IR 05000346/1989026

Partially Withheld Safety Insp Rept 50-346/89-26 on 891107-900102 (Ref 10CFR73.21(c)(2)).Violations Noted.Major Areas Inspected:Lers,Plant Operation,Emergency Preparedness, Security & Engineering & Technical Support

ML19354E717
Person / Time
Site:	Davis Besse
Issue date:	01/23/1990
From:	Jackiw I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML19354E713	List: IR 05000346/1989026 ML19354E712 ML19354E715
References
50-346-89-26, NUDOCS 9002010192
Download: ML19354E717 (19)

Text

__ __ _.

• *

.c.

,

.-

.

U. S. NUCLEAR REGULATORY COMMISSION

.

REGION III

Report No. 50-346/89026(DRP)

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

Davis-Besse 'l Inspection At:

Oak Harbor, OH Inspection Conducted: November 7,1989 to January 2,1990 Inspectors:

P. M. Byron D. C, Kosloff J. M. Ulie R. K. Walton

/

k J.$ ' 70 Approved By:

I.V J ki,

ief Reattor Pr jects Section 3A Date Inspection Summary I

!

Inspection on November 7i 1989 through January 2.1990 (Report No. 50-346/89026(DRP))

!

Areas Inspected: A routine, unannounced' safety inspection of licensee action

!

- on previous. inspection findings, licensee event reports, plant operations, radiological controls, maintenance / surveillance, emergency preparedness,.

security, engineering and technical support, safety assessment / quality.

!

verification, and regional requests was performed.

Results: The inspectors have observed that the material condition of the

,

plant remains good and the licensee continues to address equipment problems

'

in a timely manner.

Licensee management appears to be more of a team which the inspectors attribute to management changes during the'past year. The inspectors believe that this has been a significant factor in-the plant's improved performance.

Systems engineering's involvement in plant operation ~

'

and maintenance activities was generally good although systems engineering ~

!

involvement failed to prevent a Technical Specification violation (Paragraph 4).

Operator performance.was generally good although examples of inattention to.

detail continue.

Inadequate control of a maintenan:e activity caused a

!

violation.of Technical Specifications (Paragraph 4).

Improved preparations i

for cold weather could have prevented two events that' degraded safety-related.

,

equipment (Paragraph 5). The inspectors identified a security violation involving discrepancies with a' vital area door (Paragraph 9).

The licensee and the inspectors identified three procedures that were partially illegible

'

(Paragraph 11).

.

g o.m...., e g u y

%. c

.

.;.\\

9002010192 900123 FDR ADOCK 0500

..

,..

-

t

<

__

-

,.

,

.-

.

DETAILS

.

1.

Persons Contacted a.

Toledo Edison Company (TE)

D. Shelton, Vice President, Nscle,ar

• G. Gibbs, Quality Assurance N rector

• L. Storz, Plant Manager-

• W. Johnson, Plant Maintenance Manager M. Bezilla, Dperations Superintendent

• E. Salowitz, Planning and Support Director

• S._Jain, Engineering Director G. Grime, Industrial Security Director T. Anderson, Maintenance and Outage Management Manager C. Hengge, Fire Protection Compliance Supervisor

• R. Schrauder, Nuclear Licensing Manager G. Skeel, Nuclear Security Operations Manager J. Polyak, Mar.ager Radiological Coiitrol

• J. Lash, Independent Safety Engineering Manager D. Timms, Manager Systems Engineering

• G. Honma, Compliance Supervisor

• R. Brandt, Plant Operations Manager - Administration

• R, Gaston, Licensing Engineer V. Watson, Design' Engineering A. Zarkesh, Independent Safety Engineering Group

• K. Prasad, Nuclear Engineering

• L. Hughes, System Engineering

• J. Moyers, Manager, Quality Verification a

b.

,USNRC

• P. Byron, Senior Resident Inspector l

• D. Kosloff, Resident Inspector

!

J. Ulie, Reactor Inspector j-

• R. Walton, Resident Inspector in Training j

• Denotes those personnel attending the January 2, 1990 exit meeting.

'

2.

Licensee Action on Previous Inspection Findinos (92701, 92702, 92720)

- i (Closed) UnresolvedJ tem (346/86005-06(DRP)): Walkdown all fire

!

a.

barrier penetrations. The inspectors found that a weakness in the

"

licensee's -design control process allowed barrier pe~netrationi seals to be exposed to pressures greater than design pressures in.the j"

event of maximum postulated flooding conditions.

In addition, the; inspectors found that there were inadequate evaluations of all penetration seals.

The licensee committed-to perform a walkdown and evaluation of penetration seals for hazards including fire, flooding, negative pressure, high energy line break and radiation.

!

The licensee has completed its walkdown and evaluation of all penetration seals and has corrected any deficiencies. In addition, '

i r -W p g,7 t-~

.%<6

,,

,.,,,-

,

\\._.. c A

7. *:r -l0 E 7M '.

J

L "s "

pg.,, ~_,p.r.e d

__

_

_

_

-.

_

_ __

+

,...

'

.

a procedure is in place to evaluate barrier seals for hazards..The

inspectors have reviewed the procedure and have verified that the licensee is in compliance.

This item is closed, b.

(Closed) Open item (346/87031-03(DRP)):

The licensee'found'seven mispositioned switches or breakers between March 26 and December 21, 1987. The licensee's security investigators performed an' investigation and the-inspectors reviewed the investigation report and backup file.

.The security investigator conducted numerous interviews and-was unable -

i to determine the root cause of the. incidents The investigator

'

.

concluded that given the physical congestion and the traffic in the-areas that all of.the events were accidental.

Reviewing the file gives credibility to this conclusion.- The licensee had previously=.

notified the inspectors and also informed Region III of its conclusions.

The licensee gave' additional training to craft personnel. This item-is closed, c.

