ML20133C959
| ML20133C959 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 12/27/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20133C936 | List: |
| References | |
| 50-346-96-06, 50-346-96-6, NUDOCS 9701080154 | |
| Download: ML20133C959 (22) | |
See also: IR 05000346/1996006
Text
.,
'
.
,
.
V. S. NUCLEAR REGULATORY COMMISSION
REGION III
Docket Nos: 50-346
License No: NPF-3
Report No: 50-346/96006
Licensee: Toledo Edison Company
Facility: Davis-Besse Nuclear Power Station
Location: 5503 N. State Route 2
Oak Harbor. OH 43449
Dates: August 15 - October 9, 1996
Inspectors: S. Stasek, Senior Resident Inspector
K. Zellers, Resident Inspector
Approved by: John M. Jacobson, Chief,
Reactor Projects Branch 4
"
9701080154 961227
PDR ADOCK 05000346
G PDR
_ -
_
.
l
-
.
l
EXECUTIVE SUMMARY
Davis-Besse Nuclear Power Station
NRC Inspection Report 50-346/96006
This inspection included aspects of licensee operations, maintenance,
engineering, and plant support. The report covers an 8-week period of
resident inspection. .
Doerations
. Plant management was kept informed of plant conditions, equipment
status, and plant problems. Operators maintained cognizance of
equipment status and work activities ongoing in the plant. Teamwork and
productive working relationships were observed to be exhibited between j
operations and other organizations (Section 01). .
1
. Safety systems walked down/ reviewed during the inspection period were l
well maintained and in a good state of readiness (Section 02.1).
. The number of licensed Senior Reactor Operators (SR0s) available to fill
onshift positions decreased due to recent attrition. The subject
positions were being filled in the interim by staff su) port SR0s,
pending completion of an SR0 upgrade training class. io decline in
performance as a result of the staffing shortages was observed
(Section 06).
Maintenance
. Overall, the planning, review, and execution of maintenance and testing
activities observed during the inspection period were performed in a
controlled manner by qualified personnel (Sections M1, M1.1, M1.2).
. Three examples of a violation of test controls were identified by the
inspectors:
1) Documentation and disposition of a test deficiency were
improperly performed (Section M1.3). The inspectors also
observed that the SRO and R0 did not recognize the potential
for preconditioning the valve:
2) Inadequate adherence to a test procedure resulted in
improper stroke timing of a valve (Section M3.1); and
3) Inadequate control of soluble plastic used to cover floor
drains in the auxiliary building negative pressure area
resulted in a concern for the validity of previously
performed emergency ventilation system drawdown testing
(Section M8.1).
. Reader / worker communications during performance of a test procedure were
not rigorous. When communicating actions required by specific procedure
2
. .- - - . ._ - -. - .
..
-
.
. .
.
.
,
'
.'
steps to a co-worker who actually was performing the actions, the
'
procedure reader paraphrased the action requirements versus
communicating them verbatim (Section M1.4). j
1
. EDG No. 2 exhibited a functional failure, possibly due to previous
improperly performed maintenance. (Section M1.5).
. The licensee identified that an electrician had improperly performed l
3
emergency battery light testing. The electrician subsequently resigned 1
4 ano a NRC violation was assessed against the individual. Because of the j
4
licensee's followup actions, this matter was considered a non-cited '
- violation against the facility (Section M1.6).
! . The inspectors identified that certain remotely operated valves were
potentially preconditioned by the sequencing of test steps prior to
their stroke timing. At the end of the inspection period, the licensee
<
was conducting additional reviews of this matter (Section M3.2).
'
Enqineerina
j . Weaknesses were noted in engineering knowledge and familiarity with
. Generic Letter 91-18, which provided guidance concerning operability
,
determinations and resolution of degraded and nonconforming conditions
(Section E1.1).
- . The inspectors noted two minor discrepancies with licensee adherence to
Technical Specifications administrative requirements (Section E3.1). l
1 l
l Plant Suonort
1
i . The inspectors noted that some computer monitoring equipment did not
r work during the conduct of emergency planning drills (Section P2.1).
. Radiological a.'iv were properly controlled and posted. Surveys
accurately reflected actual in-plant radiological conditions.
.
i
3
_ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ . . ._ _ __ _ _ _ _ _
-
.
.
-
,
l
- l
Reoort Details '
4 Summary of Plant Status
With the exception of routine short term power reductions to accommodate
turbine valve testing, the plant operated at nominally full power throughout
the inspection period.
I. 00erations
01 Conduct of Operations
During the inspection period the inspectors attended plant management
meetings, shift turnover briefs and observed the performance of licensed
and non-licensed operators in the performance of their duties. Control
room and in-plant equipment spaces were walked down to verify
operability of safety related systems and structures. In addition, the
inspectors reviewed applicable logs and tagout (clearance) records, and
conducted discussions with operations personnel during the inspection
period.
Plant management was observed to have been kept informed of plant
conditions and equipment status, and were notified in a timely manner
regarding problems identified by )lant staff. Operators conducted
comprehensive chift briefs and ex11bited a questioning attitude
regarding the status of equipment and evolutions to be performed.
Operations management was seen to be making strides in emphasizing
adherence to proedures, and keeping operations shifts informed of
important information by issuing, in a timely manner, required reading,
night orders, and verbal communications during shift briefs. Effective
teamwork and productive working relationships were observed to be
exhibited between operations, maintenance, engineering, plant support.
