IR 05000346/1997011

Insp Rept 50-346/97-11 on 970818-0929.Violations Noted. Major Areas Inspected:Operations,Maint,Engineering & Plant Support

ML20198P101
Person / Time
Site:	Davis Besse
Issue date:	10/31/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20198P096	List: IR 05000346/1997011 ML20198P092 ML20198P098
References
50-346-97-11, NUDOCS 9711060274
Download: ML20198P101 (18)

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. i U. S. NUCLEAR REGULATORY COMMISSION REGIONlli

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Dodet No: 50 346 License No: NPF-3 Report No: 50-346/97011(DRP) .

Licensee: Toledo Edison Company Facility: Davis-Besse Nuclear Power Station

Location: 5503 N. State Route 2 Oak Harbor, OH 43449 Dates: August 18 - September 29,1997 Inspectors: S. Stasek, Senior Resident inspector K Zellers, Resident inspector C. O'Keefe, Resident inspector, Fermi Approved by: Geoffrey C. Wright, Chief, Reactor Projects Branch 4

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9711060274 971031 0 PDR ADOCK 05000346 G PDR h

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, EXECUTIVE SUMMARY

Davis-Besse Nuclear Power Station NRC inspection Report No. 50 346/97011(DRP)

This inspection included aspects of licensee operations, maintenance, engineering, and plant support. The report covers a 6 week penod of resident inspectio .

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Operations

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Control room shift briefs observed during the inspection period effectively communicated operational and equipment status to oncoming personnel to support facility operation

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In general, engineered safety features and important-to-safety systems were verified to be lined up in accordance with the updated safe;y analysis report and plant requirement However, two exception were noted that involved the component coohng water ventilation system (see below) (Section O2.1).

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On bro occasions, the inspectors identified that ventilation equipment associated with the component cooling water system wcs not properly functioning, in one case, a controller was mispositioned, and in the other, recirculation and discharge dampers were found degraded (Section O2.2).

, Maintenance l

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Equipment and supporting systems under test were verified to operate as described in

the updated safety analysis report (Section M1.1).

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The inspectors identified that a calibration of pressure switches in the auxiliary feedwater

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system was performed using bst gauges that were less accurate than required by the surveillance procedure (Section M1.2).

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. Corrective actions relateo to a problem with measuring and test equipment employed in j the aforementioned AFW pressure switch calibration activities that was identifieti in 1995, l were not completely implemented. Specifically, a design calculation, surveillance i procedure, and associated instrument information sheets were to be revised; however, L

only the surveillance procedure had been changed as of this inspection period (Section M1.2).

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!. The inspectors identified an erroneous Technical Specification acceptance limit in a l surveillance procedure prepared to test safety related under voltage relays. Although the l procedure had not yet been issued for use, it had been controlled-use validated prior to

[ inspector review without plant personnel identifying the problem (Section M3.1).

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The inspedors questioned the appropdateness of blocking open the control room access door, a high energy line break (HELB) barrier, for greater than five hours on one occasion. Use of a generic 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> s'Jowed outage time licensee guideline in this case may not have been applicable using the pre 4xisting engineering guidance (Section E2.1).

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Personnel obsetved working in the radiologicaNy restricted area adequatey adhered to radiation protection procedures and practices (Section R1).

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Report Details Summary of Plant Status e

The unit operated at nominally full power throughout the inspection period,

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L doerations 01 Conduct of Operations 0 General Comments (71702)

The inspectors observed operations personnel and control room activities throughout the inspection period. Several cleart.nces [tagouts) ware reviewed and verified to provide adequate protection of equipment and personnel during maintenance activitie Operators referenced applicable annunciator response procedures when neede Overall, the unit log accurately reflected plant conditions and shift activities. Control room personnel were cognizant of degraded material / equipment conditions and evolutions ils progress, Shift briefs effectively communicated operational stabs to oncoming personnel to support operation of the facilit Operational Status of Facilities and Equipment O2.1 System Vlatkdowns (71707)

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

. Emergency Diesel Generator #1

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Emergency Diesel Generator #2

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Decay Heat Removal / Low Pressure injection System - Trains 1 and 2

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High Pressure Injection System - Trains 1 and 2

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Containment Spray System Trains 1 and 2

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Component Cnoling Water System Trains 1 and 2

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High and Low Voltage Switchgear Rooms

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Motor Driven Feed Pump vYith one exception involving the Component Cooling Water room ventilation svstem (roference Section 02.2), the inspectors determined that each system, including necessary support equipment was properiy aligned to support operation as described in the updated safety analysis report. Equipment material condition was excellent 19 ali case .