(Closed) Violation (346/88015-01(DRP)):

Housekeeping-zone's.not specified-as required by ANSI 45.2.3-1973. The licensee revised the NQAM and revised Section 8.3.1 requires the P.lant Manager to

,

specify cleanliness zone designations. The inspectors have observed-the posting of cleanliness zones within the plant. LThis violation is closed.

d.

(Closed) Open Item (346/88015-03(DRP)):. Operation of diesel engine-in the auxiliary building train bay during fuel handling; The inspectors were concerned about a potential unmoni ered radioactive-material release path through the engine intake ano Whaust..The q

licensee's evaluation determined that the flow rate was too small to allow for a release. The inspectors' review of PCAQ 8 Bin 410, l

which documented this condition, determined that the licensee

,

concluded thr.t poor communication and inadequate documentation i

,

I related to the operation of the diesel powered'11ft were the. root j

!

causes for this condition. The inspectors review of the. root cause j

analysis closes this open item.

l

,

i e.

(Closed) Open Item (346/88015-04(DRP)):

Procedure did not-

'

specifically indicate how a preventative. maintenance (PM) computer file was to be prepared for an' event interval PM.' -The licensee i

revised Procedure DB-MN-00002, " Preventative Maintenance".to include an event interval for scheduling PM's in Section 4.16.

This-item

!

is closed.

]

.

f.

(Closed) Open Item (346/88015-06(ORP)):

Review of licensee's evaluation of check valve failure during Emergency Diesel Generator Lube Oil System Test. The licensee determined after inspection.of l

valve MP 1474 that the disc was incorrectly forged in that the seating _

!

surface was off center. The licensee inspected another valve,

MP 1476, and no defects were observed.

The other valves purchased

.

for the modification successfully passed the. modification test'.

- i This item is closed.

. (,,..., o n

'

\\

.a

..

'

' " '~

'

~

$

t]

,

. -

'

'

.

.-

J

.

g.

(Closed) Violation (346/88015-07(DRP)):

Inadequate review of

,

FCR 86-330 failed to identify a_ case where a single failure would

'

have rendered both auxiliary feedwater (AFW) trains inoperable.

The-licensee implemented a more rigorous review process.

In addition, it performed additional reviews.of-modifications implemented during

!

the fifth refueling outage.

The additional review did not identify

any significant weaknesses.

It did, however, identify several weaknesses which the licensee has taken steps.to correct. - The licensee has also established an engineering assurance (EA) '

i organization which provides an independent review of engineering

packages.

The inspectors have observed an improvement in the.

quality of the licensee's engineering reviews.

This violation is closed, ff h.

(Closed) Open Item (346/88021-04(DRP)):

Cross-di:,ciplinary review of '

procedures performed by unqualified reviewers.

The licensee issued a revision to Nuclear Group Procedure NG-IM-00115, " Preparation and Control of Nuclear Group Department and Section/ Unit Procedures",

on May 9, 1988, requiring all-individuals performing procedure '

cross-disciplinary reviews to be qualified in accordance with NG-VP-00132, " Qualified Reviewer Frogram", issued May 9, 1988.

The licensee found that 10 of the 30 randomly sampled procedures, approved after the implementation of the above procedures, had been

.

reviewed by-unqualified reviewers. The licensee has since had those 10 procedures' reviewed by' qualified reviewers and no technical: errors were found. ~ In addition, the licensee re-emphasized the ' requirement '

for having qualified-reviewers for cross-disciplinary reviews.

Approximately 6 weeks after retraining-personnel, a licensee' sample:

!

of procedures revealed that cross-disciplinary reviews were

'

i performed by qualified reviewers.

This item is closed.

i.

(Closed) Unresolved Item (346/88026-08(DRP))!

Smail: break loss of coolant accident (SBLOCA) with an initial power. level below 10 CFR 50, L

Appendix K limits.

The licensee determined that a Babcock and l

Wilcox (B&W) SBLOCA analysis assumed an initial power level of (

100 percent instead of 102 percent as required by Appendix K'of

.

10 CFR 50. This analysis was used to license the plant.; The NRC q

requested the licensee provide information related to the' history

'

and resolution of this discrepancy.

In December 1988, the licensee provided the NRC with this information.- It believed the power level discrepancy was due to an oversight in review of the original analysis. In addition,- B&W found that the core flood line break ^

i:

analysis discussed in the Safety Analysis Report likewise did'not -

use 102 percent initial power.

B&W performed calculations to assess the impact of' the 2 percent difference. in initial thermal power-l level on SBLOCA~ analysis. B&W concluded that this power level discrepancy had a minimal effect on the-SBLOCA analysis and the-plant was in compliance with the Emergency Core Cooling System (ECCS)

criteria specified in 10 CFR 50.46. The USAR was revised to reflect the results of the revised. analysis. This item is closed, i

L m,c w,nt C W n-y m

,3 y

%T!ON i

[

0 on mfd T"5 l

phge1:Dec:nuolled

,

..

.

.

.

-

. _

__

_

_

,

,

j

<-

i

'

'

.

/

.,

J.

,(Closed)UnresolvedItem(346/86023-04(DRp)): Uncontrolled storage

.

of smal_l parts removed from Service Water Pump.1-1. The inspectors have noted that increased management-attention has been devoted to.

l control of parts during maintenance and the inspectors have observed

'

significant improvement in parts control.-'This item is closed, i

4.

Licensee Event Reports Followup (90713, 92700)

i l

Throughdirectobservations,discussionswith-licenseepersonnel,a$d review of records, the following licensee event reports were reviewed to determine that reportability requirements were fulfilled,-that:immediate j

~

-

l corrective action was accomplished, and corrective action to prevent'

J

<

'

recurrence was accomplished -in accordance with-Technical Specifications (TS). The LERs listed below are considered closed:-

'

a.-

(Closed) LER 86041:

Identification and resolution of TS compliance deficiency.

The licensee discovered that two fire protection' flow

'

path valves required to be cycled annually by the TS were instead cycled on an 18 month basis. The licensee:has. changed 1ts procedure:

.

to ensure that these valves are' cycled annually.. There was no

!

deterioration of the valves due to lack of cycling. This LER is_

.

closed.

l l

b.

