IR 05000346/1988015

Insp Rept 50-346/88-15 on 880516-0630.Violations Noted.Major Areas Inspected:Licensee Action on Previous Insp Findings, Operational Safety,Maint,Surveillance,Ler Followup, Independent Safety Engineering & Emergency Preparedness

ML20151R431
Person / Time
Site:	Davis Besse
Issue date:	08/04/1988
From:	Defayette R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20151R408	List: IR 05000346/1988015 ML20151R404 ML20151R422
References
50-346-88-15, NUDOCS 8808120170
Download: ML20151R431 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-346/88015(DRP)

Docket No. 50-346 License No. NPF-3 Licensee: Toledo Edison Company Edison Plaza 300 Madison Avenue Toledo, OH 43652 Facility Naine: Davis-Besse, Unit 1 Inspection At: Davis-Besse, Oak Harbor, Ohio Inspection Conducted: May 16 through June 30, 1988 Inspectors: P. M. Byron D. C. Kosloff S. Stewart D. Passehl P. Prescott L. Valenti Approved By: .'DeFayette hief Reactor Projects Section 3A Date Inspection Summary Inspection on May 16 through June 30, 1988 (Report No. 50-246/88015(ORP))

Areas Inspected: Routine, unannounced inspection by resident inspectors of licensee action on previous inspection findings, operational safety, maintenance, surveillance, LER followup, independent safety engineering, )

emergency preparedness, and 10 CFR Part 2 Results: Of the eight areas inspected, no violations or deviations were identified in six areas, two violations were identified in the' areas of failure to implement procedures (Paragraph 31 and inadequate design review (Paragraph 7).

8808120170 880804 PDR ADOCK 05000346 Q PDC ,

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DETAILS Persons Contacted Toledo Edison Company (TED)

D. Shelton, Vice President, Nuclear

• L. Storz, Plant Manager N. Bonner, Assistant Plant Mane]er, Maintenance R. Flood, Assistant Plant Manager,- Operations

• E. Salowitz, General Superintendent Outage and Program Management

• L. Ramsett, Quality Assurance Director

• S. Jain, Independent Safety Engineering Director G. Grime, Industrial Security Director B. Beyer, Nuclear Projects Director T. Myers, Nuclear Licensing Director J. Scott-Wasilk, Nuclear Health and Safety Director P. Hildebrandt, Engineering General Director

• J. Wood, Systems Engineering Director lohnson, Primary Systems Manager G. Gibu;. Performance Engineering Director V. Watson, Gesign Engineering Director R. Scott, Chem?stry Superintendent G. Honma, Compliance Supervisor R. Schrauder, Nuclear Licensing Manager D. Erickson, Radiological Control Superintendent L. Harder, Radiological Operations Supervisor

• T. Haberland, Electrical Superintendent C. Daft, Technical Planning Superintendent D. Lightfoot, Outage and Program Management Superintendent J. Moyers, Quality Verification Manager S. Zunk, Nuclear Group Ombudsman D. Harris, Manager Quality Systems

• J. Sturdavant, Licensing Principle C. Bramson, Document Systems Manager G. Skeel, Nuclear Security Operations Manager l

• L. Wade, Quality Control Supervisor L. Worley, Configuration Process Manager i E. Benson, Nuclear Materials Manager J. Syrowski, Nuclear Training Director (Acting)

• E. Caba, Station Performance Supervisor

• P. Roelant, System Engineer

• D. Haiman, Engineering Programs Director U.S. Nuclear Regulatory Commission (USNRC)

• P. Byron, Senior Resident Inspector

• D. Kosloff, Resident Inspector P. Prescott, Reactor Inspector S. Stewart, Resident Inspector T. Barton, Technical Intern D. Passehl, Project Inspector L. Valenti, EG&G

