IR 05000346/1990021
| ML20062G078 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 11/19/1990 |
| From: | Gardner R, Hausman G, Kopp M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20062G072 | List: |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 50-346-90-21, NUDOCS 9011280384 | |
| Download: ML20062G078 (8) | |
Text
.
,
,.
U.S. NUCLEAR REGUIATORY COMMISSION
'
REGION III
Report No. 50 346/90021(DRS)
Docket No. 50 346 License No. NPF-3 Licensee:
Toledo Edison Company Edison Plaza i
'
300 Madison Avenue Toledo, Ohio 43652 Facility Name:
Davis Besse Nuclear Power Station Inspection At:
Davis Besse Site, Oak Harbor, Ohio Inspection Conducted: October 15 through November 5, 1990 Inspectors:
iM#[
// /
M. J,ljtopp Date'
'
WW-Il IO 00 G. M. llausman Date'
Approved By:
um M h p\\ w ll, 17 f#
Ronald N. Gardner, Chief Date Plant SystemsSection I
Insocetion Stimmary Inspection on October 15 throuch Novenher 5.1990 (Recort No.
50 346/90021(DRS))
Aress Inspected: Special announced safety inspection of previously identified unresolved items concerning environmental qualification (EQ) and the instrumentation system for assessing plant c editions during and following an-accident as specified in Regulatory Guide (RG) 1.97, Revision 3 i
(Modules 30703. 2515/76, and 2515/087); SIMS Number 67.3.3.
l Results: In the areas inspected, no deviations were identified.
Based on t'. sis inspection, the inspectors concluded t. hat actions have been taken to resolve nine of the twelve unresolved items identified in Inspection Reports No. 50 346/82004(DRS), No. 50-346/86024(DRS) and No.
!
t 50 346/88038(DRS).
l
,
l
.i i
l l
i
$@kC$$$$k !S!)$)hg6 l
o
,
,
.'
L
!
_
- _ _ _ _ - _ _ _ _ _ _ __ _
.
.
-
.
,
'
'
DETAILS
'
l.
Persons C_pnusitd l
Toledo Edison comparv (TEl L. Storz, Plant Manager S. Jain, Engineering Director
+V. Watson, Design Engineering Manager
+E. Caba, Performance Engineering Manager
- +G. Honma, Compliance Supervisor
+P. Jacobsen, Design Engineering Supervisor FC. Butcher, Design Engineering Supervisor
+M. Borysiak, Senior Engineer
+G. Stoner, Senior Quality Assurance Auditor
'
+L. Simon, Senior Performance Technologist E. Johnson, Environmental Qualification Engineer
+K. Filar, Licensing Engineer
'
N. Peterson, Licensing Engineer Cleveland Elcetric illuminatina Comoany (CEI)
S. Litchfield, lead Environmental Qualification Engineer
~
U. S. Nuclear Reaulatory Commission (USNRC)
+P. Byron, Senior Resident inspector, Davis Besse
+ Denotes those participating in the interim site exit meeting on October 17, 1990.
- Denotes those participating in the final exit on November 5,1990.
2.
Licensee's Actions Reaardina Previous 1v Identified NRC Finding 1
l a.
(Closed)Bulletin 82-04 (346/82004-8B):
This bulletin identified several deficiencies with Bunker Ramo electrical penetrations which utilized a hard epoxy module design.
The bulletin stated that there were potential generic safety implications and requested licensees to review the information contained in the bulletin for applicability to their facilities.
Concerning the Davis Besse facility, NVREC/CR-3795 concluded (Criteria for Closeout of Bulletin, page 3, and Table B.1, page B-2) that the licensee had provided an acceptable response which indicated that there were no affected assemblies installed in the plant.
Therefore,-this item is closed.
-
,
"
-
, - -
-4
,
w
,.
. _ - -
_.
i
'
j
.
b.
(Closed) Unresolved item (346/86024 01(DRS)):
'
This item concerned the high range radiation monitors and the l
ability of the Rockbestos coaxial cables connected to the monitors to meet the RG 1.97 accuracy criteria.
