ML20137C062
| ML20137C062 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 11/21/1985 |
| From: | Guldemond W, Holmes J, Maura F, Ulie J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20137C005 | List: |
| References | |
| 50-346-85-28, NUDOCS 8511260421 | |
| Download: ML20137C062 (22) | |
See also: IR 05000346/1985028
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
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Report No. 50-346/85028(DRS)
Docket No. 50-346' License No. NPF-3
Licensee: Toledo Edison Company
Edison Plaza
300 Madison Avenue
Toledo, OH '43652
Facility Name: Davis-Besse 1
Inspection At: Oak Harbor, OH .
Inspection Conducted: September 3 thorugh October 31, 1985
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Inspectors: . olm '
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Approved By: .G. emond, Chie f/u/p/
Operations Program Section Date ~
Inspec_ti_on
n Suninary
Inspection on September 3 through Octobe_r 31,1985(R_eportNo. 50-346/85028
(DRS)) Areas _ Inspected: ~EutTn'e,
t announced inspection to assess the tei:YnTEal
status of outstanding fire protection issues including a review of the fire
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protection program as it relates to the outstanding issues, and a review of
allegations received by the NRC relative to penetration seals. In addition,
leak testing of containment purge valves was reviewed. The inspection involved
a total of 138 inspector-hours onsite and in-office review by three NRC
inspectors including 17 inspector-hours onsite during off-shifts.
Results: In the four areas inspected, no apparent violations were identified
in three areas; one apparent violation was identified in the remaining area (no
procedure (s) existed which provided for the fabrication, installation, and
inspection of the plant flexible boot seals - Paragraph 4).
8511260421 851122
PDR ADOCK 05000346
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DETAILS
1. Persons Contacted
Toledo Edison Company
- B. Beyer, Nuclear Projects Director
- W. Connor, Assistant Plant Manager Operations
- T. Hart, Fire Protection Engineer
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- J. Helle, Nuclear Facility Engineer-Director
- J. Kapser, Mechanical Superintendent
D. Missig, Plant Engineer
- D. Momivez, Quality Assurance Supervisor
- M. Murtla, Fire Protection Engineer
- T. Myers, Nuclear Safety and Licensing Director
W. Nissia, Fire Protection Coordinator
- S. Quennoz, Group Director Nuclear Engineer
- L. Storz, Plant Manager
- A. VanDenabele, Project Manager
- S. Wideman, Senior Licensing Specialist
- J. Williams, Senior Vice-President
- J. Wood, General Superintendent-Facility Engineer
Cygna
- J. Haverly, Licensing Support
- D. Kosloff, Resident Inspector
- W. Rogers, Senior Resident Inspector
The inspectors also contacted other plant personnel. ,
- Denotes persons attending the exit meeting of September 6, 1985.
2. Action On Previous Inspection Findings
During the period July 11-29, 1983, the NRC conducted a special safety
inspection of the licensee's implementation of the requirements of
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10 CFR 50,' Appendix R (Sections III.G, J, L, and 0) and the fire pro-
tection program. Numerous deficiencies were identified during that
inspcction as documented in Part I of Inspection Report No. 50-346/83016.
Upon review of these deficiencies, the NRC concluded that certain issues
had to be resolved prior to plant restart. During September 1983, a
followup inspection was conducted to establish the status of those issues
identified as restart prereouisites. As identified in Part II of
Inspection Report No. 50-346/83016, all restart issues were satisfactorily
resolved; however, they were administrative 1y left open pending receipt of
a formal response from the licensee on those issues.
