IR 05000346/1997008

Insp Rept 50-346/97-08 on 970527-0707.Violations Noted.Major Areas Inspected:Operations,Maint,Engineering & Plant Support

ML20217C655
Person / Time
Site:	Davis Besse
Issue date:	09/23/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20217C640	List: IR 05000346/1997008 ML20217C636 ML20217C643
References
50-346-97-08, 50-346-97-8, NUDOCS 9710020005
Download: ML20217C655 (17)

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U.' S. NUCLEAR REGULATORY COMMISSION-V REGION lil

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Docket No:- 50-346

Ucense No:  !

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Report No:

50 346/97008(DRP)

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Toledo Edison Company

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Facility:

Davis-Besse Nuclear Power Station

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5503 N. State Route 2

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Oak Harbor, OH 43449

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Dates: May 27 - July 7,1997

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Inspectors' S. Stasek, Senior Resident inspector K. Zellers, Resident inspector Approved by

Geoffrey C. Wright, Chief Reactor Projects Branch 4

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9710020005 PDR 970923 G ADOCK 05000346 PDR

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. __ _ _ . _ _ - . _ _ _ _ _ . EXECUTIVE SUMMARY Y

Davis-Besse Nuclear Power Station NRC Inspection Report No. 50-346/97008(DRP)

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Th!s inspection included aspects of licensee operations, maintenance, engineering, and plant support. The report cov6.'s a 6 week period of resident inspectio Operations

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Unit restart activiti'as conducted at the beginning of the inspection period were

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accomplished in accordance with approved procedures (Section 01.1).

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No problems were identified with the meterial condition of engineered safety features

and important to safety systems (Section 02.1).

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The inspectors identified a violation of administrative requirements for r procedure

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change to address annual mayfly infestation. The inspectors also identified weaknesses in the licensee's process for controlling updates to software for

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computerized operator rounds sheets (Section 03.1).

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The inspectors identified a violation involving operators who used two " action plans," rather than reviewed and approved procedures, to drain systems covered by Technical Specification 6.8.1.a (Section 03.2).

Maintenance

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The inspectors observed strict adherence to procedures during tne performance of

" surveillance testing and maintenan:e activities. Tested systems were verified to perform in accordance with the Updated Safety Analysis Report (Section M1.1 A number of equipment spaces vcere rasceptible to rainwater intrusion. However, no immediate operability concerns were identified (Section M2.1).

Engineering

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A licensee evaluation of a worst case pipe rupture in the circulating wate- (CW)

system identified that a potential loss of all feedwater, including auxiliary feedwater, could result from a flood caused by a CW pipe break. The licensee took appropriate corrective actions, but the timeliness of some of these actions was of concern (Section E2.1).

Ptar.t Support

Onsite emergency response facilities were well maintained and in a good state of

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readiness (Section P2.2).

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- Rooort Details

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3 Summary of Plant Status

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l At the beginning of the inspection period, a plant startup was in progress following '

completion of a forced outage to replace the main transformer. The unit operated at full t,

power throughout the rest of the inspection period.-

l. 'Ooerations ll 01 Conduct of Operations

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01.1 General Comments (71707)

The inspectors conducted walkdowns of the control room throughout the inspection period. Operating activities were cbserved, logs and clearances reviewed, and

[j . . oparators interviewed. The inspectors determined that unit restart activities, overall,

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' wece appropriately accomplished in accordance with approved procedure Adn inistrative procedures and operating procedures were adequately utilized. Shift

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briefe continued to be effectively used to communicate necessary operational

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p information to oncoming shifts. However,' inspector review of a previously identified ,

issue involving the use of " action plans" concluded that action plans had been inappropriately used instead of approved procedures for two activities (reference *

. Section 08.1),

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? 02 Operational Status of Facilities and Equipment

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02.1 System Walkdowns (71707)

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F ' The inspectors walked down the accessible portions of the following engineered safety features (ESF) and important to-safety systems during the inspectiors period:

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Auxilia y Feedwater (AFW) System - Trains 1 and 2 1_ -

-- Component Cooling Water Trains 1'and 2

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Service Water System - Trains 1 and 2 j --

Motor Driven Feedpump

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Emergency Diesel Generators (EDGs) # 1 and 2 L -

Hydrogen Dilution System - Trains 1 and 2 -

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- Emergency Ventilation System - Trains 1 and 2, L.

