IR 05000346/1990015

Insp Rept 50-346/90-15 on 900701-0813.Violations Noted But Not Cited.Major Areas Inspected:Licensee Actions on Previous Insp Findings,Lers,Plant Operations,Radiological Controls, Maint/Surveillance,Emergency Preparedness & Security

ML20059G148
Person / Time
Site:	Davis Besse
Issue date:	09/04/1990
From:	Jackiw I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20059G146	List: IR 05000346/1990015 ML20059G143
References
50-346-90-15, NUDOCS 9009120161
Download: ML20059G148 (12)

Text

a

-

.

,

'

.

i

.

.

,

.-

%

.

'V

.

t

'

Ui S. NUCLEAR REGULATORY COMMISSION

'

'

,

REGION III

-

--

L Report No. 50-346/90015(DRP).

'

>

L Docket No. 50-346

. Operating License No. NPF-3 Licensee:'7 Toledo Edison Company Edison Pis:a 300 Madison Avenue Toledo, OH. 43652

'

Facility Name:. Davis-Besse 1

"

Inspection At: Oak Harbor, OH

' Inspection Conducted: ' July 1 to August 13, 1990 Inspectors:

P. M. Byron D. C. Kosloff

,

R. K. Walton l

M. D. Lynch

]-

f0 Approved By:

ac i,

ief

.

,

.

actor Pr jocts Section 3A Date

.

l

Inspection Summary-

!

Inspection on July 1 through August 13, 1990 (Report No.-50-346/90015(DRP))

Areas Inspected:

.A routine safety inspection by: resident inspectors of-licensee. actions on previous inspection findings, licensee 4 event reports, plant operations, radiological controls, maintenance / surveillance,-emergency

,

'

preparedness, security, engineering and' technical support, and-safety assessment / quality verification was performed.

.

Results: Licensee personnel allowed two events;toloccur during the inspection

,

period (Paragraphs 4 and 7). These events.were due to personnel error in

'

<

plant operations and maintenance. Operations personnel actuated a Safety--

"

Features. Actuation System (SFAS) component'during testing.and' maintenance

personnel disconnected an incorrect SFAS radiation detector'. A non-cited violation in the area of. fire protection was discovered by:the licensee (Paragraph 10). An unresolved item'regarding interpretation of operability requirements-is described in Paragraph 7.

9009120161 900904 PDR ADOCK 05000346 -,

G PNV tj

..

.

~ _

..

-

-

E

'

u.

,

9-y:

.

.

.

t

>

,

..

....

,

,

u

l t

' DET AILS.

>

,

l c-1.

Persons Contacted

!

->

a.

To.ledo Edison Company -

t

'

g ~

D. Shelton,iVic6 President, Nuclear L*J. Moyers, Manage'r, Quality Verification

• L.. Storz, Plant Manager 1.

• M. Hefiley, Maintenance Manager

.

-R. Brandt, Manager,: Plant Operations (Acting)'

M. Bezilla, Superintendent - Operations

• E. Salowitz, Director - Planning;and Support

• SEJain, Director - DB Engineering

~

.

'

L D. Timms,; Systems Engineering ~ Manager l

,

,

E. Caba Performance. Engineering Manager 1-

' V. Watson, Design. Engineering Manager

-.G.: Grime, Industrial Security Director'

t

• J. Polyak, Radiological Control Manager

. R. Coad,.-General Supervisor Radiological 7 upport S

R. Schrauder, Nuclear Licensing Manager

.

• G. Honma, Compliance Supervisor

• R. Gaston, Licensing' Technologist'-

• J. Dillich, Superintendent - Shift Operations

• T. O'Dou, Radiological Assessor

'

• N. Peterson, Licensing y

• G. McIntyre, Systems Engineering Supervisor

• H. Stevens, Independent Safety Engineering Supervisor

'

• L. Young, Systems Engineering --Fire Protection

,

b.

USNRC

_

l

'

• P. Byron, Senior Resident Inspector D. Kosloff, Resident Inspector

• R. Walton, Resident Inspector.

