IR 05000346/1988012
| ML20245K006 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 09/21/1988 |
| From: | Barton T, Defayette R, Mccormickbarge, Ward K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20245J994 | List: |
| References | |
| 50-346-88-12, NUDOCS 8907030246 | |
| Download: ML20245K006 (22) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
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Report No. 50-346/88012(DRP)
. Docket No. 50-346 License No. NPF-3
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Licensee: Toledo Edison Company Edison Plaza, 300 Madison Avenue j
Toledo, OH 43652
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Facility Name: Davis-Besse Nuclear Power Station, Unit 1 Inspection At: Davis-Besse Site, Oak Harbor, Ohio Inspection Conducted: May 4, through August 2, 1988
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. Inspector:
. W. McCorm c - arg 7/ ll /
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. D. Ward Date T[2/!sI
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. Approved By:
R e, Chi 9 d/
Reactor Projects, Section 3A DHe Inspection Summary Inspection on May 4, through August 2, 1988 (Report No. 50-346/88012(DRP))
Areas Inspected: Special, unannounced safety inspection with regard to a series of allegations related to the operation of the Davis-Besse facility.
Results: One violation with several examples was identified in Paragraph 2 for failure to follow procedures.
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Toledo Edison Company
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We will gladly discuss any questions you have concerning this inspection.
Sincerely, Edward G. Greenman, Director Division of Reactor Projects Enclosure:
Inspection Report
No. 50-346/88012(DRP)
cc w/ enclosure:
L. Storz, Plant Manager
DCD/DCB(RIDS)
Licensing Fee Management Branch
Resident Inspector, RIII
James W. Harris, State of Ohio
Robert M. Quillin, Ohio
Department of Health
State of Ohio, Public
Utilities Commission
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DETAILS
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1.
persons Contacted
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Toledo Edison Company
- D. Shelton, Vice President, Nuclear
- L. Storz, Plant Manager
- P. Hildebrandt, Engineering General Director
- R. Schrauder, Nuclear Licensing Manager
- T. Myers, Nuclear Licensing Director
- L. Ramsett, Director, Quality Assurance
G. Honma, Compliance Supervisor - Licensing
M. O'Reilly, Corporate Attorney
Other plant personnel were contacted during the inspection.
NRC
- P. M. Byron, Senior Resident Inspector
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D. C. Kosloff, Resident Inspector
R. W. DeFayette, Chief, Section 3A
- J. W. McCormick-Barger, Reactor Inspector, Branch 3, DRP
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- Denotes those persons present at the exit meeting on August 1, 1388.
2.
Allegation Reviews
Beginning in early 1988, the NRC received several allegations primarily
concerning activities associated with the Quality Control area.
The NRC
performed a series of inspections which included interviewing Quality
Assurance and Quality Control management personnel and approximately
one half of the Quality Control inspectors at the Davis-Besse site.
Additional allegations were obtained during the inspections. A
description of a portion of these allegations and the results of the
inspections of associated concerns are provided below or in Inspection
Report Number 50-346/88027.
a.
Allegation RIII-88-A-0003 (Closed)
(1) Concern: The Quality Control (QC) manager pressured a
QC inspector to sign a Maintenance Work Order (MWO) for
work on the control room emergency ventilation system,
even though it contained information that was a procedural
violation (non-approved post maintenance test instruction
for a time delay relay).
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.NRC Review: The inspector contacted the QC inspector alleged to
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be involved with the MWO. The QC inspector stated that the
control room emergency ventilation. system had been taken
out-of-service to perform periodic maintenance.. During post
maintenance testing, the test instructions provided in the MWO
did not work since plant personnel were unable to obtain
satisfactory test results. After plant personnel tried several
times to perform the test, an individual arrived on location
with an-unapproved vendor test instruction. Plant personnel
used those vendor instructions and with the QC inspector present
obtained satisfactory results. The QC inspector informed the
workers that they would have to incorporate the vendor
instructions into.the MWO, and reperform the test per the
revised MWO.
Plant personnel agreed to do so.
Later, the QC
inspector heard that plant management agreed to incorporate the
vendor test instructions into the MWO, but would not agree to
reperform the test since the QC inspector had previously
witnessed the test prior to it being. incorporated.
When the revised MWO was returned to the QC inspector for his
approval, he refused to sign it.
Later, the QC inspector was
informed that.the Quality Assurance (QA) Director, after
reviewing'the circumstances surrounding the matter, instructed
the QC supervisor to have the inspector sign the MWO based on
his witnessing of the test. prior to it being incorporated into
the MWO package. At this time the QC inspector signed the MWO.
The QC inspector stated that the QC manager was not, to his
knowledge, involved with the approval of the MWO in question.
The NRC inspector reviewed the MWO in question (MWO 3-87-1174-01)
and found that the MWO documented the performance of the
unapproved instructions prior to it being incorporated into the
MWO. This instruction was used to functionally check the timing
sequence of the oil failure safety control switch, PSL-28017,
and associated timer of the control room emergency ventilation
system condensing unit. The MWO had subsequently been revised
to incorporate the vendor instruction and was approved by
appi priate plant personnel and signed by the QC inspector.
Conclusion:
The allegation that the QC manager pressured a QC
inspector to. sign an MWO even though it contained information
that was a procedural violation (non-approved post maintenance
test instruction) was not substantiated. The test instruction
was approved (via review and approval of the revised MWO).
Also, there was no evidence found to link the QC manages to the
incident.
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However, the performance of the test on February 7,1987,' prior-
to it.being incorporated into the MWO package is a violation of
. Davis-Besse Nue' ear Group Procedure NG-DS-205 " Plant Maintenance,"
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dated November 23,'1986.
Section 6.7.4 of that procedure' states
that the Assistant Plant Manager, Maintenance, shall ensure that
only work specified in the maintenance work package is performed.
This is the first of three examples ~of a violation of 10 CFR 50,
. Appendix B,. Criterion V, which states -in part, that activities
affecting quality shall be accomplished in accordance with
documented instructions and procedures (346/88012-01A). The'
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alleged decision made by the Quality Assurance Director to
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have the QC inspector sign the revised MWO is not considered '
safety significant since it was based on the QC inspector's
witnessiig of the acceptable performance of the test. The QC
inspector did state thet he felt pressured to sign the MWO;
however,.he stated that once the issue was raised to the Quality
Assurance Director's level, he saw no need to continue to press
the issue and subsequently signed the MWD.
This concern is
considered closed.
(2) Concern: The Quality Control (QC) manager was pressuring the
Authorized Nuclear Inspector (ANI) to accept radiographs of
welds on piping being fabricated for the Feed and Bleed
Modification to the Makeup System, even though the radiographs
did not meet ASME code requirements.
NRC Review.:
The inspector interviewed the Authorized Nuclear
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Inspector (ANI) concerning the alleged pressuring of the ANI
by the QC manager.
The ANI indicated that on several occasions
the QC manager had pressured him to accept radiographs which
he had initially questioned. The ANI stated that in no case
had the QC manager succeeded in convincing him to accept a
suspect radiograph without first receiving back-up information,
such as the results of additional radiographs, or receipt and
review of the Toledo Edison's Corporate level III inspector's
interpretation of the original radiogroch.
The ANI also stated
that the QC manager had threatened to r wove him from the site
because of a confrontation between the QC manager and the ANI
over the interface between QC personnel and the ANI.
The ANI
felt this problem was apparently the result of the QC manager's
misunderstanding of the ANI's position, function, or relationship
at the Davis-Besse plant. A telephone call from the QC manager
to the ANI's management reportedly clarified the ANI's
relationship to the QC manager and resolved the issue regarding
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the ANI
The inspector questioned nearly half of the QC inspection staff
concerning QC manager's pressuring of the ANI.
