IR 05000346/1990001
| ML20058H646 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 11/09/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20058H645 | List: |
| References | |
| 50-346-90-01-01, 50-346-90-1-1, NUDOCS 9011210111 | |
| Download: ML20058H646 (12) | |
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U.S. NUCLEAR REGULATORY COMMISSION ,
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SYSTEMATIC' ASSESSMENT.OF LICENSEE-PERFORMANCE
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.nspection: Report No. 50-346/9000 l
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Enclosure 1 Davis-Besse Nuclear Power Plant Summary of Meeting with Toledo Edison Company on October 2,1990 The findings and conclusions of the SALP Board are documented in Report No. 50-346/90001 and were discussed with the licensee on October 2, 1990, at the Davis-Besse Aaministration Buildin While the meeting was primarily a discussion between the licensee and NRC, it was open to members of the public as observer The following licensee and NRC personnel were in attendance, as well as the noted observer '
Centerior Energy Corporation R.- J. Farling, President / COO M. R. Edelman, Executive Vice-President .
Power Generation Toledo Edison Company ,
D.-C. Shelton, Vice-President Nuclear G. A. Gibbs, Director, Quality Assurance
'S. C. Jain, Director, Engineering T. J. Meyers,. Director, Technical Services
'E. M, Salowitz, Director, Planning & Support R. W._Schrauder, Manager, Nuclear Licensing ,
J. M. Heffley, Maintenance Ma:iager Nuclear Regulatory Commiss;on C. J, Paperiello, Deputi Regional Administrator H. J. Miller, Director, Division of Reactor Safety
'J. N. Hannon, Directo, Project Directorate III-3, NRR I. N. Jackiw, Chief, Reactor Projects Section 3A P.:M. Byron, Senior Resident Inspector
~ A. H. Hsia, Project Manager, NRR
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R. K. Walton, Resident Inspector
'B- . Comments Received from Licensee-Toledo Edison Company response to the Davis-Besse Initial SALP 8 Report dated October 31, 1990, included several comments that have resulted in a minor revision to the Initial SALP Report. These changes are listed in Enclosure 2 and the revised pages are included as Enclosure ? w .
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p < 1 'the corrected pages includedLin: Enclosure ,
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- C, l Regional Administrator's Conclusions' Based on Consideration'of.Licens g .
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. I have- neluded thatLthe' overall. ratings in the affected areas have not
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REVISION SHEET PAGE LINE NOW READS SHOULD READ l
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12 15-19 ... additional dose " additional dose may resulted from.... have resulted when...
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piping and pumps." to begin the outage."
Basis: Further licensee evaluation has determined that the impact of not being able to use the cleanup system prior to the outage did not significantly ,
add to the station dose rate during the outag " Concerns were raised... "The licensee is valves of greatest safety developing a check significance." valve reliability maintenance... to fail and the safety significance of these valve Basis: Further review of the program by the NRC has determined that check valve safety significance is used in determining a prioritization scheme, t
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20 25 ... Verification Sectio "
... Verification The licensee's evaluation Section. A weakness !
of..." was noted concerning the previously mentioned hydrostatic testing issue. The licensee's I evaluation of..."
Basis: Sentence inaJvertently deleted from the initial repor .
24 25-26 "
...to be more introspective. "...to be more In other... was noted." introspective."
