IR 05000346/1987031

Insp Rept 50-346/87-31 on 871116-1231.Violations Noted.Major Areas Inspected:Previous Insp Findings,Operational Safety, Maint,Surveillance,Ler Followup,Ie Bulletin Followup,Onsite Followup of Events,Training & Emergency Preparedness

ML20196A598
Person / Time
Site:	Davis Besse
Issue date:	01/29/1988
From:	Defayette R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20196A589	List: IR 05000346/1987031 IR 07100116/2012031 ML20196A583
References
50-346-87-31, IEB-87-002, IEB-87-2, NUDOCS 8802050104
Download: ML20196A598 (13)

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1 U. S. NUCLEAR' REGULATORY COMMISSION r

REGION III

Report No. 50-346/87031(DRP)

Docket No. 50-346 License No. NPF-3 Licensee: Toledo Edison Company Edison Plaza, 300 Madison Avenue Toledo, OH 43652 Facility Name: Davis-Besse 1 >

Inspection At: Oak Harbor, Ohio Inspection Conducted: November 16, 1987 through December 31, 1987 i

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Inspectors: P. M. Byron D. C. Kosloff L. C. McGregor, Region III A. DeAgazio, NRR/PD 31 A. Gill, NRR/SPLD N. Wagner, NRR/SPLB ,

h Approved By: oertDeFayette,Cdief Reactor Projects Section 28 Date

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Inspection Summary Inspection on November 16 through December 31, 1987 (Report No. 50-346/87031(ORP))

l Areas Inspected: Routine, unannounced inspection by resident inspectors

, of licensee action on previous inspection findings; operational safety;

maintenance; surveillance; licensee event reports followup; 1.E. bulletin ,

i followup; training; onsite followup of events; emergency preparedness; radiological environmental monitoring; and auxiliary feedwater system reliabilit Results: Of the 11 areas inspected, no violations or deviations were  !

i identified in 10 areas. One violation was identified in the area of l licensee event reports followu <

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DETAILS 1. Persons Contacted Toledo Edison Company (TED)

D. Shelton, Vice President, Nuclear *

• L. Storz, Plant Manager

• Bonner, Assistant Plant Manager, Maintenance

• Flood, Assistant Plant Manager, Operations E. Salowitz, General Superintendent Outage and Program Management L. Ramsett, Quality Assurance Director S. Jain, Independent Safety Engineering Director D. Briden, Chemistry Program Manager G. Grime, Industrial Security Director B. Beyer, Nuclear Projects Director M. Stewart, Nuclear Training Director M. Schefers, Information Management Director T. Myers, Nuclear Licensing Director J. Scott-Wasilk, Nuclear Health & Safety Director

• Hildebrandt, Engineering General Director J. Wood, Systems Engineering Director  ;

G. Gibbs, Performance Engineering Director V. Watson, Design Engineering Director D. Wilczynski, Configuration Management Program Manager R. Scott, Chemistry Superintendent G. Honma, Compliance Supervisor

• Schrauder, Nuclear Licensing Manager D. Haiman, Engineering General Manager

• Erickson, Radiological Control Superintendent  ;

R. Donnellon, Mechanical Superintendent  ;

R. Butler, I&C Superintendent i T. Haberland, Electrical Superintendent C. Daft, Technical Planning Superintendent '

D. Lightfoot, Outage and Program Management Superintendent :

• L. Young, Licensing, Fire Protection

• J. Strausser, Fire Protection Compliance Manager  ;

J. Moyers, Quality Verification Manager '

S. Zunk, Nuclear Group Ombudsman

• Harris, Manager Quality Systems t

• J. Sturdavant, Licensing Principal i C. Bramson, Nuclear Records Manager l G. Skeel, Nuclear Security Operations Manager L. Wade, Quality Control Supervisor .

L. Worley, Document Control Manager l E. Benson, Nuclear Materials Manager

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• Byron, Senior Resident Inspector

• Kosloff, Resident Inspector

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• Denotes those personnel attending the January 6,1988 exit meeting.

, Licensee Action on Previous Inspection Findings (92701) (Closed) Open Item (346/85004-07): Modifications to provide electrical ,

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independence between redundant Safety Features Actuation System (SFAS)

instrument channels. This item was closed as LCTS #2152 in Inspection Report 50-346/86032 in Section 3,-Paragraph p.1. This item is close i

' (Closed) Open Item (346/86032-07): Conduit has colored identification tape obscured by paint. The inspectors observed that most of the safety-related conduits previously identified as having obscured color identification tape were properly identifie The inspectors also found no other obscured color identification during plant tour The inspectors reviewed completed Maintenance Work Orders documenting licensee inspections and correction of other obscured color identification found during the inspection This item is closed.