Several QC
inspectors stated that the QC manager had and does, in their
opinion, harass the ANI.
However, the QC inspectors had never
known of a case where the ANI had given in to the QC manager's
pressure or harassment.
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The QC manager was questioned concerning his alleged pressuring
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of the ANI to accept unacceptable welds. He stated that several
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times he had questioned the ANI's rejection of welds but had
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never intended it to be considered as pressuring him to accept
substandard welds. He stated that he had responsibility for
the non-destructive examination (NDE) program'and felt it was
his responsibility to question the need to perform additional
NDE when he. felt it was unnecessary.
He stated that in all
cases, if the ANI continued to feel that additional. radiographs
were necessary, then they were performed without further delay.
Conclusion:
Interviews with the ANI, QC manager, and other QC
staff members indicated that the QC manager has questioned the
ANI concerning the ANI's rejection of welds previously approved
by the licensee's NDE contractor, but no information was provided
that would suggest that the ANI accepted substandard welds as.
a result of the QC manager's questions. Although the~QC manager
questioned the ANI's rejection of some radiographs approved by
the licensee's NDE contractor, the QC manager did not appear to
be pressuring the ANI into accepting welds that did not conform
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to ASME code requirements; this appeared to be more of a matter
of radiograph interpretation disagreement discussions.
In
addition, all radiographs that were deemed to be unacceptable
by the ANI were reportably re-radiographer, and then reworked
or accepted based on acceptable new radiographs. This concern
is considered closed.
(3) Concern:
Several large completed MW0s were transmitted to QC
at 2:00 p.m. for its final review.
The QC manager instructed
two inspectors to review the packages (about two feet thick)
and not leave until it was done.
It was ' alleged.that this-
amount of work would normally take one inspector two days to
review.
NRC Review: The inspector contacted the QC inspectors alleged to
be involved with the. review of the work packages in question.
The
QC inspectors recalled their review of the MW0s and: stated that they
had already worked a full day when the QC manager told them that
the packages had to be reviewed prior to them leaving the site.
The QC inspectors stated that, as part of their approval, they had
to verify dimensional tolerances associated with design changes
and/or reinstallation of hardware.
The QC inspectors added
that these verifications were performed.
The inspectors stated
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that they performed the required review. They also said that
the packages had been reviewed to a lesser extent previously
which helped in that the packages had been returned to the
plant staff to correct the earlier identified problems prior
to delivering them to QC for their final review.
Both
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QC inspectors felt that a better job could hu e been done, had
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more time been allotted. An unsuccessful attempt to obtain-and
review the MW0s in question was made by the inspector, because
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neither the alleger nor QC inspectors involved could recall the
-actual MWO numbers.
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The inspector interviewed approximately half of the current QC
inspectors and asked if they felt that the work. load is or has
been excessive.
In general, the inspectors felt that the work-
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load was not excessive but did state that in the past during the.
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end of outages work loads tended to increase resulting in long
work days.
The inspector also discussed this matter with the QC manager.
The QC Manager stated that, on occasion, packages are sent to
QC that are. critical path to other plant activities and have
required QC staff to work extra hours ~to accomplish the required
reviews. Management did not believe this was unrealistic, nor
did they expect the inspectors to do less than an adequate job.
Conclusion: The review performed above substantiated that the
time allotted to the QC inspectors to review the work packages
was restricted.
However, the inspectors directly involved with
the task stated that they did review the entire packages
including performing in-containment as-built verifications.
Based on lack of identification of specific deficiencies
associated with review of the packages, and the response
received from other QC inspectors concerning workload, this
concern is not safety significant and is considered closed.
(4) Concern: Two QC lead inspectors were demoted as a result of
expressing differences of opinion with the QC, manager at
meetings.
NRC Review: The inspector interviewed the two.QC inspectors
alleged to have been demoted.
Neither inspector identified a
specific example of them raising safety issues that would have
accounted for their demotions.
Both inspectors indicated that
their differences of opinion related to administrative matters.
Conclusion:
Based on lack of specific examples of the
inspectors' raising safety issues which could have resulted
in employment discrimination under 10 CFR 50.7, this concern
was not reviewed further and considered closed.
(5) Concern: A PCAQR was written on the use of a non-destructive
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examination (NDE) cleaner with an expired shelf life. The QC
manager refused to sign the PCAQR and directed the PCAQR
initiator to continue to use the cleaner until the QC man?ger
could get the matter resolved.
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NRCReView: The inspector contasted the indiv'idual alleged'to
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have Tnitiated the PCAQR. The individual. stated that he had
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initiated a PCAQR.to' address -the expired two year shelf life of
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NDE cleaner but it had not been. issued because the QC manager
had refused to sign it.. The individual stated that the QC
manager told him to continue using.the cleaner and subsequently
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provided him with copies of two intra-company memoranda and a
letter from the vendor. This information stated that the NDE
cleaner shelf life was based on its ability to maintain its'-
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aerosol and that as long as the aerosol pressure was sufficient
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enough to dispense the cleaner in a spray and the. container did
not evidence any leakage of the contents, then the product had
an unlimited shelf. life.
The inspector obtained and reviewed copies of the memoranda'and
vendor letter and found them to agree with the QC inspector's
statements above and technically resolve the shelf life issue
(January 15, 1988 memo from the Engineering Assurance manager to;
the Quality control manager (QAD-88-40032), May 8, 1984 memo-
from a Toledo Edison employee to the QC supervisor, and an
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April 30,1984 letter from.the NDE supply. vendor to Toledo
Edison). The inspector also contacted the QC manger and'
discussed the PCAQR issue. The QC manager vaguely-recalled.the
NDE cleaner fluid issue but did not recall a PCAQR being
prepared or his refusing to sign it.
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Conclusion: The inspector was unable to substantiate the
concern that a PCAQR was not processed (as required per
Davis-Besse procedures). However, other examples of PCAQRs
not being appropriately processed by the QC manager were
discussed in Paragraphs 2.e.(2) and 3 of this report and a
potential violation of NRC requirements was identified.
Based
on interviews with the PCAQR initiator, the QC manager, and
a supervisor from QA's Engineering Assurance organization-
no technical concern with Davis-Besse's use of NDE cleaner
was found to exist. This concern is considered closed.
(6) Concern: AnAuditFindingReport(AFR)waswrittenagainst
QC for lack of qualification cards. At the next to last day
of the AFR responding period (120 days) new cards were produced
and the QC manager ordered inspectors to sign them in one day.
Most people just signed them rather than read the required
procedures first, since it would take three to four days to
read all the material.
NRC Review: The inspector interviewed nearly half of the
Davis-Besse QC inspectors and asked them if they were provided
adequate time to complete their qualification cards.
Inspectors
that were present during the period when the AFR was written
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-(AFR No. AR-87-INSPT-01-04) concurred that.the QC manager had
instructed them to complete.their qualification cards prior.to
leaving work-that night. Some of the inspectors-refused to do
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so and were not reprimanded for their actions. Others
interviewed stated that they stayed at-work very late and
attempted to review each procedure.. These-individuals admitted
that th'ey had not read every word of each reading assignment,.
but stated that many of the assignments covered documents that
they had previously read and/or worked with:and ' felt that they-
were already familiar with-them. New inspectors arriving.onsite
since the audit finding indicated that they have been.provided
ample time to perform required actions as specified on their
qualification cards.
The inspector reviewed the qualification cards of selected QC
inspectors and found them to generally agree.with the above,
in that some were signed off in a one-to two day period and
others were not.