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• Denotes those personr.el attending the July 7, 1988 exit meetin . Licensee Action on Previous Inspection Findings (92701) (Closed) Open Item (346/84009-25(DRP)): A' formal training program for engineers had not been developed. On December 9, 1987, the National Nuclear Accrediting Board accredited the "Technical Staff '

and Managers" training program for Davis-Besse. This item is close (Closed) Open Item (346/86032-10(DRP)): Discrepancies in Administrative Procedure Series ADM 1839. The licensee reviewed the ADM 1839 procedures for discrepancies and made some changes including delineating Reactor Operator responsibilities and upgrading qualification requirements for the Assistant Shift Superviso This item is close (Closed) Open Item (346/86032-11(DRP)): Proper logging of Shif t Supervisor Tours. The inspectors reviewed the unit log and determined that periodic shift supervisor plant tours were logged as required by Procedure ADM 1839.00, "Station Operations." This item is close (Closed) Violation (346/87004-02(DRP)): Failure to follow Technical Specification (TS) Action Statement 3.0.3. with one Emergency Diesel Generator (EDG) inoperable. 'With one EDG inoperable, additional surveillance requirements are imposed by the action statements of TS 3.8.1.1. The licensee was late performing one of the additional surveillances. The licensee issued LER 87007 which was closed in Inspection Report No. 50-346/87014. The violation was caused by personnel erro The inspectors reviewed the licensee's written response to the violation and observed the implementation of the licensee's committed corrective actions. The licensee's written response listed six corrective action The intent of the corrective actions was to increase surveillance requirement visibility and reduce the shift supervisors' administrative burden. The corrective actions are adequate, reducing the likelihood of occurrence of a similar personnel error and reducing the likelihood that a single personnel error would allow a surveillance to be missed. This item is close (Closed) Open Item (346/87004-04(DRP)): The EDG system engineer identified a possible overload condition of EDG 1-1 during a surveillance test. The licensee's evaluation of the event was reviewed and neither the electrical nor mechanical inspections revealed degradation of the diesel although wear was observed on some power assemblies. All EDG 1-1 power assemblies were replaced during the current outage. This item is close (Closed) Open Item (346/87004-08(DRP)): Increasing identified leakage from the steam volume of the pressurizer. The licensee shut down the plant, repaired the code safety valve, and verified that the valve had been allowing the leakag The leakage allowed a buildup of boron crystals on the pressurize The licensee inspected the ereas coated

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with t,oron crystals and determined that boric acid corrosion had not occurred as a result of the valve leakag The boron crystals in the '

vicinity of the leakage have been removed. This item is close (Closed) Open Item (346/87004-10(ORP)): Failure to submit approved safety evaluations to the NRC annually in accordance with 10 CFR 50.5 Procedure NG-NE-0304 has been revised to state that, "A copy of all completed safety evaluations shall be forwarded to the Nuclear Licensing Manager for incorporation into 10 CFR 50.59(b) annual report." -In addition, a summary of the 1986 cnanges, tests and experiments conducted in accordance with 10 CFR 50.59 were submitted by July 31, 1987. This item is closed, (Closed) Open Item (346/87026-03(DRP)): Failure to follow the overtime requirements of Technical Specification (T.S.) 6.2.3,

"Facility Staff Overtime." The maintenance department continuous service overtime rules were reviewed and revised when an individual on continuous service exceeded the guidelines of the rules without authorization from the Plant-Manager or Duty Plant Manager. This item is close (Closed)OpenItem(346/87026-09(DRP)l: Vehicular Traffic in Protected Areas. The inspectors had previously discussed their observation that a number of apparently empty or very lightly loaded vehicles entered the protected area (PA). The licensee performed a survey which validated the inspectors' observations. The licensee reviewed its vehicle program and limited the amount of traffic into the P Two subsequent surveys have been performed and the unnecessary vehicular traffic has been significantly reduce This item is close (0 pen) (346/88010-01(ORS)): Inspection and Testing of Component Cooling Water (CCW) Heat Exchangers (HXs). During inspection of the Service Water side of the CCW HX's, the licensee discovered significant localized corrosion of the HX shel The licensec determined that the corrosion was microbiologically induced. The corrosion was limited to carbon steel (CS) components of the HX' Stainless steel components appeared to be unaffected. A through-wall leak in a CS elbow in the SW system has also been attributed to microbiologically induced corrosion. The licensee has included l the SW sy. stem in its erosion-corrosion monitoring program. This j item will remain open pending further review of the licensee's I program to address this proble No violations or deviations were identified in this are I Operational Safety Verification (71707)