(Closed) LER 88027: Missed surveillance test for inoperable-

)

asymmetric rod fault circuitry. On: December 7, 1988, the licensee-missed the performance of a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> surveillance test tu check both~

i absolute and relative control rod' positions as reauired.by the..TS

'

due to the asymmetric fault alarm being inoperable. - The apparent-root cause of this occurrence was personnel error. 'The licensee-has committed to send all licensed operators a letter.to express

-

the importance of proper turnovers and updating the. control room I

status board.

In addition, the individuals involved in this'

occurrence have been counseled. The licensee has met its:

commitments and this LER is closed.

c.

fClosed)LER89013: Hourly fire watch patrol exceeded allowed interval by two minutes.

The hourly fire watch patrol was. required

.

by TS Limiting Condition for Operation (LCO)' 3.7.10, Action a.2.

'

An hourly fire watch patrol is required to patrol areas at.a

frequency of I hour and is allowed a 15 minute (25 percent) tolerance.

-

I On September 13, 1989, a fire watch patrol of the' Radiological.

Controlled Area began 1. hour and 17 minutes after the previous

'

patrol due to a delay in obtaining a self reading dosimeter.. This-is a violation (346/89026-01(DRS)) of'TS LCO 3.7.10.

The fire watch i

-

^

did not notify the shift supervisor of the~ problem until he was already late. This was a personnel error by the fire-watch. The licensee immediately identified this violation and the fire watch was counseled on September 21, 1989.

Additional corrective action-involved notifying all fire watches of this event and reminding

them of their responsibilities. The inspectors consider the

'

corrective actions appropriate. The inspectors have reviewed the licensee's corrective actions for other events involving late fire t

watches and have concluded that those corrective actions could not

.

!

'

"

IT ES i: R T.Z td P

u

_ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _, _

-.m

,. -, -

,-

c.

..

e

<%

-

. _ _ _

_ _ -

_ _ _ - _.

. _ _ _ _.

__

.-,

.

-.

.

-

-

,

,

,e

,

s i

reasonably have been expected to prevent this violation. This

.

violation meets the. tests of 10 CFR 2, Appendix C, Section V.G.1 (See Paragraph 14);-therefore,_a' Notice of Violation (NOV) will not

'i be issued and no response is required.

,

The LER did not comply with 10 CFR 50.73-(b) (2)'(ii) (c) in that-it did not state when the shift supervisor was. notified of the late fire watch patrol-. Additional guidance on this requirement is provided e

in NVREG 1022, " Licensee Event Report System", Supplement 2, page 9.

c L

The LER did not comply with 10 CFR 50.73 (b)~ (2)'(ii) (J) (2). (iv)

i in that it did not describe whether the fire watch was' a. licensee l

l employee or a' contract employee. 'The LER did not comply with l

10 CFR 50.73 (b) (4) in that it' did not discuss why corrective ~

s i

action for toe-previous' occurrence ' listed did not' prevent recurrence.

~

The LER also did not discuss why other corrective actions for other 1 ate or missed fire watenes did not prevent recurrence (NUREG 1022, page 19). The LER did not comply with 10 CFR 50.73 (b):(5) in that it did not list all previous LERs for similar events. The,LER also states that the last LER for a late fire watch ptrcl was LER 88-014

although LER 88-017 was submitted due to fire watch patrols being.

,

late at some points in their tours (NUREG 1022, Supplement l', Q and i

A 12.11).

The above deficiencies in this LER are not'significant enough to require a revised LER. However, the inspectors.have_also noted-similar deficiencies in other LERs and the apparent weaknesses in LER preparation will be discussed with the licensee during the rext

.

!

inspection period, r

!

!

d.

(Closed) LER 89014:

Inoperable fire detection zcne 237 and 323-due to installation of plastic sheeting. -- After this event. occurred, l

the licensee has identified two additional cases of smoke detectors l

being covered. This will remain an unresolved item (346/89026-02(DRS))

pending the inspectors review of-all three events and the licensee's corrective actions.

e.

(Closed) LER 89016: Unplanned release' to settlingL basin during

-

condensate polisher backwash.

The event described in this LER was evaluated in Inspection Report No _50-346/89023(DRSS). :Three violations were identified.

Some of the licensee's. corrective actions were evaluated _during'that; inspection. The licensee's

'

remaining corrective actions for the LER will be evaluated when o

the licensee's-corrective actions for violation 346/89023-02 are reviewed. This.LER is closed.

,

'

f.

(Closed) LER 89017:

Inadvertent start of containment spray pump 1-1 during SFAS testing,

'

g.

(Closed) LER 89018: Both hydrogen dilution blowers inoperable causing

<

entry into Technical Specification 3.0.3.

.

Atte.chmmt ConMM SAFCG'XF.D3 !!..V: 1.Tl]

Upon Sc;wn'J:n Tins -

Page is Dec:ntrciled R

.

j

_. _

g

t

.'

The following LER was reviewed but requires further inspection:

h.

. (Open) LER 89015:

Reactor Coolant System flow transmitter erroneously declared operable.

On September 23, 1989, the licensee completed the replacement of the loop 2 hot leg flow transmitter (FTRC01A2) which provides a Reactor Coolant System flow input-to Reactor Protection System (RPS) channel 2.

Channel 2 of the RPS was inoperable and the channel had been tripped as required by TS LCO 3.3.1.1.

On.

September 23, 1989, maintenance personnel made an error during-the-l

.

calibration of FTRC01A2. As a result of the error, the response of FTRC01A2 changed on September 24, = 1989,- when it was placed in service.

Licensee maintenance and engineering personnel then made an additional-oersonnel error in concluding that FTRC01A2 had experienced a "zero

shift" (a static pressure error generic to Rosemount pressure transmitters).- The instrumentation and control (I&C) superintendent authorized a zero shift adjustment.at this-point. Once this:

adjustment was made, the transmitter was_out of calibration and-inoperable.