The EQ files did not
)
adequately address performance of the cables at low radiation i
levels combined wit 1 thermally induced high leakage currents.
The i
inspectors determined that the vendor. Sorrento Electronics, had i
,
filed a 10 CFR Part 21 notification with the NRC concerning the i
Rockbestos cables. The notification stated that a review of the cable qualification report for the Rockbestos cables revealed that the dielectric insulation resistance of the cables at high
temperatures (350'F) was 2.66 M0hm' and that the minimum value
needed to meet the RG 1.97 accuracy requirements was 5.00 M0hm.
During this inspection, the inspectors reviewed the licensee's j
time lag heat transfer calculation, " Insulation Resistance of Rockbestos Cable RSS 6.'13/LD," C ECS-038.02-100, dated December 5, 1988.
The calculatior, identified the worst case insulation resistance value for the installed cables and determined the overall accuracy of the asacciated radiation monitor.
The analysis concluded that tht accuracy requirements would be met for a dose rate greater than atproximately 1.45 rads / hour.
The inspectors noted that the indicators would not be on scale until an actual dose rate of 2 rids / hour was reached.
Therefore, because the accuracy requirements would be met when the jndicators were on scale the analysis appeared to be acceptable and the
-
inspectors had no further concerns.
This unresolved item is closed, c.
(Closed) Unresolved Item (346/86024 02(DRS));
This item concerned the Amphenol electrical penetration assemblies identified in EQ file DB1003A.
The inspectors noted that the EQ test report did not include data which demonstrated that the 1.0 M0hm insulation criteria was satisfied.
The licensee was requested, per NRC letter dated January 31, 1989, to provide the NRC with a copy of the EQ test documentation for the electrical penetration assemblies installed at Davis Besse.
The NRC staff's subsequent review concluded that insufficient insulation resistance data had been taken during the loss of coolant accident (LOCA) test in that failures occurred and no follow up testing was performed. Therefore, it was determined that functional operability of the electrical penetrations had not been
demonstrated. The NRC staff required the licensee to furnish the plans and schedule to either qualify, test or replace the subject penetrations with qualified assemblies.- The licensee responded to
,
l the NRC in a letter dated May 1,1989, which stated that spare EQ
'
penetration assemblies would be removed from the plant and tested after the scheduled February 1990 outage.
The licensee indicated
..
_
_
_
._.
-
.
.
e
during this inspection that the EQ test results would be
'
incorporated into the EQ file when completed,
'
This unresolved item is closed. However, should the test results i
prove to be unacceptable, this issue will be reopened.
d.
(Closed) Unresolved Item (346/88038 OlfDRS)l This item concerned the lack of qualified cable entrance seals installed on EQ ASCO solenoid valves.
The licensee stated that seals were not required because all ASCO solenoid valves located in harsh environments would fail to the safe position in the event of an accident. However, the inspectors noted that Information Notice (IN) 88 86, Supplement 1, documented the potential for spurious actuation of ASCO solenoid valves due to the existence of ground fault paths during accident conditions.
During this inspection, the inspectors reviewed the licensee's analysis of IN 88 86.
The analysis indicated that the ground fault detection circuit installed at Davis Besse result 9d in a net resistance of 100,000 Ohms to ground.
This circuit configuration would not allow a leakage current of sufficient magnitude to flow in the circuit and cause actuation of the solenoid valves.
In addition, the control circuit design utilizes a set of contact:; at both cnds of the coil which prevent a ground fault from providing a complete circuit for the coil to be energized.
The licer.see's
-
analysis appeared to be acceptable and the inspectors had no further concerns.
l This unresolved item is closed, e.
(Ocen) Unresolved item (346/88038-02fDRS)):
During the previous NRC RG 1.97 inspection, the inspectors noted that the plant design did not include redundant instrument channels from sensor to display for steam generator level, steam generator pressure, and reactor coolant system (RCS) hot leg level (corecoolantinventory).
During this inspection, the inspectors reviewed the j
instrumentation loop schematics for these variables, and discussed
'
the issues with the licensee and the Instrumentation and Control Systems Branch (SIC 8) in NRR.