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O2.2 Component Coolina Water Ventilation Found Ingpfteble on Two Occasions Irnpection Geone (71702)

The inspectors performed walkdowns of the Component Cooling Water pump room ventilation system on August 30 and Geptember 19.

, Observations and Findinog The Compon ut Cooling Water (CCW) pump room ventilation system function is to remove heat generated from the Component Cooling Wate heat exchangers and other system equipment in the pump room due to a design basis accident. The primary source of heat would be retuming water from the Decay Heat Removal heat exchangers to the CCW heat exchangers during the recirculation phase of plant response to a loss of coolant acciden The ventilation system is comprised of two 100 percent capacity trains. Each train is required to be operable for its associated CCW train to remain operable. Each train consists of an intake damper, an exhaust fan, a recirculation damper, an exhaust damper, and associated ducting. Each exhaust fan and intake damper are automatically controlled by a temperature control circuit. Each recirculation and exhaust damper assembly are actuated by a hydra motor and controlled by a separate temperature control circuit. This control circuit serves to modulate the hydra motor so the recirculation and exhaust dampers change position to maintain room temperature at a desired value. The desired value is controlled by a controller that can either be automatically or manually controlled. When the exhaust fan is off, the hydra motor is de-energized anu fails in a position so that the exhaust damper is full open and the recirculation damper is full shu During the inspection, the temperature controller for CCW train 1 ventilation had not been property functioning in automatic, therefore, the controller had been placed in manual mode with its output adjusted to zero percent. Zero percent controller output equated to the exhaust damper being full opun and the recirculation damper being full closed. This ensured maximum cooling to the CCW pump roo On August 30 the inspectors found the temperature controller in manual mode but erroneously set at 100 percent output, thereby maximizing recirculation flow but securing exhaust flow. Operations was informed, and CCW train 1 was dec .ed inoperabl Within one hour, operations personnel determined that the ventilation system was functionin0 as designed and thereafter reset the controller to zero percent as required to consider CCW train 1 operabl The most probable cause of the controller being improperly positioned was human error, The licensee generated PCAQR 971164 to investigate the issue. As of the end of the inspection period, the root cause had not yet been determined. Preliminarily, it appeared that the controller may have been improperly positioned for several day ~

On September 19, the inspectors noted that the CCW train 2 ventilation recirculation damper was about one inch off of its closed seat. The shift supervisor subsequently investigated the situation and found that in addition to the recirculation damper not fully shut, the train 2 exhaust damper was about half closed. As a result, he declared CCW

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train 2 inoperable and requested maintenance assistance to immodiately troubleshoot and repair the proble Maintenance personnel, including supervision and planning personnel, and tr e system engineer immediately responded. They found that the exhaust damper was mispositioned due to a set screw that was not fully engaged between the hyd a motor ;

pillow block and the exhaust damper shaft. This allowed the damper shaft to rotate I independently of the hydra motor actuator arm, causing the damper alignmeM proble Thereafter, the exhaust damper was realigned, the set screw property set, und with the system satisfactorily tested, CCW train 2 was declared operable. The licer,see then generated PCAQR g71244 to document and investigate the problem. A possible root cause was inadequate maintenance during previous preventive maintenance on the damper / actuator. However, as of the end of the inspection period, the licensee had not ,

completed their review nor determined a root caus '

The system engineer determined that having the recirculation damper open one inch did not cause the ventilation system to become inoperable. The ventilation fans had ample cooling capacity and required margins would have only been slightly decreased due to the bypassed air flow. Subsequently, this matter was documanted for resolution and tracking via PCAOR 97125 Conclusions The inspectors (Jentified two instances where CCW ventilation equipment appeared to be inoperable. Licensee evaluation of both instances as well as inspe : tor follow up review were continuing to determine, in part, whether Technical Specifications or other NRC requirements had been violated. Since it had yet to be determined that personnel had improperly operated a CCW ventilation system controller, or if maintenance personnel improperly conducted maintenance on a Component Cooling Water ventilation system exhaust damper, this matter is considered an unresolved item (50-346/97011-01(DRP)).