M. Lynch, Licensing Project, Manager

• Denotes those personnel attending the August 13, 1990 exit meeting.

2.

Licensee Action on Previous Inspection Findings :(92701)

'

TMI Action Items (TI 2515/065, 92701)-

(0 pen) II.E.4.1.3.

Install Dedicated Hydrogen _ Penetrations. The inspectors reviewed training agenda and attendance sheets, control drawings and

.

operating procedures to' ensure that operations personnel are krowledgeable of the containment hydrogen removal systems.

NRR accepted the design of

"

the Dedicated Hydrogen Control Penetrations as documented in a letter

'

dated October 23, 1981.

However, on August 3, 1990, the~ licensee documented that suction piping condensation could prevent the recombiner from

!

!

functioning.

At the end of the inspection period, the licensee was still-evaluating this concern.

This item will remain.open:until the effects of suction piping condensation are fully evaluated.

,

'

. *

+

..

.

.-

< a

[

'.. ~,

~I,

~

4.

3

.'y

.; -

'

,p

,

+

o-

<

.

i

-

l-i

'

,

,

3.

.LicenseeEventReportsFollowup(9270b)

m

-

.

,,

.

.

'

,

,

Through direct observation, discussionsLwith111.censee personnel, and>

!

-

greview of. records, the following licensee; event reports-(LERs) were-reviewed to determine that reportability requirements were fulfilled,

-that:immediate corrective actions,to prevent recurrence was1

,

L'

'acenmplished in accordance with Technical Speci'ications (TS).

(Closed) LER 90-012: Minimum Units Operable Not Met ~Due to

...

Nonconservathe. Trip Setpoint. This LER reported:an event involvingi-.

,

Safety Features Actuation System radiation monitors which is discussed;

'iniParagraph 10. This LER is closed.L

'

'

?

,

,

4.

Plant Operations (71707, 71710, 93702, 92702, 40500)

'

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.1 The inspections focused!on'the implementation-:

.,

and~overall' effectiveness of the: licensee's control of operating a

'

activities, and on the-performance of' licensed and non-licensed:

,

operators and shift managers.

The inspections included direct -

observation of activities,.. tours of the facility,1 interviews and

discussions with licensee personnel, independent verification of'

safety system status and limiting conditions"of operation (LCO),t t

and reviews of facility procedures, records,.and reports. The q

following' items were considered during'these inspections:

(

Adequacy of plant staffing and supervision.

Control room professionalism, including procedu're adherence, operator attentiveness, and response to alarms, events, and:

l off-normal conditions.

j i

Operability of selected safety-related systems,-including

'

attendant alarms, instrumentation, and controls.

'

L Maintenance of quality records and reports.

'

&

The inspectors observed that control: room shift supervisors,D

shift managers, and operators:were attentive to plant conditions,

performed frequent panel walk-downs and wcre. responsive to

'

off-normal alarms and' conditions.

!

<

On July 2, 1990, with the reactor critical low in the power range, L

a preexisting half-trip in Safety Features Actuation. System (SFAS)

.

!

channel-3 was discovered during performance of SFAS testing in

'

channel 1.

SFAS channel 3 had a failed relayLfor actuation of

,

makeup system valve MV 590.. The SFAS is designed 'so that.a failed l

l~

relay will provide a half-trip signal for the affected component..

-

Testing SFAS channel 1 inserted another half. trip signal for l

MU 59D and the valve closed as required by the system design.

,

,

.

a

'

g, y

'

{"

'

.

,

,

,

,

,.s

&

x

-..

7 '.

2,,'

r

.'

'

q

,

<

<,

i

'l

,/

r

.

.

This valve isolated the piping that was providing ' seal injection; (

- water forl reactor coolant pump:(RCP) 1-2.; Within 4 ' minutes of losing,'

.

J'

seal. injection; flow, the operators stopped 61.he RCP Lin accordance with:

plant procedures. Without the heat input provided by RCP_1-2 to thet

'

>.