'
and station management personnel.
02 Operational Status of Facilities and Equipment ]
02.1 Enaineered Safety Features Systems Walkdowns (71707)
The inspectors conducted walkdowns of the accessible portions of the
following engineered safety features and important-to-safety systems '
using Inspection Procedure 71707:
-
Emergency Diesel Generator No. 1
-
High Pressure Injection System - Train 1
-
Containment Spray System - Train 2
-
Emergency Ventilation System - Trains 1 and 2 :
Auxiliary Feedwater System - Trains 1 and 2
'
-
Overall, all systems walked down were verified operable with main
flowpaths in conformance with the Updated Safety Analysis Report (USAR).
Overall equipment material condition was found to be satisfactory with
minimal oil and fluid leaks noted. Pump / motor fluid levels were within
4
- _
.
-
- ,
'
. l
,
-
.
.
their specified acceptance bands, and all necessary auxiliary equipment,
including electrical supplies, instrumentation, and cooling water,
appeared to be functional.
l
04 Operator Knowledge and Performance )
The inspectors conducted discussions with control room personnel !
throughout the inspection period concerning the operation and status of I
control room and in-plant equipment. The inspectors noted that, !
overall, operations personnel remained cognizant of equipment status and '
operating limitations, as well as the status of maintenance activities
and other evolutions in progress.
06 Operations Organization and Administration
The inspectors noted that the number of Senior Reactor Operator (SRO)
licenses that were available to man the Shift Manager, Assistant Shift
Supervisor, and Shift Supervisor positions as required by the Technical
Specifications had declined due to promotions, transfers, and attrition
associated with the above areas.
As a result, operations su) port and management personnel were routinely
substituted to cover the s1ortages with a small amount of associated
overtime incurred. No discernible related decrease in operations i
performance was noted.
From discussions with plant management, the shortage of SR0s was
projected to continue until the current SR0 upgrade class is completed
and those candidates obtain their NRC licenses. SR0 Exams are scheduled
for June 1997.
08 Miscellaneous Operations Issues (92901)
08.1 (Closed) Insoection Followuo Item (50-346/96005-02(DRP)l: Operator i
shift schedules not conJistent with Technical Specifications (TS). This i
item addressed an apparent inconsistency between the requirements of TS l
6.2.3 relating to operations shift coverage, and actual SR0 work
schedules.
!
Technical Specification 6.2.3 s)ecified, in aart, that the objective was 1
to have operating personnel wart a normal 8-lour day, 40-hour week while !
the plant was in operation. However, the inspectors noted that SR0s had
been working a nonnal 12-hour daily shift for several months.
When this matter was brought to licensee management's attention, the
plant manager took steps to authorize the deviation as allowed by TS 6.2.3. In addition, a license amendment request (LAR) was initiated and
subsequently submitted to the NRC on September 4, 1996, to revise that
portion of the TS. As such, this matter is considered closed.
4
i
5
.
-
.
.
II. Maintenance
M1 Conduct of Maintenance
For those activities observed during the inspection period, the
inspectors determined that maintenance was generally performed
satisfactorily and completed as scheduled by appropriately qualified
personnel. i
l
Major maintenance activities affecting risk significant or Technical
Specification related systems were coordinated by team leaders,
primarily designated from )lant engineering. The team leaders were 1
observed to have detailed (nowledge of the planned maintenance j
activities. l
Good involvement by plant management was noted during maintenance pre-
job briefs. Topics specifically discussed in the pre-job briefs l
observed included: potential personnel and equipment safety issues,
maintenance rule implications, restrictions imposed on the plant as a l
result of the subject maintenance, and factoring of possible inclement
weather. i
M1.1 Maintenance Activities (62707)
The inspectors observed / reviewed all or portions of the following
maintenance activities:
-
MWO 3-96-4790-01 Inspect Coupling and Motor / Pump Alignment for
HPI #1
-
MWO 3-96-0263-01 Clean, Lube, Megger, Inspect HPI #1 Pump and
Motor
-
MWO 3-96-0494-01 Clean and tube HPI Pump #1 AC Lube Motor
-
MWO 1-94-0710-00 Cutout and Replace BW 27
-
MWO 7-96-1157-01 RPS Flow / Delta Flux, Troubleshoot and Repair
-
MWO 3-97-0297-00 DHP #2 Suction from BWST, Votes Testing
-
MWO 1-94-1003-03 Service Water relief valve, SW 3962, Rebuild and
Setpoint Testing
The inspectors determined that the above listed maintenance activities
were performed by knowledgeable Jersonnel using properly authorized
maintenance work order (MWO) paccages. The observed maintenance
activities were conducted in a deliberate, methodical manner with no
time constraints or other pressures that might adversely affect worker
effectiveness noted.
Regarding MWO 1-94-1003-03, the inspectors verified the service water
relief valve lift setpoint and observed quality control personnel
independently verifying the setpoint as part of a quality control
signoff to the MWO.
During a review of a High Pressure Injection (HPI) Train 1 outage, the
inspectors noted that in-plant maintenance activities were conducted in
6
.
'
.
-
.
.
accordance with the a)propriate procedures and plant requirements.
However a review of t1e associated clearance (tagout) packages providing
isolation boundaries for the work, revealed some minor inattention-to-
detail issues. Included were: 1) errors in the number of tags
documented on the cover sheet of certain packages, 2) errors on the
cover sheet specifying the number of tag assignment sheets included in
some packages, and 3) an inprocess change in the draining lineu) for a
section of pipe for an ir. determinate reason. When brought to t1e
-
licensee's attention, a PCA0R was initiated to ensure appropriate review
and followup.