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No violations or deviations were identified in this are . Operational Safety Verification (71707)

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The inspectors observed control room operations, reviewed applicable logs,

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and conducted discussions with control room operators during the months

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of November and Decembe The inspectors verified the operability of selected emergency systems, reviewed tagout records, and verified proper return to service of affected component Tours of the auxiliary, turbine, water treatment, and service water 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 maintenanc The inspectors, by observation and direct interview, i i verified that the physical security plan was being implemented in accordance with the station security pla i The inspectors observed plant housekeeping and cleanliness conditions, and verified implementation of radiation protection control During the I months of November and December, the inspectors walked down the accessible

portions of the Auxiliary Feedwater, Main Feedwater, Reactor Protection, Instrument Air, Anticipatory Reactor Trip, Service Water, Emergency Diesel Generator, Essential 120 Volt AC, Essential 480 Volt AC, Essential 125 i Volt DC, and Component Cooling Water Systems to verify operabilit I

These reviews and observations were conducted to verify that facility l operations were in conformance with the requirements established under j j Technical Specifications, 10 CFR, and administrative procedure '

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On November 11, 1987, the licensee discovered that both radiation monitors !

(RE 8446 and RE 8447) for the spent fuel pool emergency ventilation system l (EVS) had high radiation setpoints above Technical Specification limits j since March 1977. Technical Specification 3.3.3.1.a requires that the I alarm / trip setpoint be less than or equal to two times background. RE 8446 !

currently reads between 0.5 and 0.7 mR/hr, and its high radiation setpoint '

was 25 mR/hr. RE 8447 currently reads between 0.1 and 0.4 mR/hr, and its high radiation setpoint was 24 mR/hr. Both radiation monitors were technically inoperable thus, both EVS's servicing the fuel storage pool area were technically inoperable. Technical Specification 3.9.1 requires that with no EVS servicing the storage pool area, all operations i involving movement of fuel within the storage pool, or crane operation with loads over the storage pool, must be suspended. The licensee had at least five occasions (initial fuel loading and four refuelings) when it violated this Technical Specification requirement. Upon discovery of the ;

incorrect setpoints the licensee declared the radiation monitors inoperable and verified compliance with the applicable Technical Specification j requirements. The radiation monitor setpoints were later reset to the correct values, tested, and declared operable, ,

The inspectors reviewed I&C Procedure IC 2005.03, "Process Radiation Monitor (Gaseous) Calibration," and noted that the procedure contained

the incorrect alarm / trip setpoint (25 mR/hr). The inspectors discussed I with the licensee their concern regarding the failure of the procedure to i conform with the Technical Specification. The inspectors also requested l the licensee to provide background radiation levels for the time the i monitors were required: March 1977 through November 198 The inspectors l do not consider this item to be of safety significanc This is an ,

Unresolved item (346/87031-01(ORP)) pending followup inspection of the l licensee's response l On December 4, 1987, the licensee performed a Quality Assurance surveillance of the Material Storage Station, including the Staging Warehous Discrepancies were observed in most areas. Principal findings were in the areas of material control and identificatio Previously, the inspectors had identified to the licensee discrepancies in the control of in process material (Inspection Report 50-346/87008).

The inspectors' concern with the surveillance findings was heightened by the proximity of a six month refueling outage. The inspectors discussed their concerns with the license ,

I The licensee addressed the inspectors' concerns and have taken corrective ;

actions for some of the deficiencies identified during the surveillance, j However, the licensee should make an effort to ensure its corrective j actions are adequate. The magnitude of the work effort planned during I the forthcoming outage makes it necessary that adequate material controls i are in place and are effectiv This is an open item (346/87031-02(DRP)).