Basis: ~The statement was a subjective opinion of management changes and there are no specific examples to confirm its validit _
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i - radiation monitors, installation of a standup whole-body counter, initiation of advanced radworker training for plant nd semipermanent contract maintenance workers, improvements in boratory QA/QC (quality assurance / quality control), and i roved trending of water chemistry ' parameters. Also, the lic nsee has plans to expand the laboratory space to correct
- - - pres t crowded condition The li nsee's approach to the identification and correction of techn cal issues was generally good. Total station dose in 1989, non-outage year, was low at about 37 person-rem; however, i will be much higher in 1990 inasmuch as
- 475 person- m accumulated in the refueling outage, significantly
[ more than the original dose projections for the outage owing to
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greatly increa d inservice inspection (ISI) and emergent wor Also, some addi onal dose resulted from the loss of normal system cleanup c a- ity when the cleanup system letdown valve (MU-2B) failed to after the reactor tripped to begin the outage. This cause coolantpipingandp(@)herthnprojecteddoseratesfrom k Liquid and gaseous rad . -
e effluent releases were a small fraction of-Technical. Sp tions limits and the volume of t.olid radioactive waste w . Licensee performance in
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nonradiological confirmato surements was fair
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(21 agreements in 30 compar onp;thedisagreements,which
, were attributed to problems i pqegedures and instrument
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calibrations, were mainly reso Nd'during the period. No transportation incidents were i fie _
The implementation of an advanced logical training course with hands-on laboratory for mainte ance personnel has been an effective training tool. An increas in radiation work practice infractions noted previously has been g eted. Personnel
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contaminations were lo . Performance Rating $
The licensee's performance is rated Categor23.this $\
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are The licensee's performance was rated Categor r tn the previous assessment perio . Recommendations Non _
C. Maintenance / Surveillance Analysis Evaluation of this functional area was based on 10 routine inspections performed by the resident inspectors, 2 inspect ns performed by regional inspectors, and I special team inspect n performed by regional specialist !
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radiation monitors, installation of a standup whole-body counter; initiation of advanced radworker training for plant -
and semipernanent contract maintenance workers, improvements in laboratory QA/QC (quality assurance / quality control), and improved trending of water chemistry parameters. Also, the licensee has plans to expand the laboratory space to correct present crowded condition The licensee's approach to the identification and correction ;
of technical issues was generally good. Total station dose i in 1989, a ron-outage year, was low at about 37 person-rem; ~
however, it will be much higher in 1990 inasmuch as 475 person-rem accumulated in the refueling outage, significantly more than the original dose projections for,the outage owing to greatly increased inservice inspection (ISI) and !
-emergent work. Also, some additional dose may have resulted when the cleanup system letdown valve (MU-20) failed to open after the reactor tripped to begin the outag Liquid and gaseous radioactive effluent releases were a small fraction of Technical Specifications limits and the volume of
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i solid radioactive waste was low. Licensee performance-in nonradiological confirmatory measurements was fai ,
(21 agreements in 30 comparisons); the disagreements, which-were attributed to problems in procedures and instrument calibrations, were mainly resolved during the period. No ;
transportation incidents were identifie "
The implementation of an advanced radiological training course with hands-on laboratory for maintenance personnel has been an effective training too An increase in radiation work practice infractions noted previously has been corrected. Personnel contaminations were lo . performance Rating The licensee's performance is rated Category 2 in this are The' licen%9's performance was rated Category 2 in the previous assessment perio . Recommendations Non ! Maintenance / Surveillance Analysis Evaluation of'this functional area was based on 10 routine inspections performed by the resident inspectors, 2 inspections performed by regional inspectors, and 1 special team inspection a perfor.ned by regional specialist . . . . . . -
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s Management involvement in the maintenance program was effective is demonstrated'by only 8 of 3500 PM items not being complete e percentage of total maintenance hours spent on PM increased f m 41.9 to 51.8 percent. The number of deficient control room ins uments and annunciators decreas'ed over the assessment perio The 1 ensee continued to have an excellent surveillance program Surveillances are tracked by computer; early and late dat as well as scheduled dates are tracked. Management l attention s evident in this area as demonstrated by the fact I that only t o surveillances were missed. Neither missed surveillance as safety significan .
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The licensee c pleted a 5-month refueling o6tage during the i assessment perio . Major work accomplished was the 10 year !