M1.2 Surveillances (61726) l
The following surveillance activities were observed / reviewed:
)
-
DB-SP-03338 Containment Spray Train 2 Quarterly Pump and
Valve Test I
-
DB-SP-03161 AFW Train 2 Level Control. Interlock, and Flow l
Transmitter Test !
-
DB-MI-03012 ARTS /CRD Breaker Testing
-
DB-SP-03137 DHR Pump Quarterly Test
-
DB-SC-03071 EDG #2 Monthly Test 1
-
DB-PF-04705 Performance Test of CCW Heat Exchanger #2 l
With the exception of those items noted below, surveillances were I
observed to be conducted in a controlled manner. Equipment was !
'
'
independently observed to function as designed. Process parameters such
as pump suction and discharge pressures, system flow rates and generator
voltage and currents were independently verified against the appropriate l
acceptance criteria and USAR requirements as appropriate. Associated
)iping and valves were observed for leakage. Operators were observed to
)e monitoring the operating equipment for water and fluid leaks, and
abnormal vibrations. No USAR discrepancies involving the functioning
and performance of these systems was noted.
However, several issues related to the conduct of surveillances were
identified and are further discussed in Sections M1.3, M1.4, M3.1, and
M3.2.
M1.3 Imorocer Documentation and Disoositionino of a Test Deficiency
a. Insoection Scoce (61726)
The inspector observed the 3erformance of surveillance DB-SP-03161,
" Auxiliary Feedwater Train io. 2 Level Control. Interlock and Flow
Transmitter Test" (Revision 04), that was conducted on September 25,
1996.
b. Observations and Findinas
The inspectors observed that a reactor operator (RO), performing
portions of the surveillance test in the control room, failed to
7
._
'
1
1
.
document or disposition a test deficiency as required by the licensee's
test program on two separate occasions.
During the test, the RO was required to verify response times for the
Auxiliary Feedwater (AFW) Pump 2 suction transfer to service water, and
the response time for the opening of the service water su) ply valve to
AFW. However, during the performance of those steps in t1e procedure,
he improperly operated the stopwatch. On both occasions, the operator
recognized his error and directed the designated steps of the procedure
be reperformed. He did not identify the error as a test deficiency or
"
notify shift management regarding what had occurred.
The operator indicated, after the fact, that since the issue was one of l
.
stopwatch usage, and not associated with the performance of the '
- equipment that was under test, the matter did not constitute a test
deficiency, and that reperformance of the applicable test portions was
acceptable.
The Senia Reactor Operator (SRO) also agreed that the reactor operator
had satisfactorily 3erformed the surveillance. He stated that because
there was not a pro)lem with the ecuipment under test, the stopwatch
3roblem did not constitute a test ceficiency. He also indicated that
)ecause the root cause for the problem was readily a) parent to the R0,
he would not expect the RO to have informed him of t1e proolem.
Additionally, he stated that if he had been notified, he probably would
not have instructed the R0 to handle the matter any differently.
The inspectors reviewed 3rocedure DB-DP-00013. " Surveillance and
Periodic Test Program" (levision 04), and found the definition of a test
deficiency to be "Any deviation from a test procedure requirement or
acceptance criteria which is identified during the conduct of a test, or
during the review of the test results." As such, the inspectors
determined that the inability to collect the time response data as
'
required constituted a " deviation from a test procedure requirement."
Per Section 6.3.8 of DB-DP-00013, a test deficiency required
documentation on the test deficiency list and resolution and approval
.
per Section 6.7 of DB-DP-0013.
4
c. Conclusions
The inspectors were concerned that by not documenting test deficiencies
of the ty)e noted, the fact that certain activities were not
accomplisled in the test sequence or manner initially assumed, would not
be evaluated for their potential effect on the validity of test results.
For example, the reperforming of certain steps of a test procedure could
cause the associated equipment to be inadvertently preconditioned such
that subsequent data would not accurately reflect as-found conditions.
As such, the need to change the sequence of a test procedure to allow
reperformance of an earlier step would be deemed a test deficiency.
The inspectors were also concerned that the SR0 and R0 did not recognize
the potential for preconditioning the valve.
8
-
.
-
. .
.
10 CFR Part 50, Appendix B, Criterion XI, " Test Control," states, in
part, that a test program shall be established to assure that all
testing required to demonstrate that structures, systems, and components
will perform satisfactorily in service is identified and performed in
accordance with written test procedures which incorporate the
requirements and acceptance limits contained in applicable design
documents.
Because the test deficiency was not identified, documented and
dispositioned as a test deficiency, as required by test program
procedure DB-DP-00013 (Revision 04), this is considered one example of a
violation of 10 CFR 50 Appendix B, Criterion XI (50-346/96006-
01A(DRP)).
M1.4 Reader / Worker Practices
a. Insoection Scooe (61726)
The inspectors observed the performance of DB-MI-03012. " Channel
Functional Test of Reactor Trip Breaker A. Reactor Protection System
Channel 2, Reactor Trip Module Logic, and Anticipatory Reactor Trip
System Channel 2 Output Logic" (Revision 02), that was conducted on
September 25, 1996.
b. Observations and Findinas
This surveillance activity was performed by two instrumentation and
control (I&C) technicians. The test leader read and documented the
completion of each action as directed by the associated step of the
surveillance procedure while another worker listened and performed each
, step.