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Control Room Emergency Ventilation System - Trains 1 and 2

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Containment Spray System - Trains 1 and 2 I- -

High Pressure injection System - Trains 1 and 2

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Low Pressure injection System - Trains 1 and 2

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Class 1E High Voltage Switchgear - Trains 1 and 2 j- -

Class 1E Low Voltage Switchgear - Trains 1 and 2

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Spent Fuel Pool Cooling - Trains 1 and 2

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- No substantive concerns were identified as a result of the walkdowns. System-lineups and flow paths were verified to be consistent with plant drawings and the i

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Updated Safety Analysis Report (USAR). All associated equipment was found to be ;

6 in good material condition. All pump and motor fluid levels _ wore within their normal

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bands.-' A few minor oil and fluid leaks were noted, Local and remote controllers were properly posltionM and associated instrumentation and indication appeared to be functionir g ce%ctl _03 - Operations Procedures and Documentation i

. 03.1 Revisino Operations Shiftly Rounds Sheets

a.-- Inspection Scope (71707) '

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On June 16,1997, the inspectors reviewed the preparation and implementation of a

' change to Procooure DB-OP-06913, " Seasonal Plant Preparation Checklist." The change was made to include additional operator actions and equipment checks so'

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that, in part, safety-related support equipment would not be made inoperable due to

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I mayfly fouling during the annual mayfly infestation. The procedure change and _

associated revised operator rounds had been issued for use three days prior to the

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[ inspectors' review.

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!- . Observations and Findinos

!. The inspectors noted that the implementation of the procedure change actually j-involved a two tier prec:.at. The first tier in the process was the development and

, processing of the revisic , to DB-OP-06913 using station administrative procedure j NG-NA-00115, " Control of Procedures." However, once issued, much of the procedure change was not directly used by operators during the conduct of their shiftly rounds because the oparators u',ed hand held computers, not hard copies of DP-OP-06913. Once DB-OP-06913 was revised, the operator actions and inspections specified in Attachment 5, " Operators Round Checklist for Mayfly infestation," of DP-OP-06913 were then translated to the operators' computerized

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rcunds sheets (computer software was rewritten) using the guidelines of administrative procedure DB-OP-00005, ' Operator Logs and Rounds."

The inspectors noted that DB-OP-00005 did not specify that revisions to software for performing rounds be second checked against the original procedure change prior to use. When this was brought to the attention of operations personnel, they agreed

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revised to include the second check step in the process for changing the operator rounds sheet The inspectors also obserhed that a note in Attachment 5 of DB-OP-06913 specified:

that only one normal control room chiller was to be run at a time to prevent both units becoming nonfunctional due to fouling. -Inspector review determined that this

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restriction was not consistent with the requiroments of operating procedure

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DB-OP-06522, " Chilled Water System." Procedure DB-OP-06522 was subsequently '

3 revised to make it consistent with DB-OP 0691 As a result of inspector questions, operations management found that the revision to -

the computerized rounds sheet software for mayfly infestation at tions had been ,

issued for use on June 13,1997, without signature approval auth'.,rity. Although issued and available for use, the revision had not yet been used in the field since mayfly infestation had not yet started, issuing this revision to the computerized rounds sheets for use without the prior approval of the operations superintendent, or t designee, as required by administrative procedure DB-OP-00005, Revision 6,

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' Step 6.4.3.d is considered a violation (50 346/97008 01(DRP)) of 10 CFR Part 50, Appendix B, Criterion V Conclusions Weaknesses in the preparailon and issuance of the procedure change to address annual mayfly infestation were identified. A violation of NRC requirements occurred when the procedure change was issued without appropriate management approva .2 Use of Action Plans (71707) . Inspection Scope The inspectors reviewed the use of " action plans" by operators draining portions of