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During the period September 3 through October 31, 1985, a followup
inspection was performed by Region III inspectors to revisit a number
of issues identified in Inspection Report No. 50-346/83016: remaining
open. The status of those issues is discussed below.
a. (0 pen) Violation (346/83016-01A): The alternative shutdown capa-
bility for the control room and cable spreading room did not meet
the requirements of 10 CFR 50, Appendix R in that the initial
conditions assumed were not consistent with the range of fires which
could be postulated, interaction of circuits of concern was not
addressed, it failed to uniquely address loss of offsite power, it
failed to adequately address the use of pressurizer heaters, it was
not totally independent of the control room and cable spreading room,
it failed to provide for achieving cold shutdown in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, and the
alternate shutdown panels lacked indications of neutron flux and plant
temperature. The licensee has re-evaluated the station level of com-
pliance with the requirements of 10 CFR 50, Appendix R, Sections III,
G, J, L, and O. The results of this review were submitted to the NRC
in September 1984 as the Appendix R Compliance Assessment Report
(CAR). The CAR identifies the licensee's impression of their specific
degree of compliance with Appendix R, identifies the procedural or
physical modifications required to bring the plant into compliance
with the regulation, and, in specific areas, requests exemptions from
specific requirements of Sections III, G, J, L and O. While the NRC
has not acted yet on the CAR, the licensee is proceeding with the
implementation of the corrective actions described in the report.
The inspection of this item involved a review of specific items as
described in the CAR, station procedures, and different tracking
systems being used by the licensee to ensure that procedural and
physical corrective actions are carried out. During this review, it
was noted that the documents did not generally agree with each other.
The licensee stated that since the CAR was issued, additional analyses
have been completed which are reflected in the summary of fire protec-
tion activities report, but that the tracking systems only reflect
Revision 0 of the CAR. The licensee agreed to, by March 6, 1986,
submit to the NRC a revised CAR and Fire Hazards Analysis Report
(FHAR) identifying all analysis work required to ensure compliance
with 10 CFR 50, Appendix R and any other commitments in the area of
safe shutdown and fire protection and to update all tracking mechan-
isms to correctly reflect all modifications required to bring the
plant into compliance as stated in the revised CAR and FHAR.
With respect to the specific findings identified as part of violation
346/83016-01A, the following findings were made:
(1) As indicated in Part II of Inspection Report No. 50-346/83-16,
the licensee developed procedure AB 1203.26, Serious Control
Room Fire, to address the necessary actions to achieve hot
standby and subsequent cold shutdown in the event of a fire
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resulting in total loss of the control room or cable spreading
room accompanied with loss of offsite power. The procedure is
considered " interim" since it contains a number of repair acti-
vtties required to achieve hot standby, pending satisfactory
completion of the modifications required to meet Appendix R.
This portion of this item remains open.
(2) The CAR has identified that, in a majority of the fire areas,
the pressurizer heaters remain available for pressure control;
however, in five specific areas where both trains of pressurizer
heaters could be lost as a result of a fire, the plant would
proceed to cold shutdown as directed by procedure AB 1203.02,
Serious Station Fire. As a result, the licensee does not con-
sider the pressurizer heaters as a required safe shutdown
component. The inspector reviewed procedure AB 1203.02 for two
(A and D) of the five fire areas identified in the CAR where the
heaters could be lost and noted that the procedure for fire
area A (Attachment 16.35 to AB 1203.02) "RCS System", identifies
the heaters as equipment affected, but does not require the
operators to proceed to cold shutdown. The licensee had stated
earlier, that all procedural changes required by the CAR had
been completed. As a result, the licensee will re-review all
the procedural changes required by the CAR to ensure they have
been performed. This portion of the item remains open.
(3) During the July 1983 inspection, it was determined that for a
control room / cable spreading room fire with loss of offsite
power, the licensee was not capable of achieving cold shutdown
within the required 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. On September 30, 1983, the
licensee requested an exemption from the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> requirement of
Appendix R,Section III.L.1. The NRC granted the exemption on
August 20, 1984; therefore, this issue is resolved and this
portion of this item is closed.