ISI program; comp tion of the 10 CFR Part 50, Appendix R '
requirements; feed barrel bolts; high- @ssreinjection(HPI)nozzleandthermalleed enhanceml '
sleeve inspections; r r vessel inspection; steam generator eddy current inspectio - control room modification The licensee reprioritiz scheduled outage work as emergent work was~ introduced. Mana e involvement was evident in the work prioritization, r as no required work was deleted from *,he ~ outag '
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L The licensee's management of co tr tors was mixed. While in general, the licensee did an te job of managing n contractor activities, the liftin he core support i l
assembly, insufficient time for pr ge planning, and >
poor work staging or task planning r amples of less-than-adequate contractor managem An interfacing system loss-of-coolant a iderq (ISLOCA)
l inspection was performed-by the NRC. Con q isiwere raised regarding check valve corrective and preve ty maintenance.
E 'The' licensee is developing a check valve ma h ance program f which emphasizes valves judged uost likely t f $ . However, !
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the NRC inspection determined that the krogra s w esently :
constructed did not adequately consider the val W Bf greatest safety significance. The im;slementation of the A valve ;
maintenance program snoulci ce completed during th next !
-assessment period.
L The ISI program was adequately planned, has appropria L p'riorities, and has adequate procedures. Records were complete, well maintained, and accessible. As a result f the implementation problems encountered in the use of acousti 1 q
, emission monitoring, the ' licensee is accelerating the '
I implementation of the next 10 year ISI program.
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F Management involvement in the maintenance program was effective as demonstrated by only 8 of 3500 PM items not being complete ,
The percentage of total maintenance hours spent on PM increased
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from 41.9 to 51.8. percent. The number of deficient control room ..
instruments and annunciators decreased over the assessment perio I The licensee continued to have an excellent surveillance program. Surveillances are tracked by computer; early and late dates as well as scheduled dates are tracked. Management attention is evident in this area as demonstrated by the fact that only two surveillances were missed. Neither missed surveillance was safety significan The licensee completed a 5-month refueling outage during the ;
assessment period. Major work accomplished was the 10-year ISI program; completion of the 10 CFR Part 50, Appendix R-requirements; feed and bleed enhancements;' replacement of core ;
barrel bolts; high pressure injection (HPI) nozzle and thermal -
sleeve inspections; reactor vessel inspection; steam generator eddy current inspection; and control room modification The licensee reprioritized scheduled outage work as emergent I work was introduced. Management, involvement was evident
.in the work prioritization process as' no required work was deleted from the outag <
The licensee's management of contractors was mixed. While in general, the licensee did an adequate job of managing contractor activities, the lifting of the core support assembly, insufficient time for pre-outage planning, and poor work. staging or task planning were examples of less-than-adequate contractor managemen An interfacing system loss-of-coolant accident (ISLOCA) !
inspection was performed by the NRC. The licensee is developing a check valve reliability maintenance program which emphasizes valves judged most' likely to fail' and the safety significance of these valves, The implementation of the check valve-maintenance program should be completed during the next assessment perio The ISI program was adequately planned,'has appropriate ,
o priorities, and has adequate procedures. Records were
. complete, well maintained, and accessible. As a result of the-implementation problems encountered'in the use of acoustical emission monitoring, the licensee is accelerating the implementation of the next 10 year ISI progra g 14
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< The number of errors 1ted in engineering evaluations raised a oncern regarding checking or verification of design activitie 'though the individual errors did not by themselves cause s' nificant concerns, collectively they indicate insufficient att ntion to detail. However, in one area technical reviews of the ntractors' procedures that implemented the NRC-approved
alter tive to the American Society of Mechanical Engineers Boiler ndPressureVesselCode(ASMECode),SectionXI bydrost ic pressure testing of plant systems were inadequate, j
The licens 's approach to the identification and resolution of l technical i ues was adequate. Most of the design calculations !