The inspectors observed control room operations, reviewed applicable logs and coriducted discussions with control room operators during the months of May and June. During the entire inspection period, the reactor was shutdown with all fuel off loaded to the spent fuel pool and most Technical

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Specification Limiting Conditions for Operation (LCO) were not applicabl However, the licensee maintained major safety systems in a condition that would satisfy LCO's if the plant were in the refueling mode (Mode 6) or coldshutdown(Mode 5). The inspectors verified the operability of selected safety systems, reviewed tagout records and verified proper return to service of affected component Tours of the auxiliary, reactor, turbine, water treatment and service water buildings were conducted to observe plant equipment conditions,

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including potential fire hazards, fluid leaks, and excessive vibrations and to verify that maintenance requests.had been initiated for equipment-

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in need of maintenance. The inspectors by observation and direct interview verified that the physical security plan was being implemented in accordance with the station security plan.

l The inspectors observed plant housekeeping and cleanliness conditions l and verified implementation of radiation protection controls. During the l month of May and June, the inspectors walked down the accessible portions of the Service Water, Emergency Diesel Generator, Essential 120 Volt AC, Essertial 4160 Volt AC, Essential 480 Volt AC, Essential 125 Volt DC, and Component Cooling Water and Control Room Emergency Ventilation Systems to verify operabilit These reviews and observations were conducted to verify that facility i

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operations were in conformance with the requirements established under technical specifications,10 CFR, and administrative precedures.

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The licensee has routinely performed Quality Assurance (QA) surveillances in containment during the current refueling outage. The inspectors review all QA audit and surveillance reports and selectively choose some of the reports for in-depth reviews. Surveillance Report, SR-88-041-U,

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"5RF0 Fuel Handling, 5/10-11/88 Night Shift", dated May 11, 1988 was l selected for an in-depth review. The surveillance was performed to l witness fuel handling activities which included tethering of tcols, l restriction of access of personnel and materials, and accountability I

I of tools and material. The surveillance listed only one procedure as ,

a reference, PP 1502.04 "Fuel / Control Component Shuffle." This ,

procedure contains no requirenents for control of material or personne l The inspectors questioned the licensee as to the procedures used to l determine material and personnel control in containment. The QA auditor l stated that there were not an l i

The inspectors then reviewed Procedure PP 1501.01, "Fuel Loading and i Refeeling Limits," which contains the general limits and precautions for PP 1502.04. Paragraph 5.12 of PP 1501.01 requires that all mechanisms operated over the fuel transfer canal or spent fuel pool have all snall 1 tools and loose parts secured by a safety line or some other positive means to prevent their falling into the reactor, fuel transfer canal or spent fuel pool. No other precautions relating to material and personnel control are listed. However, Procedure ADM 1844.05, "Cleanliness and Control," is listed as a referenc Paragraph 4.9 of ADM 1844.05 states that where the potential exists for dropped parts or equipment to become

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irretrievable from a system during maintenance, considerations should be I

given to-the use of lanyards or restraining devices to minimize such possibilities. Where the consequences from damage to the system could result from misplaced parts or equipment entering a system during maintenance, consideration should be given to establishing a logging niethod to provide for accountability of object Subsequent to the inspection period, on July 2,-1988, the licensee found a piece of cloth in the bottom of the reactor vesse The licensee has hypothesized that the piece of cloth entered the reactor coolant system-via a decay heat valve on which maintenance had been performed. It appears that consideration was not given to establishing a logging syste Paragraph 6.8.2 of ADM 1844.05 states that, "The Radiation Protection Manual describes the Radiation Access Control Area (RACA) and the requirements for material and personnel accountability, and prohibits use of food and tobacco l which makes RACA comparable to a Zone III as defined in ANSI 45.2.3-197 Though the controlled conditions are basically for radiation and contamination control, overall cleanliness and good housekeeping results from these controls also." The Radiation Protection Manual was cancelled approximately two years ago, and replacement. procedures address material

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control only in terms of radiological waste; cleanliness is not addressed.