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The licensee has found seven switches or breakers mispositioned since March 16,1987: a control room emergency ventilation system (EVS) local switch was found in midposition on three occasions in a three month period; on September 27, 1987, an electrical disconnect switch for the component cooling water system was found in the local position; three circuit breakers were found mispositioned between November 5 and December 21, 198 As a result of this, the licensee initiated a security investigation which is almost complete, in an attempt to determine the cause. Preliminary information indicates the first four items were too old to allow an accurate determination of the cause. However, the Operations Department previously investigated the mispositioned EVS switches and were unable to determine a cause. Preliminary findings indicate that the last three occurrences were most probably accidental. This is based on location of the device, activity in the area, and a large number of interview This is an open item (34G/07031-03(DRP)) pending review by the inspectors of the licensee's completed investigatio No violations or deviations were identified in this are . Monthly Maintenance Observation (62703)

Station maintenance activities of safety related systems and components and systems and components important to safety listed below were observed / reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides, and industry codes or standards, and were in conformance with technical specification The following items were considered during this review: the limiting conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as upplicable; functional testing and/or calibrations were performed prior to returning components or systems to service; quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; radiological controls and fire prevention controls were implemente Work requests were reviewed to determine the status of outstanding jobs and to assure that priority was assigned to maintenance of safety related equipment which could affect system performanc The following maintenance activities were observed / reviewed:

• Replacement of Service Water Valve SW 143 * Replacement of Instrument Air Dryer Valve Solenoi * Testing of Turbine Bypass Valve * Replacement of Auxiliary Feedwater Pump Turbine Governor Valve Components

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• Investigation of-inadequate temperature control in a low Voltage Switchgear Room  ?

• Modification of the Instrument Air System to allow use of a new Instrument Air Drye * Replacement of PS9806 Following completion of maintenance on the Auxiliary Feedwater and j; Instrument Air System, the inspectors verified that-these systems had been returned to service properl In the past, inspectors and NRC management have discussed spare parts availability with the licensee because of the impact spare parts availability has on timely completion of maintenance. During the outage following the June 9, 1985 loss of-feedwater event, the licensee improved its ability to deliver spare parts that had not been in stock prior to a specific need identified by maintenance personnel. However, anticipatory stocking of parts likely to be needed, review of installed equipment to identify obsolete parts that would no longer Le'available, and procurement of spare parts for plant modifications were recognized as actions that needed long term attention. The licensee has improved some of the parts stocking problems. However, during this inspection period the following examples of parts problems were noted:

• One of three Component Cooling Water (CCW) Heat Exchangers has been inoperable since September 1987 because the manufacturer of the Service Water (SW) flow control valve (SW 1434) for the.CCW Heat Exchanger no longer manufactures the valve for nuclear service, and no spares were in stock. The licensee expended considerable effort to procure replacement valves and by the close of the inspection period had installed a new valve. However, the heat-

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exchanger remained inoperable because a capscrew needed for valve indication was not available. Since the other two heat exchangers are in service, and since the Technical Specifications require only two operable heat exchangers, this condition has no direct safety significance. However, the licrnsee's inability to use the

inoperable heat exchanger limits maintenance time on the other

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two heat exchangers without entering an action statemen * One of three SW strainers has been inoperable since December 1, ;

l 1987, due to a defective motor, because no spares are in stoc ;

Since the other two strainers are in service, and since the

Technical Specifications require only two operable strainers, this ,

condition has no direct safety significanc However, the licensee's inability to use the inoperable strainer limits maintenance time on the other two strainers without entering an action statement.

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• The pressure switch (PS 9806) that controls automatic isolation of extraction steam to the Moisture Separator Reheaters failed following the reactor trip on August 21, 198 This failure contributed to a rapid cooldown (did not exceed Technical Specifications) of the Reactor Coolant System that was terminated by operator action. Since there was no replacement for PS 9806 in stock, the licensee repaired the switch. It was later discovered that the switch failed. A replacement switch was received in early December. However the plant tripped on December 7, 1987, before the new switch was installed. PS 9806 again failed and operator action was again required to limit RCS cooldow * The plant trip on December 7, 1987, was caused by the failure of a solenoid on an instrument air dryer valve. The solenoid had been in service for about ten years. There were no spares in stock to allow replacement or repair of the solenoids. The licensee was unable to procure spares from the solenoid manufacturer. The licensee replaced the old failed solenoid with a different solenoid that was in stoc However at the close of the inspection period, three other old solenoids on the air dryer had not been replaced because new solenoids were not availabl No violations or deviations were identified in this are . Monthly Surveillance Observation (61726)

The inspectors observed technical specifications required surveillance l testing on the Emergency Diesel Generator, ST 5081.01, "Diesel Generator '

Monthly Test", and verified that: testing was performed in accordance with adequate procedures; test instrumentation was calibrated; limiting conditions for operation were met; removal and restoration of the affected components were accomplished; test results conformed with Technical Specifications and procedure requirements, and were reviewed by personnel other than the individual directing the test; any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personne l The inspectors also witnessed portions of the following test activities:

i e ST 5030.02 Reactor Protection System Monthly Functional Test

• ST 5042.02 Reactor Coolant System Water Inventory Balance

• ST 5074.01 Component Cooling Water System Monthly Test

• ST 5075.01 Service Water System Morthly Test No violations or deviations were identified in this are .

