IR 05000346/1987014

Safety Insp Rept 50-346/87-14 on 870601-0731.Violation Noted.Major Areas Inspected:Licensee Action on Previous Insp Findings,Operational Safety,Mgt Meetings,Maint,Lers, Surveillance,Fire Protection & Plant Procedures

ML20235H170
Person / Time
Site:	Davis Besse
Issue date:	09/08/1987
From:	Defayette R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20235H162	List: IR 05000346/1987014 ML20235H158 ML20235H165
References
50-346-87-14, NUDOCS 8709300399
Download: ML20235H170 (11)

Text

. _ _ . _-. _ - - - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ ____- _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ - _

..,-  :

.

U. S. NUCLEAR REGULATORY COMMISSION REGION-III Report'No. 50-346/87014(DRP)

Docket No. 50-346 Operating-License No. NPF-3 i

Licensee: Toledo Edison Company 1 Edison Plaza, 300 Madison Avenue

' Toledo, OH 43652 l

l Facility Name: Davis-Besse 1 Inspection At: Oak Harbor, Ohio Inspection Conducted: June 1, 1987 to July 31, 1987 Inspectors: P. M. Byron D. C. Kosloff L. McGrego o_

R.WM i

Approved By: R. DeFayette, C6/ef 7/f E7 '\

Reactor Projects Section 28 Date I '

Inspection Summary l

Inspection on June 1 through July 31, 1987 (Report No. 50-346/87014(DRP)) f Areas Inspected: Routine, unannounced inspection by resident inspectors of i licensee action on previous inspection findings, operational safety, management  !

meetings, maintenance, surveillance, licensee event reports, fire protection, i interim performance enhancement program, performance enhancement program, and plant procedure Results: Of the 10 areas inspected, no violations or deviations were  ;

identified in 9 areas. One minor violation, (failure to follow procedures, l Paragraph 3) as identified in the area of operational safet '

i l

l l

l

<

_

'

8709300399 870909 6>

PDR ADOCK 0500 j G

i

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

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

. DETAILS Persons Contacted Toledo Edison Company (TED)

D. Shelton, Vice President, Nuclear D. Amerine, Assistant Vice President, Nuclear

+#L. Storz, Plant Manager

• R. Flood, Assistant Plant Manager, Operations

+#*N. Bonner, Assistant Plant Manager, Maintenance

• S. Smith Assistant Plant Manager, Maintenance D. Briden, Chemistry and Health Physics General Superintendent Jain, Nuclear Engineering Director

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

+*L. Ramsett, Quality Assurance Director G. Grime, Industrial Security Director

+ Beyer, Nuclear Projects Director

+ Stewart, Nuclear Training Director M. Schefers, Information Management Director T. Myers, Nuclear Licensing Director J. Scott-Wasilk, Nuclear Health & Safety Director P. Hildebrandt, Engineering General Director J. Wood, Systems Engineering Director S. Piccolo, Acting Performance Engineering Manager

1. • G. Honman, Compliance Supervisor G. Schrouder, Nuclear Licensing Manager D. Haiman, Nuclear Engineering General Manager J. Dillich, Technical Support, Engineering J. Miller, Technical Support, Engineering D. Stephenson, Senior Licensing Specialist L. Young, Licensing, Fire Protection J. Moyers, Quality Verification Manager S. Zunk, 0mbudsman D. Harris, Manager Quality Systems

+*J. Sturdavant, Licensing Principal G. Skeel, Nuclear Security Operations Manager

+*L. Wade, Quality Control Supervisor

+W. Johnson, System Engineering Manager USNRC

+#*P. Byron, Senior Resident Inspector

+*D. Kosloff, Resident Inspector

1. L. McGregor, Project Inspector

• Denotes those personnel attending the June 30, 1987, exit meetin # Denotes those personnel attending the July 17, 1987, exit meetin + Denotes those personnel attending the August 4, 1987, exit meetin .. _ _ _ _ _ _ _ _ _ _

_ -- _

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

.