. systems covered by Technican Specification 6.8. Observations and Findinos At the end of the previous inspection period, the inspectors noted that control room logs referred to operators using two " action plans" to partially drain the volume

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between containment isolation valves associated with the pressurizer auxiliary spray line and the reactor coolant drain line (Inspection Report 50 346/97006). The action plans specified particular steps required to partially drain the lines, including verification of equipment lineups and the manipulation of plant equipmen At the time, requirements for the generation, control, and execution of action plans consisted of a plant engineering policy, PE 05. This policy provided guidance to plant engineering personnelin the preparation of plant engineering action plan However, the subject action plans were prepared, reviewed and implemented by *

Operations Department personne Technical Specification 6.8.1.a required that written procedures be established, implemented and maintained covering the activities referenced in the applicable procedures in Appendix A of Regulatory Guide 1.33 (November 1972) Regulatory Guide 1.33 (Safety Guide 33), Appendix A, specified thet instructions for energizing, filling, venting,' draining, startup, shutdown and changing modes of operations were to be prepared, as appropriate, for certain systems. The associated listed systems S

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y Included the containment integrity system as well as the pressurizer pressure and spray control systonis. As such, activities performed on both systems, including system venting or draining, required the use of approved procedure Station administrativa procedure NG NA-00115, Revision 02, " Control of Procedures," established the methods and requirements for the preparation, processing, and control of station procedures, including:

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Step 6.1.9, which required that the approval authority for non administrative plant procedures be delegated only to individuals holding or acting in positions no lower than one management position below the plant manage Step 6.3.2.e. which required that a review of interfacing documents such as the Technical Specificatio.~s, USAR, Nuclear Quality Assurancr> Manual

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drawings, procedures, etc., be perfoimed to ensure the procedure was in compliance with regulatory requirements and to determine which documents would require alteration to be campatible with the procedure or procedure chang .

Steo S.3.2.k, which required that cross-disciplinary review organizations conducte be identified and that those cross-disciplinary reviews be

Step 6.3.7, which required that a qualified reviewer, who was nut the procedure preparer, review the final procedure packag The inspectors concluded that the activities of draining the containment penetra lines required properly reviewed and approved procedures. Neither o' the SJ

" action plans" incorporated the isviews and approvals discussed above, and wer therefore not procedures. Consequently, use of the " action plans" for these The inspectors reviewed other operator activities durin .

did not identify any additional examples of the use of " action plans."

At the end of the inspection period, the licensee was in the process of estab more specific guidelines for the preparation and use of action plans. Pending completion of that effort, all action plans prerNd onsite were to undergo detailed management review prior to their implementation to ensure that the use of an approved procedure was not require '

c, Conclusions The inspectors identified a violation involving operators who used two " action plans," cather than reviewed and approved procedures, to drain systems co Regulatory procedures wereGuide 1.3 identifie No additional examples of the use of " action plans"in lie I

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1, Miscellaneous Operations issues (71707,92700,92901). b'

08.1 (Closed) Unresolved item (50 346/97006-02(DRP)): Pre-startup check //st referenced i deleted TechnicalSpecification (TS) requirements. Plant procedure DB-OP-06911,

" Pre-Startup Checklist," Revision 1, Step 7.14.1, specified, in part, t' hat the plant engineering manager sign that surveillances ennducted to meet specified TS surveillance requirerrents were current prior to plant entry into operational Mode 2.

' Engineering department personnel had signed the pre-startup checklist step as i

complete; however, two of the referenced TSs had previously been deleted via license amendment 205 without DB-OP-06911 being revised.

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Based on a subsequent review, the inspectors determined that the actual engineering reviews that had been completed to support the Mode change were appropriate, and that the deletion of the two TS had not adversely impacted the adequacy of the pre-startup checklist. The inspectors concluded that the failure to note that two of the

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referenced TS su, ,illances had been deleted was a minor matter of inattention to l_

detail that did not constitute a violation of NRC requirements. This item is closed.