The inspectors noted that the reader did not read the steps of the
4
procedure verbatim out loud, but rather, read them in a paraphrased
manner to the worker. The inspectors did not identify any instances
where the procedure was not performed properly.
The inspectors discussed this with the I&C superintendent. The I&C
superintendent indicated that the performance of surveillance testing
using paraphrased step instructions did not meet his expectations. He
added that he would promulgate his expectations to I&C technicians so
that this would not occur in the future. The inspectors were unable to
determine if the paraphrasing of surveillance action steps had caused
past performance problems.
The inspectors did not note other cases of paraphrasing the action steps
of procedures. However, pending inspector followup to determine if
management expectations were adequately communicated to I&C personnel,
this matter is considered an inspection followup item (50 346/96006-
02(DRP)).
9
_ . .. _ _ _ . _ . _ _ _ _ _ _ _... _ _ _ _ _ .. _ __ _ _ _
.
-
.
.
M1.5 Emeroency Diesel Generator Functional Failure
a. Insoection Scooe (62707)
The inspectors conducted a followup review of activities related to a
functional failure of Emergency Diesel Generator No. 2 when a lube oil
check valve failed during a monthly surveillance test. This occurred on
August 22, 1996, and was documented in PCA0R 96-1124.
b. Observations and Findinas
! EDG No. 2 experienced a functional failure when diesel lube oil system
!
check valve (L0 329) disk stem cover cap fractured about 30 minutes into
a surveillance test. This created a leakage path for pressurized (about
100 psi) lube oil to spray out of the EDG, reducing EDG lube oil levels
- and soaking the EDG pedestal area.
An equipment operator observed the failure and immediately performed an
l emergency shutdown of the EDG. The EDG was declared inoperable until
l the check valve was replaced and lube oil levels restored about eight
hours afterward.
The licensee )erformed a work history search and determined that the
lube oil chec: valve had a maintenance activity performed on it in
July 1996. During that maintenance activity the stem cap had been
removed to perform an inspection activity and was then reinstalled.
After reinstallation, the EDG had been successfully run for post
maintenance testing. The EDG had about five hours of run time
associated with it prior to the cover cap blowing out.
L Afterwards, the ins)ectors visually examined the check valve and cover
i cap. The cap was o) served.to have been fractured at the threads.
l
l Preliminary root cause determination was that a material defect was
l introduced by the maintenance activity that was performed in July 1996,
l and resulted in the eventual failure. This defect could have been
! caused by a scoring of the cap threads or an overtorque of the cap into
! the valve body. Pending licensee completion of root cause and
corrective action review of this functional failure, this is an
inspection followup item (50 346/96006 03(DRP)).
l
M1.6 Imoroner Testina of Emeroency Liahtina
l a. Insoection Scoce (92902) *
l
l A followup inspection of a Potential Condition Adverse to Quality Report
!
(PCA0R) 96-0053, which documented an individual's failure to properly
perform some steps of an emergency lighting surveillance activity, was
'
performed. The electrician who conducted the surveillance activity was
suspected to have willfully not completed the procedure correctly,
j
therefore, the initial followup activity was referred to the NRC Office
.
-
10
_
-
l
l
-
of Investigation (01). That review was subsequently completed as
documented in 01 Investigation Report No. 3-96-007.
b. Observations and Findinos
A licensee audit of DB-ME-04100, " Emergency Lighting System Test "
determined that step 8.1.3.b.3 of the procedure was not performed
correctly on January 8, 1996, for Control Room Emergency Battery Lights
(EBLs). Step 8.1.3.b.3 required a 90-second burn test of each EBL while
monitoring battery discharge voltage.
-
Based upon security door transaction records, licensee management
determined that insufficient time was available for the assigned
electrician to have performed a 90-second burn test for all EBLs in the
'
Control Room. The records showed that six EBLs were documented as
tested in a four minute time frame. After discovery, the licensee
verified that the affected EBLs were operable by correctly performing
the surveillance test on them.
Licensee management questioned the electrician who performed the
surveillance activity. The electrician acknowledged that he did not
-
perform all the burn tests for a full 90-seconds, but used what he
called a fast test. Additionally, the employee indicated during the
January 18, 1996 interview that he thought that the EBL test was
unimportant.
Subsequently, the electrician was suspended and his plant access
withdrawn pending further investigation of the details of the matter.
The licensee then conducted an extent-of-condition evaluation which
included a review of the employee's record and work history. Additional
door transaction records were also checked to determine the time other
workers used to perform EBL surveillance activity with no other
discrepancies identified. Other work performed by the one individual
was reviewed with no additional quality of work concerns noted.
On January 30, 1996, during the internal investigative process, the
individual opted to resign from Toledo Edison.
Because the employee voluntarily resigned, and because the licensee
determined that the case did not involve an egregious example of willful
misconduct, his plant access was not )ermanently restricted, nor was his
name added to the Security Index data]ase.
c. Conclusions
01 concluded that the worker had deliberately falsified EBL surveillance
records and that licensee corrective actions were timely and
appropriate.
However, this is considered a violation of 10 CFR Part 50, Appendix B,
Criterion V. " Instructions Procedures, and Drawings," as implemented by
11
'
.
-
.
