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UNITED STATES
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October 9, 1984 Docket No. 50-346 MEMORANDUM FOR:
Gus C. Lainas, Assistant Director for Operating Reactors Division of Licensing THROUGH:
John F. Stolz, Chief Operating Reactors Branch No. 4 Division of Licensing FROM:
Albert De Agazio, Project Manager Operating Reactors Branch No. 4 Division of Licensing 1
SUBJECT:
BACKFIT ISSUE AT DAVIS BESSE 4
Backfit Issue The NRC has several serious safety concerns related to the Davis-Besse auxiliary feedwater (AFW) system design. These concerns include 1) the lack of diverse AFJ pump drive ie., 2 turbine driven pumps and 2) the relatively high unreliability of the AFW system. The staff has concluded that the addition of an electric motor drive.n AFd pump would improve the reliability of the AFW system and would provide the needed diversity of pump dr.ive so that the plant would not be as vulnerable to loss of decay heat removal capability through delayed start of the AFW pumps (which could lead to rapid steam generator dry-out) or certain other common-cause related failures.
The NRC has been holding discussions with Toledo Edison Company regarding the addition of an additional full capacity pump driven by a means other than steam.
Licensee's Position Until recently the licensee has resisted the addition of an additional AR4 pump and concluded that AFW system reliability could be improved to an adequate level by various modifications to system interlocks, valves, and turbine speed governcrs and that such improvement would be less costly than the addition of another pump. The licensee also investigated upgrading the existing startup feedwater pump which is electric motor driven but rejected this.
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however, the licensee recently discovered that piping to and from the startup feedwater pump affects AFW system operability because of a violation of high/ medium energy pipe break design criteria. There are also some circuit separation problems related to the existing AFW pumps (App R Sect III.G.3 censiderations). The licensee has concluded that the installation of a higher capacity (full AFW flow) startup feedwater pump in an alternate location in the turbine building will resolve the various problems associated with the AFW system and will resolve the NRC concerns for the diverse drive pump.
The licensee has not yet identified system design and has not established a schedule for modification.
Milestones
- May 16, 1979 NRC issued an order requiring licensee to take action, among others, to improve AFW capability and reliabjlity.
- July 6, 1979 SER and letter lifting suspension of operation imposed by May 16, 1979 Order called for
".. modification to provide diversity offered by a 100% capacity motor driven AFW pump or an alternative acceptable to the staff."
- May 1980 Reactor Transient Tack Force recommended, in NUREG-0667, that " Installation of a diverse-drive AFW pump should be expedited at Davis-Eesse."
- December 31, 1981 Toledo Edison Co. submits detailed reliability analysis of AFW system
- fiarch 2-3, 1984 Operational event at Davis-Besse.
Stuck open safety valve results in steam generator dry-out.
- April 23, 1984 NRC issues evaluation of Toledo Edison Co.
reliability study.
Evaluation includes BNL reliability study.
- September 19, 1984 NRC-Toledo Edison Co meeting. Tolede Edison Co.
commits to install a relocated electric motor driven startup feedwater pump with full flow capacity.
Acolicability to Other Plants None.
All other operating PWRs have or will nave diverse powered AFW pumps.
Plants in licensing are covered by BTP 10-1.
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Conclusion:==
The licensee has committed to install an electric motor driven startup feedwater pump in an alternate location (in the turbine building) frem the present p AFW startup pump to resolve potential pipe break
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In so doing, gJ the licensee believes that the staff's concerns in
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diversity will be resolved. The proposed change is V _p'v>,j) not considered a backfit.
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lbert De Agazio, reject Manager Operating Reactors Branch No. 4 Division of Licensing e
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NUCLEAR REGULATORY COYMisslON l[
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! EE3 Docket No. 50-346 Toledo Edison Company ATTN: Mr. Richard P. Crouse Vice President Nuclear Edison Plaza 300 Madison Avenue Toledo, OH 43652 Gentlemen:
This refers to the followup inspection conducted by Messrs. N. Choules and T. Taylor of this office on January 8-11, 22-25, and February 4-8, 1985, of activities at Davis Besse Station, Unit 1 authorized by NRC Operating License NPF-3. It also refers to the discussion of our findings with you and others of your staff at the conclusion of the inspection.
The enclosed copy of our inspection report identifies items revie ed during the inspection and the results of these reviews. The inspection consisted of an examination of prccedures, records, and interviews with personr.el. This inspection was conducted to followup on items identified in the NRC Perfomance Appraisal Team's Inspection Report No. 50-346/84-19.