Following the adjustment the I&C superintendent.

general supervisor, supervisor and mechanics rev;ewed the procedure '

and data and erroneously concluded that the transmitter was functioning properly. A system engineer then reviewed the transmitter output and erroneously concluded that the transmitter.

output was acceptable. The shift supervisor was informed that the

.jq new transmitter was in calibration and he declared RPS channel 2 operable and restored it to normal. This is a violation (346/89026-03(DRP)) of TS LCO 3.3.1.1.

The next day another I&C engineer independently reviewed the data and erroneously' concluded.

that the transmitter was functioning properly. On-September 25,

,

1989,^ during a routine daily check of the reactor coolant system equipment, the licensee noted that the flow transmitter was reading

' high and at 2:12 p.m. the channel was declared inoperable and tripped.

The LER has insufficient detail and will remain open until an adequate revision is submitted.

.!

No other violations or deviations.

5.

Plant Operations (42700, 64704, 71707, 71710, 71714)

a.

Operational Safety Verification Inspections were routinely performed to ensure that the. licensee conducts activities at the facility safely and-in conformance with regulatory requirements. The inspections focused on the i

,

implementation and overall effectiveness of.the licensee's control-of operating activities, and on the performance of licensed and

non-licensed operators and shift managers.- The inspections included i

.

direct observation of activities, tours of the facility, interviews and discussions with licensee personnel, independent verification of safety system status and limiting conditions of operation (LCO),

and reviews of facility procedures, records, and reports.

The following items were considered during these inspections:

'

"

Adequacy of plant staffing and supervision.

-

,

,

.m.-

.

5:

.

.,.s j

[,

"d Ti

,

j

,

_..

.-..

._- _ _ _ _ -

. --

_

-.

..

.

_

,

j

+

.

,

,

-

,

,

.

_

-i

.*

Control room professionalism, including procedure adherence,

'

-

operater attentiveness, and response to alarms, events, and-off-normal conditions, j

Operability of selected safety-related systems, including

'

,

attendant alarms, instrumentation, and controls.

.

Maintenance of. quality records and reports.

l The inspectors observed that control room shift. supervisors, shif t

managers, and operators were attentive to plant' conditions, performed frequent panel valkdowns and were generally responsive to off-normal; alarms and conditions.

The operating crew was generally cognizant of ongoing work activities.

-

SurveC11ances and testing cctivities were appropriately authorized =andi

logged.

Licensed operators were generally cognizant o' entry into and compliance with i.00 action requirements.

On December 13, IP89, the licensee discovered that the recirculation

-

line for High Pressure Injection (HPI) pump No.l2 was plugged with

-

ice due T.o failed heat tracing circuits.

The licensee declared the affected HPI pump inoperable and entered the appropriate action

,

statement. The licensee thawed the acirculation line and restored.

,

,

the HPI pump to opersbility within-the time allowed by the action

'

i statement. This item will remain unresolved (346/89026-04(DRP))-

'

pending the inspectors review cf the root cause-and the corrective

actions for this event, t

On December 15,1989, at 12:03 p.m., the sprinkler head over Service I

,

Water (SW) Pump No. I ciischarged water.

The motor for ~SW pump No. I and a nearby motor control center (MCC)'were wetted.

The. reduction--

i in fire header pressure CfJsed the electric fire pump to start.

Alarms were received in the control room ~ for both actuations. The shift superviser dispatched the assistant shift supervisor and an operator to the SW pump room to determine if' the alarms were valid.,

The operator determined that there was not-a fire and the sprinkler-

,

head over SW Pump No. I was spraying water un ' nearby equipment. The

[

operator isolated the fire suppressien system.

However, the licensee did not activate the fire brigade as required.

i by Procedure DB-0P-02529, " Fire Procedure." Section 3.1.2 requires:

that the fire brigade be activated if either the electric or' diesel:

fire pump starts in conjunction with a detection or suppression alarm.

Both events occurred.

Operations management was-quick to recognize the procedural violation and took prompt corrective actinn. The procedural requirement was

.the result of the licensee's response to viciation 346/89012-02(DRS).

'

This item is an unresolved item (346/89026-05(DRS)) pending review

'

,

by Region III.

' Attachment Cont &s SAFEGU AFCS INFCTJ/ *.T!CN Upon Sa;rtbn TWc

P,gc is L:ce:nt:!!cd t

i L

-

2-.-

.,,.

,_r

,

-

.

The licensee determined that freezing caused the sprinkler head to discharge.

The Updated Safety Analysis Report (USAR) Section 9.4.5.1 states that the SW pump room is maintained between 40 degrees Fahrenheit and 104 degrees Fahrenheit year round for all modes of operation.

The inspectors asked the licensee if a 10 CFR 50.59 review had been performed.

The licensee took temperature readings in the room and observed that the temperature readings ranged from 58 degrees Fahrenheit to 79 degrees Fahrenheit and conclud6d that j

the SW pump room fell within the USAR requirements and t 10 CFR 50.59 review was not reouired.

The licensee also took spot

temperature readings on the sprinkler pipe in the vicinity of the failed sprinkler and observed that the pipe temperature was 28 degrees Fahrenheit.

This was documented in PCAQR 8S-0614 dated December 19, 1989.

The licensee determined that the heat was lost from the pipe by convection through a penthouse over the SW pump room.

The licensee is evaluating whether other sprinklers could I

also be affected.

The licensee installed heat tracing on those i

sections of the sprinkler system which could be affected by f

convection cooling. The licensee previously experienced a frozen j

sprinkler head in the SW pump room on January 22, 1987, on a

dif ferent sprinkler. The reduced temperatures, however, were i

-

caused by a ventilation fan left on in manual and not convection as in this case.

$

[

On December 27, 1989, the inspettors noted that feedwater system pH on the controi room status board wcs 9.8 which is above the listed

!

upper limit of 9.6.