08 Miscellaneous Operations issues (92700)(92901)

08.1 (Closed) Violation (50-346/96006-01tr*.r1 Three examples of a violation of test contro The first example was for not generating a test deficiency when stroke timing of a valve had to be repeated due to a stopwatch malfunction. The licensee communicated requirements for generating test deficiencies to operations personnel, and new stop watches were purchased. Thereafter, no additional examples of operations personnel not documenting test deficiencies had been noted. Also, the new stop watches were noted to be substantially me.*e reliabl The second example involved an operator performing stroke timing for a containment spray valve from a location other than specified by the surveillance procedure. Location information was previously specified in t procedural note. The inspectors verified that inctructions for performing the stroke timing from the proper locat;on were relocated to the procedure step itsel .

The third example involved a failure to test tho emergency ventilation system (EVS) under suitable environmental conditions. Some negative pressure envelope floor drains were potentially covered with soluble plastic during testing which could have biased EVS l

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drawdown test results. The inspectors verified that the subject test procedures were revised so that all negative pressure envelope floor drains would be checked to ensure they were not covered. Additionally, EVS drawdown testing was successfully performed without soluble plastic installed over the floor drain .2 (Closed) insoection Followuo item (50 346/96010-03 (DRP1): Administrative control of I Low Voltage Switchgear Room (LVSGR) and battery room temperatures. This item involved an inspector concem about the means used to ensure that LVSGR and battery room temperatures were monitored and maintained adequately. The LVSGR ventilation i communicates directly with the battery rooms and provides heating and cooling to both space The inspectors subsequently determined that operations used an installed non-calibrated battery room temperature probe only as an early indicator that battery room temperature was decreasing, with the actus.1 temperature then validated by an equipment operator with a portable calibrated temperature meter. Additionally, when room temperature was below an administrative criteria, an operations policy memorandum required that equipment operators measure the room temperature more frequently, at 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> interval An additional concem that a LVSGR fan was potentially degraded was subsequently reviewed and determined to be operable. However, because the automatic shutoff temperature for the fan was set low, the fan would remain on and provide excessive cooling. This condition required an equipment operator to manually secure the fan. The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> tours by the equipment operators were evaluated to have been adequate to ensure that room temperatures would not decrease to the technical specification temperature limits for the station batteries. Additionally, no actual temperature below 60 degrees (the low temperature limit for the batteries) was identified. The LVSGR ventilation fan controller was subsequently restored to a fully functional status. This matter is close . Maintenance M1 Conduct of Maintenance M1.1 Maintenance and Surveillance Activities (61720@210Z)

The following maintenance and surveillance testing activities were observed / reviewed during the inspection period:

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DB ME 03020 Reactor Trip Dreaker Response Time Test

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DB PF-03968 CS [ Containment Spray) Pump 12 Discharge Check Valve Reverse Flow Test CS 9

+ DB-SP-03338 CS Train 2 Quarter 1y Pump and Valve Test

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DB-SC- 03070 Emergency Die =el Generator 1 Monthly

-+ DB SS-03091 Motor Ddven Feed Pump Quartoriy Test

• DB-SS-03042 Control Room Emergency Ventilation Train 2 Monthly Test

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DB MI-03906 Channel Calibration of AFW Pump 12 Inlet isolation on Low Inlet Pressure Interlock

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MWO 7 971133-01 Backfill LTRC14 2 [ pressurizer level instrument reference leg)

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• MWO 1 g7-0107 00 X Relay [ reactor trip breaker relay) Pitted Contacts

• MWO 3-98-047901 Inspect EHC [ turbine generator electro-hydraulic control]