< reactor coolant; system, primary temperatures slowly decreased.'. Withi i

the minimum temperature for criticality approaching,- the operators.*

restarted the RCP after reestabFishing sealcinjection; flow.1 Prior ~to-

'

'

,

Lthe start of testing,L the ' procedure requires the = operators to -obse rye

,71

the SFAS: channel 3 data-lights and determine that each component to be; A

'

Jtested is notliniathalf-trip)ed state. 0perators performing the test q;

were not abfe to determine t1at ashalf-tripped? state existed for

• Li

'

MU 59D bycobservinglthe SFAS status lights.. Improper interpretation i

'of the SFAS. data; lights: is a recurring.probrem.11The; licensee plans-t to modify the SFAS duringlthe next refuelingroutage to eliminate thist

_ problem.; 'In an; earlier' telephone; call with NRRC the inspectors-had

'

learned that singlefcomponent actuations such asithis are not reportable to;the NRC as~ Engineered Safety Features actuations. The inspectors

' reviewed data for this event and determined thatJabout: 7 PCM of

'

,

reactivity.was added when the-1-2 RCP was restarted.,This matter is

'still under review.

,;

,

,

,

- On July 28,.1990,l thel. censes temporarily reduce $ power to 90% as ta result of the loss of the ~No.:3 circulating water pump.

It was Edetermined that,the motor circuit breakeratripped due~to an electrical.

,

short.= Additional investigation' revealed that the' stator had-developed'

o a small-hole ~which resulted-in the:short ' circuit and'one of-the motor-

'

bearings was deformed.: The licensee is continuing'its root ~cause'

determination for.the motor failure. ?On occasion, the licensee has d

needed to reduce' power due'to decreasing. condenser vacuum. Motor l

replacement is planned >for September.-

' "

b.

Off-shift Inspection of Control Rooms The inspectors performed routine inspections of the_ control room during off-shift and. weekend perio_ds' these included inspections j

,

between the hours of 10:00 p.m. and<5:00ca.m. T.he inspections-

"I were conducted to assess overallEcrew' performance and,: specifically,

~

control room operator attentiveness during night; shifts.

The inspectors determined that-both licen~ sed andinon-licensed.

operators were alert and-attentive to -their duties,-and that the

.

j.

administrative controls relating to the conduct.of operation were -

being adhered to.'

'

t c.

ESF System Walk-down The operability of selected engineered safety features was

.

confirmed by the inspectors during walk-downs of the accessible

.

portions of several systems. The following' items were included:-

verification that procedures match the' plant drawings, that equipment; instrumentation, valve and electrical breaker 'line-up.

status is in agreement with procedure checklists, and verification -that locks,- tags, jumpers, etc., are' properly -

attached and identifiable. The following systems were walked

down during this inspection period:

.

e

, [,,,; &

}

x V

'

,

.

.

.

.

r

.

o,)

,x

. <

<

+

l

'

'

.>

,

,

'

Safety Featpres: Actuation :S'ystemi <

L

'

,

Steam and Feedwater Line Rupture Controls System t

'

,

• -

Emergency Diesel Generator System

,

DC Electric Distribution System'

• -

,

Service" Water System

,l

'

'

3.

l

>

,,

- d.

Plant Material 1 Conditions /Housekeepingi

I

'

The1 inspectors performed routine plant toursLto assess material

,

conditions withinithe plant, ongoing quality activities and-'

plant-wide. housekeeping.

Housekeeping;and material conditions:

were adequate'

~

Plant deficiencies were appropriately-taggedIfor deficiency '

correction.

No violations or deviations >were: identified.

5.