The inspector interviewed the QC manager and questioned him
concerning the qualification card matter. The manager stated
that'he was-told by QA to get the inspectors to complete the
cards prior to the 120 days responding period. He, therefore,
instructed his inspectors to stay as late as necessary to comply -
with the request. He also contacted the QA. department to obtain
relief. He stated that relief was provided in the form of the
grandfathering process for incumbent inspectors as discussed
below.
During review of the audit finding and qualification cards, the
' inspector noted that some qualification cards were not completed
in a timely manner (one file was found to still not be completed
nearly)eight months after the QC certification procedure was
issued. The licensee had pre
January 7,1988 (QAD-88-20007) pared a memorandum dated
, to the QA audit group stating
that incumbent inspectors would comply with QA certification
procedure (QADP 2.2, " Qualification and Certification of
Personnel Performing Quality Control Activities," dated
October 30, 1987) when the incumbents become due for
decertification. Although Paragraph 6.4.7 of QADP 2.2 allows
incumbent inspectors to be waived from completing the
" Performance Demonstration" portion of the QC Generic and
Discipline qualification cards, no such provision was provided
for waiving the reading requirement identified on the applicable
qualification cards.
Failure to comply with QADP 2.2 or revise
it to correspond with the "grandfathering process" proposed-in
the January 7,1988 memorandum described above is another
example of the violation described in Paragraph 2.a.(1)
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(346/88012-01B).
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Conclusion: The allegation was substantiated in that QC
management had requested that the inspectors complete their
qualification cards in a short period of time.
However, from
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interviews with a large sample of inspectors, some inspectors
stated that they refused to comply with the request and others
maintained that they completed the cards based on either
reviewing the procedures or having been already familiar with
some of the procedures based on their previous experience with
them during performance of work activities.
It does not appear
that inspectors who refused to comply with the request received
disciplinary action. The Qualification cards were an
enhancement to the QC inspectors' training and certification
program, although inappropriately implemented, it was found to
provide assurance that QC inspectors receive uniform plant
indoctrination. Based on the above, this allegation has no
safety significance, other than as identified in the related
violation identified above.
This concern is considered closed.
b.
Allegation RIII-88-A-0010 (Closed)
(1) Concern:
The contract between a contract QC organization
and the Toledo Edison Company was due to expire and renewal
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was uncertain.
This uncertainty was distracting the QC
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inspectors and this may have led to unintentional errors.
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Also QC coverage may be affected if the contract organization
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leaves the site.
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NRC Review:
Replacement of one contracting firm with another is
a common practice and some disruption in QC coverage can be
expected. The inspector interviewed most of the contract QC
inspectors associated with the contract in question, and was
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consistently told that they continued to perform adequate
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inspections. Management offered permanent employment to many of
the contract inspectors in question. This direct recruitment
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effort and the extension of the contract resulted in the loss of
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only a few of the contract inspectors.
In addition, the
transition from one contracting firm to another was particularly
smooth due to management's early recruitment of a new contractor,
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and the delay of the 1988 outage.
New inspectors were found to
have been provided ample time to perform required training and
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become familiar with the Davis-Besse plant.
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Conclusion: This concern was not substantiated.
No evidence
of QC inspection degradation was provided or identified.
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This concern is considered closed.
(2) Concern: A Davis-Besse employee furnished false information on
his resume.
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NRC Review:.The inspector contacted the alleger to get specific
details concerning the resume infora tion that the alleger
believed to be false.
The information concerned the. time frame
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that the employee spent at a nuclear power plant that was known
to have been cancelled. The concern was based on this public
knowledge and not on specific first. hand information.
The inspector obtained a copy of the employee's resume and.
determined that the resume indicated that the. employee worked
for a contract firm at the time in question and that during an
approximate threeLto four month period when the plant in-
question.was. cancelled, the. employee reportedly worked at the
plant.and at two other. power plant projects performing ~various
activities. The inspector contacted the utility with the-
cancelled plant and was. unable to obtain information about the
employee in question since he was a contractor and the utility
'did not maintain. personnel files on contractor' staff. -The
inspector contacted 'the contract firm and received affirmative.
information concerning the employee's employment with the firm
during the time frame in question. However, the contract firm
would not release any-information concerning the specific
activities performed by the employee.
In addition ~to the'above employment verification, the inspector
verified that certain other more extensive portions of the
resume were correct through discussions with NRC inspectors
. familiar with the individual.during various time frames. This
additional verification provided sufficient information to
conclude that the employee had appropriate experience for the
position held.
Conclusion:
Based on lack of specific first hand knowledge of
false information and the inspection described above, this
concern was not substantiated.
This concern is considered
closed.
(3). Concern:
Some painting applications that have been performed
at Davis-Besse do not conform to Davis-Besse painting / coating
procedures. These discrepancies have been identified in
nonconformance documents and accepted as-is without proper
justification and/or revisions to applicable painting
procedures.
It was alleged that areas of the plant were not
painted adequately or wrong paint was used and some areas were
not painted at all.
The bottom of pipe support base plates were
provided as examples of items that have been installed without
proper coatings (i.e., installed with prime coat only).
NRC Review: This concern was initially transmitted to the
licensee on June 14, 1988 (Attachment No. 1), for its review and
action and a response was received from the licensee dated
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July 22, 1988 (Attachment No. 2).
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The inspector reviewed the licensee's response to the above
concern and obtained a copy of Potential Condition Adverse to
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Quality Report (PCAQR) No. 88-0078. The PCAQR described in
general the same matters identified in this concern.
The
inspector also reviewed Davis-Besse Maintenance Procedure
MP-1701.48 (DB-MM-09637.06), " Application of Protective
Coatings Outside Containment," Revision 01, Dated August 25,
1987.
The. licensee's acceptance of the primer only painted pipe
support base plates was found to be in accordance with the
provisions of the maintenance procedure.
Section 5.1.6 of that
procedure allows the licensee to use design engineering approved
alternate painting techniques in lieu of-the procedure. The
licensee's_ design engineering group approved, in Request For
Assistance (RFA) 88-0237 initiated as a result of the
identification of the QC inspector's concern, the primer only
painting technique based on its limited application and lack of
exposure to corrosive environments of the surfaces in question.
Primer coat acceptance was further based on the Steel Structures
Painting Council's Painting Manual.
The inspector reviewed this
manual and determined that the licensee's actions were
technically based on the manuals statements concerning the
primers function as an anti-corrosion coating and that the
primer coated surfaces in question were protected from severe
environmental conditions for which a finish coat normally is
used for protection of the. primer coat. The allegation
concerning areas not painted or painted with the wrong paint
did not include specific examples.
From review of the specific
information provided for the allegation concerning the use of
primer coat only, which resulted.in that concern not being
substantiated, and lack of specific examples for the other
concerns, further review of the paint program was not performed.
The licensee's review and disposition of the above PCAQR
(No. 88-0078) was not thorough, in that the licensee should have
concluded that the MWO originator should have originated the
RFA requesting the painting deviation prior to issuing the MWO
and that the supports were installed prior to the RFA being
issued.
Rather than identifying the above procedural
deficiencies, the licensee concluded that the PCAQR should
be invalidated based on the MWO still being open and the
availability of the RFA process to resolve the concern. A
detailed review of the PCAQR processing and disposition program
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will be performed at a later date. This activity and the above
discrepancy will be tracked as an unresolved item (346/88012-02).
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' Conclusion:. Based on.the review of the licensee's submittal
concerning this matter and the review of the licensee's
procedures, specification, _ and deficiency ' report (PCAQR), -this
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concern was not' substantiated.in that the' licensee's actions'to
accept. primer coat only painting was within.the licensee's
administrative program and based on information obtained_or
justified in industrial standards.