The inspectors then reviewed the chemistry log

]

and found that feedwater system pH had been out of specification p

high for the previous 2 weeks.

ihe assistant shift supervisor was L

questioned about the high pH and had no explanations for it.

The Chemistry Superintendent stated that the feedwater system pH upper limit was eliminated about 6 months ago since there were no

-

circulating water-to-condensate leaks in the condenser.

The upper

limit was originally imposed to maximize the removal rate of sodium from the feedwater system should there be a conderser tube leak.

The increase in pH resulted from several factors including: a greater i

production rate of ammonium due to the chemical breakdown of hydrazine, a smaller ammonium removal rate due to lower feed flow rates through the condensate polishers, and a greater ammonium solubility due to lower condensate temperature from the colder weather.

On December 29, f. i 1989, the inspectors noted that the feedwater system pH upper limit on the control room status board had been climinated. The inspectors reviewed tne licensee procedures governing chemistry specifications

,

and confirmed that the pH limits on feedwater system chemistry were changed in late July 1989.

b.

Off-shift Inspection of the Control Room The inspectors performed routine inspections of the control room during off-shif t and weekend periods; these included inspections between the hours of 10:00 p.m. and 5:00 a.m.

The inspections were conducted to assess overall crew performance and, specifically,

_

control room operator attentiveness during night shif ts.

=

AttacN

-"P-

-

S/ G g

=

=

'

-

- _. _ _ _ _.

.

-

m

.

.

...

.

-

.

.

'

The inspectors determined that.both licensed and non-licensed.

.

operators were alert and attentive to their duties, and that j

,

!-

administrative controls for the conduct of operation were being adhered to.

d l

c.

ESF System Walkdown The operability of selected engineered safety features was confirmed

by the inspectors during walkdowns of the accessible portiont of several systems.

The following items were included:. verification that procedures match the plant drawings, that equipment, t

instrumentation,. valve and electricals breaker line-up status -is.in i-l agreement with procedure checklists, and verification that locks, L

tags, jumpers, etc.,.are reoperly attached and identifiable. - The l

following systems were walked down during this inspection' period:

i

't l

Control Room' Emergency Ventilation System

'

,

'

Direct Current Electrical Distribution System

High Pressure Injection System

Hydrogen Dilution System l

Safety Features Actuation System-

s

!

'

"

Service Water System.

!

Component Cooling Water System

Emergency Diesel Generators d.

Plant Material Conditions / Housekeeping

'

The inspectors-performed routine plant tours to assess' material conditions within the plant, ongoing' quality' activities and=

'

plant-wide housekeeping.

'

Plant deficiencies were appropriately tagged for deficiency.

correction.

No violations or deviations were identified.

'

6.

RadiologicalControls(717071

..

The licensee's radiological controls and practices were' routinely. observed:

by the inspectors during plant tours and during the inspection of' selected i

work activities.

The inspection included direct observations of health'

physics (HP) activities relating to radiological surveys and monitoring, maintenance of radiological control signs and barriers, contamination, and radioactive waste controls. The inspection also included a' routine review of the licensee's radiological and water chemistry control records

and reports.

Attachment ContNne

.

J SAFCCUAC S M % I M Upen Ec;r" '. TO

,

Page h M M M

,

.-

.

-

-

,

'

..

.

'

,

.

HP controls and practices were generally satisfactory. Housekeeping in

-

the radiological controlled areas was generally satisfactory. Knowledge and training of personnel were generally satisfactory.

No violat: ens or deviations were identified.

7.

Maintenance / Surveillance (37701. 61700, 61726. 62703. 73753. 92701. 93702)

Selected portions of plant surveillance, test and maintenance activities on systems and components important to safety were observed or reviewed to ascertain that the activities were performed in accordance with approved procedures, regulatory guides, industry codes and standards, and the Technical Specifications. The following items were considered during these inspections:

limiting conditions for operation were tut while components or systems were removed from service; approvals were obtained prior to initiating work; activities were accomplished ut ng approved i

procedures and were inspected as applicable; functional testing or calibration was performed prior to returning the components or systems to service; parts and materials used were properly certified; and appropriate fire prevention, radiological, and housekeeping conditions were maintained, a.

Maintenance The reviewed maintenance activities included:

Repair of SFAS Channel'3 Emergency Diesel Generator Sequencer

Installation of Fire Damper Access Panels in the Control Room Emergency Ventilation System (CREVS). The inspector identified potential weaknesses in control of penetrations to the CREVS boundary. These weaknesses were discussed with the licensee and the licensee agreed to review methods to eliminate the weaknesses.

• Modification of fire protection sprinkler system in Component Cooling Water (CCW) Pump Room

Inst;11ation of thermal shielding to electrical components in CCW Pump Ricm

Relocation of the shift supervisors office

Fire damper replacement.

Fire Damper FD 1155 was being installed in an outside air supply duct for Low Voltage Switchgear Room 429 from outside the Auxiliary Building.

Therefore, th6 tornado missile barrier for the duct opening was removed while the work was in progress. The inspectors reviewed the Safety Evaluation (SE-0249) in the Maintenance Work Order (MWO) package at the job site.

SE-0249 stated that the missila barrier could be removed for 12 days without affecting the operability of the safety-related equipment in Room 429 because the probability of a tornado generated missile Attrchmmt C+~

gi:

' T'D1

'

--

..

U3

.

+

pq e

-

-

'

~

__

._

_.

_ _ _ _ _

-. _.

-

_.

,

,. *

j

'

.

.

.

entering the room through the unprotected opening during that time was much smaller than the overall core melt probability.

l The workers at the job site were familiar with the contents of i

SE-0249. The sign off sheet for procedure MP 1407.00, " Missile

Barriers, at the job site indicated that the missile barrier

'

had been removed on November 27, 1989. On November 30, 1989,

!

the inscectors found that the shift supervisor was not aware

!