.
licensee procedure DB-DP-00013. " Surveillance and Periodic Test
Program", and DB-ME-04100, " Emergency Lighting System Test." in that
those procedures were not adhered to in their entirety.
This
"
was also a violation of 10 CFR 50.9 which states, in part, that
...information required by statute or by the Commission's regulations,
orders, or license conditions to be maintained by the applicant or the
licensee shall be complete and accurate in all material respects."
However, because the licensee performed timely and comprehensive
corrective actions, these licensee-identified and corrected violations
are being treated in the aggregate as a non cited violation (50-
346/96006 04(DRP)), and a Notice of Violation will not be issued
consistent with Section VII of the NRC Enforcement Policy. 1
Whereas it was concluded that the electrician had engaged in deliberate
misconduct, a violation of 10 CFR 50.5 was also determined to have
occurred and a Notice of Violation was issued against the individual I
under separate cover (reference NRC letter dated August 23, 1996, from
A. B. Beach to M. D. Nevers).
H3 Maintenance Procedures and Documentation
H3.1 Failure to Follow Test Procedure
a. Inspection Scone (61726)
The inspectors observed performance of surveillance procedure DB-SP-
03338, " Containment Spray Train 2 Quarterly Pump and Valve Test"
(Revision 02), on September 6, 1996. 4
b. Observations and Findinas
The inspectors observed that a reactor operator who was performing the
close stroke timing of containment spray (CS) valve CS1531, timed the
stroke of the valve by watching the indicating lights from the control
room, instead of at the associated motor control center (MCC) as
directed by a surveillance procedure note. The operator failed to
recognize that the note instructed that stroke timing was to have been
%rformed at the associated MCC by listening to relay dropouts at the
NCC. The specific signoff step, step 4.27 of the procedure, did not
require that the stroke time testing be done at the MCC but stated
"Close AND time CS1531, CTMT SPRAY AUTO CONTROL VALVE 1-2."
The inspectors also noted that another section of the procedure also
included similar requirements for the subject valve. Step 4.11 stated
that "Open AND time CS1531. CTMT SPRAY AUTO CONTROL VALVE 1-2." The
note directly proceeding that step also indicated that valve stroke
timing was to be performed at the associated MCC. Additionally,
examination of the procedure governing the stroke time testing of the
other train CS auto control valve (CS1530) determined that the same
conditions existed.
12
'
.
.
.
The acceptance criteria for CS1531 included a closing time
s 46.6 seconds and an opening time of s 35 seconds. The target value
was 31 seconds. The recorded stroke times for CS1531 from the Control
Room was about 25 seconds.
Once the discrepancy was pointed out to testing personnel, they
acknowledged the oversight and took actions to properly perform the
affected sections. Subsecuent to the proper performance of the stroke
timing, the inspectors incependently verified that the stroke time data
met the associated acceptance criteria and was within one second of the
target value. Additionally, the operations shift initiated PCA0R 96-
1184 and initiated procedure changes to incorporate the information
about performing the stroke timing at the MCC into the appropriate
action steps of the affected surveillance procedures.
After questioning the engineer responsible for reviewing / trending the
test data, the inspectors determined that the error would have been
eventually identified and that CS1531 would have been re-stroke timed.
The requirement to perform the stroke timing at the motor control center
was necessitated by the fact that the CS1531 control room indicating
lights indicated closed with the valve 20% open. The 20% position was
the post accident throttled position of CS1531 when the CS pump suction
would shift from the Boric Water Storage Tank to the containment
emergency sump supply.
The inspectors believed that providing critical stroke timing
instructions in the note was a contributing factor to the operator's
error in not doing the timing at the MCC. However, this did not relieve
the operator of the responsibility to read / understand the note and to
thereafter properly perform the timing.
Davis-Besse's surveillance test procedure writing guidelines
(Section 9.0, Revision 03) was reviewed to determine requirements for '
procedural notes. Section 9.5.g referenced subsection 4.12
(Section 4.0, Revision 05) for using note statements. Subsection 4.12
stated that, " Notes draw attention to important information but do not
direct the user to take action." Subsection 4.12.1.b. stated, "Do not
include actions in these statements. If any action is required, write a
step."
c. Conclusions
The operator who performed the subject surveillance activity did not
adequately read an informational note in DB-SP-03338 and as a result,
failed to properly stroke time CS1531.
Once the inspectors identified the failure, operations personnel and
management performed adequate immediate corrective actions and
subsequently wem able to test CS1531 with successful results.
13
_
'
.
'
.
,
'
.
10 CFR Part 50, Appendix B Criterion XI. " Test Control." states, in
part, that "A test program shall be established to assure that all
testing required to demonstrate that structures, systems, and components
will perform satisfactorily in service is identified and performed in
accordance with written test procedures which incorporate the i
requirements and acceptance limits contained in applicable design ,
documents." ,
However, adherence to the testing requirements specified in surveillance ,
procedure. DB-SP-03338 was inadequate in that the operator did not >
stroke time CS1531 from the MCC per the procedure unti1 informed by the '
.
NRC. This is considered one example of a violation of 10 CFR 50.
Appendix B, Criterion XI (50-346/96006 01B(DRP)). ;
M3.2 Potential Preconditionina of Remotelv Ooerated Valves
a. Inspection Scope (62703)
The inspectors reviewed procedure DB-SP-03161, " Auxiliary Feedwater .