Restart Effort-(62703, 71707, 72700,192701)'

The inspectors provided-augmented. shift coverage and observed various'

-licensee organizations during plant startup.- Initial reactor?

criticality occurred at 10:01 am'on July 1,-.1990. :The generator was:

-

synchronized with the grid at 3:49 am on-July 5, 1990.' The1 inspectors witnessed operators take the plant off its steam generator lowslevel o

e limits. This transition from low power-operations to high powerL L

operations historically has been erratic. > Good communications.between operations and engineering personnel dur<ing:this evolution-and the use of the Data Acquisition and Analysis System (DAAS)? enabled the operators to make a smooth transition.

<

6.

Radiological Controls (71707, 84750)~

The licensee's radiological controls and_ practices were routinely

,

l; observed by the. inspectors during plant tours and 'during the ; inspection f

!

of selected work activities. The inspection included direct observations-

l'

of health physics (HP) activities; relating _to radiological surveys and; L,

monitoring, maintenance of radiological control signs and barriers, contamination, and radioactive wasteicontrols. The_ inspection also q

included a routine review of the licensee's radiological and. water-chemistry control records and reports; Health physics controls and practices were satisfactory. Knowledge and training of personnel were satisfactory.

,

i

.c

_ "

,

-

-

-

-

y,

.

,

L-O 9-

,

([L

[

~

'

+

,

.

,

l

'

The inspectors:have observed the installationof DAAS~into portions of-.

l

..

the' radiological = monitoring systema ThelDAASLcan collect'and store weeks-

<

'

worth of instrument data that can'be'used by either engineering or-

radiological' controls personnel for'trendingDand analysis.. The. licensee

has installed thisfsystem to provide for a morejaccurate radiologica_1,

'

.~ data retrieval system.. The system is still'in:a developmental; stage'.

y The licensee has plans to expand..the; system.-

l

.

,

The licensee has tabulatedLits1 final total. dose foritheLoutage to be'

l

.

474(person-rem. This was slightly above their modified goal of

.

.

1470 person-rem that:was established around mid-March, iThe< original l.

goal'was revised'due t0 the' actual exposure received.early i_n.the outagei

and radiological conditions not previously;known to exist.;: Valve'MU2B,.

+

failed closed when the pla'nt tripped on January 26,11990, which prevented

post-trip cle.an-uplof the reactor coolant system.; The. licensee attributes,

.

y

,

the higher dose rates inside containment:to'the lack of cleanup'.

'

. No; violations or deviations were identified.

-7.

M_aintenance/ Surveillance (61726, 62703; 92701, 93702)

'!

',

Selectedportionsofplantsurveillance,testandmaintenancetahtivities

,

,

..on systems!and. components important'to safety were observed or reviewed:

p 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 met-while components:or systems were removed from' service; approvals were obtained prior to initiating work;; activities were accomplished'using.

approved procedures and were inspected as applicable; functional testing-D or calibration wasc performed prior to returning the~-corrpunents -orc systems to service; parts and materials used were properly certified;'and appropriate fire prevention, radiological, and housekeeping conditions

.

were maintained.

'

a.

Maintenance

.n The reviewed maintenance activities included:-

'

Troubleshooting Control Rod Drive Group 6 normal power. supply-

.

,

Maintenance on Emergency Diesel Generator 1-l>

Replacement of a temperature control switch for the Component.

>

Cooling' Water-(CCW) room ventilation system. Equipment for both CCW systems are located in the same' room.' While this work was in progress one of the two CCW room,.100 percent capacity ventilation systems could not function automatically.

Therefore, the licensee declared the No. 1 CCW' system (the system nearest the inoperable ventilation equipment) inoperable and-complied with the applicable LCO. The operable ventilation

,

system had the capability to cool both CCW systems under all'

e design conditions, but a single failure of the operable l

?

6

i:

>

y

.

.

,

,

y (

'

.

e

>

,

'

ventilation?sy' stem would have left:both CCW systems without cooling.,:The licensee considered systems cooled'by the No. 1

.

CCW system operable.=cThe inspectors requested Region III

.

,

guidance:on the, operability of systems cooled by the No. T CCW-

n system in this and similar. cases.. The' operability of systems l

_

cooled by CCW when one CCW system is considered inoperable for a

ventilation system maintenance ~.is an-Unresolved Item

(346/9]15-01(DRP))'pending.' additional guidance-from Region III.