,

that the missile barrier had been removed or that a safety i

!

evaluation required that it be replaced within 12 dayss The

[

inspectors and the shift supervisor then reviewed the copy of

the MWO (2-86-0206-15) that was in the shift supervisors file.

!

There was no record in that copy of the MWO to indicate when the missile barrier was removed or that the missile barrier had j

to be replaced within 12 days..The inspectors discussed this

weakness with licensee management personnel. The licensee

'

stated that in the future missile barriers that are removed l

,

will be listed in the inoperable equipment log in the shift j

supervisors' office.

j

.

Removal of fire door for repair. On December 9, 1989, the-inspectors observed that Fire Door 311 in the Auxiliary Building i

had been removed. The inspectors verified that an appropriate

fire watch was in place.

The shift supervisor had authorized r

removal of the door on November 21, 1989. The licensee keeps

!

an interoffice memo in the shift supervisor's office that lists

<

the doors in the plant and identifies the functions of each-

'

door.

Upon reviewing the memo, the inspectors noted that

}

Door 311 m listed as having a flooding mitigation function

.

as well n.. fire protection function. The shift supervisor

was unable to provide the inspectors with any information

concerning the flooding mitigation function of Door 311. The

,

inspectors could not find any description of the door.'s flooding mitigation function in the Updated Safety Analysis Report.

Following shif t change, the shif t manager and oncoming shift

!

,

supervisor were also unable to explain the flood mitigation

'

function of Door 311. The inspector reviewed the control room copy of the Maintenance Work Order (MWO) controlling the work

on Door 311.

The MWO did not have any information about the

'

l flooding mitigation function of Door 311 and did not describe any measures to compensate for the absence of its flooding mitigation function. Based on his knowledge of the equipment in the rooms on both sides of Door 311 and the lack of any

,

detailed information on any related postulated flooding hazard, I

the shift supervisor decided to wait until Monday to contact

'

operations management for further guidance.

Later, representatives of the licensee's engineering department

-

and Independent Safety Engineering Group met with the

inspectors to explain the function of Door 311.

Door 311 is not a water tight door, but it does mitigate flooding for

.

two postulated high energy line breaks (HELB),

For one HELB it

.

limits the extent of steam flooding (the filling of a space with

steam) and for another it limits the extent of water flooding.

If the postulated HELB's were to occur, Door 311 wedd reduce ug.T CW--

>

$I 2

-

,

UP;;'. C ^

%..

r

...

,

f

.

. _ - -,

.

_

...

.-.

.

.

r

-

_

• j,.

.

.

l.

the amount of steam or water entering a stairwell in the Auxiliary Building. With Door 311 removed, other doors in the stairwell would limit the amount of steam or water that would spread beyond the stairwell. Since the stairwell contains no safety-related equipment, the removal-of Door 311-had no safety significance.

The removal of Door 311 without first evaluating the safety significance is another example of a weakness in controlling activities related to doors.

This event is similar to violation 346/89022-04 for which the licensee has not completed its corrective action. The licensee's response to the violation is due January 12, 1990.

As of the end of the inspection period, the licensee had provided the shift supervisors with a new memo providing more detailed instructions for controlling maintenance activities on doors. This is an interim corrective action and the-licensee is developing a controlled document to control activities related to doors with multiple functions. The inspectors will review all corrective actions for control of doors when they review the corrective actions for violation 346/89022-04.

• Replacement of the fire protection sprinklers and sprinkler piping in Mechanical Penetration Rooms Number 2 and Number 4.

' Replacement of Service Water Valve SW 5068.

• Repair of Diesel Fire Protection Water Pump.

• Repair of Component Cooling Water (CCW) Pump Room Ventilation-System Outside Air Damper Actuator (HV5444C).

During this maintenance activity the ventilation system of which HV 5444C is a part was considered inoperable.

Therefore, one of the two redundant ventilation systems for the room was inoperable and a single failure of the operable ventilation system would result in the room being without ventilation.

There is no Technical Specification (TS) Action Statement for the CCW Pump Room Ventilation Systems.

Section 9.4.2.1.3.5 " Component Cooling Water Pump Rooms" of the Updated Safety Analysis Report states that the " room cannot be maintained indefinitely at or below 104 degrees Fahrenheit following a loss of both redundant trains of safety-related ventilation, regardless of outside air temperature." The licensee declared one CCW system inoperable

-

(the system with the pump nearest the inoperable outside air damper) and entered the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> TS Action Statement for an inoperable CCW loop only because the ventilation system was inoperable.

Systems directly supported by the affected CCW

loop were not declared inoperable by the licensee. This is an unresolved item (346/89026-07(DRP)) pending NRC review of the operability requirements for the systems directly supported by the aff.ected CCW loop.

-

,.. -

.

,

-

.

_ _ _ _. _ _ _, _ _ -.. _. -

...

.

.. -..

___

-

,.

'.

Preventive Maintenance Inspection of CCW/SW heat exchanger internals and removal of silt, b.

Surveillance The reviewed surveillances included:

Procedure No.

Activity

• DB-HI-03013 Channel Functional Test of RpS Channel 3 Reactor Trip Module Logic and Reactor Trip Breaker D

• DB-MI-03014 Channel Functional Test of RPS Channel 4 Reactor Trip Module Logic and Reactor Trip Breaker C

• DB-PF-03220 Imbalance, Tilt and Rod Index Calculations - Group 38 Alarms Inoperable

• DB-SP-03357 Reactor Coolant System Water Inventory Balance

• DB-MI-03212 Channel Functional Test of SFRCS Actuation Channel 2 Logic For Mode 1

• DB-SP-03030 Service Water Pump 3 Quarterly Test

• DB-MI-04537 String Check of 79A-ISR8410 Corridor 209 Radiation Monitor

• DB-PF-03811 Miscellaneous Valves Quarterly Test.

This test includes a closing stroke time test for DR 2012A, containment vessel normal sump drain containment isolation valve.