'
Train 2 Level Control. Interlock and Flow Transmitter Test"
(Revisien 04), as additional followup to the review documented in r
Section M1.3. !,
b. Ohservations and Find nas
The inspectors noted that the stroke timing of service water valve !
SW1383 was preceded in the procedure by stroking SW1383 to accomplish i'
other surveillance requirements. The inspectors were concerned that
this constituted a preconditioning of that valve prior to its inservice
testing.
10 CFR Part 50 Appendix B. Criterion XI " Test Control." states, in
part.-that "A test program shall bo established to assure that all
testing required to demonstrate that structures, systems, and components
(SSCs) will perform satisfactorily in service." This implies therefore
that standby SSCs should normally be tested in the "as-found" condition,
absent any preconditioning, since that would be their expected condition
if called upon to function. To the extent that testing could not be
performed in an as-found condition, proper justification of Jerforming
the testing in other than an as-found condition should have )een
provided. However, no written documentation was provided by the
licensee that explained the basis of stroke testing SW1383 in other than ,
an as-found condition. )
The inspectors also noted that the ASME code does not specifically
require a -found testing except in specific cases (e.g., safety valve
testir.9).
Subsequent to inspector identification of this concern, the licensee
initiated potential condition adverse to quality re) ort (PCA0R) 96-1318.
to correct the subject procedure and to determine tie extent of the
condition by performing a review of other testing procedures.
14
.
-
.
.
Pending further inspector review to determine if any regulatory
commitments or requirements were violated regarding preconditioning of
SSCs within the licensee's surveillance program, this matter is
considered an unresolved item (50-346/96006 05(DRP)).
M8 Hiscellaneous Maintenance Issues (92902)
M8.1 (Closed) Unresolved Item (50-346/96005-03(DRP)): Inadequate control of
Emergency Ventilation System (EVS) drawdown testing. This matter
involved inspector identification that soluble plastic material was
observed covering a floor drain in mechanical penetration room (MPR)
No. 2. i
1
When identified, the inspectors noted that the floor drain posed a '
Jotential lathway between the auxiliary building EVS negative pressure
)oundary (iPB) and areas outside of the NPB. As such, the floor drain
had incorporated a wafer check valve to act as a reverse flow seal for
that opening to ensure integrity of the NPB.
Subsequent review also identified that the placement of soluble plastic
over floor drains in the NPB was not formally tracked or controlled from
an o)erations perspective. As such it was indeterminate as to whether !
solu)le plastic material had been covering one or more floor drains in j
the NPB during previous EVS drawdown tests. '
The inspectors were concerned that with soluble plastic potentially
covering one or more floor drains in the NPB, the validity of previous
EVS drawdown tests was questionable. With soluble plastic covering a
given floor drain, operability of the associated wafer check valve would i
not be verified. l
The inspectors reviewed surveillance 3rocedures DB-SS-03254, " Emergency
Ventilation System Train 1 18-Month S AS Drawdown Test" (Revision 02),
and DB-SS-03255, " Emergency Ventilation System Train 2 18-Month SFAS
Drawdown Test" (Revision 02). Neither procedure included a prerequisite
to verify floor drains within the NPB were not covered with soluble
plastic prior to conducting a drawdown test.
The licensee subsequently conducted an EVS Train 2 drawdown test to !
verify NPB integrity with all soluble plastic removed from the NPB floor
drains. That test was successfully completed.
Although the licensee successfully demonstrated that the integrity of !
the NPB was intact, the validity of previous EVS drawdown tests remained
in question. As such this appeared to be a violation of 10 CFR 50.
Appendix B, Criterion XI, " Test Control."
Criterion XI states, in part, that "A test program shall be establisheu
to assure that all testing required to demonstrate that structured
systems and components will perform satisfactorily in service is
identified and performed in accordance with written test
procedures... Test procedures shall include provisions for assuring that
15
l
'
-
.
,
.
all prerequisites for the given test have been met, and that the test is i
performed under suitable environmental conditions." In this case the
licensee had failed to establish the appropriate test prerequisite ,
conditions to assure a valid test result. ;
This is considered one example of a violation of test control (50- ;
346 96006 01C(DRP)). '
M8.2 (Closed) Violation (50-346/94002-01(DRP)): Maintenance personnel
manipulated plant equipment outside of approved maintenance activities
without control room authorization.
. ' response to this violation the licensee conducted additional training
'sr associated maintenance personnel including specific required reading
for all shop personnel. In addition a memorandum was issued from the
Manager, Operations to all site personnel concerning obtaining
authorization to operate in-plant equipment during surveillance testing,
maintenance activities, etc.
No further similar exam 31es of personnel operating plant equipment
without appropriate autlorization were identified.
M8.3 (Closed) Violation (50-346/95005-03(DRP)): Inadequate control of
consumable materials. This violation regarded the inspectors'
identification of a number of consumable materials that were available
for use in the plant but were not approved for certain applications.
The licensee's administrative controls to restrict issuance of non-
approved or limited use consumables were ineffective.
In response, the licensee substantially revised the materials control
program. Additional controls were placed on the receipt process
including changes to how materials were labeled, and how transfer of
material was made from the warehouse to local points of use.