Reduction of.RPSulow pressure:and variable temperature / pressure.

l

• ~

trips

.

FlushingoftheTurbine-Plant; Cooling' Water' system-

'

'

b.

-Surveillance'

The reviewed Surveillance ectivitieslincluded

,p ST 5'030.01

. Incore Instrumentation Data Check

"DB-SP-03150 Auxiliary Feedwate'r Pump Monthly Jog-Test,

i DB-SC-03113

' SFAS Channel 4 Functional Test d

'

DB-PF-03230 RPS Daily Heat: Balance Check DB-SC-04187 Daily Checktof Rad'Honitoring System DB-ME-03003 Station Battery Charger Test.

-

Personnel performing maintenance or surveillances used correct procedures and proper work control. documents. Work authorization l

had been obtained for the jobs performed.- Prerequisites for

.

performing'the job, such as worker protection and tagging bad.

1 been performed. Surveillance continues to be an area where o'nly an occasional minor problem arises.

On July 12, 1990, with SFAS radiation detector 1 de-energized for o

trouble shooting, maintenance person.nel' mistakenly disconne_cted.'

',

SFAS radiation detector 3.. With two of four radiation detectors de-energized, an SFAS Level 1 actuation occurred. Maintenance personnel, realizing-their error, immediately reconnected the-detector. All SFAS equipment operated as expected during the actuation. Even.though the detector was located in a dark area, the electrical power cable was31abeled with a plastic identification tag. Due to the location of the tag on' the detector relative to the workers position, the tag was not visible. The root cause of this event was personnel error.. The individuals involved have'been counseled by plant management. Better labeling might have prevented this event and the inspectors will monitor the licensee's efforts in this area.

No violations or deviations were identified.

.7 i

,

e

-

_

.

n.

• ' '.l,.

,.

' _

'

'

W y

n;

.

,

,

,

.

.

,

i 1jr"

'

i 8.j ' Emergency Preparedness (71707, 82701)'

'

-

-

-

AnL nspection of emergency prep'arednessiactivities_was' performed to i

assess thetlicensee's implementation-of?the emergency.31an and

"

. implementing procedures.. The inspection included mont11y observation-

of emergency facilities and equipment', interviews with licensee staff, and a review ofs selected emergency implementing. procedures.

-

.

No violations or deviations were identifiedi

,

"

9.-

Security (71707, 81700)-

iTNe" licensee's:securityactivitieswereobserved'bytheLinspectors-Di during routine f acility tours and during the inspectors'1 site'arrivalss

".

'

,

.

and. departures. ' Observations ~ included.thejsecurity personnel's

,

,

performance associated with access" control,usecurity checks,yand.

surveillance activities, and focused on the adequacy of security

staffing, the security response-(compensatory measures),'and thel i-security staff's attentiveness'and thoroughness, a

Security personnel were observed to be alert at their posts.

l!

Appropriate _ compensatory. measures were established'in a timely manner.f

?

'

Vehicles entering the protected area were thoroughly searched.-.

-No violations or deviations were identified.

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

,

An inspection of engineering-and technical support activities was

.

.

performed to assess-the adequacy of support functions associated with

.

l operations, maintenance / modifications, surveillance and testing

activities. The inspection. focused on routine engineering involvement

.

in plant operations and response to plant problems.1 The inspection included direct' observation of engineering supportLactivitiestand s

discussions with engineering, opera $ ions, and maintenance personnel.

-

On July 13, 1990, the Safety Feat m Actuation-System'(SFAS)> channel 1-i radiation detector had been de-energized for maintenance. At,10:00 a.m.,

operators performing the first shift check of SFAS radiation detector alarm setpoints upon return-to-100% power discovered that the SFAS'

channel 3 radiation detector alarm setpoint wa6 greater than-2 times-L background.