reviewed ind ated that personnel had a clear understanding of j the issues in Ived and exhibited conservatism. For the most J
, part, the techn cal approaches used were appropriate and )
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10 CFR 50.59 rey ews were well documented and sound. The analysis submitte for licensing actions, such as for fuel Cycle I 7 operation, the s port of TMI action items, and for increasing the response time f reactor protection system "high flux / number of react giant pumps" trip circuit, showed a clear understanding o "re' technical issues. The final resolution of the post-technicallysound;howev(T4afe-shutdowncapabilityissueswas
, initial engineering approaches were ;
not well thought out requ ,ing reinspection by the Appendix R team and resubmittal of fi ection documentation as noted -
in the Safety Assessment /Qu erification Section. The licensee's evaluation of the cal merits of the testing, as implemented, were not satisfac r. Performance Engineering's
. involvement in the contractor's ities was weak in that the technical adequacy of the testin wef inadequately addresse Staffing and exp:.rience-levels wer.& ggad. Generally, the licensee staff's submittals to the monstrated good understanding of technical issues, ex 1 ing thoughtful and innovative solutions. Training an lification effectiveness was also goo ,
.- Performance Rating
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.The licensee's performance is rated Category this are The licensee'.s performance was rated Category 1 the previous assessment perio .. Recommendation,s A
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' Safety Assessment / Quality Verification Analysis Evaluation of this functional area was based on the result of l- 10 routine inspections performed by the resident inspectors
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g The number of errors cited in engineering evaluations raised a concern regarding checking or verification of design activitie .Although the individual errors did not by themselves cause significant concerns, collectively they indicate insufficient attentio detail. However, in one area technical reviews of the contractors' procedures that implemented the NRC-approved alternative to the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI hydrostatic pressure testing of plant systems were inadequat The licensee's approach to the identification and resolution of technical issues was adequate. Most of the design calculations reviewed indicated that personnel had a clear understanding of the issues involved and exhibited conservatism. For the most part, the' technical approaches used were appropriate and 10 CFR 50.59 reviews were well documented and soun The analysis cubmitted for licensing actions, such as for fuel Cycle 7 operation, the support of TMI action items, and for increasing the response time for the reactor protectior, system "high flux / number of reactor coolant pumps" trip circuit, showed a !
clear understanding of the technical issues. The final resolution of the post-fire safe-shutdown capability issues was technically '
scund; however, initial engineering approaches'were not well thought out requiring reinspection by the Appendix R team and resubmittal of fire protection documentation as noted in the Safety Assessment / Quality Verification Section. A weakness was noted concerning the previously mentioned hydrostatic' testing issue. The licensee's evaluation of the technical merits of the testing, as implemented, were not satisfactory. Performance l Engineering's involvement in the contractor's activities was weak in that the technical' adequacy of the testing was l inadequately addresse ,}
Staffing and experience levels were good. Generally, the licensee staff's submittals to the NRC demonstrated good understanding of technical issues, exhibiting thoughtful j i. '
and innovative solutions. Training and qualificatio effectiveness was also goo {
2, Performance Rating l The licensee's performance-is rated Category 2 in this are The licensee's performance was rated Category 2 'in the ';
previous assessment perio j Recommendations j Non {
l Safety Assessment / Quality Verification i Analysis Evaluation of this functional area was based on the results of 10 routine inspections performed by the resident inspectors,
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" operations and fire protection procedures, onshift overview overage during restart, and expanded overview in the area of re protectio The cope and quality of the audits'and surveillances were gene tity good and, for the most part, adequate to assess l techn' al performance, compliance with NRC requirements, and f trainin and qualification Licensee responses to the QA findings ere thorough, timely, and technically sound. The '
auditors volved were qualified to perform the audits and .
surveillan As a result o the cha aes made in the QA organization, audits !