Also, the status of your actions taken in the response to previous Region III inspection findings were reviewed.
During this inspection, certain of your activities appeared to be in noncompliance with NRC requirements, as described in the enclosed Apper. dix.
A written resporse is required.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures will be placed in the NRC Public Document Rocm.
The responses directed by this letter (and the accompanying Notice) art not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, FL 96-511.
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Toledo Edison Company 2
- 1933 We will gladly discuss any questions you have concerning this inspection.
Sincerely,
. C. 1.ittle" W. S. Little, Chief Operations Branch
Enclosure:
1.
Appendix, Notice of Violation 2.
Inspection Report No.
50-346/85-01(DRS) cc w/ encl:
S. Quennoz, Station Superintendent DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII Harcld W. Kohn, Ohio EPA James W. Harris, State of Ohio Robert H. Quillin, Ohio Department of Health I
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. Taylor Walker Hawki ns J/r' ji j '
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3/5/85
Aopendix NOTICE OF VIOLATION Docket No. 5C-346 Toledo Edison Company Davis Besse Unit 1 As a result of the inspection conducted on January 8-11, 22-25, and February 4-8 1984, and in accordance with the General Policy and Procedures for NRC Enforcement Actions, (10 CFR Part 2, Appendix C), the following violations were identified:
1.
Technical Specification, Section 6.8.3.c, requires the Station Review Board to review and the Station Superintendent to approve temporary modifications to safety-related procedures within 14 days of the date the modification was implemented.
Contrary to the above, during the period April - June 1984, eight to ten percent of the temporary modifications to safety-related procedures were reviewed and approved more than 14 days after the date the modifications were implemented.
This is a Severity Level V violation (Supplement I).
2.
Technical Specification, Section 6.8.1.a. requires that procedures be established, implemented and maintained as required by Regulatory Guide 1.33 (November 1972), Appendix A. Section H.
Contrary to the above:
Two examples were identified where uncontrolled technical a.
manuals were used in lieu of approved procedures for the cali-1 bration of instrumentation required to verify compliance with the Technical Specifications.
b.
Numerous examples were identified where approved calibration procedures were not established for the calibration of M&TE.
This is a Severity Level V violation (Supplement I).
3.
Technical Specification, Section 6.8.2, requires that all procedures implemented pursuant to Technical Specification, Section 6.8.1.a.
be reviewed by the Station Review Board and approved by the Station Superintendent.
Contrary to the above, maintenance instruction MC-71 was neither reviewed by the Station Review Board nor approved by the Station Superintendent prior to its use in a safety-related application.
- This fs a Sev'erity Level V violation (Supplement I).
Appendix 2
4 10 CFR 50, Appendix B, Criterion V, as implemented by the Toledo Edison Nucl. ear Quality Assurance Manual, Section 17.2.5, including a commitment to ANSI N18.7-1972, requires that activities affecting quality be prescribed by appropriate procedures or instructions.
ANSI N18.7-1972, Section 5.1.6.1, requires that maintenance that can affect the performance of safety-related equipment shall be properly preplanned and performed in accordance with written precedures.
Contrary to the above, the instructions provided in Maintenance Work Order Nos. 3-84-0826-01, 2-83-0062-02, and 1-84-1900-00 were not of sufficient detail for the type of activities being performed.
This is a Severity Level V violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for each item of noncompliance:
(1) cor-rective action taken and the results achieved; (2) corrective action to be taken to avoid further noncompliance; and (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown.
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U.S. NUCLEAR REGULATORY COMMISSION REGION III Report No. 50-346/85-01 Docket No. 50-346 License No. NPF-3 Licensee: Toledo Edison Company Edison Plaza, 300 Madison Avenue Toledo, Ohio 43652 Facility Name: Davis-Besse 1 Inspection At: Oak Harbor, Ohio Inspection Conducted: January 8-11, 22-25, and February 4-8, 1985 3/6 d
Inspectors:
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J/f/6' T. Taylor Date 1
Acccmcanying Personnel:
T. Martin, Performance Appraisal Team Member (January 24-25,1985)
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Approved By:
F.HawkinUChief 3/f/86~
Quality Assurance Programs Section Datie /
Inspection SunTnary Inspection on January 8-11, 22-25, and February 4-8, 1985 (Report No.
50-346/85-01(DRS))
Areas Inspected: Routine announced inspection by two regional inspectors of findings identified in the Performance Appraisal Team's Inspection Report No.