Since the SFAS radiation-detector setpoints are required to

-

be set at less than twice background, the licensee declared that two of four SFAS radiation detectors were inoperable, and entered 13 LCO 3.0.3.

which requires that the plant be shutdown, cooled down and depressurized.

The licensee exited TS 3.0.3 at 10:54 am after resetting the setpoint and performing-a-functional test on the channel 3 SFAS radiation detector.-

,

[

All other~SFAS radiation-detector setpoints were. normal. The accuracy

.

.

'

of the indicator is 1.5% of instrument span. Any drift in the instrument i

string or misinterpretation by the operator could 'cause a channel to

.

become inoperable. The licensee plans to submit a change to the Technical.-

!

Specifications to raise the existing setpoint.

<

i

l

....

.

.

-

,

.

g

-

, - -

--

,

r

>

n

,u

.

[

.;

,.;

,

?

.

.

~

,

):{ j

'On July 20,11990, the licensee' determined that'a fire protection'

<

procedure-(DB-FP-03023): erroneously: implemented a Technicar i.

Specification (TS) surveillancefrequirement to allow for:one-sided-X inspection-of inaccessible firoibarriersU TS 4.7.10.a.: requires that a visual inspection of-exposed; surfaces'be-performed every 18 months.-

The licensee has "aetermined that: 99 barriers have 'had, inspections e

<

. performed.on one side only and-that:57 barriers have'not been

' inspected in.accordance with the:TS, including the inner annulus wall-which.has>never been inspected;.LThis'is,alviolation'of TS 4.7.10.ai

.(346/90015-0?(DRP)).. The licensee has;taken compensatory actions land-q

,

Ehas discussed this' event with the PRC. LThe licensee plans-to submit a-

.

!

~ interpretation'of'the TS. An 1.ER will be issued by the: licensee-at ac

/j letter to.the NRC providing a technical justification fortits later.. date. Since the: violation was: discovered by the: licensee,= and J

t

= has. little: safety significance, it meets the, criteria of 10. CFR 2, j

Appendix C. Section-V.G11, an NOV will not be issued and'no~ response; a

'(other, than the LER) is(required

This item.isiclosed.

'

j J

,

.

_

.. -

.

,

.

.,

System engineering andjdesign engineering continue -to provide' adequate

-

,

coverage and; response..

'

<

e

,

,

'

'

lNo cited ' violations or deviationsiwere identified.'

i 11. Safety Assessment /0uality' Verification'-(92701', 30703,'92700,'90712)-

,

,

An inspection of the licensee's quality progrrmslwas' performed to a

assess the' implementation and; effectiveness cf programs' associated.

!

with management control,. verification,: andJoversight = activities;- The'

il inspectors considered areas indicative'.of _overall management involvement _

.

in quality matters, self-improvement programs,-response to regulatory and-industry initiatives,Jthe frequency of: management plant tours and control-

room. observations, and management personne1's' participation'in technical

and planning' meetings. The inspectors, reviewed Potential Condition =

l Adverse lto 0uality Reports (PCAQR), Station Review Board (SRB) Land:

q Company Nuclear Review Board meeting minutes, event. critiques, and

related documents; focusing on the licensee's root cause determinations i

and corrective actions. TheJinspection.also included a' review of~ quality j

records and selected quality assurance audit and surveillance activities.

Two events, which_ occurred on June 9 and June'1.1, 1990,';and were e described in Inspection Report 50-346/90013, were voluntarily reported-l

.to the NRC on August 6,1990, by the licensee.

A telephone. conversation (

held between the licensee and NRR-on. July 116, 1990, conclud.edlthat since.

the reactor-trip breakers wereinot opened by the reactor protection

-

a system that the event was not reportable in accordance with.10 CFR 50.73

'

but.that a-voluntary report would be submitted to provide technical-

'

details of the events.

H

'

'No viniations or devietions were identified.

,

1

2

m.

~ ~

p.

, g *-

g

<

,

j~.

1J

'

"

A-

,

.,.

