IR 05000346/1988013

Insp Rept 50-346/88-13 on 880412-14.No Violations or Deviations Noted.Major Areas Inspected:Allegations Re Operation of Facility

ML20151X952
Person / Time
Site:	Davis Besse
Issue date:	04/27/1988
From:	Defayette R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20151X950	List: IR 05000346/1988013 ML20151X945
References
50-346-88-13, NUDOCS 8805040294
Download: ML20151X952 (12)

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U.S. NUCLEAR REGULATORY C0m!SSION

REGION III

Report No. 50-346/88013(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 Nuclear Power Station, Unit 1 Inspection At: Davis-Besse Site, Oak Harbor, Ohio

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Inspection Conducted: April 12-14, 1988

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Inspector: M. J. Farber

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Approved By: Robert DeFayette, Chief$ fs7fjS -

Reactor Projects, Section 3A Date

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Inspection Summary [

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Inspection on April 12-14, 1988 (Report No. 50-346/88013(DRP))

Areas Inspected: Special, unannounced safety inspection with regard to a series of allegations related to the operation of the Davis-Besse facilit Results: No violations or deviations were identifie ;

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8805040294 880427 PDR ADOCK 05000346 Q DCD

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CETAILS Persons Contacted Toledo Edison Company S. Aparicio, System Engineer

• L. Storz, Plant Manager

• N. Bonner, Assistant Plant Manager Maintenance

• P. Hildebrandt, Engineering General Director R. Flood, Assistant Plant Manager, Operations

• R. Schrauder, Nuclear Licensing Manager

• T. Myers, Nuclear Licensing Director

• C. Daft, Technical Planning Superintendent

• S. Jain, Director, Nuclear Engineering

• L. Ramsett, Director, Quality Assurance G. Homma. Compliance Supervisor - Licensing T. Isely, I&C Lead Engineer L. Evans, I&C Engineer NRC P. M. Byren, Senior Resident Inspector

• D. C. Kosloff, Resident Inspector R. W. DeFayette, Chief. Section 3A

• Denotes those persons present at exit meeting cn April 14, 198 . Background Since March 1986, NRC Region III has been dealing with a series of allegations regarding the operation and management of Davis-Besse Nuclear Power Station Unit 1, by the Toledo Edison Company. Each of these allegations consists of a number of technical concerns with '

some aspect of plant operation, and all are linked by the common concern that employees who identify deficiencies in Toledo Edison programs, voice opinions contrary to the company position, or raise safety concerns are subjected to harassment, intimidation, and adverse job actions. Allegations of this nature are not uncommon in the industr The portions of the allegations regarding harassment, intimidation, a adverse job actions were not reviewed during this f aspection; the intenc  !

of this inspection was to review the circumstances surrounding the technical concerns, determine whether or not the allegations are  ;

substantiated, and resolve the technical issue Some of these technt:a1 issues have been inspected by other individuals and their rosults are documented in inspection reports which will be referenced in this repor .

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AllegationReview(RIII-86-A-0051;RIII-86-A-0184;RI!!,-87-A-0076)

' Technical Concern Concern: Plant workers are afraid to use new parts during maintenance work so they return used parts to servic NRC Review: The maintenance program at Davis-Besse is continuously monitored by the resident inspectors and has been the subject of several maintenance oriented inspections, among them an industry peer group maintenance inspection, an Augmented Inspection Team (50-346/87025(AIT)) in September 1987, and a Special NRC Maintenance Inspection Team (50-346/87030) in November 1987. In each case, the availability of spare parts was noted either as a restraint to completion of specific tasks or as a general concer The licensee, in its Course of Action Plan, developed following the June 9, 1985 event, acknowledged a spare parts problem and has, when necessary, refurbished components and returned them to service. Refurbishment is conducted under maintenance procedures, and the components and systems are subject to the same surveillance and operability requirements as new parts. To date, the

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use of refurbished parts, where new parts were availabl has not been the cause of any of the equipment related occurrences at Davis-Besse since the plant was restarted in December 1986. The licensee is implementing an improvement program for spare parts availability, has committed significant resources to the program, and is

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expected to continue with the effort under the auspices of its Configuration Management Progra '