2.- Licensee Action'on Previous Inspection' Findings (92701) (Closed)OpenItem(346/85025-23(DRP)): Provide additional enhancement to data retrieval software. The licensee was using DATA BOSS /4 when this item was opened. . The licensee replaced DATA BOSS /4 with BASIS in August 198 BASIS includes enhancements which improve data retrievability. The licensee demonstrated the capabilities of BASIS to the inspectors and the new software does provide enhanced retrieval capability. This item is close (Closed) Open Item _(346/86016-05(DRP)) and TI 2515-75: Deportability of Limitorque wiring problems. The licensee identified wiring discrepancies in Limitorque valve motor operators and documented them ,

in Nonconformance Report (NCR) No. 85-1602 dated October 31, 198 (

The licensee inspected 116 Limitorque motor operators and discovered {

that 109 of the operators had wires which either did not meet EQ- t requirements or did not have the proper documentation. The licensee performed the work under Maintenance Work Order-(MW0) 1-85-2817-3 J The licensee documented its findings in Potential Condition Adverse j to Quality (PCAQ) No. 86-0067. The licensee's actions were documented in Inspection Report No. 50-346/8601 The PCAQ ;

evaluation had not determined if the findings were reportable and the i Open Item was generate The licensee reviewed PCAQ 86-0067 and determined that its findings 1 were reportable under 10 CFR 50.73 and reported them in Licensee Event  !

Report (LER) 86-06 Revision 1 dated August 1, 1986. The work had 1 been completed prior to the issuance of TI 2515-75. The inspectors reviewed the MWO rather than have the licensee reopen the ' motor ]

operators and found that all documentation appeared to be in orde ]

These actions close both the Open Item and TI 2515-7 j (Closed) Open Item (346/87008-08(DRP)): Employee Assistance Program's (EAP) ability to accommodate confidentiality and legal requirements. The licensee explored various avenues with the provider organization which implemented its EAP, in order to reach an ,

'

accommodation which would allow the licensee to fulfill all of its 10 CFR 55 requirements. The licensee was unable to reach an agreement with the provider and terminated its contract. An agreement has been reached with another provider organization. The new agreement contains a clause which states that confidentiality will be maintained except with the written consent of the program participants or where required by law or by Federal regulatio This clause addresses the inspectors' concerns and this item is close No violations or deviations were identified in this are l l

!

i

___ _ _ _ _ - _ _ . ___

- _ ____ _ _ - ___ - ___ - - - - - - - - - -

.

. Operational Safety Verification (71707) The inspectors observed control room operations, reviewed applicable logs and conducted discussions with control room operators during the months of June and July. The inspectors verified the operability of selected emergency systems, reviewed tagout records and verified proper return to service of affected components, Tours of the auxiliary, turbine, service water and water treatment 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 controls. During the months of June and July, the inspectors walked down the accessible portions of the Reactor Protection and Emergency Diesel Generator systems to verify operabilit These reviews and observations were conducted to verify that facility operations were in conformance with the requirements established under technical specifications, 10 CFR, and administrative procedure The inspectors reviewed procedures AD 1810.00.09, " Station Fire Protection" and AD 1810.04.02, " Administrative Controls for Fire Detection Systems and Fire Barriers (Dampers, Doors and Barriers)".

The review revealed that neither procedure contained any actions or references as to the requirements of maintaining fire doors closed or actions to be taken when they were to be temporarily blocked ope Additional review by the inspectors determined that this information is contained in Generic Guidance Memorandum POL-22 "The Blocking of Fire Barrier and Negative Pressure Boundary Doors". The inspectors review indicated that the administrative controls contained in AD 1810.04.02 were sparse. This is an Open Item (346/87014-01(DRP)). Nuclear Group Procedure, NG-AV-115, " Preparation and Control of Nuclear Group, Division and Department Procedures," Section states that a Procedure Specification (SPEC) shall delineate the methods established by each Nuclear Group Division for the preparation, review, approval, revision, periodic review, and cancellation of its Division and Department Procedure Furthermore, Section 6.3.5.c states that SPECS shall not authorize the use of memoranda to revise or change requirements contained in a procedur ________ - _ _ _ _ _ _ _ _ _ _ _ _

_ __ -. _ _ . _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ - .

.J

.