(4) With respect to the missing process variables necessary to
perform and control reactor shutdown from outside the control
room, the licensee plans to provide source range flux and
reactor coolant temperature (Th and Tc for both loops) indica-
tion outside the control room. Specific completion dates for
these modifications have not been established. Inspection
Report No. 50-346/83-16, Part II, describes the NRC accepted
interim measures being used to compensate for the present lack
of these process variables. This portion of the issue remains
open.
Violation 346/83016-01A remains open pending completion of all
procedural and physical modifications required to bring the plant
in compliance with Appendix R, NRR acceptance of the licensee's pro-
posed resolutions including all requested exemptions in this area,
and a satisfactory reinspection to ensure compliance with the
regulation.
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b. (0 pen) Violation (346/83016-01B): Failure to perform a spurious
signal analysis for valves in the service water discharge line, the
pressurizer Power Operated Relief Valve (PORV) and block valve, and
the letdown cooler isolation valves. Prior to restart after the
July 1983 inspection, the inspectors verified that the licensee had
taken procedural actions to ensure that at least one of the four
service water discharge valves is normally open and de-energized to
assure a service water flow path regardless of fire location, and that
the PORV block valve (RC-11) and the letdown isolation valve (MU2B)
would be closed prior to control room evacuation. This was documented
in Part II of Inspection Report No. 50-346/83016.
In the case of the service water discharge valves, these actions
provide a permanent acceptable fix.
The CAR addresses the concern of spurious signals activating any of
these valves. In the case of the PORV and its block valve, RC-11,
the analysis showed that a single fire in one area, Area U, could
cause the PORV to open and simultaneously prevent closure of RC-11,
thereby producing an unisolable leakage path from the reactor coolant
system. The licensee has proposed wrapping cable tray 1CJM with
a one hour fire barrier to ensure the operability of valve RC-11.
The licensee had scheduled this activity for completion prior to
startup following the next refueling outage; however, Region III has
recommended to NRR that completion of this modification be made a
condition for startup from the current outage.
In the case of the letdown coolers' inlet and outlet isolation valves,
the analysis indicates that a fire in containment could disable both
valves; however, isolation capability can be provided by a third
isolation valve (MUO3) downstream of the other two valves for either
cooler. Valve MUO3 is a normally open air operated valve which fails
closed on loss of power. Its circuits are not within containment.
The inspector verified that procedure AB 1203.02, Serious Plant Fires,
Attachment No. 43 addresses the closing of MUO3 if the primary isola-
tion valves for the letdown coolers are affected; however, it was
noted that there is a lack of guidance available to the operator to
make the determination that the isolation valves for either letdown
cooler have remained open.
This item will remain open pending a revision to procedure AB 1203.02
to adecuately reflect operation of valve MUO3, and satisfactory
resolution of the concerns related to simultaneous spurious operation
of the PORV and its block valve.
c. (Closed) Violation (346/83016-07): Reactor coolant pump cil collec-
tion systems not capable of holding the entire lubricating oil system
inventory. On September 30, 1983, the licensee requested an exemption
from the requirements of 10 CFR 50, Appendix R, Section III.O. to have
a reactor coolant pump oil collection system large enough to hold the
entire lubricating oil system inventory. On August 20, 1984, the NRC
granted the exemption, resolving this issue.
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d. (Closed) Open Item (346/83016-08): Failure of procedures to address
spurious actuation of decay heat isolation valves. Prior to restart
following the July 1983 inspection, the licensee revised procedure
SP 1104.04 to require deenergizing one of the two motor operated
valves, DH-11 or DH-12, in the decay heat removal system. This is
documented in Part II of Inspection Report No. 50-346/83016, and is
considered an acceptable permanent resolution to this issue.
e. (0 pen) Open Item (346/83016-09): Failure to perform an analysis to
determine the level of Gaitronics Communication system operability
that would remain after a control room / cable spreading room fire. At
the conclusion of the September 1983 inspection, prior to plant
restart, (Inspection Report 50-346/83016, Part II), the inspectors
determined that the licensee had developed procedures to ensure an
adequate alternate means of communications using portable handheld
VHF radios. The CAR addresses the communications problem, identi -
fies the need for a sound powered phone system, and the need to
determine if additional equipment is required after the communication
needs for shutting dcwn the plant are identified. The installation
of the sound powered phone system was completed in May 1984. The
licensee stated that an informal field verification test was performed
to ensure that adequate communication systems were available for
the implementation of safe shutdown procedures (AB 1203.02 and
AB 1203.26). The licensee agreed to perform and document a formal
verification test.