Pump Motor i e

MWO-3-98-0486 01 Inspect and Lubricate EHC Pump Coupling l

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Equipment and supporting systems under test were observed to operate as described in the USAR. Personnel adherence to procedures during the performance of surveillance testing activities was good. Applicable limiting conditions for operation were entered as needed. Independent verification of critical surveillance steps was done appropriatel Test acceptance criteria appeared to adequately reflect operability requirement The inspectors also noted that precautions for backfilling a level transmitter were appropriately observed. Lifted wire logs were utilized effectively. Adequate safety precautions were observed when racking in/out breakers. Shift briefs effectively communicated important maintenance related information to the operating crews. Work history logs were updated in the field during the maintenance activity and accurately reflected the work performe M1.2 Auxklafy Feed Water Pressure Switch Calibration '

. Inspection Scqpe (01726)(37551)

On August 26 the inspectors observed the performance of surveillance DB-MI-03906,

" Channel Calibration of PSL 107A D, Auxiliary Feed Pump Turbine 12 inlet isolation on Low Inlet Pressure interiocks," the Updated Safety Analysis Report, design calculation C-ICE-050.01-001, "Setpoint for SOR Pressure Switches PSL 106A D and 107A D," PCAQRs 95-0884 and 0986, the Nuclear Quality Assurance Manual (NQAM), and applicable surveillance procedures were also reviewe , Observations and Firtdjngs Meam.tArina an.sil eJt Eauipment Eaulvalency During the test, the inspectors observed that Step 6.1.1 of the procedure required the use of four 0 72 psi test gauges with 0.05 percent accuracy or equivalent, but the electrical and controls (E&C) technicians were actually using 0-60 psi gauges with 0.5 percent accuracy. When questioned, the workers stated that the gauges in use were the recommended terit equipment listed in the instrument information sheets associated with the surveillance. Work was stopped and the issue was reported to the workers'

supervisor. The licensee initiated PCAQR 97-1141 to document the use of gauges with

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less accuracy than specified by the procedur Maintenance supervision promptly reviewed the matter and concluded that the less accurate gauges were considered equivalent to the gauges specified in the surveillance procedure. This conclusion was based on the licensee's Nuclear Quality Assurance Manual (NQAM), Section 12,.4.5, which specified that, "The inaccuracy of the calibration standards shall contribute no more than one-fourth of the allowable M&TE tolerance."

! The surveillance was then recommenced using the 0-60 psi gauges.

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Howevor, afterwards the inspectors reviewed design calculation C-lCE-050.01001, and nots 0 that the measuring and test equipment (M&TE) specified by the design calculation was 0 60 psig with an accuracy of 0.05 percen The three documents therefore specified the following M&TE gauges:

• Design Calcula0on: 0-60 psi,0.05% (0.03 psi accuracy)

• Surveillance Procedure: 0-72 psi,0.05% (0.035 psi accuracy)

Instrument Information Sheet: 060 psi,0.5% (0.3 psl accuracy)

It was evident that the M&TE specified by the surveillance procedure was very near the M&TE accuracy assumed in the design calculation, however, the instrument information sheet specified M&TE.with an accuracy that was approximately a factor of 10 less accurate. As such, the inspectors concluded that the M&TE specified by the instrument information sheet was not equivalent to the M&TE specified by the surveillance procedure. Station administrative procedure DB DP-00013," Surveillance and Periodic Testing,"(Revision 04), Step 6.3.7.J, required that M&TE used in tests shall satisfy the requirements of the fest procedure and be within its calibration due date. Using the test gauges recommended in (Se instrument information sheet instead of the gauges specified in surveillance procedure DB MI-03906 was considered a violation of 10 CFR 50, Appendix B, Criterion V, * Instructions, Procedures, and Drawings" (50-346/9701102(DRP)). Likewise, the inspectors identified that different ,A&TE was specified by surveillance procedure DB MI-03903, * Channel calibration of PSL 106A D, Auxiliary Feed Pump Turbine 1 1 Inlet isolation on Low Inlet Pressure Interlocks," versus its associated instrument information stieet The inspectors also noted that there was no written station policy on how to determine equivalency between M&TE. Further, the inspectors considered that the NQAM requirement could not have been met by any M&TE in this instance because the design calculation assumed zero M&TE error, Prior Corrective Actions Were Incomplete While reviewing the aforementioned discrepancy between the surveillance procedure and instrument information sheets, the licensee determined that PCAQR 95-0884 and 95-0986 had previously identified that DB-MI-03003 and DB-MI 03906 specified the use of gauges that were unavailable, namely 0-60 psi,0.05 percent accuracy gauge The proposed corrective actions associated with PCAQRs 95 0884 and 95-0986 included modifying Design Calculation C-lCE-040.01001 to specify a ditferent gauge type (0-100 psi,0.1 percent accuracy), and then to revise the subject surveillance procedures and instrument information sheets to be consistent with the design calculatio However, the design calculation had not since been revised, nor had the associated instrument information sheets. Altematively, the surveillance procedure had been revised without a documented engineering justification in place to do so. Failure to complete the planned corrective actions for PCAQRs 95-0884 and 95-0986 contributed to this event, and were considered a violation of 10 CFR 50, Appendix B, Criterion XVI, " Corrective Actions"(50-346/9701103(DRP)).