,

+

a

,

}

,

>

'

'

'

E12. Management Meetings;(30702,-7305 5 l

r

,,

'.On July 18p1990,ithe Regional.' Administrator and the' Assistant' Director,:_

s

!NRR for/ Region III; Reactors and selected members of their staff, met with-

.

_ senior corporate and licensee management and selected members of their o

,

l,

. staff for a Quarterly Status meeting. They_ discussed matters of mutual

-

concern.and' toured the facility.

.

q On July 31,c1990, senior licensee management met with the' Regional-

• *

'

Administrator and members' oflhis-staff to discuss ~ the licensee's.

response regarding-a violation of Instrumented' Inspection Techniques.

j

'

"

. --

!

13. Allegations (RIII-90-A-0050)-

,

4 1A former; employee who had been terminated for cause made:several allegations to the licensee but not toithe NRC. ;The licensee informed the Region III of the' allegations. The allegations were' investigated

!

by:the nlicensee and the results were reviewed by the. inspectors.

' The' allegations and thelresults ofathe investigation are as follows:

l

.

a.

-0n June 19, 1986, a QC inspector was verbally intimidated by-

a member of: management for. writing a. potential condition adverse to quality report (PCAQR) relating to a Raychem electrical wire.

-splice.in the presence of.the alleger-.and the inspector's supervisor

'

who made no effort:to initiate corrective action.,The; allegation

.

was substantiated in part. The' management individual, who isyno

longer employed by. the licensee, did speak harshly. to.-the QC-'

inspector. The-QC; inspector did not stopl writing PCAQRs,'as.

observed by the inspectors, and the supervisor informed _his L

management of the event.

b.

During the 1988 outage a State Code. Inspector-was. requested from Perry to provide assistance t'o the Davis-Besse State Code. Inspector.

The' individual.was only certified to perform state code related

inspections and was not= certified to perform inspections requiring-certification to ANSI N45.2.6.

The inspectoriconducted'and signed-for acceptance inspections within the scupe of ANSliN45.2.6. The issue was previously identified and documented _in PCAQR 88-0765.

,

The inspectors reviewed the closed out PCAQR and' concluded that L

there was no basis for the allegation, c.

A QA manager signed off Quality Assurance Procedure Review and L

Implementation Checklists-(QAPRIC) indicating training was complete prior to actual training being conducted or when training was i

conducted prior to procedure' approval by~the QA Director.

Procedures QADP-00060, 00062, and 00252 were listed as examples.

The allegation was substantiated in part..The licensee was able to locate tt QA manager named 1,1 the allegation. The indiv.idual stated

that in some limited cases training may.have occurred prior to final-approval where revisions were being made..In all cases, the revision was reviewed to determine if additional training was required. The

-

}

,

d v

- -.

'

,

E.

T

,

. - G., f,.;

~

,

~

'

,

-

iridividualistated that the changes were ' administrative in nature andh

to.the best of his knowledge, no retraining was: required.. He also-

.

stated that his' actions were done with the full knowledge ^of.his

>

staff'and' supervisors. The inspectors reviewed the QAPRIC and'

- >

l training records for the~3 procedures listed in'the allegation.-

.

,

In all cases,the required training,Lwhich was reading, was completed-

,

,

prior.to.the' effective'date of.the procedure for all required!

inspectors except for two who were on vacation..:Inlone case a-revision was-issued and a' determination was made andl documented-

}

that no retraining'was required.

,

'

.i The inspectors were not able.to substantiate the allegation.-

,

d.' -The QA manager was confronted by another QA person. He was'adyised-that he had committed a procedural violation-and.a PCAQR should'be written.

The QA manager stated _.that he was under'a great deal:of-o pressure to get procedures revised and issued. He alto threatened-.

the-individual not to write a.PCAQR.

No;PCA0R was written. The.

licensee was able to contact..the QA manager who is no longer.

employed by the licensee. - The_ QA manager denied making the -

statement and the licensee was: unable to identify;any witnesses or the-QA individual. involved. The. inspectors review indicated that no PCAQR was required.

e.