I Section 8 of the Nuclear Quality Assurance Manual (NQAM), "Housekeeping and Cleanliness Control" requires that implementation procedures shall incorporate the applicable requirements of ANSI N 45.2.3 and cleanliness

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requirements shall be established by the Engineering Department on the I

basis of zones that are setup in accordance vith the ANSI standard. The licensee has not designated cleanliness zones in the plant, and its implementing procedures do riot adequately implement the requirements of ANSI 45.2.3-1973. This is a violation of Criterion V of 10 CFR 50, Appendix B which requires that activities affecting the quality shall be prescribed by procedures appropriate to the circumstances (346/88015-01(DRS)).

Subsequent to the inspectors' finding, the licensee identified several situations while performing surveillances which substantiated the findin Potential Condition Adverse to Quality (PCAQ) reports were written to document the finding The licensee informed the inspectors of the results of tests of the heat transfer capability of the Decay Heat-Coolers. The licensee was not aware of any previous testing of the heat transfer capability of the coolers. The tests revealed that both coolers had a lower heat transfer

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capability than stated in the USAR. The licensee inspected the internals i

of both coolers. Neither cooler showed any signs of degradation or '

significant foulin The licensee concluded that the heat transfer l capability of the coolers has been lower than stated in the USAR for I a significant period of the operating life of the plant (years). The l licensee evaluated the USAR accident analyses and determined that the l coolers are capable'of performing their safety function. The licensee i is documenting this situation and its resolution in Potential Condition I l Adverse to Quality (PCAQ) Report 88-041 This will remain an Unresolved Item (346/88015-02(DRP)) until the inspectors can review the licensee's i evaluation and corrective actions.

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Region III management requested that the inspectors review the licensee's method of monitoring the temperature of the AFW system piping and determine if there had been any history of elevated temperature of that pipin The licensee informed the inspectors that the temperature of the' piping is

. checked periodically by touching it near Valves AF 599 and AF 608. These valves are located just outside the shield buildin Licensee personnel could not recall any times when any of the AFW system piping had been at an elevated temperature. Whenever the inspectors have checked the AFW piping in the past it has been at ambient temperatur On June 2, 1988, the licensee identified a potential problem with small gaps below the door for the auxiliary building train bay near the spent fuel poo The licensee documented this situation in PCAQ Report 88-041 A diesel powered manlift was being used intermittently near the door. An exhaust hose from the diesel had been temporarily installed beneath the doo The gaps, which had been sealed when the hose was installed, were next to the hose. The licensee evaluated the gaps and determined that they were too small to prevent the Emergency Ventilation System from maintaining a negative prassure in the spent fuel pool area. On June 3,

, 1988, upon reviewing the licensee's evaluation, the inspectors determined that the potential also existed for an unmonitored release path if a fuel handling accident were to occur while the diesel was running. The inspectors brought this to the attention of cognizant licensee managers and work involving the manlift was stopped while formal written controls were established to prevent the diesel from being operated while fuel handling was in progress. The licensee determined that the diesel had not been operated while fuel was being move An engineering evaluation determined that the location of the diesel and the small air flow rate through the engine and exhaust would have prevented a radioactive release if the diesel had been running during a fuel handling acciden This will remain an Open Item (346/88015-03(DRP)) until the inspectors can review the licensee's root cause analysi ,

No other violations or deviations were identified in this are ' Monthly Maintenance Observation (62703)  !

Station maintenance activities of safety-related systems and components i listed below were observed / reviewed to ascertain that they were conducted in accordance with approved precedures, regulatory guides and industry ]

l codes or standards and in conformance with technical specification I The following items were considered during this review: the limiting conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicable; functional testing or calibrations were performed prior to returning components or systems to service; quality :ontrol records were ,

maintained; activities were accomplished by qualified personnel; parts '

and materials used were properly certified; radiological controls were implemented; and, fire prevention controls were implemented.