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The inspectors also identined that the design *W had set the *Devios Allowance" (i.e., setpoint drtit between calibrations) based on a 31-day calibration periodicity, but the calibration was actually conducted every 18 months. Since this could have resulted in en increased amount of setpoint drift between calibrations, PCAQR 971141 was inlilated to evaluate the operability of the switches. Atr7sy, the licensee determined that the actual amourd of setpoint drift had been minimal historically nnd no operability conooms currently existed, it was also identified that Design Basis Engineering did not control and maintain design calculations similar to other station documents. While revisions to design calculations were reviewed and approved, the cunent revision reRecting the as-built condition was not always clear, in addition, design calculations were not centrally filed and controlled. In the case of C lCE-050.01001, the actual cunent revision that reflooted the as-built -

condition was Revision 1.- However, Revisions 2,3 and 4 were also approved, but not actually in effect. A similar concem was documented in inspection Report No. 50 346/97201, Section E1.2.2.2.g. Further evaluation of the licensee's program for controlling design calculations and changes thereto will be accomplished in a future inspection. Pending completion of NRC review, this is considered an inspection follow up item (60 344/9701144(DRP)).

b.3 Control of instrument Information Sheets The inspectors determined that instrument information sheets were issued by ESC for each instrument tested by a surveillance procedure. The instrument information sheets included setpoint, setpoint tolmance, and vendor information, The instrument information sheets also listed the recommended M&TE and were used to record the as found data and infomiation for the M&T3 use The inspectors determined that instrument information sheets were not reviewed and

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approved in the same manner as were the associated surveillance procedures. The instrument information sheets were reviewed and approved within the ESC maintenance organization, but were not formally a part of the surveillance procedure change process, Changes to instrument information sheets were not tracked under the Procedure Change Request (POR) system (or any other system). The inspectors determined that this lack of control had contributed to the incomplete corrective actions associated with PCAQRs 95-0884 and 95-0986, PCAQR 95-0986 specified * completing the PCR,' The associated PCR specified the two surveillance procedures and the eight associated instrument information sheets were to be revised with the individual documents not ~

tracked separatel .

The inspectors were concemed that the instrument information sheets were in fact an -

inseparable part of surveillance procedures in some cases, and, as such, should be controlled in a like manner. NRC review of this was ongoing at the end of the inspection period, As such, this matter is considered an inspection follow up item pending _

completion of NRC evaluation of the interrelationships between surveillance procedures and instrument information sheets (50-344/9701105(DRP)).

