IR 05000346/1993013

Insp Rept 50-346/93-13 on 930701-0813.Violations Noted. Major Areas Inspected:Lers,Operational Safety,Surveillances & Maint

ML20056H266
Person / Time
Site:	Davis Besse
Issue date:	08/30/1993
From:	Lanksbury R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20056H260	List: IR 05000346/1993013 ML20056H259
References
50-346-93-13, NUDOCS 9309090063
Download: ML20056H266 (11)

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U. S. NUCLEAR REGULATORY C0HMISSION

REGION III

Report No. 50-346/93013(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 Nuclear Power Station Inspection At: Oak Harbor, Ohio Inspection Conducted: July 1, 1993, through August 13, 1993 Inspectors: S. Stasek R. K. Walton J. M. Shine W. J. Kropp O .s .

Approved By: 'k . [5wm SlV}%

R. D. Lanksbdry, Chigf' 'Date Reactor Projects Section 3B Inspection Summary Inspection on July 1. 1993. throuah Auoust 13. 1993 (Report No. 50-346/93013(DRP))

Areas Inspected: A routine safety inspection by resident inspectors of action on previous inspection findings, licensee event reports, operational safety, surveillances, and maintenanc Results: An executive summary follows:

Plant Operations: Overall, performance of the operating crews was good this inspection period. Adherence to administrative controls was adequate. Shift turnovers observed were well conducted and in conformance to regulatory and procedural requirements. Logkeeping was, in general, sufficient to reconstruct shift activities. The licensee entered into Mode 2 during tre startup from the refueling outage with the auxiliary feedwater system inoperable due to an open check valve. This non-cited violation is discussed in Paragraph High atmospheric temperature conditions affected the operation of the safety-related portion of the service water syste Even though the system responded as designed, the inspectors were concerned _wit the operators recognition of the event. This is an inspection follow up item and is documented in paragraph Due to an inadequate procedure, operators realigned one of two Technical Specification required boron injection flowpaths to an alternate lineup without ensuring adequate heat tracing was. in 9309090063 930830 "

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operation on the additional run of pipe. Operators assumed the safety-related l heat tracing was checked by a weekly surveillance when it was not. This non- i cited violation is discussed in paragraph l Maintenance: Maintenance and surveillance activities observed / reviewed during this inspection period were conducted in accordance with licensee procedures ,

and regulatory requirements. The inspectors were concerned with maintenance  !

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workers leaving electrical cabinets open and unattended. This item is a followup item and is discussed in paragraph :

Enoineerino: A failed component in the Safety Features Actuation System ,

(SFAS) resulted in a channel of SFAS being declared inoperable. The component was replaced and the licensee was evaluating a modification to remove the i component from the SFAS cabinets. This item is discussed as an inspection >

followup item in paragraph i

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Plant Suonort: Adherence to radiation protection program requirements was l good this period with no substantive problems noted. Also, the licensee implemented the second part of their reorganization during the inspection perio l

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DETAILS [ Persons Contacted

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Toledo Edison Comnany L. f. Storz, Vice President, Nuclear

• G. A. Gibbs, Director, Engineering

• S. C. Jain, D# rector, Nuclear Services  :

J. K. Wood, /lant Manager ,

J. W. Rogers, Manager, Maintenance T. J. Myers, Director, Nuclear Assurance >

• J. Dillich, t4 nager, Radiation Protection

• S. Byrne, Manager, Plant Operations

• B. Donnello., Manager, Plant Engineering  !

• J. Holden, Manager, Design Engineering

• J. E. Moyers, Manager, Quality Assessment .

• D. Crouch, Superintendent, Mechanical Maintenance

• G. Honma, Supervisor, licensing i

• M. A. Turkal, Licensing Engineer i

• A. W. Rabe, Supervisor, Quality Assurance

• P. Ricci, Supervisor, Operations  :

• J. Michaelis, Supervisor, Outage Planning .i

• R. A. Simpkins, Supervisor, Operations Training  ;

• K. C. Prasad, Staff Engineer, Nuclear Engineering '!

• J. L. Tabbert, Sr. Engineer Independent Safety Engineering

• J. L. Lee, Engineer, Plant Engineering .

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• Denntes those licensee personnel attending the August 13, 1993, exit meetin . Followun of Previous insoection findinas (92701)

(Closed) Inspection follow-up Item (346/92005-01(DRP)): The licensee

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experienced periodic trips of the control room normal ventilation system l due to spiking of radiation detector RE4598AA. The detector spiking l; would occur after returning the detector to service following routine maintenance. The licensee adjusted the instruments to reduce instrument .