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Work requests were reviewed to determine status of outstanding jobs and to assure that priority is assigned to safety-related equipment maintenance which may affect system performanc The following maintenance activities were observed / reviewed:

• Offsite refurbishment of Service Water self-cleaning strainer by the strainer manufacturer, R. P. Adam After the strainer was received s by R. P. Adams, commercial terms could not be agreed upon and no work (

was don The strainer was shipped back to the site.- The licensee informed the inspectors that R. P. Adams and S. P. Kinney, the only domestic manufacturers of self-cleaning strainers, are no longer certified to perform work on nuclear components and do not intend to regain such certificatio The licensee now intends to ir.spect the strainer onsite and perform any required maintenanc * Calibration of boric acid addition tank level indicators, LI-MU49-2 and LI-MU65- Operational Safety Team Inspection (OSTI)

Report No. 50-346/87024 included the observation that the failure to establish specified calibration intervals for LI-MU49-2 and LI-MU65-2, as required by Section 12.4 of the licensee's Nuclear Quality Assurance Manual, was considered a weakness. The licensee reviewed the OSTI report and provided the inspectors with a copy of an intra-company memorandum, "LCTS No. 4431," dated April 7, 1988, copies of Maintenance Work Orders 3-84-1670-01 and 3-84-1672, and printouts of the computer ,

files for preventive maintenance (PM) activities 1670 and 1672 (printed April 5, 1988). The inspectors' review of these documents and Procedure DB-MN-00002, Revision 8. "Preventive Maintenance,"

indicates that the licensee had established specified calibration intervals for LI-MU49-2 and LI-MU65- These indicators are calibrated as part of a string calibration every_other refueling outage. The licensee considers this an "event" interval P DB-MN-00002 does not specifically indicate how a PM computer file is to prepared for an event interval P This weakness in DB-MN-00002 is an Open Item (346/88015-04(DRP)).

• Repair of microbiological 1y induced corrosion in Service Water to Component Cooling Water Heat Exchange ,

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• Replacement of Service Water system valve l l

• Balancing of Auxiliary Feedwater (AFW) Pump Turbine roto l

• Installation of EDG lubrication oil pump l

• Installation cf local control panels for the motor driven feedwater pump syste * Functional verification of pressurizer vapor sample line valve i modification (FCR 86-0031).  ;

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• Steam and Feedwater Line Rupture Control System modification (FCR 87-1107).

• Low voltage circuit check of new switchgear for Substation F7

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(FCR 86-0425).

• Installation of new AFW piping and valves (FCR 86-0330).

• Reorientation of AFW main steam admission valves (FCR 88-0049).

• Low voltage circuit check of annunciator reflash modification (FCR 87-1110). The inspectors noted that four slide links were fused shut. Discussion with the Electrical Superintendent revealed that the slide links had been brazed. shut intentionally as an electrical safety measure. However, the affected drawings had not been corrected. The inspectors also noted that an apparently uncontrolled vendor document was used during this maintenance-activit This is an Unresolved Item (346/88015-05(DRP)) until the inspectors can review the licensee's ovaluation of these condition Following completion of maintenance on the EDG, SW and CCW systems, the inspectors verified that these systems had been returned to service properl No violations or deviations were identified in this are . Monthly Surveillance Observation (61726)

The ir.spectors observed technical specifications required surveillance testing on the pressurizer level instrumentation, DB-MI-03151.07, "Channel Calibration of 64B-ISLRC14-1, Reactor Coolant Pressurizer Level," and verified that testing was performed.in accordance with adequate procedures, that test instrumentation was calibrated, that limiting conditions for operation were met, that removal and restoration of the affected components were accomplished, that test results conformed with technical specifications and procedure requirements and were reviewed by personnel other than the individual directing the test, and that any deficiencies identified during the testing were properly reviewed and resolved by appropriate management persuane The inspectors also witnessed portions of the following test activities:

• ST 5099.05, "Shift Channel Check of the Radiation Monitoring System." l

• DB-ME-03001, "Station Batteries Quarterly Surveillance."

• DB-ME-03002, "Station Battery Service and Performance Discharge Test."

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• DB-PF-10031, "Auxiliary Feedwater System Main Steam Test."

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• DB-PF-10048, "Reactor Power Auctioneer Acceptance Test."

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• 08-SC-10002, "Emergency Diesel Generator Lube Oil System Test."