III. Engineerina
El Conduct of Engineering
El.1 Enaineerina Followuo of Haddam Neck Containment Air Cooler Waterhammer l
Issue l
a. Insoection Scone (37551)
The inspectors conducted a review of the licensee's followup of an issue I
identified originally at Haddam Neck Nuclear Station. The issue
concerned the evaluation of whether voiding of con *ainment air cooler
(CAC) piping within containment could result in a subsequent waterhammer I
event that could damage associated piping during accident conditions. I
This was documented by the licensee in PCA0R 96-1025. This matter was '
under review by NRC Region III Division of Reactor Safety for specific
applicability to Region III plants.
16
4
__ _. __ _ _ - _ _ . . _ . _ _ . _ _ _ . - . _ _. _ _ - -
, .
l
.
~
.
, b. Observations and Findinas i
t
t
- During inspector followup of how the engineering evaluation was . !
- conducted at Davis-Besse, weaknesses were noted in the level of
familiarity that some engineering personnel had with Generic Letter 91-
3
i
18. Generic Letter 91-18 discusses guidance regarding operability ;
determinations and resolution of degraded and nonconforming conditions. '
! This matter was discussed with engineering management who agreed that I
. engineering familiarity with Generic Letter 91-18 guidance needed
- improvement. i
i
At the conclusion of the inspection period, the licensee was evaluating j
what. additional training was needed in this regard. Until that '
- determination is made and the additional training conducted for
appropriate engineering personnel, this matter is considered an
- inspection followup item (50 346/%006 06(DRP)).
- E2 Engineering Support of Facilities and Equipment
,
E2.1 Technical Soecifications Administrative Discrecancies
a. Insoection Scooe (37551)
The inspectors conducted a review of certain administrative requirements
,
in Section 6 of the plant's Technical Specifications (TS).
b. Observations and Conclusions
l
- Station Review Board Composition
1
Technical Specification 6.5.1.2 specified that the Station Review
i ~
Board (SRB) shall be comprised of at least six members from each
i of the following disciplines: Plant Operations Maintenance.
.
Planning Radiological Controls, Engineering, and Quality
i Assurance. However, the inspectors noted that the most recent
4
plant manager memorandum designated SRB membership did not include
the planning discipline as requiring representation.
-
The inspectors did note that several members did bring to the
i board expertise in the planning area, but the memorandum itself
did not expressly address the need to have all Technical
Specification required disciplines represented on the board.
. Discussions with licensee personnel revealed that a license
amendment request (LAR) was currently in process to relocate, in
i
part, the SRB requirements to the USAR. The current proposed date
i of submittal was to be December 1996.
I The inspectors did not have a concern over the overall quality of
current SRB reviews due to the identified discrepancy. Subsec uent
j to the inspection, the plant manager issued a revised memorancum
'
17
4
'
.
'
.
.
'
again specifying SRB comDosition, but also including the members
credited with representing the planning discipline.
. Inaccurate References to 10 CFR Part 20
TS 6.8.4.d.3, TS 6.9.1.5.a (Note 1), TS 6.12.1, and TS 6.15.a.2
referenced superseded paragraphs of 10 CFR Part 20.
Although Part 20 was revised several years ago, the associated
statements of consideration indicated that separate TS change
recuests for the. aforementioned specifics would not have to be
mac e. Rather, when a TS change request was being made for other
reasons, updated Part 20 references were to be included at that
time.
Subsequent guidance as to what should be included in the
associated references was discussed between the B&W Owners Group
and NRR. The intent apparently was to develop the guidance and
issue it to the industry in the form of a Generic Letter.
However, with a substantial amount of time having since elapsed,
the licensee recently decided to 3repare an additional LAR to
update the Part 20 references witlout waiting for generic letter
guidance. At the time of the inspection, that LAR was in the
preparatory phase.
c. Conclusion
The inspectors concluded that, overall, the TS administrative
requirements reviewed accurately reflected actual plant activities with
the exception of the aforementioned two minor items.
IV. Plant Sucoort
P2 Status of EP Facilities Equipment, and Resources
P2.1 Operations Suonort Center Comouter Terminal Ecuioment Not Available
The inspectors observed the performance of operations support center
(OSC) personnel and equipment during emergency preparedness training
drills conducted during September 1996.
The inspectors observed that on two occasions, computer monitor
equipment that provided information from the plant computer to
engineering support )ersonnel in the OSC did not operate correctly.
This was also noted )y licensee personnel with corrective action
planned.
Pending inspector evaluation of the licensee's resolution of this
deficiency, this is considered an inspection followup item (50-
346/96006 07(DRP)).
18
i
. . _ _ _ _ . _ . _ _ _ _ _ __ _ _ . _ _. _ _ _ _ - __ _ _ _ _ . _ .
-
.
+
>
.
a
[ R2 Status of RP&C Facilities and Equipment
During the inspection period, the inspectors conducted several walkdowns .
.
of the equipment spaces within the Radiological Restricted Area (RRA).
All observed radiation, high radiation and contaminated areas appeared
, 3roperly controlled and posted. Surveys were reviewed and determined to .
'
-
Je reflective of actual area radiological conditions. A sample of
survey instruments observed in use during the inspection period were :
assessed to be properly calibrated and functional.
'
V. Management Meetinas
j !
Exit Meeting Summary
'
X1
4 The inspectors -) resented the inspection results to members of licensee
'
management at t1e conclusion of the inspection on October 9,1996. The
licensee acknowledged the findings presented.
The in.?cectors asked the licensee whether any materials examined during the
inspection should be considered proprietary. No proprietary information was
identified.
.
t
i
l
i
!
!