RG 1.97, Table 1, Paragraph 2,-
addresses redundancy and states, "... Within each redundant i
division of a safety system, redundant monitoring channels are not needed except for steam generator level instrumentation in two-loop plants." The licensee interpreted this statement to mean that redundancy was only required for the steam generator level instrument channels, and not for other RG 1.97 variables.
However, NRR/SICB stated that this statement only applied to the steam generator level variable and that redundant instrument channels for other Category 1 instrumentation was required.
As a
'
,
o
i
!
_ _ _ _ _
.__. _.. -
-
-
.
.
.
"
.
result of this discussion, the following actions were agreed upon:
,
o The licensee committed to install two redundant steam generator level instrument channels for each steam generator prior to plant restart from refueling outage number 7, tentatively scheduled for September 1991.
!
O The installation of two redundant steam generator pressure instrument channels remained unresolved pending further review by NRR.
O NRR/SICB stated that the RCS hot leg level instrumentation was considered acceptable based upon NRR's acceptance of NUREG 0737, Item II.F.2.
This unresolved item remains open periding NRR review of the licensee's March 19, 1990 submittal concerning the steam generator pressure instrumentation, f.
(Closed) Unresolved Item (346/88038 03(DRS)):
During the previous NRC RG.1.97 inspection, the inspectors noted during the inspection walk down that various exceptions were taken by the licensee with respect to physical separation requirements.
During this inspection, the inspectors reviewed the licensee's existing documentation and instrumentation and determined that the Davis Besse Updated Safety Analysis Report (USAR), Section 8.1.5, Design Bases, does not require specific compliance with RG 1.75 requirements since plant design pre dated the issuance of RG 1.75.
In addition, the Davis Besse USAR, Section 8.3.1.2.25 permits, within enclosures (control boards, instrument cabinets,
.
distribution panels, motor control centers, etc.), the routing,
'
bundling, or forming of non class 1E cables with class 1E cables provided certain specific requiremants are maintained and that any deviations to these requirements ars documented and analyzed.
The inspectors concluded, based upon the above information and discussions with NRR/SICB, that the licensee meets RG 1.97 separation requirements. Therefore, this unresolved item is closed, g.
(Onen) Unresolved Item (346/88038 04(DRS)):
During the previous NRC RG 1.97 inspection, a review of the I
control room normal ventilation status (CRNVS) instrumentation
{
revealed that, contrary to RG 1.97, Honeywell pressure switches PS 5301 and PS 5311 were installed as non safety related devices.
'
- .
-
_
.
.
.
'
During this inspection, the inspectors noted that the CRNVS instrument channel interfaced with a safety related circuit where qualified isolation did not appear to be provided. The inspectors i
discussed the CRNVS pressure switch circuitry with the licencee and with NRR/SICB.
The licensee had classified the CRNVS instrument loop as Category 1, Type A.
RG 1.97, Revision 3, classifies CRNVS as Category 2, type D.
It appeared to the inspectors that this instrument loop meets the Category 2 criteria.
The licensee committed to evaluate their designation of this variable as Category 1. Type A to determine if CRNVS can be downgraded and to document this review.
The licensee also committed to review the circuit to determine if proper isolation of the circuit was provided.
The unresolved item is considered open pending further licensee i
review, h.
(closed) Unresolved item (346/88038 05(DRS)):
This item identified certain inaccuracies between the RG 1.97 j
instrument list and the RG 1.97 control room matrix list.
The inspectors noted that the lists contained incorrect instrument numbers.
The licensee committed to review the lists.and correct
!
any errors found.
During this inspection, the inspectors reviewed the RG 1.97 instrument list and the RG 1.97 control room matrix list and found that the licensee had corrected the discrepancies.
The inspectors i
had no further concerns.
This unresolved item is closed.
1.
(Closed) Unresolved Item (346/88038 06(DRS));
During the previous NRC inspection, the inspectors nott.d that, contrary to RG 1.97, Revision 3, the indicators for berated water l
storage tank (BWST) level and centainment narrow ranF, (CNR)
pressure (Category 1, Type A variables) were identiff.ed as non-class 1E devices.