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. Licensee Event Reports Followup (92700)

Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine ,

that reportability requirements were fulfilled, immediate corrective !

action was accomplished, and corrective action to prevent recurrence had been accomplished in accordance with technical specifications:

(Closed) LER No. 87-014: Inoperable Fire Hose Station HCS 30 due to

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Inadequate Procedural Guidance. The licensee was performing fire hose hydrostatic tests (PT 5116.11) in which each fire hose is removed from l l its station, replaced with another hose, and hydrostatically teste On

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October 22, 1987, the licensee replaced a 75 foot long hose with a

50 foot long hose at fire hose station HCS-30 in the Containment Purge

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Exhaust Fan Room (Room 515). However, the replacement hose was inadequate to protect all of the safety-related equipment in Room 515

because Emergency Ventilation System train #2 fan and filter units could not be reached. Therefore, the system is inoperabl This condition existed until October 26, 1987, when the shift supervisor '

was notified that a 50 foot section of hose was in use as a temporary replacement for the 75 foot section of hos He took immediate action to have another length of hose added to the hose at fire hose station HCS-3 Technical Specification 3.7.9.3.a requires that with one or more fire hose stations inoperable, an additional equivalent capacity fire hose shall be routed from an operable hose station to the unprotected area within one hour. Since this corrective action was taken more than one hour after the fire hose station was made inoperable, this is a violation of TechnicalSpecification 3.7.9.3 (346/87031-04(DRS)). Although the Shift Supervisor'saction was prompt and appropriate, the analysis and reporting of the eventwere tardy. The event date was October 22, 1987, the discovery date was October 26, 1987, and the report date was December 28, 1987. In .

the LER, the licensee incorrectly identified the event date as November 25, !

1987 and did not explain the difference between the event date, the discovery date, and the report date as discussed in NUREG 1022, Supplement j The shift supervisor also initiated Potential Condition Adverse to I Quality Report (PCAQ) No.87-059 The licensee reviewed the PCAQ and

, during a November 25, 1987 review, determined that a 75 foot section of i hose was necessary to reach all equipment important to safety in Room 515.

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The inspectors discussed this event with the Region III fire protection i specialist, and concluded that the event was not safety significant. This

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conclusion was reached because fire detection equipment is installed in Room 515 and was available to provide early notification of a fire in the room; the room does not have an abnormally high combustible loading; and the 50 foot hose was available for initial fire fighting, providing coverage for most of the roo No other violations or deviations were identified in this are I

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. IE Bulletin Followup (92703)

IE Bulletin 87-02, Fastener Testing to Determine Conformance with Applicable Material Specification The inspectors reviewed the licensee's records of fastener usage and fastener warehouse inventor The inspectors also observed the fastener storage area and inspected selected fasteners. The inspectors and the licensee personnel then removed fasteners from stock for testing. Additional fasteners were selected when it was found that the initial sample selection included several fasteners from the same material "heat". The inspectors observed the fasteners for proper identification prior to shipmen No violations or deviations were identified in this are . Training On December 9, 1987, the licensee was certified as a full member of the National Academy for Nuclear Training (NANT) when INP0 accredited four licensee training programs - shift technical advisors, chemistry technicians, radiological protection technicians, and technical staff and managers. INPO has now accredited a total of ten training programs Which qualifies the licensee for full membership in NANT, No violations or deviaticas were identified in this are . Onsite Followup of Events (62702 and 93702)

During the inspection period, the 1.icensee experienced several events which required prompt notificaticr. of the NRC pursuant to 10 CFR 50.7 The inspectors pursued the events onsite with licensee personnel. 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 recurrenc The specific events are as follows:

• Reactor trip caused by loss of instrument ai * Unusual Event due to low water level in ultimate heat sink No violations or deviations were identified in this are . Emergency Preparedness (82701)

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On December 10, 1987, the licensee conducted an unannounced after hours emergency response drill. The drill scenario consisted of a resin spill in the fuel handling area with one person becoming contaminated. The emergency response team responded within the allotted team with one exception. However, there were sufficient personnel on site to fill the !