50-346/84-19, Region III Inspection Report No. 50-346/84-09, and other Region III Inspection reports.
The inspection involved a total of 102 inspector hours on site.
Results: Of the 21 items reviewed,12 were closed and four items of noncompliance were identified: Paragraph 3.a (failure to approve procedure changes within 14 days); Paragraph 3.g. and 3.h. (failure to have approved procedures for calibra-tions); Paragraph 3.g. (failure to use an appoved procedure for maintenance); and
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. Paragraph 3'11. (failure to provide adequate instructions on maintenance work ordersJ. ~
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DETAILS 1.
Persons Contacted Toledo Edison Comoany
- R. P. Crouse, Vice President Nuclear
- T. D. Murray, Assistant Vice President - Nuclear Operations
- J. A. Faris, Administrative Coordinator
- C. T. Daft, QA Director
- D. Lee, Maintenance Engineer
- J. K. Wood, Facility ' Engineering supervisor
- T. J. Meyer, Nuclear Service Director
- J. R. Lingenfelter, Technical Engineer
- S. G. Wideman, Senior Licensing Specialist
- P. N. Carr, Engineering Services Manager
- 0. J. Stephenson, Compliance Coordinator
- D. J. Mominee, Quality Engineering Supervisor
- L. Reynolds, Design Document Control Clerk
- C. J. Greer, Operations Quality Assurance Supervisor US NRC
- W. D. Shafer, Chief, Operations Branch
- I. M. Jackiw, Section Chief, Operations Branch "W. G. Rcdgers, Senior Resident Inspector
- 0. Kosloff, Resident Inspector
- Cenotes those attending the exit interview on February 5,1985.
The inspectors contacted other licensee personnel as a matter of routine during the inspection.
2.
Introduction i
The focus of this inspection was to review and evaluate the findings of the NRC Performance Appraisal Team (Report No. 50-346/84-19) in the areas of corrective action, quality assurance, maintenance, design change, and procurement. As a result of this inspection and through discussions with members of the Performance Appraisal Team (PAT), Region III intends to perform a series of augmented inspections to assess the quality assurance, maintenance, and corrective action programs and their implementation.
It is our intent to continue these inspections until adequate confidence is established. Review and evaluation of the Corrective Action System has begun; the results will be docur.ented in Report No. 50-346/85-05.
3.
Action on Previous Inspection Findincs a.
(Closed) PAT Unresolved Item (346/84-19-01)
PAT Finding:
Failure of the Station Review Board (SRS) to review procedure modifications within 14 days of their effective date.
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Regicn III Finding: The inspector verified that, contrary to
_sechnical 5pecification, Section 6.8.3.c, temporary changes to 4
safety-related procedures were reviewed by the SRB and approved by the Station Superintendent more than 14 days af ter the date of implementation.
During the period April - June,1984, eight to ten percent of the temporary modifications were not reviewed and approved within the specified time.
Three specific examples were as follows:
(1) Temporary Modification (T-Mod) 7956 modified SP1104.14, (" Control Room HVAC System"). The modification was implemented on May 18, 1984, and reviewed by the SRB on June 13, 1984 (2) T-Mod 7992 modified ST5031.06 (" Safety FeOtures Actuation System Overall Response Time Calculation").
The mcdification was l
implemented on April 10, 1984, and reviewed by tha 5% on May 30, t
1984.
(3) T-Mod 7868 modified PT5175.00 (" Differential Red Worth at Pcwer").
The modification was implemented on March 15, 1984, and reviewed by the SRB on April 4, 1984 These failures to review temporary changes as required by the Technical Specification are considered to be an item of noncompliance (346/85-01-01).
b.
(Closed) PAT Unresolved Item (346/84-19-02)
PAT Finding:
Failure of the Company Nuclear Review Board (CNRB) to review a recognized indication of a deficiency in the design of a safety-related component.
Region III Finding: The review of this item was difficult, in that records of that time period were not sufficient in detail.
There was no proof or disproof of the CNR8 review of the January 3, 1979, high pressure injection pump event until January 1981. Because of this event, the licensee issued LER 79-034 and the NRC issued IE Bulletin 79-24; both the LER and the licensee's response to the bulletin were reviewed by Region III within the purview of the routine inspection program.
In lieu of detailed documented CNRB review, it is the inspector's conclusien that the bulletin and LER constitute sufficient review.
c.