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08.2 [ Closed) Unresolved item 50-346/97006-04(DRP): Controlof Action Piens. This item *is discussed in Section O3.2 of this report. A violation was identified and this item was-closed.

'- 08.3 (Closed) License Event Report (LER) 50-346/97-010-00: Reactor Trip Due to Main TransformerDeluge System Actuation. This LER described a reactor trip that occurred

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" on May 4,1997, due to an inadvertent transformer deluge system actuation and resultant phase-to-ground flashover and generator / turbine tri This event was documented in NRC Inspection Report 50 346/97006. The licensee determined the most probable root cause of the transformer deluge initiation was a trip of

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a temperature sensor that occurred at a lower than anticipated main transformer

' temperature. All temperature sensors associated with the main transformer were subsequently replaced with a different type sensor, in addition, the licensee was reviewing temperature sensors associated with otherlarge transformers onsite to

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determine whether additional sensor replacements were necessary. The inspectors concluded that the licensee's corrective actions were appropriate and this item was closed.

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11. Maintenance

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M1 Conduct of Maintenance I

M1.1' Maintenance and Surveillance Activities (61726)(62707)

- The following maintenance work orders (MWOs) and surveillance testing activities j were reviewed during the inspection period:

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MWO 1-951018-00 g Auxiliary Feedwater IAFW) #1 Trip Throttle Valve i TTV1 Position Indication Adjustment

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MWO 3 97-0944-01 SW 1383 VOTES Testing MWO 3 97-1700-01 AFW #1 Governor and TTV Lubrication MWO 7-97-0565-01 AF 3870 Position Indicating Light Socket Replacement DB-MI-03212

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Channel Functional Test of SFRCS ISteam and Feedwater Rupture Control Systeml Actuation Channel 2 Logic for Mode 1

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DB-M1-03014 Channel Functional Test of Reactor Trip Breaker C RPS 1 Reactor Protection System) Channel 4 Reactor Trip Module Logic, and ARTS lAnticipatory Reactor Trip System] Channel 4 Output Logic DB-MI-03201

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Channel Functional Test and Calibration of SFRCS ACH

lactuation channel) 1 Pressure inputs PS 36898, PS-3689D, PS 3689F, PS 3689H, PS-3689K, PS-3689L, PS-3689M, and i

PS-3689N.

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The inspectors noted that test procedures were followed during the performance of surveillance testing, Good reader / worker practices were observed in all cases. Test deficiencies, when identified, were appropriately documented and dispositione Entries int * TS action statements were recognized, appropriately logged, and followed. Tested systems were verified to perform in accordance with USAR requirements.

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Maintenance activities reviewed were conducted in accordance with approved procedures and regulatory requirements. Work activities on safety-related equipment were adequately scheduled and coordinated to minimize out of service time Maintenance workers were properly tralned and knowledgeable of the equipment being worked on, Maintenance work order instructions and soquencing were properly adherert to in all case M2 Maintenance and Material Condition of Facilities and Equipment M2.1 _ Rainwater Intrurion into Equipment Spaces ' inspection Scope (71707)

The inspectcrs walked down the service water tunnel, the intake structure, the emergency diesel generator rooms, and the high voltage switchgear rooms during a heavy rainstorm on June 21,1997, equipment spaces had occurre to determine whether rainwater inleakage to

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Service Water Pump #1, a safety-related component located in the intake structure, was observed to be exposed to rainwater in leakage through an overhead ventilation intak Water was entering the ventilation intake box due to the high wind. This water was dripping on top of the pump motor and was flowing down tha sides of the motor air intake louvers. Some of the water droplets were then being drawn through the louvers into the motor. Operations personnel and the inspectors independently concluded that there was no immediate operability concern; however, the inspectors were concerned about possible long term pump degradatio The inspectors observed that an emergency battery light located on the east wall of the north end of the service water tunnel was wetted by an approximstely one gallon per minute stream of water. The source of the flow appeared to be the junction of the tunnel roof and the intake structure.