Conclusions: Region III is aware of the licensee's refurbishment and reuse of components and the reasons that it takes plac This part of the allegatbn is substantiated; however, since there is no regulatory prohibition against the reuse of parts, the work is done in accordance with procedures, the systems are required to meet technical specification surveillance and operability requirements, and refurbished parts have not been the cause of an event, there is no safety concern in this regard. Beyond the concern expressed by the original alleger, no other individuals have come forward within the past eighteen months and expressed similar concerns. This, coupled with the fact that there was an acknowledged reason (i.e., lack of spare parts availability) for reuse of parts, leads to the conclusion that this part of the allegation is not substantiate Concern:

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Admiral Williams had everything painted, "including the sump pump springs and then the pumps wouldn't work."

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NRC Review: The inspector reviewed the maintenance history for 1986 and 1987 for the Containment Normal sumps, the Auxiliary Building sumps, and the Emergency Core Cooling System (ECCS) sump There were 41 Maintenance Work Orders (MW0s) written during that time period for the Containment Normal sump Five of these were written regarding the pumps or pumping problems. The inspector reviewed the problem description and work summary for these five and found that four were for electrical problems and one was for a clogged sum None of the MW0s reviewed by the inspector dealt with problems traceable to pump spring There were 82 MW0s written during that time period for the Auxiliary Building sumps. Forty-one of these were related to the pumps. Review of the problem description and work summary revealed that all were for routine inspection and lubricatio There were 37 MW0s written during that time period for the ECCS sumps. Twenty-one of these were related to the pumps and pumping problems. Review of the problem description and work summaries of all 21 MW0s revealed that they dealt with replacement, termination, and testing of new pumps, electrical problems, design of sump pump piping which resulted in inoperability of the sumps during maintenance, a clogged sump, and replacement of the pump with the clogged sump. None were related to problems traceable to the pump spring Conclusion: Detailed review of the 66 of the 160 MW0s written for the sumps revealed no problems with the pumps that could be traced to painting of the pump springs. This part of the allegation is not substantiated and considered close Concern: Poorly written procedures, prepared by professional procedure writers who have no idea of plant equipment, have resulted in errors which management has blamed on personne NRC Review: The alleger did not provide instances which would have identified specific procedures for review. At the request of Region III, an Operational Safety Team Inspection (OSTI)wasconductedbytheOfficeof Nuclear Reactor Regulation from September 28 through October 9, 1987 (Inspection Report No. 50-346/87024),

to obtain an independent assessment of Davis-Besse performance, strengths and weaknesses, and potential problem areas. Part of this inspection involved the direct review of 24 procedures of various types and careful monitoring of the use of many other prodedures

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by operators and technicians. The team noted that maintenance procedures used were adequate to control the activities, surveillance procedures were well ,

written and provided adequate guidelines for technicians and operators, and that operators had good awareness, understanding, and implementation of plant procedure Conclusion: With regard to "poor procedures in a system which contains thousands of procedures, there will be some number which du not meet the same standard of quality as the rest; the system provides for periodic review and revision of procedures to currect these problem With regard to errors which occur during the conduct of orocedures, it is understood and accepted that errors will occasionally occur during the performance of even the most accurate procedures. The OSTI, as a result of its review of procedures and procedure use, concluded that the licensee had fundamentally sound procedures and practices in place at the plant. This part of the allegation is unsubstantiated and close Concern: Removal of all individual step signoffs and checkoffs had resulted in at least one procedural erro NRC Review: Absent a specific example, the alleger's claim could not be directly reviewed; however, the Resident Inspectors reviewed the system used by the licensee for procedure signoffs. They detemined that although the individual step signoffs and checkoffs hid been removed from the body of procedures, they had been retained on a separate attachment which was to be used along with the procedur The inspector reviewed a sample of I&C, Mechanical, and Electrical maintenance procedures and confimed the use of the separate signoff sheets. As discussed above, the OSTI found that procedure use and implementation at Davis-Besse were satisfactor Conclusion: The removal of signoffs from the body of procedures could not be tied to a personnel errer. As noted above, the OSTI found fundamentally sound procedures and practices in place at the plant and that procedure use and implementation were satisfactory. This part of the allegation is unsubstantiated and is close Concern: The Auxiliary Feedwater Pump Turbine steam admission valves were installed in an orientation not recommended by the manufacture NRC Review: In response to concerns expressed by Region III personnel over potential operational problems with the Auxiliary Feedwater (AFW) system, a two-day special inspection was