are more perfo ance and less programmatic based, audit findings and assessments re more clearly communicated, and responsibilities are better delin The surveillance program is more aggressive and surveillances rformed more frequently which results in better real. time in r tio The QA organization is more l responsive and produ -. than in previous assessment period l QA commenications witi the NRC resident staff continues to be I
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open and forthrigh During the assessment'per h ere were numerous management "
i changes such as the Engine dandQAdirectors,theOperations, Maintenance, System Enginee n p and ISEG managers, and the
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Operations, Mechanical Maint a p and I&C superintendents. As
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a result of some of the change ,panagement appears to function (
more as a team and to be more i t ective. In other cases, 4 some loss of continuity in direc i as note '
Management demonstrated increased fety awareness as shown by its actions at the end of the assess @ period when, after a series of events, the restart effort topped and the plant was cooled dow Previous events were ssed and discussed with the operations staff, and operator TEN retrained on startup ,
procedures. Additionally, an outside un SN peer review group ;
L with representatives from three other util('t gi was brought in- i to review the-events before plant restart c ntinued. The licensee action to stop work and initiate an independent review of control of plant operations is viewed very ositively by the i NR I performance Rating l The licensee's performance is rated Category 2 in t s are The licensee's-performance was rated Category 2 in t previous .
assessment perio [ Recommendations None, i
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I operations and fire protection procedures, onshift overview coverage during restart, and expanded overview in the area of fire protectio i The scope and quality of the audits and surveillances were generally good and, for the most part, adequate to assess technical performance, compliance with NRC requirements, and training and qualification Licensee responses to the QA findings were thorough, timely, and technically sound. The auditors involved were qualified to perform the audits and surveillance .
As a result of-the changes made in the QA organization, audits
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are more performance and less programmatic based, audit findings and assessments are more clearly communicated, and responsibilities ;
are better delineated. The surveillance program is more aggressive and surveillances are performed more frequently which results in better real time information. -The QA organization is more responsive and productive than in previous assessment period QA communications with the NRC resident staff continues to be open and forthrigh During the assessment period there were numerous management changes such as the Engineering. and QA directors, the Operations,
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Maintenance, System Engineering, and ISEG managers, and the Operations, Mechanical Maintenance and.1&C. superintendents. As a. result of some of the changes, management appears to-function more as a team and to be more introspectiv .
Management demonstrated increased safety awareness as shown by its actions at'the end of the assessment period when, after a
' series of events, the restart effort was stopped and the plant was cooled down. ' Previous events were assessed and discussed with the operations staff, and operators were retrained on startup:
procedures. : Additionally, an outside' unbiased peer review group-with representatives from three other utilities was brought in to review the events before plant restart continued. The (
licensee action to stop work and initiate an independent review of control of plant operations is viewed very positively by the NR , performance Ratin '
The licensee's performance is rated Category 2 in this are The licensee's performance was rated Category 2 in the' previous assessment perio . Recommendations Non '
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.ytepresman mehy co n sges toisdo. 0H 4M624001 -
(419)2 4 2300 Docket Number 50-346 L1eens Number NPF-3 ,
. Serial Number 1-936' .
l p October 31, 1990
, United States Nuclear Regulatory Commission l~ Document Control Desk .,
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l Vashington, D. '
Subject: Response to initial NRC Systematic Aa.sessment of License Performance (SALP) B Board Report '
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l Gentlemani
~ Toledo Edison Company (TE) has reviewed the initial SALP 8 Board Report I (Inspection' Report No. 50-346/90001) for the Davis-Besse Nuclear Pover Station, covering the-period March 1, 1989 through June 30, 199 The SALP transmittal letter (Log Number 1-236'0), dated September 20, 1990, u-stated that.TE may provide written comments to the NRC within 30 days af ter
%he October 2,.1990, SALP 8 meetin < Attached are TE's comments concerning the SALP 8 report.These comments
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11nclude corrections to' apparent errors of fact contained in the repor i If you have 'any questions regarding this matter, please contact Mr. R. V.