This concern is considered
closed.
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(4) Concern: An insufficient amount of time was allotted for the
quality control inspectors to read documents' required for
qualification following the issuance of Toledo Edison Intra-
. Company Memorandum QAD-88-20030.
NRC Review: The memorandum in question concerns Quality-
Assurance's response to the auditing group for Audit Finding
AR-87-INSPT-01-04. This is the same. audit finding and concern
discussed in allegation RIII-88-A-0003, Paragraph 2.(a).(b).
Conclusion:
Based on the review discussed in Allegation
RIII-88-A-0003, Paragraph 2.a.(6), this matter was
substantiated and found to not have safety significance.
This concern is considered closed.
(5) Concern: Approximately 12 new contract QC inspectors were
given a certification test the week of February 8,1988; only
one passed. The contractor then gave copies of a test to the
.
inspectors (that failed) for them to study. The in,pectors
were then retested and all passed,
It was not known if all
the tests were the same.
NRC Review: The inspector contacted the only contract employee
who was alleged to have first hand knowledge of the allegation.
This individual could not recall any individual that had
been provided a copy of a test prior to taking'the.
qualification test.
At Davis-Besse, contract QC inspectors can be qualified by
the contractor, rather than the licensee, if the contractor's
organization is on the approved vendors' list and its
certification program has been approved by the Davis-Besse
QA group.
Because failed examinations are not maintained in the files and
the individual alleged to have had first hand information could
not support the allegation, the inspector could not identify
anyone who had failed examinations.. Interviews with about half
the contract QC inspectors revealed that they were required to
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take a qualification test prior to being referred to the licensee
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for: employment consideration. All those interviewed stated that
they passed on the first try without reviewing a copy of a test.
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The QC. inspectors stated that had they failed the test,'they
would not have been' considered for employment nor would they.
have been allowed to retake the test for at least 30 days. The
QC ~ inspectors also stated that' they knew of no-incident.of a
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testing irregularity similar to that described above.
The inspector also reviewed a sample of contract QC inspectors
qualification records and found no testing irregularities or
inspectors with weak backgrounds and/or experience.
Conclusion: Based on a lack of specific details and the review
identified above, the inspector was unable to substantiate the
concern. This concern is considered closed.
(6) Concern: Two new contract QC inspectors were certified as
Level 2. inspectors for disciplines.in which they had not.
previously worked. One was inappropriately certified as an
electrical inspector and the other as an instrumentation and
control (I&C) inspector.
NRC Review: As stated in the previous paragraph,'the licensee
had provisions in its procedures and contracts to accept the QC
certifications provided by its contractors. The licensee also
stipulated in its procedures and contracts that the Level.3
Inspectors (QC supervisors)'for the various disciplines had the
final say concerning certifications'and could require additional
testing, training, or other activities prior to accepting the
contractor provided certifications.
Interviews with the QC
supervisors revealed that during their reviews of the contract.
QC inspectors' resumes they identified several individuals with
backgrounds that did not seem appropriate for the inspectors'
certifications provided..The supervisors stated that the
contractor's bases for the inspectors' certifications were the
successful passing of the tests provided and~the inspectors'
prior work experience.
Since the I&C/ electrical test had few
questions concerning the I&C disciplines, passing the test based
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on a strong electrical background would be possible.
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addition, the contractor accepted construction I&C inspection
experience as acceptable for the I&C certification. The
supervisors stated that operating plant I&C activities are
substantially different than that of construction I&C where
instrument tubing may be the activity witnessed by the I&C
inspector.
The supervisors prepared an I&C test that was designed to test
the new inspector's knowledge of operational I&C activities.
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This-test was administrated to the'. contract I&C certified.
'QC inspectors. 'Most of the inspectors were found to have
significant weaknesses.in the I&C area. As'a result, the
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supervisors limited these inspectors certifications to the
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electrical discipline (the discipline where they possessed
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adequate knowledge'and background). The supervisors also
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required.that, in the future' the contractor provide.only I&C.
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inspectors with strong' operational I&C experience. They also
closely reviewed. additional inspector resumes and qualification
submittals, prior to accepting the inspectors:for employment,
to assure well qualified I&C inspectors were being procured.
The inspector reviewed selected contract QC inspector
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qualification records and found them to be.in accordance
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with Davis-Besse procedures.. Employee. background information
appeared to be'in agreement with the certifications accepted
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by the QC supervisors.
The individual' alleged to.have had first hand knowledge of the
concern could not substantiate the issue.
No specific example
of an inappropriately certified electrical QC inspector was
identified by the alleger or NRC inspector during this review.
Conclusion: This allegation was substantiated in that the
QC contractor was providing certified QC inspectors with
inappropriate backgrounds for the QC inspector task required by
the certifications at Davis-Besse. However, the QC supervisors
responsible for approving these certifications identified this
weakness and took appropriate corrective actions as provided
for in both the contractor contract and the QC qualification
procedures. Therefore, the licensee met its ' requirements and
there is no safety significance to this concern. This concern
is considered closed.
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c.
Allegation No. RIII-88-A-0070 (Open)
Concern: QC procedures are not up-to-date with revised plant
procedures causing QC inspectors to not be in verbatim compliance
with QC procedures since activities required to be verified by QC
procedures may no longer be required by revised plant procedures.
QC procedures have many inconsistencies. QC management has not
been aggressive in correcting this problem.
Numerous specific examples of procedural problems were arovided
for Toledo Edison Quality Control Instruction (QCI) 3144, Revision 9,
dated May 22, 1986, "FCR/MWO Package Maintenance, Inspection and
Turnover," and QCI 3I03, Revision 13, dated May 22, 1986,
" Maintenance." These examples included specifying designated QC
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personnel to perform activities that are currently being performed by
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other.than designated personnel (i.e., inspectors versus supervisors),
referencing or specifying the wrong and/or deleted.' procedures, and
requiring non-safety-related work activities that are currently not
being performed.
It was also alleged that other department's procedures (i.e.,
-Maintenance, Operations, etc.) have the same type problems and
are not being adequately corrected.
NRC Review: The inspector informed the licensee of these procedural
concerns and informed them of the specific problems provided.to the
inspector by the allegers.
In response to this concern the licensee
performed an audit of QC procedures and presented its findings to-
NRC Regional Management on August 18, 1988. The audit report included
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a review of all Davis-Besse QCI's and revealed numerous similar
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findings as those described in the allegation.
In response to
Regional concerns about these QC procedural problems and the
possibility of similar problems in other departments (which was also.
alleged), the licensee committed to a number of corrective actions in
a letter dated August 26, 1988, to the NRC' Region III Regional
Administrator (Attachment 3).
In this letter, the licensee committed
to correct the known procedural problems, perform an extensive
interdisciplinary audit of Davis-Besse procedures, review the
procedure change process, and perform a root cause evaluation for
the procedural problems.
The licensee committed to complete these
activities by November 10, 1988.
Followup on the results of the
licensee's findings and corrective actions will be tracked as an
unresolveditem(346/88012-03).
During review of this item, the NRC inspector was informed that
the QC manager had attempted to direct his QC inspectors to violate
Nuclear Mission Procedure, NMP-QA-702, " Potential Condition Adverse
to Quality Reporting". This occurred when the licensee added section
6.1.14 to the PCAQR procedure to allow PCAQRs to be closed based on
the initiation of a 7 prefixed MWO.
Since 7 prefixed MW0s cannot be
voided, they would serve as the tracking mechanism for assuring that
the required work to resolve the PCAQR would be completed.