. spiking and changed procedure DB-CH-03008 to require waiting 45 minutes prior to placing the detector back in service to allow for detector spiking to die out. There have been no trips.of control room normal ventilation since the corrective actions were implemented. The >

inspectors reviewed the procedure change and this item is close t (Closed) Inspection follow-up Item (346/93004-01(DRP)h Acceptability ,

of preconditioning equipment prior to Technical Specification required ;

surveillance testing. This concern involved the observation of ,

personnel tightening filter element hold-down bolts in the emergency- i ventilation system prior to performing Technical Specification required surveillance testing to insure that filter by-pass flow was acceptabl Licensee actions.were in conformance with plant procedures, Regulatory Guide 1.52, and activities per ANSI N510. Since the preconditioning of 3  !

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the subject equipment appeared to be inconsistent with existing NRC testing philosophies, further clarification was requeste The office of Nuclear Reactor Regulation (NRR) reviewed the potential consequences of performing such preconditioning activities in response- l to concerns raised related to recent testing of the standby gas- !

treatment system at the Dresden Nuclear Power Station. In a memorandum i dated July 22,1993, (TAC Nos. M84897 and M84898), NRR concluded that performing the stated preconditioning activities was a recognized-testing methodology and had been reconciled with general NRC testin ,

philosophy. This matter is close i (Closed) Unresolved Item (346/93010-OlfDRP)): Adequacies of Makeup Pump Indication Circuit Desig It was subsequently determined that the subject design where the control power fuses for the 4160 volt makeup pump power breaker could be removed without loss of control room indication was generic to 4160 volt breakers. However, it was found that the present design was consistent with required industry standard ;

Further, discussions with the Region III Division of Reactor Safety

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revealed that the current breaker design was adequat ;

As a result of a previous event involving a loss of close power to a 4160 volt breaker, the licensee installed an annunciator that would alarm upon loss of control power to any one of the 4160 volt safety-related breakers. Although the annunciator did not provide full

"reflash" capabilities, during normal power operations none of the '

subject breakers would be anticipated to be out of servic :

Since the current breaker design meets regulatory requirements, and the ,

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licensee had previously taken steps to preclude unknown losses of control power to the subject breakers during power operations by the addition of the annunciator, this item is close ;

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(Closed) Unresolved Item (346/93012-Ol(DRP)): Modification to check valves MS734 and MS735 may prevent the valves from closing during a high ,

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energy line break (HELB). The licensee determined that valve MS735 was not closed prior to entry into MODE 2 on April 12, 1993, which is not .

allowed by TS 3.0.4. The licensee documented this es.nt in licensee ,

event report (LER) 93004, which is discussed in paragraph 3.a. This item is close . Followup of Licensee Event Reports (92700)

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lhrough direct observations, discussions with licensee personnel, and review of records, the following licensee event reports (LERs) were reviewed to determine that reportability requirements were fulfilled, I immediate corrective action was accomplished, and corrective action to i prevent recurrence had been accomplished in accordance with technical-specification (Closed) LER 93004, Mode 2 Entry with Auxiliary feedwater Train 2 :

Inoperable. On April 28, 1993, at 12:12 p.m., the plant entered into l, 4  !

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Mode 2 with the main steam supply to auxiliary feedwater pump turbine check valve, MS735, open. With the check valve open, it was uncertain if the auxiliary feedwater pump would have operated in the unlikely j event of a high energy line break (HELB). The licensee believed that -

the check valve was left in the open position after testing on the l previous day. The licensee closed MS735 at about 3:00 p.m., on  !

April 28, 199 ,

Check valves MS734 and MS735 were replaced during the outage with valves [

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having an external shaft. The external shaft packing required an additional amount of torque _to be applied to the valve disc to effect  !

movement. Operators continued to perform periodic visual inspections of MS734 and MS735 to ensure they remain closed. After the modification t was completed, an engineering analysis concluded that the check valve [

might not have prevented backflow during certain HELBs. The quality i assurance department performed a surveillance associated with this  !

modification and found weaknesses in the modification. The quality  :

assurance director and engineering director discussed these weaknesses  ;

and proposed changes to address these concerns. The inspectors determined that the modification had not properly addressed the effect i of the packing load on the valves' operation. As a result, MODE 2 was entered with valve MS735 not closed. This matter was previously ,

addressed as unresolved item (346/93012-01(DRP)).

The entry into Mode 2 with valve MS735 not closed constituted a .