(0 pen) PAT Unresolved Item (346/84-19-03)
PAT Finding: Failure to include observations of maintenance and operations activities in the quality assurance audit program as required by ANSI 18.7-1972.
Region III Finding: The review of audit reports indicated that some
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ob'servations of operations and maintenance activites were performed.
Additionally, QC observes most safety-related maintenance and GA
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performs surveillances of maintenance and operations; however,the 3
reports of these activities (surveillances) are not sent to the offsite comittee. Only an Audit Finding Report (AFR), generated by QA, is submitted. Although audit reports were not explicit regarding observation of activities in progress, sufficient detail was included
-to identify that observations were performed.
Examples of observations are Audit 1078 (August 12-24,1983),1192, (June 4-8,1984),1076 (August 5 - September 1,1984),1138, (February 13-17,1984),1129 (January 9-16, 1984), 1089 (September 12-16, 1983), 1067 (August 8-12, 1983),1029 (April 4-3,1984), 99.1 (January 3-10,1983), and AFR 1127 (surveillance performed December 9,1983).
The inspector does agree that there are weaknesses in this area.
In response, the licensee has agreed to increase observation of in progress activities and improve documentation of the cbservations.
Also, the licensee has agreed to provide the offsite comittee with information regarding surveillances. This item will remain open pending further review.
d.
(0 pen) PAT Unresolved Item (346/84-19-04)
PAT Finding: Failure to provide adequate management representation at quality assurance post-audit conferences.
Region III Finding: Af ter interviewing the Toledo Edison personnel involved, the inspector determined that a management designee was present at the post-audit conference described in the PAT report.
Management for the audited organization had been briefed of the audit findings by the auditor prior to the post audit conference.
Both i
the inspector and licensee personnel recognize that the program would be improved if a higher level of management attended the post audit conferences, even though there are no regulatory requirements to do so. Accordingly, the licensee has agreed to issue a directive to require, when possible, that a higher level of management (super-visor or manager in audited <.rea) will attend post-audit conferences.
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(0 pen) PAT Unresolved Item (346/84-19-05)
PAT Finding: Failure to establish administrative procedures required by Appendix A of Regulatory Guide 1.33 to address procedure adherence, procedure changes, and procedure review and approval.
Procedures do exist which address these topics, but they apply only to the Davis-Besse station organization and not to support activities such as QA, Nuclear Training, Nuclear Purchasing and Procurecent, and Nuclear Facilities Engineering.
Region III Finding: The licensee's procedures for the support activities referred to in the PAT report do exist, but some are weak in content. Specifically, procedures for Purchasing and Procurecent were weak, in that their format and revision control were not addressed.
The licensee agreed to either revise the existing J'
procedures 'or write a generic. procedure for all. departments.
This issue will remain open pending further review.
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(0 pen) PAT Unresolved Item (3a6/E4-19-06)
PAT Finding:
Procedural deficiency wnich provides the potential for omission of safety evaluations recuired by 10 CFR 50.59.
Region III Finding: Review of tnis item revealed that the definition of Nuclear Safety Related (NSR) pro /ided in procedura AD 1345.00
(" Changes, Tests, and Experiments", Revision 6,) if followed, would require safety evaluations in accordance with 10 CFR 50.59.
The wording in AD 1845.00 and attached checklists could be improved to ensure proper reviews are conducted for items which are not safety-related but could affect safety-related systems. The licensee agreed to revise AD 1845.00 to better ensure adequate reviews are performed.
There was no indication during this inspection that the procedural weakness had led to incomplete implementation of the review process.
This item will remain open pending further review.
g.
(Closed) PAT Unresolved Item (346/84-19-11)
PAT Finding:
Failure to provide review and control.over vendor manuals and maintenance instructions used to conduct safety-related maintenance.
Region III Finding: The inspectors interviewed licensee personnel and reviewed the calibration process referred to in'the PAT Report. The licensee is using the preventive maintenance system to schedule the calibration of items that are used for indication of safety-related plant parameters. The inspector verified that the licensee is using uncontrolled technical manuals in lieu of approved procedures for calibration of instrumentation required to verify comoliance with the Technical Specifications, but not required to be calibrated by the Technical Specifications.
Two specific examples were identified:
(1) The vendor manual used for the calibration of LT CF362, Core Flooding Tank 1 Level Transmitter, on September 7,1983, was not reviewed by the SRB or approved by the Station Superintendent.
(2) The vendor manual used to perform a calibration check of FT 4522, Auxiliary Feed Water Flow Transmitter, on June 25, 1984, was not reviewed by the SRB or approved by the Station Superintendent.