The test could not be completed due to the failure of a check valve. The licensee documented the valve failure in PCAQ Report No.88-042 This is an Open Item (346/88015-06(ORP)) pending review of the licensee's evaluatio * 08-SP-10065, "Decay Heat 13A/B and Decay Heat 14A/B Valve Test."

During the test briefing for this test the inspectors noted that the test leader interacted with the assistant shift supervisor in a non professional manner. This was brought to the attention of licensee management. A short time later the plant manager directed the test halted and the test leader was relieved of his duties. A new test leader was assigned and the test was complete No violations or deviations were identified in this are . Licensee Event Reports Followup (92700) Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine that reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had been accomplished in accordance with technical specification * (Closed) LER 88-012: Inadvertent SFAS initiation due to Radioactive Material Transfe The following LER's were reviewed during the inspection period, but could not be closed:

• (0 pen) LER 88-011: Incorrect termination of a continuous fire watch following maintenanc e (0 pen) LER 88-013: Inoperable fire detection due to inadequate desig No violations or deviations were identified in this are . Independent Safety Engineering (ISE) (71707) i l

The licensee's Independent Safety Engineerir.g (ISE) Division performed a Safety System Outage Modification Inspection (SS0MI) of Facility Change Request (FCR)86-330. The FCR implements flow control improvements to the auxiliary feedwater (AFW) system. On May 16, 1988, the licensee issued an interim report which covered Phase I of the inspectio Phase I consisted of a critical assessment of the detailed design and engineering aspects of the modificatio The inspection identified several potential weaknesses in several area , - -

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'The: licensee identified problems'with the pressure drop calculations for -

hardware whicn was to be utilized in the modification. The calculations were non conservative which led to an error in the valve specification The, valves as specified could potentially have resulted in the AFW system being incapable of satisfying its intended functio However, the vendor supplied a valve with better characteristics than specified which offset the calculation errors. Most of=the: deficiencies identified ~ appeared to be caused by inattention to detai The SSOMI identified a condition in which a. single failure would have '

readered the AFW system inoperable with a main steam line brea Valves AF 599 and AF 608 provide a common flow path to their' respective steam generators for a main steam line break. A short circuit between

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Conductors X31 and CL in the respective valve cables would result in the closure of the respective valve which would cause the AFW system to be incapable of performing its safety function. - This is a violation of-Criterion 3 of 10 CFR 50, Appendix B (346/88015-07(DRP)). The licensee had approved the modification and ~its normal review process did not-identify the discreparcy. The deficiency would not have been identified during the modification testing of the AFW system. It was fortuitous that ISE chose the AFW system to perform its 550M No other violations or deviations were identified in this are . Followup on 10 CFR Part 21, Emergency Diesel Generator Engines On April 26, 1988, Morrison-Knudson Company, Ind, issued a report on defective upper connecting rod bearings for EMD 645 diesel engines as

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required by 10 CFR 21.21. Certain bearings (P/N 835411M were defective

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and could not be used for nuclear service. The licensee performed an inspection on both emergency diesel generator engines and determined that neither diesel had the defective bearings installed. The work was controlled by MWO 7-88-0384-0 This item is close No violations or deviations were identified in this are . Emergency Precaredness (82203)

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Near the end of the inspection period, individual sirens in the Prompt l Notification System actuated without'bein0 sent an authorized command, i The inspectors determined that the licensee was giving this problem adequate attention. Region III Emergency Preparedness inspectors were informed of the situation and will review the licensees resolution of ;

this proble I No violations or deviations were identified in this are . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, noncompliance, or deviations. Unresolved items disclosed during the inspection are discussed in Paragraphs 3 and _

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11. Open Items Open items are matters which have been~ discussed with the licensee,-which will be reviewed further by the inspectors, and which involve some' action on.the part of NRC or licensee or bot Open items disclosed during the inspection are discussed in Paragraphs 3, 4, and . Exit Interview (30703) ,

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

throughout the: month and at the conclusion of the inspection and summarized the scope and findings of the inspection activities. The licensee acknowledged the findings. After discussions with the licensee, the'

inspectors-have determined there is no proprietary data contained in this inspection report.

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