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The inspectors conduded that workers did not M+yf; review surveillance procedure DB446 03908 during the performance of associated testing motiv6 ties, and thus failed to i

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note the M&TE discrepancy between the instrumord information sheets and the surveillance procedure. When the discrepancy was identined to the workers, work was '

property stopped to resolve the issue. However, maintenanos supervision improperty

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concluded that the MATE in use was equivalent to that specined, and permitted workers -  !

to resume work using the same M&TE, rather than wwltching to the required gauges or  !

changing the procedure to allow the less scourate gauge Effective corrective action was not implemented for a previously identified problem with

, the M&TE specified in the design calculation, surveillance procedure and instrument .

information sheets. Although all three documents were identified as requiring revision, '

only one, the surveillance procedure, was subsequently revise Design calculation information was not controlled and maintained like other controlled facility documents. While revisions to design calculations were reviewed and approved, the current revision that reflected the as built condition was not always clear. In addition, design calculations were not centrally filed and controlled. The calibration interval assumed in Design Calculation C-ICE 050.01001 did not match the actual calibration surveillance interval, which resulted in the subject instruments being calibrated once per 18 months versus once per month. The difference in surveillance iniorval should havo  ;

been corrected by revising the design calculation thru the 1995 FCAQRs resolution discussed abov ,

Additionally, the inspectors questioned how instrument information sheets were controlled, it appeared that some were actually a part of certain surveillance procedures, and therefore, shou'd be controlled in an equivalent manner. Inadequate control of these documents contributed to the incomplete corrective actions relating to a 1995 issue as previously discusse M3 Maintenance Procedures and Documentation

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M3.1 Erroneous Procedure Acceptance Limit Inspection Scope (61726)

The inspectors observed the controlled-use-validation of surveillance procedure DB-ME 03045, "C1 Bus Under voltage Units Monthly Functional Tert," conducted on September 15,1997, Observations and Findinas The newly approved procedure was to combine, for efficiency reasons, the technical specification (TS) surveillance procedures for response time and voltage trip setpoint

. verification for the Class 1E under voltage devices. By performing the controlled us validation,' additional assurance was provided that the approved procedure was of sufficient quality prior to its actual us .

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The inspectors noted that the in-field pytion of the validation demonstrated that the '

procedure could be performed on the affected equipment, although some procedure changes were identified by the personnel performing the validation. Subsequently, the pmcedure was updated to incorporate the identified items, and a final copy was provided to the inspectors for revie i

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Upon review, the inspectors noted a discrepancy associated with the procedurally specified Sgpercent under voltage device TS lower voltage limit. The maintenance department then, after the inspector identified the one item, identified that two limits had not been property transferred from the draft procedure documentation to the final approved version. The station generated PCAQR 971251 to document the matte Since validation of the procedure had just been completed, the procedow had not yet been actually used to perform TS required surveillance activities. Additionally..even if the procedure been used with the erroneous TS acceptance limit, a more stringent administrative acceptance limit was included in the procedure which would have flagged an equipment problem requiring resolution. However, as-found instrumentation reading below the administrative limit but above the erroneous TS limit may not have been recognized as an inoperable condition for the under voltage device, Conclusions An error in a TS accepince limit was not identified by station personnel during the procedure review and approval process, even though a controlled use validation had been completed. However, et the time the inspectors had identified the discrepancy, the procedure had not yet been used in the field.

M8 Miscellaneous Maintenance issues QJYO2)

M8.1 iClosed) Unresolved item f 50-348/95010-01(DR.f.)): Battery room heating augmentatio This issue related to an inspector observation that temporary portable heaters had been installed outside of one of the battery rooms to provide additional heating to the battery room. This had been done to augment normal plant HVAC to maintain temperatures in the room above 60 degrees (the limit when the battery would have been declared inoperable). Low room temperatures (60-70 degreos) were the result of cold weather conditions and wind impirigement on a ventilation louver that was leaking b Subsequent inspector review determined that the use of temporary portable equipment was allowed by station administrative procedures and that no NRC requirements had been violated. Maintenance department personnel performed adjustments to the dampers to improve their leaktightness. Periodic preventive maintenance work orders were revised to check damper clearances and to perform functional checks of the LVSGR heating system (which also provides heating to the battery rooms). The corrective actions were effective in restoring the subject room temperatures to nonnal bands without having to rely on augmented heatin .