However,
section 6.8 stated that QC inspectors were to sign the PCAQRs only
after all corrective action work had been completed. When the QC
inspectors refused to sign the PCAQRs due to the procedural conflict
described above, the QC manager wrote an intra-company memorandum
dated August 24,1987 (QAD87-50173), to his staff directing them to
signoff on the PCAQRs if 7 previxed MW0s were initiated. The QC
manager also stated that the procedural conflict was brought to the
attention of Quality Systems (the QA group responsible for QA/QC
procedures) who would in the future be taking the appropriate steps
to revise the procedure to alleviate the conflict and better define
the intent of the procedure.
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The QC inspectors again refused to sign PCAQRs with 7 prefixed
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MW0s until the procedure was changed.
Due to this management /
. inspector conflict, a. meeting was called with the QC organization
and the.QA Director. At the conclusion of the meeting, the QA
Director agreed to resolve the procedural conflict prior to
requiring QC inspectors to sign the PCAQRs.
.Since the QC inspectors refused to comply with the QC managers'
memorandum, and the QA Director agreed to change the procedure
prior to requiring QC inspectors to sign the pCAQRs in question,
no violation of NRC requirements was identified. However, the
QC manager's attempt to work through a procedural problem rather
than fix the problem first, may partially account for the
numerous procedural problems identified in the QC area.
Conclusion:.This concern was substantiated.
Numerous additional
examples of QC procedural deficiencies were identified by a
licensee' audit and the licensee has committed to an extensive
program to review procedures from all disciplines. The NRC
followup and enforcement actions associated with this concern
will be tracked per unresolved item 346/88012-03. This concern
is closed.
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d.
Allegation No. RIII-88-A-0072 (Closed)
(1) Concern: QC inspectors only perform a percentage of weld
inspections for ASME Section III piping welds (50% for ASME
Class II and less than 50% for ASME Class III).
NRC Review: The inspector determined that Davis-Besse QC
inspectors perform 100% inspection on ASME Section III, Class I
welds. This includes fit-up (weld. preparation, pre-weld
cleanliness, alignment,.etc.).
For Class II at.least 50% of the
welds are inspected during fit-up and for Class III at least 10%
of the welds are inspected during fit-up. These percentages are
determined on a work package bases and could result in a greater
percentage of fit-up inspections being performed if, for
example, only one weld is required to be performed in the work
package.
In all cases, 100% of ASME Section III Class I, II
and III welds have at least a final visual weld inspection
performed. The licensee's program as described above was found
to be inaccordance with the requirements of the ASME code.
Conclusion: This allegation was substantiated in that ASME
Section III Class II and III welds may receive less than 100%
fit-up inspections. However, the licensee's program meets the
ASME requirements for weld inspections. Therefore, this concern
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has no safety significance and is considered closed.
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(2) Concern: Non-destructive examinations (NDE) are being performed
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at Davis-Besse by a contractor. The contractor submitted NDE
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procedures to the licensee for approval. These procedures were
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returned to the contractor with comments but never revised and
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returned to the licensee for final approval. The contractor is
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therefore currently working at Davis-Besse with procedures that
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have not been formally approved by the licensee.
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NRC Review: The inspector reviewed the procedures used by the
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NDE contractor and found that they were approved by the licensee
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with comments. The comments were attached to the front of the
NDE procedures and were minor in nature.
In accordance with the
licensee's contract with the NDE contractor, use of the
procedures with the comments attached is allowed. The contractor
is supposed to eventually incorporate the licensee's comments
and resubmit the procedures to the licensee for its final
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approval. This had been done prior to the inspector's review.
Conclusion:
This allegation was substantiated in that the
contractor's NDE procedures were being used prior to the
licensee's final approval. However, the contractual agreement
between the licensee and the contractor allowed the contractor
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to perform work in accordance with the procedures and the
attached licensee's comments.
This was a contractual rather
than a safety matter. This concern is considered closed.
(3) Concern:
Final approval of the weld travelers is performed
by the NDE contractor. This may not be in accordance with the
ASME code. Although the licensee need not have a qualified NDE
expert to approve the NDE performed by the contractor, the
licensee nevertheless should be approving the completed weld
travelers.
NRC Review: The inspector reviewed a sample of the licensee's
completed weld traveler packages and procedures related to weld
travelers.
The inspector also met with licensee representatives
associated with the Davis-Besse weld program to discuss this
concern.
From these reviews and discussion with licensee
representatives, the inspector learned that the NDE required by
the weld travelers is performed and signed off on the traveler
by the NDE contractor.
However, the final review of the weld
traveler is performed by the licensee's QC supervisor and the
licensee's special piping inspector.
The licensee's NDE
contractor's review and app-oval of NDE performed by the
contractor based on its approved NDE program is in accordance
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with the ASME code requirements.
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Conclusion: This allegation was not substantiated in that
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although the NDE contractor does sign off the traveler for NDE
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performed and reviewed by its organization, it does not perform
the final approval. of the weld, traveler. Although the method
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currently used by the license to perform and review NDE is
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acceptable, as a further program enhancement, the licensee
stated that it is attempting to hire a qualified Level'III NDE,
inspector to review the NDE contractor's work. This concern is
considered closed.
e.
Allegation No. RIII-88-A-0073 (Closed)
(1) Concern:
During early to mid-1987, a QA audit of QC activities'
was performed.
During this audit, one of the auditors (a. TED
contractor) was informed of problems in the QC area. After
being informed of these problems, the auditor allegedly informed
a QC inspector that he (the auditor) was told that he would lose
his contract if..he did not provide an audit report of the QC
area with little or no audit findings.
Subsequent to this
conversation, an audit report was issued with only one.or two
minor-QC related discrepancies identified.
Issues raised by the-
individuals were not addressed in the audit report.
NRC Review: The inspector interviewed the individuals alleged
to have provided problems to the auditor concerning the QC area.
Two of the three individuals could not recall any specific
concerns that they may have provided to the auditor but
remempered having general discussions with the auditor
concerning QC activities. The third individual stated that
he expressed concerns to the auditor about the QC manager's
decision to discard the QC office's copies of Facility Change
Request (FCR) packages, which were duplicates that were kept
around just in case a package in the field was lost. The
individual did not inform the auditor and apparently was not
aware that maintaining duplicate FCR packages was a procedural
requirement. The individual did state to the auditor that it
was a good idea to keep the copies around since if the field
package is lost, the associated inspection program must be
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repeated.
The inspector interviewed the QA auditor in question concerning
the audit report of QC activities (Audit Report
No. AR-87-INSPT-01).
The auditor vs.rified that he was involved
in conducting the QC audit, and was partially involved with
Audit Finding Report (AFR) No. 11, the only finding concerning
the QC department. This finding was not related to the FCR
package issue. The auditor stated that he had received concerns
from QC staff, but in his judgement, they held no significance
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'When specifica11y' asked about'his alleged statement to a QC
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inspector.concerning losing his contract if;he did not issue a
relatively clear audit report, the auditor denied that he made
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that statement. The auditor said he may have stated that if he
reported findings that were not based on plant requirements, he
might lose his contract..The auditor stated that his management
expected only findings that were solidly based and would hold up'
under plant management's scrutiny.
Subsequent to the above interviews, the inspector determined
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that procedure QCI 3144, "FCR/MWO Package Maintenance,
Inspection and Turnover," Revision 9, dated May 22, 1986, did
require that QC maintain duplicate FCR packages. The inspector
recontracted the QC auditor and asked him if he was aware of this
procedural requirement.
The auditor stated he.was not and would
~have processed an AFR if he had known of the procedural
requirement. The above issue concerning lack of procedural
comp 1.iance is addressed in Paragraph 2.c. of this report.