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conducted by NRR staff personnel on October 6 and 7,1987, The results of this inspection, which concluded that the material condition of the AFW system was adequate to allow the system to perform its safety function, were conveyed to Region III in a letter from D. M. Crutchfield to C. E. Nore11us, dated January 22, 1988, and documented in Inspection Report No. 50-346/87031(DRP). Prior to the restart of Davis-Besse in December 1986, the type and lecation of the Auxiliary Feedwater Pump Turbine (AFPT)

steam admission valves were modified. The valves are now located neer the turbines and are fail open, air-operated '

control valves where previously they were motor-operated gate valves located approximately a hundred feet from the AFPT. The relocation of the valves was intended to reduce the amount of condensate that would otherwise be produced in a long length of unheated steam line. Both new valves, manufactured by the Masoneilan Company, are identical but are installed in different orientations; one (AFPT 1-1)

vertically with the stem horizontal and the other (AFPT 1-2) horizontally with the stem vertical. While both valves have been subject to leakage, the valve associated <

with AFPT 1-1 has exhibited far greater leakage than AFPT 1-2. Toledo Edison staff personnel reported that a Maseneilan Co. representative stated that leak tightness of the valves installed vertically cannot be guarantee The NRR staff was informed by the licensee Design Engineering staff that new valves from a different manufacturer (Valtec) have been ordered to replace the Masoneilan valves. These valves will be installed during the current refueling outage anc will be mounted horizontall It should be noted that adherence to a manufacturer's .

installation recommendation is not a requirement, and  :

that installation orientation is often subject to other  ;

factors such as interferences or piping configuration While the plant was operating prior to the current outage, the licensee had implemented a program of increased surveillances and compensatory actions to ensure that the AFPTs would properly respond when required. During i 1987, the AFPTs were required to operate during a number i of plant transients, and they always did so successfull Replacement of the leaking steam admission valves with ,

valves of an appropriate design and installation of these valves in the recommended orientation it expected to

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eliminate the introduction of steam or condensate into the AFPT while the AFW system is not in operation.

. Conclusion: The allegation is substantiated, in that one of the two i valves (AFPT 1-1) was installed in an orientation such i that, according to a vendor representative, leak lightness

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Because the licensee had an adequate program of ,

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compensatory actions in place during operation and because appropriate modifications are scheduled for I the current outage, no hazard to the health and safety of the general public was posed as a result of the ;

orientation of AFPT 1-1. steam admission valve. This ;

part of the allegation is close l t

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. Concern: Themocouples welded to the Steam Generator shell had

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calibration infonnation that indicated that the i calibration was accomplished on dates that it would not i have been possible for the calibration to have been don .

NRC Review: The Resident Inspectors reviewed the calibration .

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, docu'wntation for the Steam Generator thermocouples in j question and the Procedure IC 2700.48.01. "Calibration !

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Check and Verification of Thennocouples and RTDs." which :

i was listed in the Maintenance Work Order (MWO) as the 4 procedure used to calibrate the thermocouples. They :

determined that the procedure was inadequate, in that !

it did not address in-place calibration of temperature ;

elements. The alleger's concern was raised because the ,

thennocouples were welded to the shell, and the insulation !

was in place on the steam generator at the time when they !

were documented as being calibrated. Since the !

thermocouples could not be calibrated in accordance t with the procedure, the allegers did not believe that !

the thermocouples had been calibrated at all. Further !

review by the residents revealed that it was possible -

to calibrate the thermocouples in-place by the method described in the MWO although the procedure did not :

strictly address this situation, j Conclusion: The inspectors detennined that the calibration of the !

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subject thermocouples was performed, but without the !

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benefit of a proper procedure. The licensee was infonned, !

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and the procedure has been revised. No violation was !

issued because this was a non-safety related temperature ;

j element. This part of the allegation is unsubstantiated i and is close ,

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Concern: The low and low-low pressure switches for a makeup !

isolation valve were reversed and the switches had not

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been calibrated between 1976 and 1986. A Potential !

