IR 05000346/1988032
| ML20206K266 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 11/21/1988 |
| From: | Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Shelton D TOLEDO EDISON CO. |
| Shared Package | |
| ML20206K271 | List: |
| References | |
| NUDOCS 8811290342 | |
| Download: ML20206K266 (2) | |
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NOV 211988 Docket No. 50-346 Toledo Edison Company ATTN: Mr. Donald Shelton Vice President Nuclear Edison Plaza I
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300 Madison Avenue
Toledo, OH 43652
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This refers to the special safety inspection conducted by Mr. J. McCormick-Barger
of this office from September 12 through November 3,1988, of activities at the
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Davis-Besse Nuclear Power Station authorized by Facility Operating License No. NPF-3 and to the dis:ussion of our findings with you and others of your i
staff at the conclusion of the inspection.
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l The enclosed copy of our inspection report identifies areas examined during
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the Inspection. Within these areas, the inspection consisted of a selective
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i examination of procedures and representative records, observations, and
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interviews with personnel.
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No violations of NRC requirements were identified during the course of this l'
inspection.
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In accordance with 10 CFR 2.790 of the Commission's ragulations, a copy of
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this letter and the enclosed inspection report will be placed in the NRC
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Public Document Room.
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The responses directed by this letter and the accompanying Notice are not I
subject to the clearance procedures of the Office of Management and Budget i
as required by the Paperwork Reduction Act of 1980, PL 96-511.
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We will gladly discuss any questions you have concerning this inspection, f
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Sincerely,
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Richard C. Knop, Chief i
Reactor Projects Branch 3 i
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Enclosure:
Inspection Report
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No. 50-346/88032(ORP)
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Toledo Edison Company
NOV 21 1988
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Distribution:
REGION III==
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Report No. 50-346/88032(DRP)
Docket No. 50-346
License No, NPF-3
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Licensee:
Toledo Edison Company
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Edison Plaza, 300 Madison Avenue
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Toledo, OH 43652
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Facility Name: Davis-Besse Nuclear Power Station Unit 1
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Inspection At: Davis-Besse Site, Oak Harbor, Ohio
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Inspection Conducted:
September 12 through November 3,1988
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Inspector:
J. W. McCormick-Barger
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Approvad By: Robert W.
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Reactor Projects, Section 3A
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Inspection Summary
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Inspection on Sestember 12 through November 3, 1988 (Report
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No.50-346/88032()RP))
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Areas Inspected:
Special, unannounced safety inspection with regard to
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licensee actions on previous inspection findings; and review of a series of
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allegations related to the operation of the Davis-Besse facility.
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Results:
No violations or deviations were identified.
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8811290344 881121
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DETAILS
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1.
Persons Cor tacted
Toledo Edison Company
- L. Storz, Plant Manager
- P. Hildeb"andt, Engineering General Director
"E. Salowitz, Planning and Support Director
- R. Schrauder, Nuclear Licensing Manager
- L. Ramsett, Director, Quality Assurance
- B. Shingleton, Licensing Engineer
Other pla it personnel were contacted during the inspection.
NRC
- P. M. Byron, Senior Resident Inspector
- D. C. Kosloff, Resident Inspector
- J. W. McCormick-Barger, Reactor Engineer, Branch 3, DRP
- Denotes those persons present at the exit meeting on November 3, 1988,
2.
Licensee Action on Previous Inspection Findings (92701)
a.
(Closed) Violation (346/87012-01A(DRp)):
Failure to follow
procedures requiring plant workers to only perform activities as
directed bv approved Maintenance Work Orders (MW0s).
Plant staff
unsuccessfully attempted to perform a functional check of the timing
sequence of the oil failure safety control switch, PSL-2807, and
associated timer for the control room emergency ventilation system
condensing unit per MWO 3-87-1174-01, subsequently they obtained an
uncontrolled manufacturer's instruction for testing the time delay
and conducted this test prior to incorporating it into the work
package.
The inspector reviewed the licensee's response to this violation
dated October 25, 1988.
The response acknowledged the violation and
stated that the existing procedure (if followed) is an effective
mechanism for controlling work and post maintenance / modification
testing. The licensee also stated that personnel involved in the
maintenance activity were made aware of the specific procedural
violation and the procedural requirements for performing the
post maintenance testing. The inspector reviewed memoranda
dated November 2, 1988, from the Assistant Plant Manager,
Maintenance, and the Director, Quality Assurance, to their staffs
informing them of the violation and that "a contributing cause of
the violation was the apparent agreement by individuals involved in
performing the functional check that testing outside the scope of
the MWO was acceptable for this special situation".
