2 Quarterly ,

, Test;" and determined that Step 3.1.5 of:the Preca'utions 'andt Limitations Section requires an operator in the AFW Room be'in direct contact with the Control Room to close valve AF 22 should ~

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a Steam and Feedwater. Line Rupture Control System' actuation '

! occur with valve AF 23 ope'n. Closing AF 22 would: assure-i adequate AFW flow to the appropriate steam generator. The-inspector verified that a note for TS 4.7.1.2 includes;the

'

' requirement stated in the recommendation.- . .

t GL-3: At least o'ne AFW system pomp 'and -its associated flow p~ath' and essential instrumentation should automatically initiate AFW '

system flow and be capable of bein~g-operatedJindependently,of-any AC power source for;at-least two hours. Conversion,of:DC-

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power to AC. power is acceptable.

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' Status: The-inspectors previously reported that-No'. l AFW pump is-

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capable of operating independently of.AC power' sources.

.

However, this item' remained open1because the AFW pump room

- - ' ventilation system _is~ powered with alternating current. -The

. ventilation system must be operable to maintain operability-

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. , of the'AFW pump. The inspector contacted the NRR licensing.

I project manager in February, 1987-to discuss.whether or'nott  ;

F the support systems for an AFW train are_ required to be .:

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functional without alternating current. :The NRR: licensing'

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U project manager stated th'at .only . valves are within!the scop'e-of recommendation:GL-3. -During later discussions with the- ll

_ licensee ~the inspectors! learned that'an analysisEperformed- 1 for the-licensee ~shows that even.without ventilation th .

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, AFE pumps are= capable;of functioning forLa period considerably,

in excess of'two hours. This item.is~~ closed.

1 (0 pen) II.F.2.3.B,. Inadequate, Core Cooling ~ Instrumentation': ,  ; .

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Thezlicensee's void coefficient. monitoring: system is:the:only:part. .

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Lof this item that-remains to be. reviewed. The inspectors' reviewed

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a: preliminary NRC evaluation of. instrumentation to detect core cooling '

dated September 6,:1983. The evaluation; included atrequestsfor; . ~

additional'information'(RAI). Items ~11 and112 of the RAI concerned the

'

lic'ensee's: void coefficient monitoring systemL(called the Reactor. Coolant )

; Pump Monitor Program-(RCPMP))'. 1The. licensee responded.to Item 11 in a-

_

E letter dated December 8,_1983 and_. Item 12 in atletter dated February 10, 1984.- The inspectors contacted the NRR' licensing project manager by telephone to _ discuss' the status of the review.of the RCPMP. ,The:NRR '

licensing project manager stated that the~ review'was scheduled to be completed by March 31, 1987; The inspectors will complete the~ inspection'

r of the RCPMP after the NRR review of the RCPMP-is issued.

,

No violations or deviations were identified in this area.-

l 1 Performance Enhancement Program (PEP)

l (Closed) Item (346/RP-99610) A-3, Management Trainin The licensee performed a Needs Analysis during.the Fall of 1985'to identify the .  ;

knowledge and skills appropriate for NL-lear Group Management and a '

management training matrix was developed. Core management courses.were

developed utilizing the Needs Analysis

and are designed to incorporate the' building block method of . learning. The~ core. curriculum-is available

. for.1987 resource training and development. This item-is close (Closed) Item (346/RP-99014) D/QA-1,- Quality Assurance (QA) Awareness

, Program. The PEP' Program had identified a-serious deficiency in-the-area of-QA knowledge and commitment-by licensee nuclear personnel'.

The licensee developed a program which included defining the QA program, '

identifying QA rules and responsibilities, preparing.a groupwidecprocedure,.. -

and developing a training program. The licensee has reorganized and restructured its-QA organization since the. original-PEP _ implementation

'

plan was issued. The original-plan was revised to accommodate the changes'

and includes the original program elements. Two-important: elements are

, the-reformatted functional basis Nuclear Quality Assurance Manual-and; the revised QA Awareness Training'Proaram. -The inspectors reviewed thof '

b revisedprogramandconsiderthatitmeets.theobjectivesoftheoriginal~

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comaitment. This item is closed.

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14. -Quality:Assurancei A

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The inspectors reviewed 10 CFR 50.59 and noted thatiSection (b)1 requires-

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the'licenseelto' submit at11 east annually a report to the NRC which contains .