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violation of Technical Specification (TS) 3.0.4, which prohibited mode changes unless the limiting conditions of operation were met without  !

reliance on the action statement. The licensee's corrective actions  ;

included, closing valve MS735 upon discovery and checking the valves in  :

their shut position periodically. Additionally, this LER was to be  ;

discussed with design engineers by August 31, 1993, in an attempt t improve the modification process. The inspectors considered this event ,!

to be of minor safety significance, since the time spent in this

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condition was minimal (<3 hours) and the immediate actions taken by the J licensee were appropriate to ensure system operability. This licensee .

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identified condition was not cited because it met the criteria specified in Section VII.B of the " General Statement of Policy and Procedure for i NRC Enforcement Actions," (Enforcement Policy,10 CFR Part 2, -

Appendix C). -

No deviations were identified in this area; however, one non-cited violation was identifie . Operational Safety Verification (40500) (71707) (84750) (90712) (93702)

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The inspectors observed control room operations, reviewed applicable I logs, and conducted discussions with control room operators during the {

inspection period. The inspectors verified the operability of selected i emergency systems, reviewed tagout records, and verified tracking of '

limiting conditions for operation (LCOs) associated with affected l components. Tours of the auxiliary and turbine buildings were conducted

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to observe plant equipment conditions including potential fire hazards,

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fluid leaks, and excessive vibrations, and to verify that maintenance requests had been initiated for certain pieces of equipment in need of maintenance. Walkdowns of the accessible portions of the following systems were conducted to verify operability by comparing system lineups with plant drawings, as-built configuration, or present valve lineup lists; observing equipment conditions that could degrade performance; and verifying that instrumentation was properly valved, functioning, and calibrate Emergency Diesel Generators (Both trains)

- Auxiliary Feedwater System (Train #1)

- Station Blackout Diesel Generator The inspectors, by observation and direct interview, verified that the physical security plan was being implemented in accordance with the station security plan, including badging of personnel, access control, security walkdowns, security response (compensatory actions), visitor control, security staff attentiveness, and operation of security equipmen Additionally, the inspectors observed plant housekeeping, general plant cleanliness conditions, and verified implementation of radiation protection control Specific observations and reviews included the following: On July 20, 1993, at about 4:12 a.m., operators declared the Safety Features Actuation System (SFAS) channel #2 containment high pressure bistable inoperable due to an inexplicable failur Operators entered technical specification action statement 3.3. and tripped the containment high pressure bistable less than an hour later as required. At 9:09 a.m., the same morning, the SFAS channel #2 containment radiation bistable failed. Operators tripped the affected bistable as required by TSs and shortly thereafter, smelled the odor of burning plastic near the SFAS channel #2 cabinet. At 9:28 a.m., operators deenergized SFAS channel #2. Subsequent troubleshooting of the affected cabinet determined that a calibrating meter in the cabinet had a fault which resulted in it drawing an excessive electrical current, _

heating up, and distorting the meter. This fault disrupted the power supplies to both the containment high pressure and containment radiation instruments. The meter was replaced and subsequent testing was performed to verify operability of SFAS channel #2. SFAS channel #2 was declared operable at 6:48 the same da The calibrating meter was installed in the cabinet, but had not been used due to the use of an external meter. The inspectors were concerned that a non-critical component in the SFAS induced problems in critical portions of the SFAS cabinet. The licensee explained that the meter and other non-critical components in SFAS were quality controlled pieces of equipment which had not caused

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problems with the critical sensing portions of SFAS cabinets in the past. At the end of the inspection period, the licensee was ,

reviewing the possible removal of the calibrating meters and other ,

non-critical components from the SFAS cabinets. This is an t inspection follow-up item, (346/93013-01(DRP)), pending inspector review of the licensee's corrective action b. On July 26, 1993, about 1:17 p.m., train #1 service water (SW)

supply pressure dropped to about 55 psig which isolated service ,

water supply to the non-vital turbine plant cooling water system -

(TPCW). TPCW cooling was automatically transferred to the circulating water system. Operators did not immediately detect

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the service water header low pressure condition because an annunciator apparently did not alarm. Operators detected the '

condition about 15 minutes later when a TPCW cooled component reached a high temperature alarm setpoin The licensee determined that the SW pressure drop occurred whe with train #1 of the component cooling water system (CCW) lined up ,

in a standby configuration, temperature modulating valve SW1424 throttled open over a 70 minute period when it sensed a CCW temperature of 95 F. This was due to an elevated CCW pump room ,

temperature, resulting from high ambient air temperatures, and a CCW system temperature detector which did not compensate for i ambient temperature conditions. When SW flow was initiated .

through the idled cooler, SW system pressure dropped. The low SW -

pressure condition caused SW isolation from the non-vital TPCW ,

cooling, as designed, and should have initiated an annunciator in the control room to alert the operators of the abnormal conditio After control room operators detected the condition, operators ,

isolated the SW flow through the idled cooler and stationed a watch at SW1424 until the temperature modulating valve setpoint I was adjusted higher than room temperature. The SW1424 valve then throttled closed.