On November 22, 1989, the first four times the operators attempted to close this valve from the control room it did not close.

It was then cycled five more times and closed each time in about 10 seconds which is near to its normal closing time. The valve is inside containment.

Later it was cycled again and the operating current was measured at the valve motor operator breaker. The running current was about 10 percent higher than baseline running current. The licensee considered the valve operable, but is now stroking the valve every.

2 weeks. The stroke times have remained

'/t' r % :nt 0e + ! 3 S A prpi } A me i.

e....,

.

.

'

,

-

U.: F. w.:rc;cd

,

_

^

~

,

,

-

..

.

.

normal and the motor running current

.

has remained at about 10 percent above baseline. The licensee plans to e

continue stroking the valve every 2 weeks until the refueling outage starts (February 1,1990). The licensee will then inspect the valve and evaluate it again.

• DB-SP-03358

"RCS Flow Rate Test"

• ST 5099.01

Miscellaneous Instrument Shift Checks."

The inspectors noted that the operator performing this test was having difficulty reading the procedure.

See paragraph 13.b for further discussion of this issue.

No other violations or deviations were identified.

8.

Emergency Preparedness (71707)

An inspection of emergency preparedness activities was performed to assess the licensee's implementation.of the emergency plan and implementing procedures.

The inspection included monthly observation of emergency facilities and equipment, interviews with licensee staff, and a review of' selected emergency implementing procedures.

No violations or deviations were identified.

9.

Security (71707, 81700)

The licensee's security activities were observed by the inspectors during routine facility tours and during the inspectors' site arrivals and departures. Observations included the security personnel's performance sssociated with access control, security checks, and surveillance activities, and focused on the adequacy of security staffing, the security response (compensatory measures), and the security staff s attentiveness and thoroughness.

The security personnel were observed to be alert at their posts.

Appropriate compensatory measures were established in a timely manner.

Vehicles entering the protected area were thoroughly searched.

The inspectors have attended the licensee's escort training which was held to meet the requirements of 10 CFR 26.22.

The inspectors concluded that the training as given meets the intent of 10 CFR 26 but could be enhanced by adjusting areas of emphasis.

The inspectors met with the licensee and its contractor to discuss the inspectors' concerns. The licensee's contractor stated that he would re-evaluate the escort-training course.

Attechment C: Pins SAFEGUIE G 150 C A D

'

Upon Sepseu:n Thb

Paco is Cccentrened

'I

+,

,.,

.+u

.

&

\\

'

.

.

I

.

.

j

'

.

On November 15, 1989, the inspectors observed discrepancies with a vital

-

area door.

The inspectors informed the licensee of their concern which is considered to be a violation (346/89026-08(DRSS))~.

(The violation and details of the inspection are described in Attachments 1 and 2 to this report.)

No other violations or deviations were identified.

l 10.

-

Engineering and Technical Support (42700, 62703, 64704. 71707, 92701, 93702)

An inspection of engineering and technical support activities was performed to assess the adequacy of support functions associated with

operations, maintenance / modifications, surveillance and testing activities.

The inspection focused on routine engineering involvement in plant operations and response to plant problems.

The inspection included

direct observation of engineering support activities and discussions

'

with engineering, operations, and maintenance personnel.

,

a.

The licensee has a continuing problem with doors. Some doors

are repeatedly repaired for the same problem.

It appears that

';

insufficient attention is being paid to the application and usage uf doors.

The inspectors previously identified difficulty in closing pressure barrier doors which have flush crash bars

,

(Inspection Report 50-346/89011).

The inspectors identified

'

specific doors and the licensee took prompt corrective action.

!

However, on December 15, 1989, the inspectors identified another pressure barrier door (Door 494) with a flush crash bar which was difficult to close. The inspectors do not understand why after i

they identified the original problem the licensee did not attempt to identify similar doors and take corrective action.

<

The licensee also experiences a high incidence of door operating mechanism problems. The inspectors have discussed their concerns

regarding doors and the apparent remedial action with the licensee.

• These problems assoc.iated with doors will be an open item (346/89026-09(DRP)) pending adequate licensee corrective actions for identifying and resolving these concerns.

b.

The inspectors have reviewed the licensee's response to NUREG/CR-5078,

,

"A Reliability Program for Emergency. Diesel Generators at Nuclear Power Plants." The licensee agrees with the intent of NUREG/CR-5078 although full implementation is not considered practical due to.

engine configuration and cost effectiveness. The. licensee intends to make some enhancements, including formal. documentation of the

'

actions and responsibilities of the emergency diesel generator (EDG)

Systems Engineer, additional maintenance inspection requirements,

'

additional static and dynamic engine checks for trending purposes and installation of additional EDG instrumentation.

.

The inspectors have compared the licensee's present EDG surveillance

program as well as its static and dynamic checks with NUREG/CR-5078

!

guidelines.

The licensee's surveillance program is very similar to NUREG/CR-5078 although it does not perform an EDG turbocha.rger-AttcchiM W'.i ',.. -,s.

,

Sld 1G ' C ^

g-;

-

~O

,

n.., g y +.

k j

,

.

,,

..

,

.......

-

,.

i

,

.

.

surveillance due to lack of instrumentation.

The licensee plans to add pressure instrumentation to the turbocharger in the future to assist in trending EDG performance.

The frequency of EDG static checks is not consistent with NUREG/CR-bO78. The licensee performs most suggested checks less -

frequently than called for by the guidance although a few checks

~

are done more frequently than suggested.

Some checks, such as visual inspection of hangers'and supports and EDG structural checks,

'

are not performed and will either be added by the licensee or are under review for change.

The licensee's dynamic engine checks are similar to the NUREG guidelines. Some parameters are not measured due to lack of instrumentation. After considering the potential for added instrumentation to decrease EDG reliability, the licensee plans L

to add some instrumentation that it considers both practical and d

significantly useful.

The inspectors will continue their review of the licensee's EDG preventive maintenance practices and will continue monitoring the licensee's response to NUREG/CR-5078.