The managers
reminded their staffs that this is an unacceptable practice. This
item is considered closed.
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b.
(Closed) Violation 346/87012-01BJ:
Failure of the Quality Control
(QC) department to comply with Quality Assurance Division Procedure
(QADP) No. 2.2 (QA-QC-07002.02)), "Qualification and Certification
of Personnel Performing Quality Control Activities". Although the
subject procedure required all QC inspectors to have completed
qualification cards, several inspectors were found to have not
completed the qualification cards.
The licensee had identified
this problem during a QA audit but did not adequately resolve the
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audit finding. QC inspectors who had been at the site prior to
the issuance of QADP No. 2.2 had been previously qualified under
the requirements of Quality Control Instruction (QCI) 3020. This
procedure did not require qualification cards.
In response to the
audit finding, the licensee wrote a memorandum dated January 7,
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1988, to the QA audit group stating that incumbent inspectors would
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nnply with the new QA certification requirement when they were
recertified.
The QC inspectors found not to be in compliance with
the new procedure were not due for recertification.
Although the
proposed "grandfather clause" is generally an acceptable solution
to update incumbent inspectors when qualification procedures are
changed, the licensee should have incorporated the grandfather
clause into the procedure rather than rely on a memorandum.
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The inspector reviewed the licensee's resoonse to this violation
dated October 25, 1988.
To correct this deficiency, the licensee
revised the qualification procedure to allow incumbent inspectors
not to have completed qualification cards until they recertify in
their inspection discipline.
The inspector reviewed the revised
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procedure and found it to adequately respond to the violaticn.
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This item is considered closed.
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c.
(Closed) Violation (346/87012-01C):
Failure to process Potential
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Conditions Adverse to Quality Reports (PCAQRs).
Twu PCAQR were
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identified that were initiated but not processed (not sent) to
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the shift supervisor and PCAQR review board) as required by
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Procedure NMP-QA-702, "Potential Condition Adverse to Quality
Reporting," Revision 1, dated May 25, 1986.
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The inspector reviewed the licensee's response to this violation
dated October 25, 1988.
In this response the lirensee acknowledges
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that in both cases personnel failed to follow procedures.
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licensee stated that the failure to process the PCAQR was not a
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deliberate attempt to suppress the identification or correction of a
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problem.
The inspector concluded from his review of the events
leading to this violation, as identified in Inspection Report
Nc. 346/88012(DRP), that the discrepancies identified in the
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PCAQRs were addressed in a technically adequate manner.
However,
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as the licensee stated in '.s response, the improper handling of
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the PCAQRs undermined the LCAQR process.
To resolve this concern,
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the licensee revised its ?CAQR procedure to better define the role
supervisors have when rr. viewing and signing PCAQRs being prepared
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by the supervisors' nbordinates.
Training was also conducted for
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all supervisory prsonnel emphasizing that once a PCAQR is initiated,
it must be pr..essed per the requirements of the PCAQk procedure.
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The licensee alto issued new PCAQRs to formally address the
discrepancies identified in the PCAQRs that were not processed.
The inspector reviewed these reports and found them to adequately
address the original concerns. This item is considered closed.
d.
(Closed) Unresolved Item (346/88012-03:
The review and disposition
of 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 implementing the
MWO and that the supports were installed prior to the Request for
Assistance (RFA) being issued.
From discussion with Davis-Besse Facility Maintenancs Department
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(FMD) supervisory personnel, the inspector learned Caat the decision
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to install the pipe supports identified in the PCAQR with the
bottoms of the base plates painted with primer paint only, was made
based on the belief that primer paint met the requirements of the
applicable procedure.
The inspector reviewed Maintenance Procedure MP 1701.48,
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"Application of Protective Coatings Outside Con'ainment,"
Revision 01, dated August 25, 1987.
Section 8.2.8 of this
procedure requires that "surfaces which require paint protection
and will be inaccessible after installation shall be painted before
installations". This procedure does not define the activity paint
or painted.
Section 5.1.6 of this procedure states that "surface
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preparation, color selection, painting system to be used, and
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coating application shall be in accordance with the requirements
of this procedure.
This procedure again did not define painting
system, however, it did list, as Enclosure 1, painting systems
for various physical and/or environmental conditions.