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The inspectors observed approximately 10 gallons of rainwater on the floor of the Number 1 emergency diesel generator (EDG) room, with about 1/4 inch of standing water in contact v;ith EDG Control and Relay Cab; net C3615 and about 2-1/2 inches of water in the vicinity of a floor drain. The combination of strong' winds and rain impacting on the EDG room access door verticallouvered surfaces appeared to have resulted in rainwater being forced into the room through small openings and gaps. A 2 inch high lip around the floor drain prevented water drainage, causing the l

accumulation. The inspectors sub,sequently examined the internal configuration of the EDG control cabinet and determined that the observed water levels would not have adversely affected operation of the enclosed electrical circuitr The inspectors had not completed review of the EDG room floor drain lip design and

- installation at the conclusion of the inspection period, Additionally, a larger sample of plant areas potentially vulnerable to rainwater Intrusion will be inspected. Pending completion of inspector review, this matter is considered an inspection follow-up item (50 346/97008-03). Conclustons A number of equipment spaces were found to be susceptible to rainwater intrusio However, no immediate operability concerns were identifie M8 Miscellaneous Maintenance issues (92902) ,

M (Closed) Violation (50-348/96002-04tDRP)); /noperable spent fue/ pool (SFP)

emergency ventilation system (EVS). The violation occurred when maintenance was conducted on a nonsafety-related ventilation system ductwork that, because of its location in the SFP EVS negative pressure boundary, adversely affected the capability of the system to draw the design negative pressure. Corrective actions included labeling the subject ductwork as a negative pressure boundary and revising procedures on work orders to include a tie between the physical location of

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g equipment to be worked on and potential effects on other nearby equipment and structure MB.2 (Closed) Violation (50-346197004-02(DRP)h EDG Undervoltage Relay functional Testing Not Performed within the Frequencies Required by TS. The licensee subsequently scheduled the relays to be functionally tested monthly in accordence with the TS surveillance requirements. When tested, all relays performed satisfactorily,

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M8.3 (Closed) LER 50-346196-00*3-00: Discrepancy in Surveillance Requirements for the Testing of Absorbent Matel la/In the EVS. This LER described a minor, non-technical

- issus. Inspector follow-up did not identify vy additional concerns beyond those described in the LE M8.4 (Closed) LER 50-346195-002-00: Terminal Nuts Missing From Power Supply Leads in Cabinet C3629. The inspector follow up did not identify any additional concems beyond those described in the LE M8.5 (Closed) LER 50-346/97-009-00: Safety Features Actuation System Sequence Logic Channels Survell/ance Testing. This LER was discussed in inspection Report 50-346197004 and Section M8.2 of this report.

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lit. Engineerina E2 Engineering Support of Facilities and Equipment E Circulatina Water (CW) System Pipe Rupture Analysis Inspection Scope (37551)

The inspectors reviewed licensee follow-up actions relating to Potential Condition Adverse to Quality Report (PCAOR) 95-0849 initiated on October 4,1995, which documented a concern with a postulated pipe rupture in the CW system, Observations and Findings The originallicensing basis for intemally initiated flooding at Davis-Besse evaluated only a double-ended rupture of the CW piping at the expansion joints at the inlet to'

the main condenser. This size break was considered to bound other possible CW pipe break To mitigate a CW expansion joint rupture, the licensee had installed pressure switches on the discharge piping from each CW pump. The pressure switches were set to trip the pumps when a low pressure condition corresponding to the expansion joint rupture was sensed. However, this engineering solution did not protect the f acility from flooding caused by line breaks smaller then that use to determine the

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L discharge pressure switch set-points. - The smaller break size would allow the CW pumps to continue to run, the pressure reduction not being great enough to trip the -

pressure-the areas. switches, thereby continuing to force flow through the pipe break flooding