The licensee appears to have some difficulty in following this procedure as demonstrated by the following examples: Administrative Procedure AD 1828.08, " Instant Senior Reactor Operator Training Program", Section 6.9.1.a.2 requires that candidates fulfill the practical requirements in the Non-Licensed Operator Proficiency Manua In actual practice candidates are also required to fulfill the requirements of the Zone Manual. The Zone Manual, a separate manual containing both practical and knowledge requirements, was erroneously omitted as a reference in AD 1828.08. Section 3.0 of the Zone Manual stated that system checkouts given to demonstrate knowledge requirements must be given by licensed operators. The Zone Manual is considered to be a Nuclear Training Division procedure as it delineates requirements for training. The licensee, by memorandum dated July 2,1987, modified the manual to allow system engineers to give checkouts. Changes to Nuclear Training Division procedures are controlled by Nuclear Training Division Procedure NT-DP-0002, " Development, Review, Approval, and Control of Nuclear Training Division Procedures". NT-DP-0002 does not allow procedure changes to be made by mem This failure to follow procedure is a example of a violation of Technical Specification 6.8.1 (346/87014-02A(DRP)). The inspectors informed the licensee of their concern. The licensee's immediate corrective action was to a issue a memorandum dated July 10, 1987, cancelling the July 2nd memorandum and to revise both AD 1828.08 and the Zone Manual to specifically delineate those authorized to give checkouts. The inspectors consider that the licensee's corrective action is adequate and this item is close . The licensee recently appointed an individual to the position of Operations Superintendent (0S) who does not have an SRO license for Davis-Besse, but is in an SR0 training clas Administrative Procedure AD 1839.00, " Station Operations",

Section 5.3.12 states that the Operations Superintendent is responsible for maintaining an NRC Senior Operator's License on the uni In June, 1987 the licensee verbally assigned those OS duties requiring a license to a licensed individual until the newly assi0ned OS meets the requirements. This verbal reassignment of duties was a procedure chang Changes to procedures developed for use within the Operations Department are controlled by Administrative Procedure AD 1805.00.07 (DB-DP-0003), " Procedure Preparation and Maintenance". Steps 6.1.1 through 6.1.15 of AD 1805.00.07 are required to be followed to change a procedure developed for use within the Operations Department.

l

!

AD 1805.00.07 does not allow procedure changes to be made without documentation. This failure to follow procedure is a example of a violation of Technical Specification 6. (346/87014-02B(DRP)).

!

_ _ _ _ k

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _

f'

l l

.

In the two cases discussed above, improper changes to procedures not only violated procedures but also allowed changes to be made without the SRB review required by Technical Specification 6.8.2. Since this Technical Specification violation was a direct result of the procedure violation discussed above and the corrective actions for the procedure violations should prevent recurrence of the Technical Specification 6.8.2 violation, a separate notice of violation has not been prepare No other violations or deviations were identified in this are . Management Meetings (30702)

The Vice President Nuclear met with the Regional Administrator at Region III on July 21, 1987, to discuss items of mutual interes Members of their respective staffs met to discuss the licensee's Quality Assurance Progra The Director of the Region III Division of Reactor Projects and members of his staff toured the site on July 30, 1987, and met with the Vice President Nuclear and members of his staf . Monthly Maintenance Observation (62703)

Station maintenance activities of safety related systems and components listed below were observed / reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides and industry codes or standards and in conformance with technical specifications.

l The following items were considered during this review: the limiting conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicable; functional testing and/or calibrations were performed prior to returning components or systems '.o service; quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were implemented; and, fire prevention controls were implemente Work requests and maintenance work orders (MW0) were reviewed to determine the status of outstanding jobs and to assure that priority is assigned to safety related equipment maintenance which may affect system performanc The following maintenance activities were observed / reviewed:

_

Removal and disassembly of service water flow control valv _

Installation of cooling fans in essential inverter _

Replacement of auxiliary feedwater (AFW) pump turbine steam supply low pressure switche _

Preventive maintenance of Emergency Core Cooling Systems (ECCS)

room cooler.1- _ _ _ _ _ _ _ _ _ _ _ __

__

_ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ __ .

'

i

t

..

i

_ Replacement of defective circuit cards associated with the incore detector syste ,

l Following completion of maintenance on the essential inverters, the I

'

AFW system, the incore detector system and the ECCS room cooler, the {

inspectors verified that these systems had been returned to service properl No violations or deviations were identified in this are . Monthly Surveillance Observation (61726)

The irispectors observed technical specifications required surveillance i testing on the High Pressure Injection (HPI) System, ST 5051.09.08, {

"HPI Pump and Check Valve Test", and the Reactor Protection System, j ST 5030.12.14. " Channel Functional Testing of the Reactor Trip Module {

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

l

_ ST 5030.01 Reactor Protection System Daily Heat Balance Check i i

_ ST 5071.21 Auxiliary Feedwater Pump 2 Monthly Jog Test }

)

_ ST 5042.02 RCS Water Balance Inventory No violations or deviations were identified in this are . Licensee Event Reports Followup (90712 and 92700) l

!

Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine that deportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence i had been accomplished in accordance with technical specification (Closed) LER 87001, Reactor trip due to loss of feedwate I On January 1,1987, Main Feedwater Pump Turbine (MFPT) I tripped as -l a result of high vibration due to bearing failure. The loss of j l feedwater initiated the Anticipatory Reactor Trip System (ARTS)/  !

!

!

Reactor Protection System (RPS) of the unit. The bearing failed due )

to a plugged oil line. A pipe plug which was apparently dislodged I

l i

'

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

'

_-_-----___----j

J

.

during previous maintenance caused the blockage. The pipe plug could only have entered the oil line while the bearing assembly was disassembled and it was last disassembled in 198 The licensee stated that it had already taken corrective action to preclude such events in the future. Prior to the event but after the disassembly of the bearing it had changed its procedures such that all critical maintenance activities would be performed per procedure. The licensee stated this has been done throughout the outage which commenced June 9,1985. The licensee also added Quality Control hold points for critical steps and installation verificatio The inspectors reviewed Administrative Procedures AD 1844.00.16

" Conduct of Maintenance", and AD 1844.02.02, " Control of Work" and noted that both procedures contain steps which ensure that procedures will be used for complex tasks and QC hold points for critical steps will be initiated. This item is close b. (Closed) LER 87003, Service Water valve incorrectly declared inoperable during mode change The licensee performed maintenance on a containment air cooler service water outlet valve. The valve has three functions, two of which are safety related. Maintenance was performed on the nonsafety related function (flow modulation in response to temperature) and did not affect the safety related functions. The licensee's corrective action was to counsel involved personnel, clarify Technical Specifications and revise the Maintenance Work Order (MW0) proces ,

The licensee is also performing a detailed review of all Technical '

Specifications (TS) with its formal Technical Specification Verification Program (TSVP). The TSVP is-intended to improve the clarity of TS, verify that implementing procedures are correct and complete, verify that equipment listed in a particular TS is in the correct TS, and verify that the TS surveillance requirements are  !

consistent with the technical base The inspectors reviewed a revision to Administrative Procedure AD 1844.02.02, " Control of Work (MWO)" which now contains steps to ensure that the effects of work on a component function are reviewe This item is close c. (Closed) LER 87007, Missed surveillance to demonstrate operability of remaining AC source The licensee removed an emergency diesel generator from service for maintenance and failed to perform a surveillance test to verify the availability of offsite AC sources to satisfy the Limiting Condition of Operation (LCO). The surveillance test was performed initially but the following surveillance was not performed in the time period specified in the technical specification action statement. The missed surveillance was noted by an oncoming shift superviso l

_ _ _ _ _ _ _ -

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

,

..

[

The licensee'sLcorrective action was to revise Shift Technical Advisor and Shift Supervisor turnover checklists to include detailed information for action required by all LC0's including time and date

'

when the next surveillance is due. A status board was installed in the. shift supervisor's office as an interim measure until the

' checklists were revised. The inspectors reviewed Administrative Procedure AD 1839.05.05 " Shift Turnover" dated June 18, 1987, and noted that the turnover checklists had been' revised. This item is closed. The inspectors noted that the highly visible status board is still in use and appears to be a valuable tool for insuring safe plant operatio No violations or deviations were identified in this are . Fire Protection (64704)

While investigating an operational problem with a reactor coolant pump (RCP) bearing thermocouple, the licensee found that one of the two RCP oil collection tanks in containment was partially filled with wate This will remain an Open Item (346/87014-03(DRP)) pending completion of the inspectors' review of-the effect the partially filled tank had on the licensee's fire protection capability and the inspector's review of the licensee's corrective actio No violations or deviations were identified in this are . - Interim Performance Enhancement Program (IPEP) (92701) <

(Closed) Item (346/RP-10037) 10-3(07): Obtain contractor support to complete certain programmatic requirements such as SAR update. The licensee awarded a contract to TERA Corporation to review documentation from January 22, 1983, to January 22, 1984, and make proposed changes to the USAR. This contract was documented in Memorandum NLM No.84-040, dated February 23, 1984. The licensee closed the item based on its .

!

action for the single example listed in an April 18, 1984 memorandu The inspectors consider that this item was vague and it was based on the licensee's inability to meet programmatic commitments because of the paucity of licensing personnel. The licensee has increased its staff and the concern is no longer valid. This item is close No violations or deviations were identified in this are . Performance Enhancement Program (PEP) (92701)

! (Closed) Item (346/RP-88008) B-4: Implement a Human Resource Planning Program that identifies Human Resources needs are adequate to achieve mission / company strategies. The licensee issued a corporate procedure, Personnel Division Procedure 5-113. " Human  !