However,
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Enclosure 1 is not referred to in the body of the procedure.
From
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the above, the inspector concluded that FMD's interpretation of the
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activity "painted" to allow the bottoms of base plates to be painted
with primer only did not directly conflict with the procedure as
written.
To prevent further confusion concerning required painting,
the licensee stated that the procedure would be reviewed and changes,
as necessary, would be made.
Prior to writing the subject PCAQR, the QC inspector informed FMD
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supervision that its interpretation of the painting procedure to
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allow primer only paint was not conservative and may violate the
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intent of the procedure. To resolve the QC inspector's concern,
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FMD prepared Request for Assistance (RFA) Number 88-0237, requesting
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engineering to evaluate the acceptability of primer coat as
referenced in the s,'ecific.ition and procedure as an acceptable
coating for inaccessible areas.
Design engineering responded to
this RFA on the same day stating that primer coat is acceptable for
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base plates on the "grouted side or side to wall." FMD informed the
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QC inspector of Design Engineering's response.
The following day,
the PCAQR was written describing the QC inspector's original concern.
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This PCAQR was apparently written because the QC inspector did not
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understand that the RFA was a procedurally allowed method to deviate
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from the painting procedure or did not agree with the resolution of
the RFA.
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Based on review of the disposition of the PCAQR, and its acceptance
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of the primer only painted pipe support base plated as described in
Inspection Report 346/88012 Paragraph 2.b.(3), and the information
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identified above, the inspector determined that the licensee's
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actions were in accordance with NRC requirements. This unresolved
item is closed,
e.
(Close)UnresolvedItem(346/88027-0D: Davis-Besse engineering's
inappropriate use of an HWO continuat. ion sheet to specify design
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information. During review of the inappropriate invalidation
of a PCAQR prepared to document a Raychem insulation installation
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activity for K40-1-86-0991-04 documented in NRC Inspect *on Report
No. 346/88027, the NRC inspector identified an apparent
inappropriate use of the Md0 continuation sheet to specify design
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information in the form of engineering instructions prepared on
May 16, 1986. A review of the events and requirements at the tir.e
the engineering instruction was prepared revealed the following:
Prior to May 9, 1986, Raychem insulation installations were specified
by Rd0 planners based on field data and the Raychem installation
manual and a drawing depicting terminations for solenoid valves,
motor valves, and motors (drawing E302A sheet 39M).
Due to problems
associated with the termination drawing and methods used to install
the insulation, Davis-Besse determined that many of these installations
were not in accordance with Raychem's installation requirements. On
May 9,1986, Licensee Event Report (LER) No.86-021 was initiated to
identify the Raychem insulation problem, and all Raychem installation
field work was stopped. A task force was organized to inspect
TheNRCgRaycheminstallationsandreworkdiscrepantapplications.
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s review of the licensee's corrective actions was performed
as part of the closecut of LER 86-021. On May 16, 1986, engineering
began preparing engineering instructions to be attached to MW0s to
allow maintenance work involving Raychem installations to continue.
The engineering instructions consisted of specifying a Raychem
application kit and including installation instructions identical to
those instructions found in the applicable Raychem kit.
These
engineering instructions were based on field data obtained by the
engineering department and the controlled Raychem installation
manual.
In order to provide a long term record of Raychem work activities,
on June 9,1986, engineering issued Nuclear Facility Engineering
Instructions, NEl-031,1, "Processing Raychem Installation Instruction
Sketches," and revised NEP-031, "Engineering Sketches " to allow
engineering sketches to be incorporated into Md0s. After establishing
the above program, engineering began issuing engineering sketches
similar to the engineering instructions issued during the previous
3 weeks, except that each unique installation had its own controlled
sketch depicting the Raychem kit and instructions used to install
the insulation. On August 5, 1986, engineering reportably
retrofitted Raychem engineering instructions provided with Md0s
between May 16, 1986, and June 9,1986, to comply with NEI-031.1
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and NEP-031. On November 14, 1987, engineering incorporated Raychem
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approved sketches into drawing E-1037A "Instruction Manual for
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Preparation and Installation of Raychem Kits." This manual includes
a matrix of all Raychem applications listed by device number.
From review of the above information the inspector concluded that
the program used to specify Raychem insulation applications during
the May 16, 1986 through June 9, 1986 timeframe was acceptable
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per existing Davis-Besse procedures since engineering was not
specifying design requirements, but rather interpreting requirements
already provided in the controlled Raychem installation manual.