No violations or deviations were identified.

11. Safety Assessment / Quality Verification (30702, 30703, 40500, 92720. 93702)

.

An inspection of the licensee's quality programs was performed to assess the implementation and effectiveness of programs associated with management control, verification, and oversight activities.

The inspectors considered areas indicative of overall management involvement in quality matters, self-improvement programs, response to regulatory and industry initiatives, the frequency of management plant tours and control room observations, and management personnel's participation in technical and planning meetings.

The inspectors reviewed Potential Condition Adverse to Quality Reports (PCAQR), Station Review Board (SRB) and Company Nuclear Review Board-meeting minutes, event critiques, and related documents; focusing on the licensee's root cause determinations and corrective actions. The inspection also included a review of quality records and selected quality l

assurance audit and surveillance activities, During a tour of the auxiliary building in the last inspection a.

period the inspectors observed that lights and emergency lights in i

the main stairwell had been disconnected. The inspectors informed the shift supervisor of their observation and he had them reconnected.

On December 6, 1989, the inspectors observed in Mechanical Penetration Room No. 4 that the lights and emergency lights had been deenergized and temporary lighting had been installed. Modifications to the

. fire protection system were being performed in the room.

Several contract employees were working in the area. A significant personnel safety hazard existed in the event power was lost to the temporary lighting. The inspectors also noted that on one occasion some of the temporary lighting was out and the north end of the room was Attachment Contalm s/JEGUUCS IMD'

U?on Separation This page is Dce:ntr:lled

-

- -.

,.

i

'

,a

'

'

'

dark. The inspectors brought their concerns to operations management I

and the nuclear industrial safety supervisor.

The licensee took corrective action by installing temporary emergency lights and

!

restoring temporary lighting in the north end of the room.

I The inspectors are concerned about the apparent lack of industrial i

safety involvement either before the work was begun or during its implementation.

The inspectors will follow the licensee's i

corrective actiont,.

b.

The inspectors and the licensee both have identified problems i

with the legibility of procedures. On December 9, 1989, the shift supervisor issued PCAQR 89-0599 describing the illegibility of Procedure DB-0P-03011 " Radioactive Liquid Batch Release." The

-

inspectors observed that Procedures DB-0P-03012. " Radioactive

-

Gaseous Batch Release" and ST 5099.01, " Miscellaneous Instrument

Shift Checks," were also illegible..Only portions of the procedures were illegible.

.

!

The inspectors believed that procedures would be checked during

-

reproduction and illegible procedures would not.be issued.

The

~

,

problems were observed in changes and temporary approvals. The

inspectors are concerned that despite all of.the efforts made in

!

the procedures program in the past 16 months that products of such dubious quality would be issued, and even more important, the user

'

would accept a product of such poor quality.

,

The inspectors discussed their concerns with the licensee on December 22, 1989.

The licensee believes that making copies from

'

multigeneration copies is the cause of the poor quality.

The i

licensee stated it would initiate a program to improve quality

,

,

.

control during reproduction, and also take steps to improve the.

.

t quality of the documents from which copies are made. This is an

!

i l

openitem(346/89026-10(DRP)).

-

No violations or deviations were identified.

i 12.

Regional Request (92701)

Due to the potential for loss of required shutdown margin during

!

refueling described in NRC Information Notice (IN) 89-51 and NRC Bulletin 89-03, Region III management requested that'the inspectors

.

'

review the licensee's control of shutdown margin during refueling. The next refueling outage is scheduled to begin in February 1990.

The'

inspectors found that the licensee was changing some of its procedures

,

in response to the.IN and Bulletin, even though it does not normally use.

intermediate refueling configurations.

The analysis of refueling configuration, prepared by the fuel vendor, appeared adequate.

'

No violations or deviations were identified, p 4.,,,..e W w - -

,

{l5 L. N,'N b N.. r b

Q ::. c

~ '

' T'*'~

P. y ic WW.M

~t a

-

-

..

. - -

-

.--

-

.

.

.-.

__

_

... _

.

.

.*

%

.-

,

..

.

13. Open Items

i Open items are raatters which have been discussed with the licensee, which will be reviewed further by the inspectors, and which involve some action

_

on the part of NRC or licensee or both. An open item disclosed during the inspection is discussed in Paragraphs 10 and 11.

14. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations.

Unresolved items disclosed during the inspection are discussed in Paragraphs 4 and 5.

15. Violations for Which a " Notice of Violation" Will Not Be Issued The NRC uses the Notice of Violation (NOV) as a standard method for formalizing the existence of a violation of a legally binding requirement.

However, because the NRC wants to encourage and support licensee's

-

initiatives for self-identification and correction of problems, the NRC will not generally issue a NOV for a violation that meets the tests of 10 CFR 2, Appendix C, Section V.G.I.

These tests are:

(1) the violation was identified by the licensee; (2) the violation would be categorized as Severity Level IV or V: (3) the violation was reported to the NRC, if required; (4) the violation will be corrected, including measures to prevent recurrence, within a reasonable time period; and (5)'it was not

-

a violation that could reasonably be expected to have been prevented by the licensee's corrective action for a previous violation.

In addition,Section V.A. states that for isolated Severity Level V violations, an

-

NOV normally will not be issued regardless of who identifies the as violation provided the licensee has initiated appropriate corrective action befors' the report ends. Violations of a regulatory requirement identified during the inspection for which a NOV will not be issued are discussed in Paragraphs 4 and 7.

16. Exit Interview (30703)

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

throughout the inspectici period and at the conclusion of the inspection and sommarized 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.

-

Attachments:

1.

Notice of Violation 2.

Discussion of Vital Area Door Violation (UNCLASSIFIED )

_

..,, g 7" ^ N

-

a

.

.

,,,

. n e..,

.

1. 6s.

w.

,. -

,

-

_

......

..

.

.

.

.

.

.....

.

.... _,.

.

.,,,,.,,,,,,

.-