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til. Ennineerina E2 Engineering Support of Facilities and Equipment E2.1 Hioh Enerav Line break Barrier Allowed Outano Times - jnsoection Scope (71707)(37551)

i On September 10, the inspectors noted t5st the access door 50 the main control room was blocked open with a security officer in attendance providing access for personnel to the control room. The door was designated a fire door as well as a high energy line break (HELB) barrier. The inspectors thereafter evaluated Nant administrative controls goveming inoperable HELB barriers such as the contiol room door, Observations and Findinas The inspectors subsequently determined the control room access door had been blocked open for greater than five hours due to ongoing work associated with the security computer system. When questioned whetner blocking the door open for an extended period of time was appropriate, operations personnel indicated that by procedure the door could be blocked open for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> based on previous engineering analysi The inspectors were subsequently provided a copy of an intra-company memorandum from the manager, nuclear engineering to the manager, operations, dated April 23,1991, that established a general allowed outage time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for any degraded flood, HELB, seismic, etc. hazard protection equipment. The evaluation compared the proposed allowed outage times for the hazard protection equipment with that for the safety equipment enclosed in the associated areas and concluded that since the specific safety equipment was allowed to be out-of service tur up to, for instance,72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, HELB, flood, seismic, etc., barriers protecting that same safety equipment should likew;se be allowed to be out of service for a similar;;oriod of time. However, the inspectors noted that a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed outage time was originally intended to apply to equipment rooms that housed only one train of safety equipment, inherent with the licensee's analysis was that the other train of redundant safety equipment was unaffecte The inspectors questioned the application of a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> time clock O a HELB door protecting the control room which housod control and instrumentation for more than one train of safety equipment, and in addition, functioned to protect personnel necessary to ensure adequate plant response following a postulated HELB. The inspectors were also concemed that the HELB door hau unnecessari!y been blocked spen when there was not  ;

a physical problem associated with the door itself. It appeare6 that the door could have been maintained closed except for normalingress and egress o' personnel to the control room which could have been manually controlled by the st'curity officer posted at the door, Conclusions The inspectors determined that Davis-Besse was required by NRC regulations to analyze design basis HELB, flood, and seismic events and install and maintain appropriate protective squipment to mitigate these events. However, although the station

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I established general guidelines for allowed outage times for HELB, flood, and seismic barders that could become inoperable, the inspectors were concemed that the station guidelines were not applied appropriately to the inoperable control room access doo Ponding further NRC review, this matter is considered an inspection foNow up Nem

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(60-344/9701106(DRP)).

E8 - MieooNaneous Engineering leeues (92903)

E (Closed) insoection Follow up item (50446/95010-02(DRP)): Updated Safety Analysis l Report (USAR) Table 6.2 23 did not include all containment isolation valves. Specifically, j small bore vent, drain, and test connections were not included in the subject tabl i Altematively, the licensee administratively controlled positioning and operation of the subject containment isolation valves by incorporating them into a controlled procedur Changes to the procedure were only to be done by use of the 10 CFR Part 50.59 safety evaluation process. This matteris close E (Closed) Unretolved item (50446/96003 05(DRP)): Storage of equipment in containment. This matter involved a concem where a test flange had been stored within the containment emergency sump area without a documented engineering evaluatio An informal engineering review apparently had been completed, however, documentation was lacking in that maintenance personnel had documented that the engineering evaluation had been done via a telephone memorandum. As a result, the inspectors reviewed the engineering justifications for several other components or materials that were stored within the containment during power operations and verified that each had been appropriately evaluated. The licensee subsequently identified that a complete re-inventory of materials in containment should be conducted to ensure that all had been appropriately evaluated. This inventory was to be performed during the next refuel outage. Since the inspectors had not identified any additional cases where materials stored in containment during power operation had not been appropriately evaluated, this matter is considered close IV. Plant Support R1 Radiological Protection and Chemistry (RP&C) Controls (71750)(71707)

The inspectors toured the radiologically restricted area (RRA) throughout the inspection period. Radiological postings for radiation and contamination areas were found to be up-to-date and accurate. Personnel observed working in the RRA were adhering to radiation protection procedures and practices. The inspectors attended an ALARA brief held to support a containment entry to backfill a pressurizer level instrument reference leg and '

noted good participation by involved personnel and information presented adequately reflected expected i ediological conditions and dos P2 Status of EP Facilities, Equipment, and Resources (71750)