i Schrauder,' Manager - Nuclear Licensing, at (419) 249-236 [;
_Very truly yours,
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ri cet . H. Byron, DB-1 NRC Senior Resident Inspector A. B. Davis, Regional Administrator, NRC Region III A. H. Hsia, NRC/NRR Davis-Besse Backup Project Manager j r
M.-'D. -Lynch, DB-1 NRC Senior Project Manager C. 'J. Paperiello, NRC Region III Deputy Administrator Utility. Radiologic 61 Safety Board '
h\ \ V )k operenne companies:
C:eveland(*tnc!!!umanctino ,
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Docket Hunber 50-346
.Licensa Nu2bar NPF-3 '
Serial Nu ber 1-936
. Attachment 1-Page 1 RESPONSE TO SALP 8 REPORT
& High Dose Rates Due to MU2B Pailure on Page 12, in the Radiological Controls Analysis (paragraph 6), the SALP report states that higher than projected total station dose was experienced during the sixth refueling outage due to increased inservice inspection (ISI) vork, emergent vork, and failure of letdown isolation valve MU25. During a September 21, 1990 conference call to Region III staff Toledo Edison explained that the failure of MU2B vas not the cause of highar Reactor Coolant System (RCS) pump and piping dose rates :
following the January 26. 1990 trip. The chemistry data and radiation survey data collected following tha trip indicated that no significant increased dose rates vare seen on the RCS piping and pump surfaces. In addition, the erw burst which occurred following the trip was lover than experienced during previous shutdowns. Therefore, because only minor plating out of radioactive cobalts occurred in the RCS, high dose
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rates were not observe The reference to MU2B should be removed from the final SALP 8 repor .
, Check Valve Maintenance Program 4
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On Page 14, in the maintenance / Surveillance Analysis (paragraph 11), the SALP report states: " Concerns vere raised regarding check valve l corrective and preventive maintenance. The licensee is developing a check valve maintenance program which emphasises valves judged most likely to fail. However, the NRC inspection determined that the maintenance program as presently constructed did not adequately consider the valves of greatest safety significance."
During the March 28, 1990 ISLOCA meeting with the NRC, Toledo Edison responded to those specific findings and open items discussed in the
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ISLOCA inspection report (IR 89-201). Following the meeting, Toledo i
Edison submitted a response (Serial 1793, dated April 27, 1990) stating that the Check Valve Reliability Program at' Davis-lesse was initiated in 1986. This was approximately the same time that INPO vas preparing 50ER 86-03 on check valve performance. The program initially consisted of a review of approximately 200 check valves in 15 of 34 systems containing valves from the. System Reviev and Test Progra Elements of the program include testing, inspection, and design review. Toledo Edison's goal is to have a comprehensive prioritised check valve Preventive / Predictive Maintenance Program with a basis similar to that developed for motor operated valves (MOVs) and air operated valves (A0Vs) at Davis-Bess In addition, Toledo Edison has assumed a very aggressive and proactive role in various industry activities relating to check valves. Toledo Edison's "0 heck Valve Reliability Program" does establish a prioritization scheme based on the valve's safety function as well as its service conditions. This program was provided to the NRC staff during the ISLOCA inspection. Furthermore, the check valve
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Serial Number 1-936 Attachment 1 Page 2 prioritisation issue was not raised by the NRC during the March 28, 1990 meeting vith the NRC staff concerning Toledo Edison's check valve program. Toledo Edison vae unavars thet the NRC staff had takan exception to the prioritization of check valves at Davis-Besse until the initial SALP 8 report was fasued. Therefore, the final SALP report should be revised to retlect these comment Management Changes On Page 24, in the Safety Assessment / Quality Verification Analysis (paragraph 15), the SALP report states that numerous management changes during the assessment period resulted in some loss of continuity in direction. Toledo Edison is aware of no area where a loss of continuity occurred as a result of management change. Accordingly, the statement should be deleted.
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