A review of the audit report and associated audit report
checklist indicated that although QCI 3144 was part of the scope -
of the audit, inspection-of the. duplicate FCR packages was not a
checklist item.
Conclusion:
The inspector was unable to substantiate that.the
QC auditor was told that he would lose his contract if he did
not provide an audit report of the QC area with little or no
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audit findings. Since the only' concern specifically identified
by the individuals to the QA auditor was not a regulatory
requirement and not identified to the auditor as a procedural
requirement, it seemed reasonable for the auditor to assume that
it was a concern that lacked a technical bases for an AFR.
Based on the above, this concern is closed.
(2) Concern No. 2: A QC inspector was informed by a plant worker
that a steamline (not in use) located internal.to the High
Pressure Condenser (HPE-7-1) had broken welds and cracks. The
QC inspector inspected the area, took pictures of the damaged
pipe, wrote a surveillance report on the discrepancy, and
notified the shift supervisor and his QC supervisor
(subsequently the QC manager) of the problem.
The QC supervisor
instructed the alleger to write a Potential Condition Adverse to
Quality Report (PCAQR) identifying the discrepancy.
The QC
inspector prepared the PCAQR and attended a meeting with
engineering and plant management to discuss the PCAQR in
question.
During the meeting, the QC inspector was chastised
for writing the PCAQR possibly because it would delay the plant
start-up (mode change).
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As a result of the meeting, the-QC supervisor wrote "Not Issued"
across the PCAQR.and told the QC inspector to " tuck this away in
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your files." The steamline broken welds and cracks were
subsequently identified by engineering in a non-PCAQR document
(either an MWO or FCR) along with an engineering justification
for not repairing the steamline until the next outage.
NRC Review: During. the NRC inspector's initial visit to
Davis-Besse, the inspector asked the QC manager, who was the
QC supervisor identified above during the timeframe of the.
steamline weld break / crack incident, if he had ever not
processed a PCAQR that had been generated by his inspectors.
At that time, the manager stated that he had never, to his
recollection, not processed a PCAQR report initiated by his
' inspectors. During a subsequent interview, the QC manager
stated that he did stop the issuance of the PCAQR in question
based on the mutual agreement.of engineering, plant management,
and himself that a PCAQR was not needed.
The inspector contacted the QC inspector involved with the
matter and obtained the voided PCAQR in question, a copy of
an intra-company memorandum (File: T2.1 SUS 043-03, NES:
87-30065), dated May 14, 1987, from system engineering to the QC
supervisor documenting engineering's actions associated with the
broken welds / cracks of the used piping in the High Pressure
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condenser, and a copy of the Work Request (WR) that tracked the
piping discrepancy and its scheduled 1988 refueling outage
repair activity.
The i_nspector reviewed the above described documents and found
them to generally agree with the described concern in that the
PCAQR was marked "Not Issued," and a note was attached informing
the QC inspector to " tuck this away in your files" and signed
with the QC supervisor's initials.
The inspector determined that the handling of the PCAQR was not
in accordance with the administrative procedure for processing
PCAQRs. Nuclear Mission Procedure NMP-QA-702, " Potential
Condition Adverse to Quality Reporting," dated May 25, 1986,
Section 6.2.3, " Processing," states in part that, "Following
supervisory review, all PCAQ reports shall be hand carried to
the shift supervisor for numbering, logging, and completion of
those sections of Part 1 that apply, but were not addressed,
and determination of their deportability." By not processing
the PCAQR, the QC supervisor violated the above stated procedure
requirement. This is the third example of a procedural
violation and the first of two examples of a violation of the
PCAQR processing requirements (50-346/88012-01C, Example 1).
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Conclusion: This concern was substantiated. As described
above.a violation of NRC requirements was. identified for not
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processing the PCAQR in accordance with procedures. The
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licensee's corrective actions will be reviewed under the
violation's. tracking number. - The' inspector did.not identity a
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safety concern with engineering',s decision to delay repairing
the unused piping until-_the 1988 refueling outage. This concern
is considered closed.
3.
Followup on Prr.ypusly Identified Item (Closed) Unresolved Item
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(346/88027-03)
Improper. handling of a.PCAQR concerning Ray Chem rework activities.
The second example of.the Quality Control department's mishandling
of a PCAQR that was initiated by a QC inspector was. brought to the
'NRC's attention?as part of allegation RIII-88-A-0067 and documented
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.in inspection Report 50-346/88027. This example concerned a PCAQR
. written on July 10, 1986, to-document a QC inspector's concern.about
deficiencies with Raychem splice documentation identified'in'
maintenance Work Order 1-86-0991-04. This PCAQR was' reviewed by QC
management and inappropriately invalidated in that the invalidated
PCAQR was not'sent to the shift supervisor for his review and
subsequently forwarded to the PCAQR Review Board. This is the
second of two examples of a violation (50-346/88012-01C
Example 2)-.
4.
. Unresolved Items
Unresolved items are matt a s about which more information is required
in order to ascertain whether they are acceptable items, violations, or
deviations. Two unresolved items disclosed during this inspection were
discussed in Paragraphs 2.b and 2.c.
5.
Exit Interview
The inspector met with licensee representatives (denoted in Paragraph 1)
at the conclusion of the inspection on September 1,1988, and summarized
the scope and findings of the inspection. The inspector also discussed
the likely informational content of the' inspection report. The licensee
acknowledged the information and did not identify any of the information
disclosed during the inspection as proprietary.
Attachments
1.
Letter f rom Region III to Toledo Edison dated June 14, 1988.
2.
Letter from Toledo Edison to Region III dated July 22, 1988.
3.
Letter from Tolede Edison to Region III dated August 26, 1988.
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()Dur/xtion Report 346/88012
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Docket No. 50-346
.1JUN 1419BB
. Toledo Edison Company
ATTN: Mr. Donald Shelton-
Vice President Nuclear
Edison Plaza
-300 Madison Avenue
Toledo, OH 43652
Gentlemen:
The NRC recently received several allegations concerning activities at the
Davis-Besse Nuclear Power Plant.
for your review and followup.
Details of these allegations are provided
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The NRC requests that results of your reviews and dispositions of these
matters be. submitted to Region III within 30 days of the date of this letter.
The enclosure to this letter is considered exempt from disclosure according to
section 2.790 of the NRC's " Rules of Practice", Part 2, Title 10,, Code of
Federal Regulations, and will not be placed in the NRC Public Document-Room.
Therefore, the results of your review and the dispositions of these matters
should' provide an equivalent degree of protection.
-Your cooperation with us is appreciated. We will gladly discuss any questions
you have concerning this information.
Sincerely,
~~hi4${an:3EyI*.0.Ortc5?#~
sk{ardi.Gr~eenman, Director
E
Division of Reactor Projects
Enclosure:
As Stated
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cc w/o enclosure:
L. Storz, Plant Manager
DCD/DCB (RIDS)
Licensing Fee Management Branch
' Resident Inspector, RIII
James W. Harris, State of Ohio
Robert M. Quillin, Ohio
Department of Health
State of Ohio, Public
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Utilities Commission
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Enclosure
Specific Details of Allegations
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Allegation Number RIII-88-A-0010
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It has been alleged that some work that is being performed in the plant does
not conform to Davis-Besse painting / coating procedures, and that these
discrepancies have been identified in non-conformance documents and accepted
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as-is without proper justification and/or revisions to applicable painting
procedures.
It is alleged that areas of the plant were not painted adequately
or wrong paint was used and some areas were not painted at all. The bottom of
pipe support base plates were provided as examples of items that have been
installed without proper coatings (i.e., installed with prime coat only).