These failures to establish approved procedures for the calibration of instrumentation required to verify compliance with the Technical Specifications are considered to be an item of noncompliance with the Technical Specification, Section 6.8.1.a and Regulatory Guide 1.33 (346/85-01-02A).
Corrective action with regard to this item should include a review of safety-related systems to ensure that all instruments (1) used to determine compliance with limiting conditions for operation and (2) to monitor that the plant is being operated within required parameters, are calibrated using SRB approved procedures.
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Additionally, the inspector identified that the licensee was using maintenance instruction MI-71 ("Installaticn of Anchor Bolts",
Revision 3) to install and torque safety-related anchor bolts relative to Maintenance Work Order No. 2-78-0126-18; the procedure had neither been reviewed by the SRB nor approved by the Station Superintendent as required by Technical Specification, Section 6.8.2.
This failure to properly review and approved maintenance instructions is considered to be an item of nonccmpliance with Technical Specification, Section 6.8.2 (346/85-01-03).
h.
(Closed) PAT Unresolved Item (346/84-19-09)
PAT Finding: Failure to provide the necessary procedures to control the calibration of measuring and test equipment (M&TE).
Region III Finding: Technical Specification Section 6.8.1.a.
through its reference to Regulatory Guide 1.33, requires that procedures be provided to properly calibrate and adjust M&TE to maintain accuracy. The inspector verified by observation and personnel interviews that the licensee had not established approved calibration procedures for the calibration of torque wrenches, dial indicators, pressure gauges, digital multimeters, digital potentiometers, digital calibrators, and digital temperature indicators. The licensee is using the skill of the craft technique to perform the calibrations. The inspector recognizes that the skill of the craft technique is appropriate for limited application for specific types of equipment.
Nevertheless, the extent to which the technique is being employed at Davis Besse is not considered acceptable. This is considered to be a further example of ncncompliance with Technical Specification, Section 6.8.1.a (346/85-01-02B(ORS)).
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(Cicsed) PAT Unresolved Iten (346/84-19-12)
PAT Finding: Failure of maintenance work order to specify adequate work instructions.
Region III Finding: ANSI 18.7-1972, Section 5.1.6.1, requires that maintenance that can affect the performance of safety-related equipment shall be performed in accordance with written procedures.
The following specific observations were made:
(1) MWO 3-84-0826-01 did not provide instructions for the repair of components identified as defective.
The M'n0 authorized the replacement and repair of components, as needed, on the spent fuel cask crane.
(2) MWO 2-83-0062-02, for installation of conduit, provided no instructions for required torquing or setting the anchor bolts.
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-(3) MWO-1-84-1900-00 specified the performance of a calibration check on
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~ ' auxiliary feedwater flow transmitter FT 4522. While' performing the calibration check, the flow transmitter pcwer supply was replaced.
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The power supply replacement was beycnd the scope o instructions.
These failures to perform safety-related maintenance in accort with adequately defined instructions is considered to be an itei.
noncompliance with 10 CFR 50, Appendix B, Criterien V (346/85-01 s
.j (Closed) PAT Unresolved Item (346/84-19-16)
PAT Finding: Failure to evaluate a B&W preliminary safety concern (PSC) within the. required time period.
Region III Finding:
The B&W concern was issued en March 25, 1981.
A review of the vendor's concern was documented twice by the licensee: once on July 2, 1981, and another time on May 23, 1983.
The May 23, 1983, review was conducted in accordance with procedure SERV-002, approved in December 1982; this is the review identified by PAT. The July 2, 1981, review also addressed the B&W concern, but was not conducted in accordance with an established procedure.
Documentation of the 1981 review was not available for the PAT team to review at the time of their inspection. The inspectors consider this item closed.
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(0 pen) PAT Unresolved Item (346/84-19-18)
PAT Finding: Lack of procedural guidance for procurement of replacement parts to original specifications.
Regicn III Finding: The licensee's procedures NFES-071 and 072 were reviewed anc licensee perscnnel interviewed.
As a result of the inspector's concerns, the licensee agreed to review the procedures and make necessary revisions to increase assurance that replacement parts are procured in accordance with original specifications.
The inspector did not identify any indication that the procedural weaknesses had lead to procurement of substandard or otherwise unacceptable material or equipment. This item will remain open pending further review.
1.
(Closed) Unresolved Item (346/79-30-02):
Storage of Quality Assurance records. The inspector determined that the records which had been transferred tc the new storage vault had been sorted and filed into permanent filing cabinets.