This was done to preclude the possibility of erroneous installations
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similar to those that had occurred prior to May 9, 1986.
In addition,
the licensee developed a program to enhance its control and
documentation of Raychem applications and retroactively included the
engineering instructions provided at the beginning of the Raychem
improvement program.
The NRC inspector verified that the Raychem
application specified in MWO-1-80-0991-04 (the MWO in question) had
been retroactively included in the new Raychem installation manual
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(drawing E-1037A).
This unresolved item is closed.
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No violations or deviations were identified.
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3.
Allegation Reviews (92701)
a.
Allegation RIII-88-A-0012 (Closed)
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Concern No. 1: A contract employee was assigned a task of trimming
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fire barrier sealing material.
The employee used a hacksaw for the
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task and accidentally cut the insulation of an electrical cable,
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causing an electrical short.
The matter was reviewed by licensee
personnel to determine the cause of the electrical short, but the
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employee did not mention his use of the hacksaw.
Because of this,
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the investigation of the electrical short concluded that the cable
insulation was brittle and the cable had been bent too sharply.
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was also alleged that metal tools are by procedure not allowed to
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be used to trim sealing material (only plastic tools, which do not
work). However, as of January 1988, metal tools were often used to
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perform this type of work,
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NRC Review:
This concern was initially transmitted to the licensee
Tor its review and action on June 14, 1988 (Attachment 1). On
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July 22,1988, the licensee provided the NRC with written results
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of its review and disposition of the matter (Attachment 2).
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The inspector reviewed the licensee's written response, Maintenance
Procedure (MP) 1405.03, "Installation of Silicone Foam / Caulk
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Penetration Sealing Systems," and Potential Condition Adverse to
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Quality Report (PCAQR) Number 87-589 generated for the electrical
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cable short event.
From this review the inspector determined that
the use of metal tools to trim sealing material from fire barrier
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penetrations was a procedurally allowed activity during the tirne of
the event.
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The licensee concluded that the event. described in the PCAQR was due
to cable damage attributed to craft personnel attempting to push
cable back into a condnit fitting with sharp edges while performing
work on a penetration.
However, to preclude the possibility that
using metal tools might cause such an event in the future, the
licensee generated conduit sealing requirements in a memorandum
dated October 30,1987 (FM-87-860).
These requirements included
instructions to use hands rather than a knife or hacksaw blade to
remove excess foam from the face of conduits.
Training to these
requirements was reported in the PCAQR as being provided to contract
employees on November 2, 1987.
The licensee issued a change to the
maintenance procedure on February 24, 1988, that also disallowed the
use of a knife or hacksaw blade to remove excess foam.
The
inspector attempted to contact the worker alleged to be responsible
for cutting the conduit, but was informed by the contract
organization that he no longer works for the contractor. The
inspector also attempted to witness trimming activities but was
informed by the licensee that most conduit trimming activities have
been completed and no current trimming activities were in progress.
Conclusion:
The inspector was not able to substantiate that metal
tools have caused electrical cable shorts or that metal tools are
currently being used to trim conduit sealant. The licensee's
corrective actions for the event in question appeared to be adequate
in addressing the use of metal tools. Documented trainig was
conducted and procedures were revised.
In addition, the licensee
conducted an audit of the penetration seal repair project due to
similar allegations received by the licensee's Ombudsman. This
audit revealed several procedural problems but found no evidence
that would question the quality of the seal repairs being performed
under the controlled program.
This concern is considered closed.
Concern do. 2: During $eptember 1987, a contract employee overheard
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a conversation in which a contract foreman assigned an employee to
a task for which the employee was not qualified.
The employee told
the foreman that he was not qualified to perform the task, the
foreman replied that another worker, who was qualified, wayld be
working within fifteen feet of the job and the qualified worker
would sign for the work performed by the unqualified worker.
NRC Review:
The inspector reviewed Davis-Besse Nuclear Training
Division Procedure NT-MT-7021 "lraining and Qualification of
Maintenance Personnel", Revision 0, dated July 10, 1987. The
procedure specifies the training requirements for all maintenance
personnel at the Davis-Besse site.
Section 6.1 of this procedure
requires that all personnel performing maintenance activities within
a specific qualification area at the site shall either be qualified
(via qualification cards) or "perform assignments in that area only
under the close supervision of a qualified individual."