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Based upon a reevaluation of this slightly smaller CW pipe break size performed subsequent to plant licensing, the licensee determined that flooding of the turbine building could occur that would cause a loss of all main feedwater as well as a loss of auxiliary feedwater {AFW), This event would require the use of primary side feed-and-bleed operation to cool xhe reactor cor Potential corrective actions were developed in late 1995 and a contractor was retained to perform a probabilistic safety assessment (PSA). The results of the PSA were provided to the site in May 1996 and indicated that the time line from initial -

pipe break to a loss of all feedwater, including AFW, was approximately six minutes

in the worst case. The PSA concluded that this one accident sequence increased it e overall plant core damage frequency by approximately 25 percent, from 6.6E to 8.2E '.

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At the end of the inspection period, the licenseo was in the process of installing a L series of level switches in the main condenser pit to provide a direct automatic trip of I the CW pumps upon sensing a flooding condition. Interim measures the licensee implemented included

1) requiring an operator be stationed at the condenser pit when CW pumps were started or stopped,2) conducting an inspection of the CW

. expansion joints to assess their material condition, and 3) taking actions to improve the material condition of the CW discharge valves by modifying the valve operators

, to better assure their capability to close if neede in addition, following discussions with the NRC late in the inspection period, the

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licensee instituted additionalinterim compensatory measures to give operators more time to respond to the postulated event, as well as to provide procedural guidance and training for the' operators to aid them in their response actions. Specifically, the turbine building roll up door was to be maintained at least three feet open to pmvide

an additional flow path for the water to exit the building, thereby giving opesators additional time to take mitigating action. Also, operations abnormal procedure DB-OP-02517, " Circulating Water Pump Trip / System Rupture" was revised to incorporate "immediate action" steps (those actions operators have to memorize

- versus being able to reference in a procedure) to quickly secure the CW pumps when symptoms of flooding warrant. The operators were also trained on the procedure '

change as well as the PSA conclusions and expected flooding times for the acciden .The inspectors were concerned with the time which elapsed Isetween issuance of the PSA in May 1996 and the implementation of interim and permanent corrective j

actions in 1997. The inspectors were also concerned that plant management and operations department personnel did not appear to be fully cognizant of the issue until the NRC became involved. At the end of the inspection period, the inspectors

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a condition adversa to quality as defined in 10 CFR Part 50, Appendix B. Pending .. j completion of this NRC review, this matter is considered an unresolved item

(50-346/97008 04(DRP)).

" . Con, clusions A licensee evaluation of a worst case pipe rupture in the CW system identified that a potential loss of all feedwater, including auxiliary foodwater, could result from a flood caused by a CW pipe break. The licensee took appropriate corrective actions, with perio the timeliness of those actions under NRC review at the end of the inspection E8 Miscellaneous Engineering issues (92903)

, E (Closed) Inspection Follow up Item (50 346/95010-03(DRP)): USAR discrepancy -

inconsistent RCS hotleg volumes. RCS hot leg volumes could have been used in calculations for determining plant operating limits, inaccurate volumes could have adversely affected those calculations. After investigation, the inspectors could not determine that inconsistently documented RCS volumes affected any operational

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- parameters of limits. The issue appeared to be an administrative matter only.-

E (Closed) Inspection Follow up item (50-346/95010-09(ORPil: USAR discrepancy -

capability oflategrated controlsystem (ICS) unclear. Tbe inspectors had identified apparent discrepancies in the USAR description of the ICS. The licensee subsequently the ICS system. revised Section 7.7.1.2 of the USAR to better describe the capability of E8.3 (Closed) Unresolved item (50-346/96002-08(DRP)): T. reduct/on action plan. -

During review of the licensee's T. reduction action plan, the inspectors identified

- concerns with how the action plan was being implemented. As discussed in Section 08.1 of this report, the control over the preparation and implementation of

" action plans" was determined to be inadequate. As of the end of the inspection

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. period, the licensee was in the process of developing additional guidelines for action plan plans,"