In addicion, the inspection reveated that there was no control room indi',ation for the Category 1, Type B core l
coolant inventory (RCS 'iot leg level) variable.
During this inspection, the inspectors reviewed the appropriate BWST level and CNR ins:rumentation drawings.
This review showed that the indicators were powered via current loops from essential l
power sources through qualified class 1E isolators located within the safety features actuation system (SFAS) cabinets.
During
'
discussions with NRP., NRR/SICB stated that since the class 1E to -
non class 1E interface (BWST level /CNR pressure variables to associated indicators) was made via qualified isolators and plant
!
design pre dated t?) issuance of RG 1.75 as well as IEEE 384 1974, the instrumentation complied with the intent of RG 1.97.
Also,
,
I l
!
.
_
i
-
.
l
'
,
,
'
the inspectors determined that the core coolant inventory (RCS hot leg level) instrumentation loops LT 544BA and LT 5448B provided indication in the control room via the Safety Parameter Display System (SPLS) computer display at computer points L/21 and L720, respectively. The hot leg level monitoring system (HLLMS) was installed as part of the inadequate core cooling (ICC)
.
'
instrumentation system to conform with NUREG 0737, Item II.F.2.
This unresolved item is closed.
j.
(Closed) Unresolved Item (346/88038 07(DRS)):
During the previous NRC RG 1.97 inspection, the inspectors noted i
that for the recording of Category 1 essential variables, the licensee failed to provide class 1E recording devices.
'
During this inspection, the inspectors determined that the RG 1.97 variables were monitored by either the plant computer and/or the Safety Parameter Display System (SPDS). Qualified channel isolation was provided for the RG 1.97 class 1E instrumentation to non class 13 plant computer and SPDS interface. The licensee-stated that the signals to the computer systems were not essential
,
for immediate operator information or action since direct indication is utilized for operational procedures and recorded information is only used for subsequent transient assessment.
The inspectors discussed the above information with NRR/SICB.
Since the subject recording instrumentation is not used for essential operator information or action and qualified channel isolation is provided for'the class 1E to non class 1E interface, the requirements of RG 1.97 are satisfied.
This unresolved item is closed, k.
(ooen) Unresolved Item (346/88038 08(DRS)):
l This item concerned identification of RG 1.97 instruments located on the control room panels.
RG 1.97, Revision 3 requires identification of Category 1 and 2, Type A, B, and C instruments.
However, the licensee deviated from this requirement in that a number of instruments have not been identified.
I During this inspection, the inspectors informed the lic-nsee that this item would be referred to NRR for review.
This unresolved item remains open pending further NRR review.
7
.
.-
..
.
.
.
.
1.
(Closed) Unresolved Item (346/88038 09fDRS)):
This item concerned RG 1.97 training for operstors.
The inspectors noted that the operators had not been trained or made adequately aware of the use of RG 1.97 instruments and that the Emergency Operating Procedures (EOPs) did not address the use of RG 1.97 instrumentation.
During this inspection, the ins)ectors reviewed the licensee's training records and verified t1at operators were trained and made aware of the use of RG 1.97. instruments.
In addition, the licensee stated that the E0Ps direct the operators to RG 1.97 instrumentation but do not specifically inform the operator that the instruments are RG 1.97 related. The inspector concluded that the licensee had taken adequate measures to resolve this item.
This unresolved item is closed.
l 3.
Unresolved Items An unresolved item is a matter about which more information is required l
in order to ascertain whether it is an acceptable item, an open item, a
'
deviation, or a violation. Unresolved items remaining open during this inspection are discussed in Paragraphs 2.e, 2.g, and 2.k.
4.
Exit Interview l
i The Region 111 inspectors met with the licensee's representatives
!
(denoted in Paragraph 1) on October 17 and November 5,1990, and
'
discussed their findings at the conclusion of the inspection on November 5, 1990. The inspectors discussed the likely content of the inspection report with regard to documents or processes reviewed by the inspectors.
The licensee did not identify any such documents or processes as proprietary.
!
l I
!
!
L
!
l t
i