Resource Planning", in April 1987. This procedure addresses career planning and succession and satisfies the concerns of B-4. This item is close _ _ _ _ - - - _ _ .

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

.-

l'

b.- (Closed) Item (346/RP-88012)C/RM-1: Nuclear mission preparations for use of records management system. This was accomplished by incorporating the Records Management Syrtem into- the Nuclear Grou 'A direct link was established between the user and records management. Nuclear Group Procedure NG-AV-106, " Nuclear Records-

,

Management" is the organization's governing document. This item is

'

close (Closed) Item (346/RP-88013) C/RM-2: Records Management System

' Enhancements. The licensee implemented an enhanced records-management program in June 1986. Elements of this program are included in NG-AV-106 which describes the interface of the Nuclear Group with Nuclear Records. Management (NRM). New NRM divisional procedures were written to enhance work flow within records l management. Records-lists were-developed and encoding guidelines were utilized for censistent indexing into the computer system. The records residing in the old' software were converted to the new BASIS software (see Open Item 346/85025-23, Paragraph 2a.). The licensee's actions satisfy the commitments and this item is close (Closed) Item (346/RP-88014) D/FP-2: Improve awareness of risks associated with fire hazards. The licensee has upgraded its General Orientation Training to include additional fire protection awarenes The Industrial Safety Group performs fire protection inspections and includes fire safety in its industrial safety education program. In addition, a full time Fire Brigade instructor is part of'the training department staff. The inspectors consider.that the

. licensee;has adequately addressed fire awareness concerns'and this item is close (Closed) Item (346/RP-99614) D/FP-1: Provide cost effective fire protection through decreased regulatory exposure. The licensee has created and staffed a fire protection department which is headed by a Fire Protection Compliance Manager. The inspectors consider that this item has been elevated to a. sufficient level to ensure that its programs will be implemented. The licensee has embarked on a program to upgrade its fire protection program and bring the plant into compliance with Appendix R by the end of the 6th refueling outag This item is close (Closed) Item (346/RP-99625)D/SM-9: Nuclear industry operations  !

experience progra The licensee's action was to provide a procedure  !

which established guidelines and requirements for the handling of industry experience data. The inspectors reviewed Operation Engineering Department Procedure OPE-001, " Operating Experience Assessment Progra Review Operating Experience," dated August 4, 1986. The procedure contains the elements necessary to ensure that applicable operating experience is disseminated and tracked. This item is close No violations or deviations were identified in this area.

t

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

C

...

1 Plant Procedures (42700)

Administrative Procedure AD 1805.00, " Procedure Preparation and Maintenance", Section 6.1.10 requires that all documents affected by a procedure change be listed on a Document Interface Worksheet (DIW).

Section 6.2.1.c requires the qualified reviewer to review the DIW and Section 6.5 requires the necessary action to be take Administrative Procedure AD 1848.00, " Station Records Management" contained training records retention requirements. The licensee cancelled this procedure in December 1986 and superseded it with Procedure NG-AV-0106, " Nuclear Records Management". However, NG-AV-0106 exempts training records and references training procedure NTD-Oll, " Training Records". NTD-011 references AD 1828.04 which states that training records will be retained in accordance with AD 1848.0 Thus with AD 1848.00 cancelled there were no procedural requirements for the retention of training records which are required to be retained as Quality Assurance record !

The inspectors questioned the licensee about the use of nonexistent procedures as references. The licensee stated that it was unabic to provide an answer but would review all cancelled procedures and verify that all references to them had been deleted. This is an Unresolved Item (346/87014-04(DRP)) pending the inspectors' review of the licensee's corrective actio No violations or deviations were identified in this are . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of .

noncompliance, or deviations. An Unresolved item disclosed during the  !

inspection is discussed in Paragraph 1 . Open items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspectors, and which involve some action on the part of NRC or licensee or both. Open items disclosed during the inspection are discussed in Paragraphs 3.c.,and . Exit Interview (30703)

The inspectors met with licensee representatives (denoted in Paragraph 1)

throughout the month and at the conclusion of the inspection and summarized the scope and findings of the inspection activities. The licensee acknowledged the findings. After discussions with the licensee, l the inspectors have determined there is no proprietary data contained in

'

this inspection report, i 11

. _ _ _ _ _ _ _ _ _ -