The new program was intended to completely restructure the use of " action E8.4 (Closed) LER 50 346/95-001-00: Potentia //y Non-Conservat/ve LOCA (Loss Of Coolant Accident] Analysis Due to Modeling Errors. This LER dealt with errors in the Babcock & Wilcox supplied accident analysis for the plant. The inspector fc4 tow-up

- did not identify any additional concerns beyond those described in the LE _

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1 IV. Plant Support R1 Radiological Protection and Chemistry (RP&C) Controls

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R1.1 General Comments (71750)

During the inspection period, the inspectors performed frequent walkdowns of the l radiologically restricted area (RRA; and observed work activities in the RRA. The I inspecte s determined that radiological postings and labels were in accordance with NRC regulations and plant procedures. A sample of doors providing accass to high radiation areas (> 1000 mrem /hr) were verified t.o be locked with their associated keys adequately controlled. Personnel performing work in the RRA adhered to radiation program requirements and good practice R8 Miscellaneous RP&C issues (92904)

R (Closed) Unresolved item (50-346/97006-05(DRP)): Outdated LocalRadiological Survey Maps. The inspectors had identified outdated local radiological survey map The irspectors determined that there were no procedural requirements necessitating the placement of local survey maps. The licensee's program did not require local survey maps. Subsequently, the licensee updated the maps with current survey

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informatio P2 Status of Emergency Preparedness Facilities, Eqdpment, and Resources P2.2 Walkdowns of Emergency Response Facilities (71750)

The inspectors walked down selected onsite emergency response facilities during the inspection period. The technical support center, emergency control center and operations support center were examined and all facilities appeared to be well maintained and in a gvod state of readiness, No concerns were note P8 Miscellaneous Emergency Planning (EP) lasues (92904)

P (Closed) Inspection Follow-up Item (50-346/96006-07(DRPil: OperationalSupport Center (OSC) Computer Terminalinoperability. The inspectors had noted that the computer terminals in the OSC were not fully functional during two previous emergency preparedness (EP) drills. Subsequently, the plant upgraded the associat6d equipment and further ensured that computer te minals in the OSC would be available for use during an actual event. The inspectors independently verified that the OSC computers were functional during the June 4 EP exercis F8 Miscellaneoas Fire Protection issues (92904)

F (Closed) Unresolved item (50-346/97004-04(DRPI): Qual /// cation of Fire Door Armor P/aring. The licensee determined that the armor plating currently installed on several

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plant fire doors to function as kick-plates was of a material type and gauge that had ( not been approved by Underwriters Laboratories (UL). Two of the doors,309 and 406, were designated to meet 10 CFR Part 50, Appendix R requirements. The licensee determined that the screw fasteners used to secure the sheeting to the doors were not approved by Under Writers Laboratory (UL). '

O. ,e identified, the licensee declared the subject doors inoperable and initiated hourly fire watches as required by the plant fire protection program. The licenses contacted UL to pursue possible qualification testing of the as found door configurations. UL indicated that the mirror insulation sheeting used for the kick-plates would probably pass the required fire testing. The inspectors concluded that the structural integrity of tho doors remained unchanged and the doors would adequately function as 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire barriers if neede Based upon the minimalimpact of the unauthorized kick-plate material, this issue is being treated as a non-cited vio!ation 150 346/97008-05(DRPI) of 10 CFR Part 50, Appendix R. Section Ill.G.2.a, consistent with Section IV of the NRC Enforcement Polic .

V. Management Meetinos X1 Exit Meeting Summary The inspectors presented the inspection results to mambers of licensee management at the conclusion of the inspection on July 7,1907. The licensee acknowledged the .

findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

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PARTIAL UST OF PERSONS CONTACTED ,

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Ucensee J. K. Wood,-Vice President, Nuclear

J. Hi Lash, Plant Manager --

R. E. Donnellon, Director, Engineering & Services j _T. J.' Myers, Director, Nuclear Assurance L M. Dohrmann, Manager, Quality Services

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. J. L. Michaelis, Manager, Maintenance .