Condition Adverse to Quality Report (PCAQR) was written i on the reversed switches, but the lack of calibration !

was not documente t

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l NRC Review: This concern related to two pressure switches. PSL-MU33 ;

and PSLL-MU33, which are low and low-low air pressure ;

switches on the backup air accumulator for MU-33, the ;

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nonnal Reactor Coolant System makeup containment isolation valve. The backup accumulator assures an air supply to MU-33 to keep it open in the event of a loss of the instrument air system. PSL-MU33 provides a computer alann at 90 psig in the accumulator, and PSLL-MU33 closes MU-33 at 75 psi The inspector reviewed the following documents:

PCAQR No. 86-0564

MWO No. 1-86-3349-00

MWO No. 7-86-4045-00

DB-MI-05152, "Calibration of Static 0-Ring Pressure Switches" (formerlyIC 2701.42)

Davis-Besse Technical Specifications, Sections 3/ (Instrumentation)and3/4.6(Containment)

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Updated Safety Analysis Report, Section 9.3.4, Makeup and Purification Systems The inspector also reviewed the calibration requirements and calibration history of PSL-MU33 and PSLL-MU33. The switches are considered safety-related; however, there is no required technical specification surveillance. The instrument records showed no evidence of any maintenance since original installation in 1976. The records showed that when the switches were checked in November 1986, prior to plant restart following the June 9, 1985 event, they were both out-of-tolerance low and required recalibration. There was no evidence that any periodic calibration requirement for these switches existed. In discussions with I&C personnel the inspector found that PSL-MU33 and PSLL-MU33 had no established calibration requirement in place until March 18, 198 A review of the PCAQR revealed that there was no mention in the description of the possibility that these pressure switches had not been calibrated between 1976 and 198 On November 13, 1986, the day before the allegers made their complaint, an I&C supervisor identified that neither the instrument record nor Davis-Besse Maintenance Modification System equipment history had any record of maintenance on those switches since the original installation. The root cause and resolution sections of the PCAQR failed to address this condition nor did they address the possible safety significance of the ten-year lack of calibratio ,

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Conclusion: The PCAQR did not address the ten-year lack of calibration or its potential safety significance, and the allegation '

is substantiated. Because the pressure switches, which provide warning and protection for an engineered safety function, were found out-of tolerance, there is some question as to whether or not MU-33 would have closed as required when PSLL-MU33 did actuate. This is an unresolveditem(50-346/88013-01) pending an engineering <

evaluation addressing the ability of the backup accumulator to close MU-33 at the reduced air pressure setpoint found during the November 1986 calibratio Concern: The alleger was refused access to a "Procedure Writer's Guide" when he requested it in order to determine how coments he had made on a procedure had been resolve The alleger stated that he was told he could not see it because he was not on the list of people who were authorize NRC Review: The alleger did not identify the individual who denied his access to the Procedure Writer's Manual. To determine whether or not access restrictions had been, or were presently, in place on the Procedure Writer's Guide, the inspector reviewed the following related to the development and control of Davis-Besse procedures:

NG-!M-00100. Rev. O, "Preparation and Control of Nuclear Group Procedures"

NG-IM-00114. Rev. O "Preparation and Control of Administrative Guidelines"

NG-IM-00115, Rev. 1. "Preparation and Control of Nuclear Division and Department Procedures"

NP-DP-00001, Rev. O, "Development, Review, Approval, and Control of NPD Procedures"

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DB-DP-00003, Rev. O. "Procedure Preparation and Maintenance"

Davis-Besse Nuclear Power Station Procedure Writer's Manual, Volumes I through IV The inspector also spoke with the Systems and Procedures Manager, the former Technical Support Superintendent, and the Lead I&C Enginee These reviews and interviews revealed that the "Procedure Writer's Manual" was controlled by the Technical Support group under the Plant Manager, and that use of the

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procedure was mandated by DB-DP-00003 and its predecessor documents, the AD-1805.00 series. When the document was first issued, it was under a controlled distribution with a limited number of copies given to specific department ,