The inspector contacted the individual alleged to have been directed
to perform the work. The individual, who is no longer a Davis-Besse
worker, stated that he did not recall the incident, nor did he
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believe that the foreman would have had him do work that he was not
qualified to do. The inspector also questioned about one-half of the
remaining craft workers currently qualified to perform penetration
sealing work about work qualification irregularities.
These craft
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workers stated that they were unaware of anyone performing work for
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which they were not qualified.
The licensee also reviewed an allegation similar to this and after
reviewing a sample of completed work packages and performing a QA
audit of the penetration sealing program, was unable to substantiate
its allegation.
The licensee performed documented training with the
contractor organization, expressing among other things the need to
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follow Davis-Besse procedures.
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Conclusion: The inspector was unable to substantiate this concern.
This concern is considered closed.
Concern No. 3: A worker cleaned a fire barrier penetration.
Prior to the installation of the fire seal a quality control (QC)
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inspector determined that the penetration was not sufficiently
clean.
The worker cleaned the penetration again, but the inspector
refused to reinspect the penetration and just told the worker to go
ahead and install the fire seal material.
In another incident a
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quality control inspector refused to inspect an installed fire
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barrier penetration seal due to the difficulty of reaching the
NRC Review: The NRC inspector contacted the alleger in an attempt
to obtain aaditional information concerning this allegation.
The
NRC inspector obtained the name of the QC inspector that was alleged
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to be involved with the incidents. The NRC inspector determined
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that the QC inspector in question no longer worked at the site.
The NRC inspector was informed that a similar concern was provided
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to the Davis-Besse Ombudsman.
The NRC inspector reviewed the
Ombudsman report including the investigation of the concern.
The
licensee's investigation included interviewing several QC inspectors
(including the QC inspector in question). The licensee also selected
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25 sealant activity work packages that were inspected by the
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QC inspector in question, and verified through security access
records that the QC inspector was in the area at the time of the
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QC signoff. Based on the above, the Ombudsman report concluded that
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the concern could not be substantiated.
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The NRC inspector questioned about one-half of the QC inspectors at
Davis-Sesse concerning whether they knew of any inspectors that did
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not perform all inspections that were required.
In no case did the
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QC inspectors know of a case where a QC inspector did not perform
the required inspections.
The NRC inspector also questioned about
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one-half of the remaining contractor employees that were responsible
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for penetration sealant work.
These employees also knew of no
case where QC inspeetors had not performed required inspections,
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Conclusion: The NRC inspector was unable to substantiate this
concern.
This concern is considered closed.
Concern No. 4: The spent fuel pool was inadequately protected
Because it was easily accessible to people walking by and someone
could easily drop or throw something into it.
NRC Review:
The inspector examined the fuel pool for gross
cleanliness and found it to be acceptable. The licensee's access
control the fuel pool was found to be acceptable in that access is
limited to trained or escorted plant personnel / visitors and
appropriate radiological and cleanliness controls were in place.
Conclusion:
This concern was not substantiated. This concern
is considered closed.
b.
Allegation RIII-88-A-0036 (Closed)
Concern:
Before or during early March,1988, contractors who were going to
be working on safety-related snubbers failed a qualification test.
The tests were evaluated and when "plant specific" questions were
deleted, the contractors were deemed to have passed the tests.
NRC Review: On May 4, 1988, this allegation was sent to the
licensee for its review and action (Attachment No. 3).
The
licensee provided its findings to this allegation in a response
to NRC Pegion III on June 1, 1988 (Attachment No. 4). The
inspector reviewed the licensee's response to the allegation and
reviewed the licensee's training procedures and selected training
records. A review of some tests administered for snubber work
activities during early March 1988, revealed that some test scores
were revised, resulting in at least one worker's score being raised
from a failing score to a passing score.
The reason for the revised
scores wcs due to the after-the-fact deletion of a test question
that was inapprop*iate to the objectives of the test being adminis-
tered.
The inspector agreed with the licensee's decision to delete
the question from the test, and found no irregularities with the
testing program.
Conclusion:
This allegation was not substantiated in that the
inspector was not able to find instances where test scores were
changed due to the removal of "plant specific" questions (only
inappropriate questions),
This allegation is considered closed,
c.
Allegation No. RIII-88-A-0070 (Closed)
Concern No. 2: The Potential Condition Adverse to Quality Report
(PCAQR) program is not effective.