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adverse to quality report (PCAQR 93-0368). At the end of the i inspection period, the licensee was determining why the SW low pressure alarm did not function and was evaluating whether the CCW pump room temperature setpoint could be raise t The inspectors did not consider this a safety issue since the SW !

system was designed to isolate from the non-vital TPCW system on a ;

low SW system pressure condition. The inspectors were concerned :

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that an annunciator and a computer alarm did not actuate to warn [

operators of an abnormal plant condition. Additionally, the j inspectors are concerned with the ability of the CCW pump room [

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ventilation to maintain room temperature. These matters were  ;

considered an inspection follow-up item (346/93013-02(DRP)) f pending NRC review of the licensee's evaluatio [

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• On July 20, 1993, the licensee announced the second part of its site reorganization plan. Certain departments were merged, resulting in a reduction of managers from 20 to 14. Six of these managers were new to their positions. The next step in site '

I reorganization is expected to be the appointment and announcement of supervisors, which was expected to be completed in mid-Augus '

No violations or deviations were identified in this are i' Surveillance (61726)

The inspectors observed safety-related surveillance testing and verified i that the testing was performed in accordance with adequate procedures, ,

that test instrumentation was calibrated, that limiting condition for ,

operation (LCOs) were met, that removal and restoration of the affected components were accomplished, that test results conformed with technical specification and procedure requirements and were reviewed by personnel other than the individual directing the test, and that any deficiencies -

identified during the testing were properly reviewed and resolved by ,

appropriate management personne l l The following test activities were observed and/or. reviewed: ]

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DB-MI-03208 Channel 4 Functional Test, Reactor Coolant Pump Monitor to SFRCS and RP !

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DB-SC-03059 Boric Acid Flow Path Heat Tracing Weekly Test  ;

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DB-SC-03070 Emergency Diesel Generator #1 Monthly Test  !

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DB-SC-03111 Safety Features Actuation System Channel #2 Functional ;

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DB-SP-03382 Boron Injection Flowpath Monthly Valve Verification l On July 13,1993, at 5:10 a.m., the licensee isolated one of the two j technical specifications (TS) required boron injection flowpaths to perform maintenance on MU152, " Batch Totalizer Inlet Isolation Valve". q An alternate flowpath was established to satisfy the TS,-and no limiting '

condition for operation (LC0) entry was mad ,

In response to questions raised by the inspectors about the adequacy of .

the isolation boundary for the MU152 work, the licensee determined  ;

applicable TS criteria for the alternate flowpath were not satisfie l

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TS 4.1.2.2.a required the boron injection flowpath piping be verified to j

[ be equal to or greater than 105 degrees Fahrenheit ( F). Approximately ~

l 200 feet of the heat traced portion of the alternate flowpath from the >

l concentrated boric acid system was not verified greater than or equal-to

105 F prior to its use. Consequently, since the alternate flowpath

could not be considered operable, when the normal flowpath was isolated, j

! the licensee unintentionally entered LC0 3.1.2.2, which required  !

i remedial action within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The licensee retroactively entered LC0 l

3.1.2.2. prior to exceeding the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> !

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The apparent cause of the event was procedure inadequacy. The operators utilized surveillance procedure 08-5C-03059, " Boric Acid Flowpath lieat Tracing Weekly Test", to verify that the TS requirements were met for ;

the alternate flowpath. The purpose of the procedure stated that .he ;

procedure verified that the boron injection flowpaths wera operable per '

TS 4.1.2.2.a. The operators concluded, based on a review of the current !

heat trace surveillance data, that the alternate flow path was operable, !

and the TS LCO was not applicable. However, the procedure did not verify operability of all the heat tracing on the alternate run of pip The licensee subsequently determined that the temperature of the  ;

alternate flowpath piping was greater than TS minimum requirements

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during the period. Maintenance was completed and the normal flowpath established on July 14, at 12:19 p.m., and the LCO was exite The licensee generated a Potential Condition Adverse to Quality Report to document the event. Changes were initiated to the heat tracing '

procedure to include all the alternate flowpaths. The inspectors reviewed the changes, which appeared adequat Because the procedure was inadequate for verifying heat tracing  :

operability, use of surveillance procedure DB-50-03059 to verify TS :

requirements for the alternate boron injection flowpath was a violation !