(Closed) Open Item (346/83-04-01): Lack of definitive guideline m.
documents for the development of training programs and schedules.
The licensee had prepared and approved procedures NSP/NT-002
(" Development and Approval of Nuclear Training Department lesson Plans"), NSP/NT-007 (" Training Program Implementation"), and NSP/NT-013("TrainingSchedules").
The procedures are to be used in th,e devel,opment.of training programs and schedules.
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(Closed) Open Item (346/83-04-03): The licensee's Master Schedules Scard and the yearly training program cutlines for tnree maintenance areas (electrical, mechanical, anc instrucentation and control) were not adequately developed or uniform in their contents or format.
The inspector's found that the licensee had deveicoed 1985 Training Schedules for the maintenance groups.
The schedules were uniform in l
their format and content and were reviewed and approved by the Training i
Manager and the responsible maintenance department management.
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(Closed) Unresolved Item (346/83-13-01): No administrative controls were identified to ensure prcmpt review and evaluation of vendor bulletins and circulars.
The licensee had revised a January 6, 1983, instruction to address the licensee's reviews and responses to vendor bulletins and circulars.
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(Closed)OpenItem(346/84-09-01): Maintenance work order (MWO) procedure concerns. The licensee had revised Procedure AD 1844.00
(" Maintenance") to address the items listed in the inspection report, F
with the exception of requiring the equipment tag out number to be recorded on the MWO.
The licensee maintains a copy of the t gout fonn with the MWO package to maintain traceability.
The inspector has no further questions regarding this matter at this time.
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(Closed)Ncnccmpliance-(346/84-09-02):
Failure to require independent verification of tagging equipment out of service.
The inspector verified that the licensee had ccmpleted the corrective action detailed in their response dated November 29, 1984.
Specifically, Procedures l
AD 1803.00 (" Safety Tagging"), AD 1839.00 (" Station Operation") and PP 1101.22 (" Pre-Startup Checklists") had been revised to incorporate l
requirements for independent verification. The inspector also reviewed several completed lineup lists. The review indicated that independent verification was being performed when equipment was removed from service.
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(Closed) Open Item (346/84-09-10):
SRB approval of the installation l
of jumpers and bypasses was not required.
The licensee had revised j
procedure 1823.00 (" Jumper and Lifted Wire Control Procedure") to l
require SRB approval of safety-related jumper and lifted lead installations. The inspector reviewed several completed records which demonstrated that the SRB was following the procedure.
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(Closed) Noncompliance (346/84-09-15):
Inadequate storage of quality l
assurance records. The inspector verified that the licensee had
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i completed the corrective action detailed in their response dated October 3, 1984 Auditor qualification / certification records had been transferred to the licensee's storage vault.
Quality control j
test and measuring equipment records had been transferred to one hour 4
fire rated cabinets in the Instrument and Control shop for storage.
The licensee submitted a change to their Nuclear Quality Assurance Pr,ogram to. permit storage of c,alibration records in one hour fire rated g_
c.abinets. This change was approved by Region I!!.
The inspector has i-no further questions regarding this item.
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(Closed) Noncompliance (346/84-09-22):
The Master Training Schedule for 1984 did not identify any training for chemistry and health physics (C&HP) and electrical maintenance personnel. As stated in the licensee's response dated August 17,1984, the 1984 training schecule was updated to include C&HP and electrical maintenance training.
Training schedules for 1985 have also been developed using procecure NSP/NT-013 (" Training Schedules") which was issued September 30, 1964 The inspectors reviewed a sample of training records to verify that training was being completed. The inspectors have no further questions regarding this item.
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(Closed) Open Item (346/84-09-23):
No procedure existed for the development of training lesson plans. The licensee had prepared and approved procedure NSP/NT-002 (" Development and Approval of Nuclear Training Department lesson Plans") for use in preparing lesson plans.
The licensee was using this procedure and requiring contractors to follow the procedure in the preparation of lesson plans.
The inspec-tors reviewed a sample of lesson plans. There was a major improvement in quality over previous lesson plans.
4 Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1) on February 8,1985, and summarized the purpose, scope and findings of the inspe: tion.
On Feb-uary 21, 1985, the inspector discussed with Mr. C. Daf t by telephcne the likely informational content of tne inscection report with regard to documents or processes reviewed by the inspector during the inspection. Mr. Daft did not identify any such documents / processes as p roprie ta ry.
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