The PCAQR review board is quick
to either invalidate or disposition PCAQRs with little or no
rework. Justification for these actions are not based on the
plant's procedures or other requirements. Some PCAQR dispositions
are based on simple majority rule, rather than technical validity.
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As an example of an inappropriately dispositioned PCAQR, PCAQR
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Number 88-0015 was identified as being inappropriately dispositioned
in that it was invalidated even though a software deficiency existed
in the field (safety-related conduit support missing support number
identification.)
NRC Review: The inspector reviewed Nuclear Group Procedure
NG-QA-00702, "Potential Condition Adverse to Quality Reporting,"
Revision 0, dated August 1, 1988.
This procedure provided the
instructions for initiating, processing, and closing PCAQRs. The
inspector also observed the conduct of a review board and reviewed
several PCAQRs being processed by the board.
From the above reviews
and observations the inspector determined that PCAQRs are generally
processed in a controlled and organized matter. The NRC Davis-Besse
residents receive copies and perform cursory reviews of nearly all
PCAQRs when initially issued and perfom detailed reviews of
selected PCAQRs during and/or after they have been processed by
the PCAQR review board and are either closed or ready for closure.
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The number reviewed in detail is only a small percentage of the
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number processed yearly by the PCAQR review board which can total a
thousand or more.
The residents have concluded that generally the
dispositions of PCAQRs are adequate and conservative.
However, the
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residents have identified isolated examples of PCAQRs that had
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dispositions that were less than conservative.
These examples have
not represented a significant weakness in the program, and were
subsequently corrected.
The inspector reviewed PCAQR No. 68-0015, which w3s identified
as an example of a PCAQR that was inappropriately dispositioned
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(invalidated). This PCAQR identified that several Class IE
electrical supports had been installed without permanent identift-
cation numbers as required by FCR 87-087 Supplement Number 74.
This FCR specified a new raceway support identification system to
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be used on all new seismic raceway supports for Class 1E and II/I
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raceway supports.
Frem discussions with plant engineering, the
supports identified by the PCAQR, were installed under the old
support identification program.
Under this old program QC had been
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providing and installing raceway support identification numbers.
Because of this, the QC inspector should have obtained
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identification numbers and attached them to the supports prior to
final closure of the support installation packages as agreed to in
the resolution of. Request For Assistance (RFA) 87-0343-00. This
RFA was generated by QC for engineering to evaluate the need for a
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support numbering system and to identify who is responsible for the
numbering system, if required, since existing support numbering
procedures had been canceled.
Engineering responded to the RFA by
developing the numbering system identified in FCR 87-087 Supplement
Number 74
An agreement was made with QC and documented in
engineering's response to RFA 87-0343-00 for QC to continue to
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provide support numbers until such time that isometrics sketches
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began to reflect support numbers in a manner identified in the FCR.
From review of the above documents, it appears that invalidating
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the subject PCAQR was a proper disposition.
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Apparently QC had decided, subsequent to receiving the response to
the RFA, to discontinue maintaining the old support identification
log.
Because of this, the QC inspector who initiated the PCAQR,
was unable to assign permanent identification numbers to the
supports in question.
This information was not identified in the
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PCAQR and apparently not made known to the PCAQR review board.
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However, engineering was subsequently informed of this, and revised
its program to include providing support numbers to all recently
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installed or modified electrical supports upon request.
This
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program was incorporated into Maintenance Procedure DB-MM-01001,
"Installation Procedure for Essential Electrical Hangers and
Supports," Revision 00, dated June 23, 1988.
The inspector
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determined that the supports identified in the PCAQR were assigned
permanent support identification numbers prior to their final
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installation package closures.
Ouring the inspector's review of selected PCAQR, the inspector
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noted that several PCAQRs had identified corrective actions that
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were subsequently removed by the PCAQR review board, apparently to
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expedite the closure of the PCAQRs. A similar observations was
noted during a Davis-Besse Quality Assurance (QA) audit of the
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plant's corrective action program. Observation Number 7 of Audit
Number AR-88-CORAC-01 identified several corrective actions to
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prevent recurrence that were evaluated by the PCAQR review board as
not being necessary for closure.
The PCAQR review board chairman
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responded to the QA observation in a memorandum dated May 18, 1988.
]
In this response the chairman stated that the review board had
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instituted a new policy (reportably approved by the Vice President,
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Nuclear) to limit the proposed corrective actions to items directly
affecting the condition adverse to quality. The chairman stated
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that enhancements to existing programs should be accompitshed by
other management methods such as the Request for Assistance (RFA)
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program.