of 10 CFR Part 50, Appendix B, Criterion V. Specifically, adequate ;

acceptance criteria, to demonstrate operability of the alternate

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flowpath, an activity affecting quality, were not included. Based on the alternate flowpath heat traced piping being greater than 105 F and the licensee's prompt action to revise the surveillance procedure, the violation met the criteria specified in Section VII.B of the " General Statement of Policy and Procedures for NRC Enforcement Actions," and was ;

not cite This item is close '

No deviations were identified in this area; however, one non-cited violation was identifie ; Maintenance (62703J *

Station maintenance activities of safety-related systems and components !

were observed and/or reviewed during the inspection period to ensure that they were conducted in accordance with approved procedures,  !

regulatory guides, and industry codes or standards, and in conformance with technical specification The following items were considered during this review: -the limiting 6 conditions for operation (LCOs) were met while components or systems l were removed from service; approvals were obtained prior to initiating- ;

the work; activities were accomplished using approved procedures and .!

were inspected as applicable; functional testing and/or calibrations l were performed prior to returning components or systems to service; !

quality control records were maintained; activities were accomplished by l

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qualified personnel; parts and materials used.were properly certified; radiological controls were implemented; and fire prevention controls were implemente j Maintenance work orders (MW0s) were reviewed to determine status of outstanding jobs and to assure that priority was assigned to safety- i related equipment maintenance which may affect system performanc l The following maintenance activities were observed and/or reviewed: i

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Valve Diaphragm Leaks (MWO 1-93-0325-00)

- Output Voltage Not Steady - DBC2PN (MWO l-93-0257)

Preventive Maintenance ME09201 - DBC2PN (MWO 3-93-0697-01)

- Replace Valve CV624B (MWO 7-93-0328-01)

- Troubleshoot and Repair Safety Features Actuation Channel #2 :

(MWO 7-93-0363-01)

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Weld Repair Piping Near CW840 (MWO l-93-0839-00)

- Replace and Calibrate Transducer for Emergency Diesel Generator #1 Local Wattmeter and Voltmeter Indicators (MWO l-92-0495-00) '

- High Pressure Injection Train #2 General Maintenance During a tour of the facility by the NRC Region III Regional -

Administrator and resident' inspector on July 26, 1993, the control ;

cabinet for the #1 emergency diesel generator (EDG) was found open and unattended. The inspector spoke to the shift manager who determined that the workers temporarily left the work area while performing :

maintenance. The maintenance activity involved working on local indication of watt and voltage meters and was considered not to render .

1. 1 EDG inoperable since it could still perform its safety function >

without local indication available. However, with the cabinet doors open, the rigidity of the cabinet during a seismic event was in question. The licensee documented this event on a potential condition adverse to quality report (PCAQR 93-0371), which should address corrective actions and reportability. The inspectors spoke with the i maintenance manager about this event. The maintenance manager noted that the analysis of.the cabinet, performed subsequent to finding the ,

cabinet door open, determined that the cabinet was rigid enough with the doors open to withstand a seismic event. However, the generic concern !

of leaving cabinet doors open and unattended was still being pursued at the end of the inspection period. This item is an inspection followup item (346/93013-03(DRP)), pending review of the licensee's followup ,

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No violations or deviations were identified in this are s Manaaement Site Visits and Meetinas (307021 On July 26 and 27, 1993, the NRC Regional Administrator for Region III, toured the facility and interviewed licensee directors and manager Items discussed included the site reorganization plan and other topics i of mutual interes l

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, Inspection followun items i Inspection followup items are matters that 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. Inspection followup items disclosed during the inspection are discussed in paragraphs 4.a. , 4.b. , and . Non-cited Violations The NRC uses the Notice of Violation to formally document failure to l meet a lega,1y binding requirement. However, because the NRC wants to encourage and support licens' e's initiatives for self-identification and I correction of problems, the NRC will not issue a Notice of Violation if the requirements set forth in 10 CfR Part 2, Appendix C, Section Vll. or Vll.B.2 are met. Violations of regulatory requirements identified l during the inspection for which a Notice of Violation will not be issued '

are discussed in paragraphs 3 and !

10. [ lit Interview The inspectors met with licensee representatives (denoted in paragraph 1) throughout the inspection period and at.the conclusion of the inspection on August 13, 1993, and summarized the scope and findings' :

of the inspection activities. The licensee acknowledged the finding ; After discussions with the licensee, the inspectors-determincd there was no proprietary information contained in this inspection repor ;

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