The inspectors walked down the emergency control center, technical support center, and operations support center during the inspc,:: tion period. All emergency response fa cihties were well maintained in a suitable state of readines _

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S2 Status of Security Facilities and Equipment (71750)

The inspectors verified the integrity of the protected area fence barriers, that the protoded area isolation zones were appropriately cordrolled, that protoded area lighting l was adequate, and that secudty rounds were conducted in accordance wkh program  ;

requirements dudng the inspection pedod. Personnel processing facility ingress '

monitonng equipment was verif%d to be functional. Securtty officers processed personnel into and out of the protected area in accordance with the station security plan sna NRC requirement V. Mansaemant Meetinas X1 Exit Meeting Summary The inspectors presented the inspe.ction results to members of licensee management at the conclusion of the inspection on September 29,1997. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary infermation was identified.

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PARTIAL LIST OF PERSONS CONTACTED Licensee J. K. Wood, Vice President, Nudoar _

J. H. Lash, Plant Manager

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T. J. Myers, Director, Nuclear Support Sonicos J. L Michaelis, Manager, Maintenance D. L Esholman, Manager, Operations M. C. Beier, Manager, Quality Assurance  ;

L M, Dohrmann, Manager, Quality Services F. L Swanger, Manager, Engineering J. L. Freels, Manager, Regulatory Affairs H. W. Stevens, Manager, Nuclear Safety & Inspections J. W. Rogers, Manager, Mant Engineering G. A. Skeel, Manager, Security

~ W. J. Molpus, Manager, Nuclear Training C. A. Price, Manager, Business Services D. M. Imlay, Superintendent, Operatioris D. J. Mominee, Supervisor, DB Supply R. A. Greenwood, Supervisor, Health Physics D. H. Lockwood, Supervisor, Compliance G. M. Wolf, Engineer, IJcensing K. A. Filar, Engineer, Chemistry J. M. Baldwin, Shift Supervisor T. J. Chambers, Shift Manager

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INSPECTION PROCEDURES USED IP 37551: Onsite Engineering .

IP 61726: Surveillance Observations l lP 62707: Maintenance Observation

lP 71707: Plant Operations

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IP 71750: Plant Support Activities  ;

IP 92700: Onsite Follow-up of Wettien Reporis of Nontoutine Everds at Power Reactor Facilities  ;

IP 92901: Follow up- Plant Operations  :

IP 92902: Follow up Maintenance IP 92903: Follow up Ergineering

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i ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50 346/9701101(DRP) URI Inoperable Component Cooling Weler Ventilation 50 346/9701102(DRP) VIO Failure to follow test procedure during calibration of AFW

. pressure switches 50-34C/9701103(DRP) VIO Failure to implement corrective actions 50-346/9701104(DRP) IFl Control of desl9n calculations 50-346/9701105(DRP) IFl Control of instrument information sheets 50 346/9701106(DRP) IFl HELB barrier allowed outage times i Closed i 50-346/96606-01(DRP) VIO Inadequate control of testing 50-346/96010-03(DRP) IFl Control of low voltage switchgear room and battery room temperatures

'50 346/95010-01(DRP) URI Battery room heating augmentation 50 346/95010-02(DRP) 'IFl Certain containment isolation valves not included in USAR table 6.2 23 '

50 346/96003-05(DRP) URI Storage of equipment in containment -

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LIST OF ACRONYMS AND INITIALISMS USED AFW Auxiliary Feedwater CCW Component Cooling Water -

CFR Code of Federal Regulations ESF Enginoored Safe 9 Feature ESC Electrical and Controls

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EVS Emergency Ventilation System HELB High Energy Line break HVAC Heating, Ventilation, and Air Conditioning l&C - Instrumentation and Controls IFl Inspection Follow up item

. IR inspection Report LVSGR Low Voltage Switchgear Room M&TE . Measuring and Test Equipment MWO Maintenance Work Order NQAM Nuclear Quality Assurance Manual NRC Nuclear Regulatory Commission

~PCAQR Potential Condition Adverse to Quality Report PCR Procedure Change Request PDR Public Document Room RRA Radiologically Restricted Area TS Technical Specification URI Unresolved item USAR Updaled Safety Analysis Report

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