"

a brief description of changes in the-facility.or changes to~proceduresias

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'

described ;in the Safety Analysis Report (SAR) and tests and experiments'.not;

' described in' ..the 'SAR,L including .a summary .of . each.- ^ The, inspector ,

,

performed'a quick review and-found no evide'nce'that the' licensee had met" thisLrequirement. On September 11,~1986, the inspectors. discussed,their ..

concern with.the licensee's Quality Assurance (QA) Department:and requested! ,

to. review all= completed audits relating to 10 CFR 50.59(b). The' inspectors-

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Lalso suggested to QA that it might be appropriate.to audit the licensee's>

compliance.with'10.CFR 50.59. On September 15, 1986,'.the" inspectors-documented this discussion.~

The licensee ~ performed an audit to determine if it.had met the'requiremests; of.10 CFR 50.59(b). ~0n March 6,' 1987,sthe licensee: issued Audit Finding Report AR-87-LICEN-01-which contained two findings:

~ The licensee did not have procedures which delegated responsibilities-for the coordination and integration of activities to' assure all provisions of 10 CFR 50.59 are complied wit . I The-licensee had not been submitting procedure cha'nges and the corresponding safety evaluations to the NRC at least annually as

. required by 10 CFR 50.59(f). In additions tests.and experiments,.

temporary mechanical modifications, electrical jumpers'.and. lifted wires were only reported to the NRC.if-a safety evaluation'and safety review had been performed by_a Facility Change Reques This is a violation' of 10 CFR 50.59(b)l(346/87004-10(DRP)).

The licensee determined that it had not performed audits ~of requirements but rather audits were performed of.its procedures-whichsimplemented.the requirements. .This method did.not offer the~ licensee a method'to' determine if it met the requirements. The inspectors discussed this issue with the licensee. The licensee stated that it would perform audits based on the requirements. This is an Unresolved-Item (346/87004-11(DRP)).

No other violations or deviations were identified.-

1 Emergency-Preparedness Exercise

.

On March 31, 1987, the licensee participated .in its annual emergenc preparedness exercise with state and local organizations.. The NRC observed the onsite activities and the Federal Fmergency Management

! Agency (FEMA) observed offsite activities. FEMA evaluated the Lucas .

County," Ottawa County and State of Ohio organizations for performance and interagency coordinatio ;

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~The inspectors ob' served and evaluated licensee activitiesland' operator performance in-the-control room and the; operations s'upport center 1(OSC).

The NRC and FEMA;have scheduled exit meetings with the licensee.for -

April 2, 1987..The NRC will document the inspection of the onsite-

' activities'in: Inspection' Report No. 50-346/87008 and FEMA will-

.

document:its. findings and conclusions 4in'a-separate repor >

$ 16._ Regional-Requests-

~

E The inspectors were requested by Region-III to determine'if the licensee

"

used AMP splices and terminal lugs in EQ applications. Affirmativ responses required 1 additional;information relating to application and--

I" justification.forcontinuedoperation. The: licensee does'not have an : AMP. splices-or terminal lugs in-EQ-appl.ication l ' 17.- Management Meetings ,

The licensee requested a meeting with' Region-III' personnel to-discuss '

'

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problems and corrective actions. .A management meeting was held at'

Region III on February 27,'1987. The Vice President-Nuclear, the Acting

Regional Administrator.and members'of their. staffs met to discuss'recent- ~

) i.ssues involving management control The. licensee addressed concerns i previously-identified by the inspectors and in addition discussed other? r concerns related to management control and the corrective action taken .

'

to prevent recurrenc The root cause of the problems described appeared

'

l to be lack.of attention to detail and poor-inter-organizational.

j communication. The licensee' stated that it would take' measures to improve communication .

1 Unresolved Items

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, Unresolved items are matters about which more information is reycired 1 in order to' ascertain whether they are acceptable' items, items of-

noncompliance, or deviations. Unresolved items disclosed during

l a

the inspection is discussed in Paragraphs 3 and 1 l

1

, 1 Open Items l Open items are matters which have been discussed with the licensee, f which will be reviewed further by the inspectors,-and which involve some action on the part of NRC or licensee or both. 10 pen items disclosed during:the inspection are discussed in Paragraphs 3.,.4.a., 7., 9.,

11.f., 11.g., and 1 . Exit Interview I' The inspector met with licensee representatives (denoted in Paragraph-1)

F throughout the inspection period and at the conclusion' of the inspection

.

.and summarized the scope and findings of the inspection activities. 1The licensee' acknowledged the findings'. After discussions with the licensee,

! the inspectors have determined there is;no proprietary data contained in this inspection repor '

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