The NRC requests that you review previous and current painting practices
against your approved procedures and determine if there exists a disagreement
between the two.
In addition, a walk down of modification activities
conducted since the beginning of the June 9, 1986 outage, should be conducted
to detennine if appropriate painting applications have been performed.
If
accessible or inaccessible areas have not been properly painted per
Davis-Besse required procedures, provide your planned corrective actions or
justification for accepting the as-found conditions of the unpainted surfaces.
Allegation Number RIII-88-A-0012
It has been alleged that General Electrical and Mechanical (GEM) employees
use metal tools (e.g. hacksaws) to trim excessive fire barrier sealing
material,
In one case it was alleged that insulation on an electrical cable
was accidentally cut, causing an electrical short (Note: This may have been
the cause of the October 23, 1987 partial loss of EHC control power).
The
matter was reviewed by the Operations Department to determine the cause of
the electrical short, but the GEM employee did not mention the use of the
hacksaw.
It was also alleged that procedures did not allow the use of metal
tools, only plastic or fiberglass; however, GEM employees have used and still
use metal tools because the allowed tools do not work.
The NRC requests that you review plant fire barrier sealant trimming practices
to determine if the above activities are occurring, and if so, take appropriate
corrective actions.
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Xctachment No. 2 to
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pection Report 346/88012
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TOLEDO
EDISON
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t. Canterer eneroy Comoanv
DONAu) C. SHELTON
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Docket No. 50-346
License No. NPF-0
Serial No. 1-815
July 22, 1988
United States Nuclear Regulatory Commission
Document Control Desk
Vashington, D. C.
20555
Subject:
Response to Allegations Concerning Activities at the Davis-Besse
Nuclear Power Plant
Gentlemen:
Toledo Edison (TED) received your letter dated June 14, 1988 (Log 1-1833)
which contained allegations concerning:
1) adherence to painting / coatings
procedures (Allegation No. RIII-88-A-0010); and 2) the use of knives and
,
'
hacksaw blades in the installation of electrical conduit sealant (Allegation
No. RIII-88-A-0012).. 9 requested, TED has performed a review of the concerns
'.
and provides the follcving information.
Based on our discussion with
Mr. R. DeFayette on July 14, 1988 the response to these allegations was
extended to July 22, 1988.
Allegation No. RIII-88-A-0010
Toledo Edison has reviewed the concerns raised regarding paint / coating
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practices at Davis-Besse. The review indicated that the alleger's concerns
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Vere documented via Potential Conditions Adverse to Quality (PCA0) Reports and
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Requests for Assistance (RFA) process. The concerns range from installation
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of pipe supports with a coating of primer alone to an Appendix R fire door
being painted the wrong color.
The specific concern of pipe support base plates being installed without
proper coatings was reviewed with the following conclusion:
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The coating procedure directs plant personnel to initiate an RFA
requesting additional information and clarification of the
instructions given when a specific situation is not addressed in the
procedure. Therefore, RFAs were initiated by Toledo Edison's Quality
Control and Facility Modification Departments requesting clarifi-
cation of the coating specification and procedure.
JUL 2 919884
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THE TOLEOO EDISON COMPANY
EOISON PLAZA
200 MAOISON AVENUE
TOLEDO. OHIO 43652
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License No. NPF-3
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One RFA requested clarification of whether paint / coating was required
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for installation of steel (pipe supports and base plates) when the
surfaces would not be exposed or accessible.
The other RFA requested
a clarification pertaining to acceptability of primer coat alone for
inaccessible areas. A coating system is generically composed of a
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primer coat and a top coat. These two RFAs were evaluated and
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responded to in approximately the same time frame.
Design Engineering reviewed these RFAs addressing the concerns of
what surfaces require what type of protective coating. The
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evaluation concluded that base plates outside containment having only
a primer coat on the inaccessible areas as a protective coating are
acceptable. This is based on the Steel Structures Painting Council
(SSPC), Steel Structures Painting Hanual (SSPM) which is the accepted
standard in protective anti-corrosion coatings. Chapter 1.2 of the
SSPM states that the primer is the critical element in most coating
systems.
The primer is the most important for preserving the
metallic state of the substrate (surface metal).
It also states that
the finish coat provides color and protects the primer from the
environment so the primer can perform its function (inhibit
corrosion) without being degraded. The RFA response concluded the
primer coat provides sufficient protection against corrosion due to
the limited exposure to the corrosive environments these surfaces
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vill be subject to.
There have been other concerns, as noted in the allegation letter, of doors
and structural steel being installed in the plant without the proper coating
system being applied. These concerns have been documented via our PCAQ
system, addressed, and reviewed by both the PCAO Review Board and by Toledo
Edison Quality Assurance and no further actions were considered necessary.
Toledo Edison believes that the guidance given pertaining to coatings of
structural steel is in conformance with the intent of the Steel Structures
Painting Council guidance and does not believe there exist discrepancies
between current practices and approved procedures. Therefore, TED believes
that the PCAQs and RFAs were generated in accordance with approved procedural
requirements and have been dispositioned appropriately and therefore no
further action is warranted.
Allegation No. RIII-88-A-0012
As stated in this allegation the use of metal tools has been an approved
method for trimming excess sealing material from around conduits. The use of
hacksaw blades and knives is permitted by Maintenance Procedure (MP) 1405.03,
" Installation of Silicone Foam / Caulk Penetration Sealing Systems", for the
purpose of trimming excess sealant material.
The events surrounding the
specific allegation concerning the October 23, 1987 partial loss of
Electro-Hydraulic Control (EHC) control power for the main turbine generator
were incorrectly reported by the alleger. The partial loss of EHC control
power was determined to be caused by the damaged cable insulation. This
occurred when the craft personnel vere attempting to push the cable back into
a conduit fitting while performing vork on the penetration. The cause of the
cable damage was attributed to the conduit fitting having sharp edges.
A
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-Dockat No. 50-346
License No. NPF-3
Serial.No. 1-815
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-Page 3
. review of the October 23, 1987 partial loss of EHC control power was
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documented in Potential Condition Adverse to Quality (PCAQ) Report No.87-589.
.As part of the corrective actions for PCAQR 87-589 several additional
requirements were generated for sealing conduits. These include checking
fittings for sharp edges and pulling rather than pushing cables back into the
~
conduit when required. In addition to the root cause corrective actions,
several other-program enhancements were identified during the review of this
PCAOR.
One of the enhancements made was prohibiting the use of knives and
'
hacksaw blades-in trimming excess sealant from conduits. The root cause
corrective' actions and the additional enhancements have.been added to
procedure MP 1405.03. The use of knives and hacksav blades continues to be
permitted for trimming sealant in areas other than conduit. Therefore, TED
believes that there are no further actions required concerning this
allegation.
Very trul yours,
fh%bd
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JCS/ sag
cc:- DB-1 Resident Inspector
A;<B;9 Davis;1 Regional-Administrator?'
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A. V. DeAgazio, NRR DB-1 Project Manager
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tachment No. 3 to
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ion Report 346/88012
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TOLEDO
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A Cameror Energy Cermany
DONALD C, SH LT t
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Docket No. 50-346f
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License No. NPF-3
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Serial No. 1-829
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August 26, 1988
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Mr. A. B. Davis, Regional Administrator
Region III
799 Roosevelt. Road
Glen Ellyn, IL 60137
Subject: Toledo Edison's Action Plan on Procedures
,
Dear Mr. Davis
On August 18, 1988, a meeting was held at the NRC Region III office between
Toledo Edison (TE) and members of your staff.
The purpose of the meeting was
to discuss the ongoing NRC Region III inspection in the Davis-Besse Quality
Assurance / Quality Control areas.