19
_
. ._ _ _ . _ . _ .._ _ _ _ ___ _ _ _ _ _ _ . _ . _ . . _ _ . . - __ _
- .
\ *
.
,
i
PARTIAL LIST OF PERSONS CONTACTED
Licensee ,
J. K. Wood, Vice President, Nuclear
J. H. Lash, Plant Manager
R. E. Donnellon, Director. Engineering & Services
, L. M. Dohrmann, Manager, Quality Services ,
l J. L. Michaelis,. Manager, Maintenance ;
l J. L. Freels, Manager, Regulatory Affairs i
l G. A. Skeel, Manager, Security. '
l K. L. Tyger, Manager. Quality Assurance
l A. J. VanDenabeele, Supervisor. Quality Assurance
K. C. Prasad, Senior Staff Engineer
'
D. P. Ricci, Supervisor, Operations
D. M. Imlay,. Superintendent, Plant Operations
l D. L. Miller, Senior Engineer, Licensing
G. M. Wolf, Engineer, Licensing
M. K. Leisure, Senior Engineer, Licensing i
D. R. Wuokko, Supervisor, Nuclear Regulatory Affairs
D. H. Lockwood, Supervisor, Compliance :
R. A. Simpkins, Supervisor, Operations Training '
R. J. Scott. Manager, Radiation Protection
D. C. Geisen, Supervisor, E/C Systems
R. B. Ewing, Manager. D. B. Supply
C. A. Price, Manager, Business Services '
l
l
l
l
i
i
!
{ 20
p
w .
_ . .. _ . _ . _ _ . _ _ _ _ . - _ .- - _ - . _ . _ _ . _ . _ . _ _ - . _ . _ _ .
-
.
- l
INSPECTION PROCEDURES USED
IP 37551: Onsite Engineering
IP 40500: Effectiveness of Licensee Controls in Identifying, Resolving, and
Preventing Problems ;
j IP 61726: Surveillance 1
l IP 62707: Maintenance
IP 71707: Plant Operations 1
IP 92901: Followup - Operations !
IP 92902: Followup - Engineering
IP 92903: Followup - Maintenance
!
l
ITEMS OPENED. CLOSED. AND DISCUSSED
Ooened
50-346/96006-01A VIO Improper Documentation and Dispositioning of a Test
Deficiency
50-346/96006-02 IFI Reader / Worker Practices 1
50-346/96006-03 IFI EDG Functional Failure
50-346/96006-04 NCV Emergency Battery Light Tests Not properly Performed
50-346/96006-018 VIO Test Procedure Not Adequately Followed
50-346/96006-05 URI Potential Precondition 1ng of Remotely operated Valves
! 50-346/96006-01C VIO Emergency Ventilation System Inadequate Drawdown
Testing Control
50-346/96006-06 IFI Engineering Personnel Familiarity With Generic Letter 91-18 Guidance
50-346/96006-07 IFI Operations Support Center Computer Terminal Equipment
Not Available
Closed
50-346/96005-02 IFI Operator Shift Schedules Not Consistent With Technical
Specifications
50-346/96005-03 URI Emergency Ventilation System Inadequate Drawdown
Testing Control
50-346/94002-01 VIO Maintenance Personnel Manipulated Plant Equipment
Outside of Approved Maintenance Activities Without
Control Room Authorization
50-346/95005-03 VIO Inadequate Control of Consumable Materials i
50-346/96006-04 NCV Emergency Battery Light Tests Not properly Performed )
l
I
l
c
21
l
, - _ . , _ , _ -
--- ~ - - , . , - - . -
-
_ . _
_ - . _ . _ _. . - _ _ _ _ _ _ _ _ _ _ . . _ _ . - _ _ . _ _ . . _ . . _ _
,
'
.
-
,
.
4
LIST OF ACRONYMS USED I
'
ALARA As Low As Reasonably Achievable
ARTS Anticipatory Reactor Trip System ;
j ASME American Society of Nechanical Engineers ;
a B&W Babcock and Wilcox
4- )
BWST Borated Water Storage Tank !
3 CAC Containment Air Cooler
i CCW Component Cooling Water
CDF Core Damage Frequency
,
CFR Code of Federal Regulations
, CNRB Company Nuclear Review Board
! CRD Control Rod Drive
- CTMT Containment
- DHP Decay Heat Pump
J
! ESF Engineered Safety Feature
! EVS Emergency Ventilation System
j
HPI High Pressure Injection
- I&C Instrumentation and Controls
i IFI Inspection Followup Item
-
IR Inspection Report j
! ISI Inservice Inspection !
i LAR Licensee Amendment Request l
- LER Licensee Event Report i
! HCC Motor Control Center
j MWO Maintenance Work Order
i NCV Non-Cited Violation
i NDE Non-Destructive Examination 1
' NPB Negative Pressure Boundary l
- ~ NRC Nuclear Regulatory Commission !
NRR Office of Nuclear Reactor Regulation j
- DEFP Operational Experience Feedback Program
01 Office of Investigations (NRC) ;
i
Operations Support Center
'
i PCA0R Potential Condition Adverse to Quality Report
i 0A Quality Assurance
! OC Quality Control
R0 Reactor Operator
RP Radiation Protection
!:i RRA Radiological Restricted Area
1 SFAS Safety Features Actuation System
4
SRB Station Review Board
i SR0 Senior Reactor Operator
.
.
t
TS Technical Specification
UE Unusual Event
4
VIO Violation
4
] 22
,
i