position. Both the Emergency Operations Facility and Technical Support j 9 l

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Center were fully manne The licensee corrected most of th l deficiencies noted in the previous unannounced after hours dril The inspectors observed the drill and considered it to be suess/u I

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No violations or deviations were identified in this are j Radiological Environmental Monitorino (80721) i 1 On December 2, 1987, the inspectors were notified that the licensee had found low but detectable levels of Iodine-131 in a sample of sewage sludge from Toledo that was being applied to farmland about 2.7 miles  !

west of the plant. On December 3,1987, the resident inspector l accompanied licensee personnel and representatives of the State of Ohio r and Ottawa County to the general location of the sludge spreading. Soil i samples (control sample) were taken from three locations on land where ,

the sludge had not been applied. In addition, sludge samples were taken i

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from the sludge application equipment. The samples were independently analyzed by Toledo Edison, the State of Ohio and the NRC. . The NRC samples were returned to the Region III office on December 8, 1987, and l analyzed using gamma spectroscopy on December 9. The results (summarized *

l in Attachment 2) confirmed the presence of Iodine-131 in the sludge and  ;

l failed to identify it in the control sampl Region III inspectors' l l compared the NRC results with the results obtained by the licensee and i the State of Ohio. The NRC sludge result was not inconsistent with the .

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licensee's value given the inherent uncertainties in using counting  !

efficiencies not specific to this medium. No other man-made nuclides ,

were positively identified except for expected fallout cesium-137 in  ;

two of the three controls. Based on these analyses, it is concluded that  !

the radioactivity in the environmental samplos is not attributable to the '

Davis Besse plant, i No violations or deviations were identified in this area, 1 Team Inspection  !

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As noted in Paragraph 13 of Inspection Report 50-346/87026, staff members j of the Office of Nuclear Reactor Regulation conducted a review and inspection of the Davis-Besse auxiliary feedwater (AFW) system to [

independently assess the reliability of the system. The scope of the .

inspection included-

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• a partial walkdown of the AFW system, specifically, equipment in the AFW pump, and components of the condensate drain system in the Detergent Waste Drain Tank room;

• observing a surveillance test on AFW train 1-1;  :

• observing a periodic jog test on AFW train 1-2;

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• discussing with system engineers operating procedures for surveillance testing, jog testing, and condensate draining;

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• reviewing plans to modify condensate drains and steam admission '

valves, and refurbishing governor valve Also_ examined were documents pertaining to the:

• acceptable amount of condensate accumulation in turbine casing;

• test results of turbine starts without draining the casing for  !

various periods;  ;

• AFPT performance on system challenges;

• records of condensate collected from periodic drainin Based upon the inspection, the inspectors concluded that the licensee took proper corrective actions to ensure that the installed AFW system will operate as designed if called upon and has taken the necessary actions to redesign and modify portions of the system during the fifth refueling outage. The inspectors concluded that the material condition of the AFW system is adequate to allow the system to perform its safety i function reliabilit i No violations or deviations identified in this are . Enforcement Conference

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! On November 19, 1987, an enforcement conference was held in Region III

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l regarding a failure to maintain the integrity of a vital area security barrier. Details of the event are described in Inspection

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j j Report 50-346/87028. The enforcement conference is described in

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Inspection Report 50-346/87032. On December 18, 1987, the NRC issued a Notice of Violation and a proposed imposition of a civil penalty in the amount of $25,00 .

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i 1 Unresolved Items l  :

! Unresolved items are matters about which more information is required in  !

, order to ascertr.in whether they are acceptable items, violations, or

{ deviations. An unresolved item disclosed during the inspection is  ;

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discussed in Paragre.ph 3.

a 15. Open Items ,

Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspectors, and which involve some action on the part of NRC or licensee or both. Open items disclosed during the j inspection are discussed in Paragraph 3.

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16. Exit Interview (30703)

T5e 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, ;

the inspectors have determined there is no proprietary data contained in !

this inspection report, j

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ATTACHMENT 2 TABLE: ACTIVITY IN SLUDGE AND S0IL SAMPLES ACTIVITY (pCi/g)t 2 SAMPLE N TYPE 1131 Cs137 K40 Ra226 Th232 87-592 Control <0.08 0.1510.04 14.51 .6210.07 1.31 Control <0.09 0.1210.02 13.51 .6410.06 1.21 Control <0.08 <0.08 10.31 .4910.07 1.11 Sludge 0.291.05 <0.07 4.31 < <0.4 l One standard deviation random uncertainty Systematic uncertainty estimated at 50%

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