Subsequent to the meeting,
Mr. Robert V. DeFayette of your staff discussed the following NRC concerns by
telephone with Toledo Edison, representatives on August 23, 1988:
1)
Quality Control Instructions (0CIs) are not.being adequately
controlled;
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2)
OC inspectors are not promptly initiating the process to resolve
identified procedural deficiencies;
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3)
Procedural compliance has not' been thoroughly assessed for the entire
Nuclear Group;
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4)
Adherence to the procedure change process has not been evaluated for
the entire Nuclear Group;
5)
The root cause of the procedural compliance concern has not been
. evaluated.
As discussed with your staff, TE vill take the following actfons.
1.
The remaining Quality Control Instructions (OCIs) vill be superseded by
Quality Asst.rance Division Procedures (OADPs).
Concurrently with
superseding the OCIs, all OADPs vill be reviewed and identified
THE TOLEDO EDISON COMPANY
EDISON PLAZA
300 MAOISON AVENUE
TOLEDO. OHIO 43652
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Liccnsa No. NPF-3
Serial No. 1-829
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deficiencies vill be corrected.
0ADPs that are revised or which
supersede OCIs vill be approved by September 1, 1988 and become effective
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by September'8, 1988, following required training,
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In conjunction'vith the change from QCIs to 0ADPs and the revision of
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identified QADP deficiencies, the OA Division vill conduct retraining on
the PCR process. This retraining vill re-emphasize the need to promptly
initiate actions to correct identified procedural deficiencies.
Retraining vill be completed by September 16, 1988.
Additionally, if the
results of the audit indicate other divisions are having similar
problems, retraining vill be conducted for those divisions as well.
3.
Toledo Edison vill conduct an interdisciplinary audit to assess
procedural compliance and the overall administration of. toe procedure
program. The audit vill analyze a representative sample oi procedures to
determine if the procedures are functionally adequate (capable of being
^
followed), and whether identified procedural deficiencies have had
,
corrective actions initiated
(i.e., via Procedure Change Requests or
Potential Condition Adverse to Quality Reports).
If it is determined
that a corrective action has not been initiated, the necessary
corrective action vill be taken and the cause of the failure to take this
action vill be determined.
A minimum sample of 125 procedures (4% of the population) vill be
selected for the audit.
Procedures vill be selected from each Nuclear
,
Group Division. The sample vill include recently revised procedures,
older working level procedures and administrative procedures.
The audit
vill be conducted by a team of individuals knowledgeable in the procedure
program and audit practices.
This audit is scheduled to begin on September 6, 1988 and vill be
completed by October 14, 1988.
An audit report vill be issued by
October 28, 1983.
4.
The current procedure change process at Davis-Besse requires individuals
from all departments, including OA, to stop work and notify their
supervisor whenever a technical deficiency is discovered in a procedure
that they are following.
Procedures found to contain such deficiencies
are required to be corrected prior to continuing work.
The individual discovering a deficiency is required to submit a Procedure
Change Request (PCR) form.
Processing time for accepted PCRs is a
function of the number of change requests currently in the system.
However, each department and division has the ability to expedite the
change process for any procedure deemed to require immediate attention.
Procedure changes and revisions can, and have been, processed in as
little as one day.
If the audit results indicate that the time required to change or revise
a procedure, using the current procedure change nrocess. is a contributor
to procedural noncompliance, TE vill revise the change process such that
the processing time is reduced.
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5.
A root cause evaluation vill be conducted to determine the reason for the
Increase in procedural noncompliance, which has been identified by TE's
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Trend Report.
Much of the information necessary to. perform this
evaluation vill be obtained during the audit process described above.
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Evaluation of this information vill begin upon completion of the audit
(October 14, 1988) and will ba completed by November 10, 1988.
Your
staff vill then be notified of the results.
Please contact Mr. R. V.
Schrauder, Nuclear Licensing Manager, at
(419) 249-2366 if there are any questions.
Sincerely
yours,
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A. V. DeAgazio. Proj ect Manager
Document Control Desk
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VOLATON OR DEVIATCN fnter up 10 N00 Characters I6r each item. If Me teel OECeeds tha, number, it will be necessery to paraphrase. Limit lines 10 50 characters each. )
1.
10 CFR 50, Appendix B, Criterion V, " Instructions, Frocedures, and
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Drawings," requires in part that activities affecting quality be
,
accomplished in accordance with appropriate procedures. This requirement
is implemented by the Toledo Edison Company Nuclear Quality Assurance
Manual, Section 5, Paragraph 5.4.1.1 which states in part that activities
,
that affect quality shall be accomplished in accordance with procedures.
6.
1.
Nuclear Group Procedure NG-DS-205, " Plant Maintenance," dated
,~
November 25, 1986, Paragraph 6.7.4, " Scope of Work," states, in
part, that the Assistant Plant Manager, Maintenance, shall ensure
that only work specified in the Maintenance Work Package is to be
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performed.
10.
'
Contrary to the above, on February 7, 1987, the Assistant Plant Manager
u.
failed to ensure that only work specified in the Maintenance Work Package
was performed in that after plant staff unsuccessfully attempted to
perform a functional check of the timing sequence of the oil failure
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safety control switch, PSL-2807, and associated ti,ner for the control
"-
room emergency ventilation system condensing unit per Maintenance Work
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Order 3-87-1174-01, they obtained an uncontrolled manufacture's
instruction for, testing the time delay and conducted this test prior
"
to incorporating it into the work package.
17.
2.
Quality Assurance Division Procedure (QADP) No. 2.2 (QA-QC-07002.02),
"
" Qualification and Certification of Personnel Performing Quality Control
f
Activities," Revision 1, dated October 16, 1987, Paragraph 6.4.3,
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requires, in part, that individuals who meet the education and experience
requirements for a specific level and discipline, and who have been
previously certified in that discipline shall be qualified based on, among
a
other things, completion of Generic and Discipline qualification cards.
,
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Contrary to the above, on July 14, 1988, the inspector determined that
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several Davis-Besse certified QC inspectors had not completed the
qualification cards, identified above, or had not completed them in a
timely manner.
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3.
Toledo Edison Company procedure, NMP-QA-702 R1, dated May 25, 1986,
" Potential Condition Adverse to Quality Reporting," Section 6.2.3,
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" Processing," states in part that, "Following supervisory review, all
"
PCAQ reports shall be hand carried to the shift supervisor for numbering,
logging, completion of those sections of part 1 that apply, but were not
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addressed, and determination of their deportability."
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2.
Section 6.3.3, " Technical Support Department Review," states in part
'-
that, "following deportability determination, the PCAQ report shall be
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forwarded to the Plant Technical Support Department for review and
submittal to the PCAQ Review Board."
j
e.
a.
Contrary to the above, on May 14, 1987, a Potential Condition
j
Adverse to Quality Report (PCAQR) was written by a Quality Control
l
inspector concerning the HP E-7-1 Condenser internal steamline
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weld and pipe cracks. The PCAQR was reviewed by his supervisor,
but not delivered to the shift supervisor or to the PCAQR Review
,
Board for review and processing.
b.
Contrary to the above, on July 10, 1986, a PCAQR was written
k
11.
by a QC inspector concerning deficiencies with Raychem splice
'
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documentation identified in MWO 1-86-0991-04. The PCAQR was
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reviewed by the QC supervisor, but not delivered to the
shift supervisor or to the PCAQR Review Board for review
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and processing.
,,
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Collectively, these v.iolations have been categorized as a Severity Level IV
problem (Supplement I).
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u.S. NUCLEAR REGULATORY COMMissloN
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