According to the former Technical Support Superintendent, ,

there were no other access controls placed on the document, and the intent was to provide availability through the department. The Lead IAC Engineer stated that at no time in the past, nor were there presently, any restrictions t on access to the "Procedure Writer's Manual," that it was stored in an open bookshelf, and that its use was ,

encouraged by the I&C Superintenden Conclusion: Absent the identity of the individual allegedly denying information and having determined that there were no procedural restrictions to the guide, the inspector must conclude that this part of the allegation can not be substantiated and is considered close Concern: A maintenance worker was directed to hamer on a Core Flood system check valve with a sledge hame NRC Review: This concern related to the methods used by the Mechanical Maintenance Department to seat a back-leaking Core Flood systemcheckvalve(CF-30). The function of CF-30 is to prevent backflow from the reactor coolant system to the core flood tanks and the decay heat removal system and allow forward flow under accident conditions or when decay heat removal flow is needed. At the time of the allegation, CF-30 was leaking in excess of Technical Specification requirement and the mechanics were attempting to seat the valv The inspector reviewed the following documents:

MWO 1-86-4196-00, dated 12/3/86

MWO 1-86-4196-04, dated 12/5/86

MWO 1-86-4196-06, dated 12/19/86 7

MWO 1-86-4196-07, dated 3/13/87 ,

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MWO 1-86-4196-09, dated 5/7/87

Facility Change Request 86-403, Install Anti-Rotation Devices in CF-30 and 31

• PCAQR No. 86-0639, dated 12/5/86

PCAQR No. 87-0260, dated 5/23/87 i i

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CompanyNuclearReviewBoard(CNRB)MeetingMinutes-Meeting No. 185, Rev. 0

CNRB Meeting Minutes - Meeting No. 186, Rev. 1 ,

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CNRB Meeting Minutes - Meeting No. 190, Rev. 1

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Technical Specification 3/4. CF-30 had been experiencing back-leakage problems in early December 1986. During this time frame, the CNRB, Enginecring, Maintenance, and Operations devoted extensive resources to the evaluation of the methods used to seat CF-30. These methods and the evaluations were carefully documented in the MW0s and the CNRB Minutes listed abov There were three primary methods termed "mechanical agitation " used either individJally or in combination in the attempts to seat the valve. They were:

A "dead-blow" hamer, filled with lead shot such that there is little or no recoil or bounce of the type which would cause damage to the valve bod *

An air-operated tamp with 4"x4"x4" oak blocks, such that there was no metal-to-metal contac *

Air-operatedpipeshakers(vibrators)werestrapped to the piping above and below the valv The problem was believed to be off center seating of the valve disk as a result of wear of the anti-rotation pins, and the intent of these mechanical agitation techniques was to center the dis ,

A combination of these techniques was successful in December 1986 and again in March 1987. At the time of the allegation, the plant had been shutdown, and surveillance -

testing required prior to a mode change had shown that CF-30 had again failed to properly seat and was leakin Combinations of mechanical agitation techniques were used without success, and the plant returned to cold shutdow The valve was dismantled and the modifications described in FCR 86-403 implemented. The plant subsequently returned to power with no problems with CF-30. Following the September 1986 shutdown, the plant again returned to 1 power with no evidence of problems with CF-30. The MW0s and PCAQR related to CF-30 have been closed. However, e the FCR will remain open until the modification is completed for CF-31 d:Jring the current refueling outag .

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Conclusion: The allegation that a sledge hamer was used on CF-30 l emerged from Occupational Health and Safety A*ninistration (05HA) comunications with the Resident Inspector. The -

alleger had filed a complaint with OSHA regarding what he felt were unsafe work practices at Davis-Besse: use of hamers and air-operated tamps on CF-30 at temperature and pressur The problem of leaking check valves is not unique to Davis-Besse, nor are the techniques used by the l licensee in its attempts to seat CF-30. The records :

show that the use of mechanical agitation was carefully reviewed and that its applications to CF-30 were fully dccumented. The use of a hamer and air-operated tamps is acknowledged; the practice is not considered unsafe, and the issue has no safety significance. The allegation is not substantiated, and this matter regarding use of a sledge hamer is considered close . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable, violations, or deviations. An unresolved item disclosed during this inspection is discussed in Paragraph . Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1) l at the conclusion of the inspection on April 14, 1988, and sumarized the scope and findings of the inspection. The inspector also discussed the likely informational content of the inspection report. The licensee l acknowledged the information and did not identify any of the information disclosed during the inspection as proprietar ;

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