The chairman also stat +d that th+ board is very careful
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when they evaluate a proposed action as only an enhancement.
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The inspector reviewed several PCa.QRs that had currective actions
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removed from the activities required to be completed prior to
closure.
The inspector concluded that these activities were not
,
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necessary to correct the condition adverse to quality, and were
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enhancements that clearly went beyond regqlatory requirements.
Since most of these PCAQRs were several months to a year or more
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old, the inspector selected several enhancements that had been
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removed from the PCAQR and attempted to verified that they had been
accomplished even though they were not required by the applicable
PCAQRs. All but one of the enhancements bad been completed.
The
,
one activity not performed concerned revising a stock crde for an
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0-ring used during hydrostatic testing (PCAQR No. 68-0163).
The
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intent of the revis'en was to delete the requirement to have the
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vendor provide a ce *tificate of conformance for the non-safety
material.
The inirector wes informed that the appropriate
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individuals ware rot infomed of the need to revise the stock code.
The result of not revising the stock code would be the initiation of
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another PLAQR upon the receipt of a new order of the subject 0-rings.
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Conclusion: This allegation was not substantiated.
Review of the
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PCAQR procedure, observations of the PCAQR review board activities,
and followup on selected PCAQRs including the example provided in
this allegation have not revealed significant weaknesses in the
PCAQR program.
This concern is considered closed.
No violations or deviations were identified.
4.
Exit Meeting
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The inspector met with site representatives (denoted in Persons Contacted
paragraph) at the conclusion of the inspection.
The inspector sunmarized
the scope and findings of the inspection noted in this report.
The
inspector also discussed the likely informational content of the
inspection report. The licensee did not identify any information that
might be considered as proprietary,
f
Attachments:
1.
Letter from NRC to Licensee dated June 14, 1988, describing s..
'ted
concerns of allegation Rill-88-A-0010 and RIII-88-A-0012.
2.
Letter from Licensee to NRC dated July 22, 1988, responding to concerns
identified in attachment No. I above.
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3.
Letter from NRC to Licensee dated May 4, 1988, describing the concern of
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allegation RI!!-88-A-0036,
4.
Letter from Licensee to NRC dated June 1, 1988, responding to the concern
identified in attachment No. 3 above.
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Attachment No.1
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Occket No. 50-346
WN 141988
,
Toledo Edison Company
ATTN: Mr. Donald Shelton
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Vice President Nuclear
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Edison Plaza
'
300 Madison Avenue
Toledo, CH 43652
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Gentlemen:
t
The NRC recently received several allegations concerning activities at the
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Davis-Besse Nuclear Power Plant. D(tails of these allegations are provided
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for your review and followup.
.
The NkC 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 acccrding 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.
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Therefore, the results of your review and the dispositions of these matters
should provide an equivalent degree of ptstection.
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Your cooperation with us is appreciated.
We will gladly discuss any questions
you have concerning this infonnation.
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Sincerely,
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"ob'rI [I treenman? I'*0* OICC O U'
k.$ IOU:
3I
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E wa
, Director
Division of Reactor Projects
[
Enclosure: As Stated
cc w/o enclosure:
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L. Storz, Plant Manager
DCD/DCB (RIDS)
,
Licensing fee Management Branch
Resident inspector, R!!!
<
James W. Harris. State of Ohio
Robert M. Quillin, Ohio
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Department of Health
[
State of Ohio, Public
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Utilities Corr ission
[
Ag
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L,^ilir.I,_ _
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I IIIIIfl
III.IIII II I
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At
h
t No. 1
,
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Enclosure
Specific Details of Allegations
Allegation th.mber Rl!!-88-A-0010
.
It has been alleged that some work that is being perfomed in the plant does
not confom to Davis-Besse painting / coating procedures, and that these
discrepancies have been identified in non-confomance documents and accepted
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 detemine 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 detemine if appropriate painting applications have been perfomed.
.
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 detemine the cause of
the electrical short, but the GEM employee did not mention the use of the
hacksaw.
It was also alleged that arecedures did not allow the use of metal
tools, only plastic or fiberglass; aowever, GEM employees have used and still
use metal tools because the allowed tools do not work.
The NPC requests that you review plant fire barrier sealant triming practices
to detemine if the above activities are cccurring, and if so, take appropriate
cor:'ective actions.
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