J. L. Freels, Manager, Regulatory Affairs M. C. Beier, Manager, Quality Assessment .

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H W. J. Molpus, Manager, Nuclear" Training J. W. Rogers, Manager, Plant Engineering

. F. L Swanger, Manager, Design Basis Engineering INSPECTION PROCEDURES USED

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IP 37551: .. Onsite '"agineering IP 61726: . Surveillance Observations IP 62707: - Maintenance Observation IP 71707: - Plant Operations IP 7( F50: . Plant Support Activities IP 92700: .Onsite Follow-up of Written Reports of Nonroutine Events at Power Reactor Facilities IP 92901: Follow-up - Plant Operations e

- IP 92902: Follow-up - Maintenance IP 92903: - . Follow-up - Engineering IP 92904: Follow-up'- Plant Support ITEMS OPENED, CLOSED,'AND DISCUSSED

Opened 50-346/97008-01tDRP) VIO Rounds Sheets Revised Without Operations Superintendent Approval .

s 50-346/97008-02DRP) VIO Inadequate Control of Action Plans 50-346/97008-03DRP) IFl Rainwater intrusion into Plant Equipment Spaces '

50-346/97008-04DRP)

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URI Turbine Building Flooding Analysis 50-346/97008-05DRP) NCV Fire Door Armor plating

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50-346/97006-04(DRP) URI Control of Action Plans 50 346/97006 02(DRP) URI Pre-startup Checklist Referenced Two Deleted Technical Specification Sections

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50 346/97 010 00 LER Reactor Trip Due to Main Transformer Deluge System ( Actuation 50 346/96002 04tDRP) VIO Inoperable Spent Fuel Pool Emerpncy Ventilation System 50 346/97004-02(DRP) VIO Emergency Diesel Generator Undervoltage Relay Functional Testing Not Performed Within the Frequencies Required by Technical Specifications 50 346/96-003 00 LER Discrepancy in Surveillance Requirements for the Testing of Absorbent Materialin the EVS 1 50 346 95 002 00 LER Terminal Nuts Missing From Power Supply Leeds in Cabinet C3629 50 346 97-009 00 LER Safety Features Actuation System Sequence Logic Channels Surveillance Testing 50-346 9501n-03tDRP) IFl USAR Discrepancy -Inconsistent RCS Hot Log Volumes 50 346/95010 09(DRP) IFl USAR Discrepancy . Capability of Integrated Control System Uncleat 50 346/96002 08(DRP) URI T Reduction Action Plan l

50 346/95 001 00 LER Potentially Non-Conservative LOCA Analysis Due to Modeling Errors -

50 346/97006 05(DRP) URI Outdated Local Radiological Survey Maps 50 346/96006 07(DRP) IFl Operational Support Center Computer Terminal inoperability 5048/37004 04tDRP) URI Qualifiestion of Fire Door armor plating 50 346/97008 05(DRP) NCV Fire Door Armor plating

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LIST OF ACRONYMS AND INITIALISMS ACH Actuation Channel AFW Auxillary Foodwater ASTM American Society for Testing and Materials CDF Core Damage Frequency CFR Code of Federal Regulations CW Circulating Water DSS Diverse f cram System EDG Emvigency Diesel Generator EP Emorgoney Planning

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ESF Cngincored Safety Feature EVS Emergency Ventilation System IFl Inspection Follow up item IR inspection Report LER Ucensee Event Report LOCA Loss of Coolant Accident MWO Maintenance Work Order NRC Nuclear Regulatory Commission OSC Operat!ons Support Center PCAOR Potential Condition Adverse ^o Quality Report PDR Public Document Room RCS Roactor Coolant System RP Radiation Protection RPS Radiation Protection System SFAS Safety Features Actuation System SFP Spent Fuel Pool SFRCS Steam and Foodwater Rupture Control System TS Technical Specification UL Underwriters Laboratories USAR Updated Safety Analysis Report VIO Violation

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