On August 31, 1988, a Qualified Reviewer was overheard stating to an unknown individual that You can'ttwrite a:PCAQR against~ a Qualified Reviewer -: we -have a way of :getting even." On several; occasions between August 25 and September _23,r1988, the' individual was'

-

overheard stating, "Sure, I can be bribed," to individuals inquiring

,

as to the status of procedures being reviewed-by the' individual.-

'

,

'

The licensee determined from. interviews that the statements.were made in jest with=no intent of malice.c

'

f.

A contract QC inspector-indicated on his resume' that h'e had 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> L

of training for' silicon foam,ihighl density,-and boot seals.. The L

training is not verifiable.and the inspector may have been prematurely l

certified based on false information provided by his lead inspector.

,

L The concern was not substantiated. The licensee's investigation l-revealed that the individual had received the specified training and.

was-certified as a Level II. inspector for' inspection of installation only.

g.

An individual was informed by his supervisor that the processing of a PCA0R was a costly item for Toledo. Edison and therefor the'

'l L

initiation'of PCAQRs should be minimized.

It was further indicated

'

that the initiation of PCAQRs would be reflected negatively on merit

'

'

reviews and when raises were considered. This. allegation was L

substantiated in part. The individual was told that PCAQRs ~were

expensive to process, and if possible, a single PCAQR should be l

written rather that rH ting several for the same event. The issue

!

relating to merit reviews and raises was determined to be false.

The inspectors reviewed all of the individual's merit reviews and raise records and did not find a neative review nor find that he had'been denied a merit increase.

,

,

l

.

u

.

,

-

-

_,

,

- =3

-

.

.

.....

.

..

..

..

,.,w s a:

-

<

.. _ -

.

-

-

...

.

T y

,

.

~

-Afterreviewingtheallegatibn,[theconclusions'of! the-licensee's1

-

'

'

'

security. investigator, the investigators file, land'certain QALand;

personnel records.othe inspectors.have; concluded that the allegation

,

F has no-safety significance, thellicensee's" efforts lwere satisfactory,"

>

and.the allegation ~could not be substantiatedt This allegation ~is:

closed.

-

.

. - -

!,

'

'

No violations or: deviations ^ were identified.' +

o

,*

i14.

Violations for Which a " Notice of Violation"!Will Not Be Issued The'NRC'uses the Notice'ofl Violation (NOV)'as'a standafd method for~

formalizing the existence;ofLa-violation of a legally! binding requirement. However,-because'the NRC wants'toLencourage and support?

,

licensees'-initiatives for self-identification ~and correction of:. -

.,-

s

problems, the NRC will not generally issue;a NOV foria violation thati; meets the tests:of 10 CFR= 2, Appendix.C,'Section: V.G,1. : These tests are:

(1) the violation was identified-by the. licensee;L-(2) the a

>

violation would be-categor.ized as Se' verity Level IV or V;'(3)Lthe violation was reported to the NRC.Jif required;t(4)sthe1 violation will be corrected, including measures to prevent recurrence, within a

' reasonable time period; and (5) it wasinot:a violation that could-reasonably be expected to have been prevented by the licensee's.

i corrective action for a previous violationn.ALviolation-.of regulatory

'

requirements identified during the inspection for!whichJa,NOV will not<

be issued is discussed in Paragraph.10.

15. Unresolved Items

'

Unresolved itens are matters about which more information is required.

,

in order to ascertain whether they are acceptable: items, violations,

)l or deviations. -An unresolved item disclosed during)the1 inspection _is-discussed in Paragraph 7.

)

16. Exit Interview (30703)

I'

The inspectors met with licensee representatiives (denoted in: Paragraph 1)

throughout the inspection period and at the conclusion of-the inspection-

.;

and sumarized the scope and findings of the-inspection activities.

.

The-

!

licensee acknowledged the findings.

After/ iscussions with the licensec, d

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

j

?

t

i