Pending the completion of the formal test to verify that adequate
communication systems are available to implement AB 1203.02 and
AB 1203.26, this item remains open.
f. (0 pen) Unresolved Item (346/83-16-14): Automatic sprinklers not
installed in accordance with Chapter 4 of NFPA 13 in 19 areas
containing equipment required for safe shutdown. Specifically,
the systems do not appear to adequately accommodate ceiling
congestion.
Applicable requirements include Section 4-2.5 of NFPA 13 (1978) whit.n
requires that a minimum of 18 inches clearance be maintained between
the top of storage and ceiling sprinkler deflectors. Section 4-3 of
NFPA 13 (1978) requires that deflectors of sprinklers be located not
less than 1 inch or more than 22 inches from ceilings. Section 4-4.13
of NFPA 13 (1978) permits the installation of sprinklers beneath ducts
over four feet wide if ceiling sprinklers cannot be spaced in
accordance with Table 4-2.4.6 and Section 4.3 of NFPA 13.
A review of the NRC's correspondence to the licensee (J. F. Stolz-NRC
to L. E. Roe-TED) dated October 3, 1978, identified that the NRC
apparently endorsed the installation of sprinkler systems below
obstructions in heavily congested ceilings in certain areas. It is
not clear that this correspondence also endorsed not installing
sprinklers above the obstructions as required by NFPA 13. The
licensee is committed to NFPA 13 by Paragraph 6 of Section 2.1 of the
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fire protection SER for Davis-Besse dated July 26, 1979, which states
in part, " Automatic sprinkler systems...are designed to the require-
ments of NFPA Standard 13." Additionally, Section 9.5.1.2.1 of the
Updated Safety Analysis Report (U.S.A.R.) Revision 0, dated July 1982,
does not identify any deviations from NFPA 13. Thus, prior to the
inspection documented in Inspection Report No. 50-346/83016, the
licensee had not formally identified to the NRC that sprinkler system
design did not conform to NFPA 13.
A May 18, 1979 correspondence to the licensee from their Architect-
Engineering (AE) firm (M. Malcolm of Bechtel to J. Balfour, Jr. of
TED) identified that the sprinkler installations deviated from the
requirements of Chapter 4 of NFPA 13 because the ceiling spaces are
heavily congested with large diameter steel piping, rigid steel
conduits, and steel cable trays with solid bottoms. The justifications
provided by the AE firm for the deviations were that:
(1) The Nuclear Regulatory Commission (NRC) has requested that the
sprinkler heads be placed in such a manner that they will
adequately control and extinguish any fire that could initiate
on the floor and cause an exposure to equipment required for
(2) The ceiling spaces of the various rooms which are to be
sprinklered, are heavily congested with large diameter steel
piping, rigid steel conduits, and steel cable trays with solid
metal bottoms. The cabling in the cable trays has been fire
tested and has proved to be a non propagating fire retardant
type. The tops of the cable trays are enclosed with a 2 inch
thick Kaowool thermal blanket which has a fire resistive rating
of 1/2 hour. Hence, the equipment located within the ceiling
spaces is considered to be non-combustible.
(3) With the sprinkler heads located near the ceiling slab,
inadequate sprinkler water distribution and accessibility
to the heads for inspection and replacement would exist. ,
(4) The heavy congestion of piping, cable trays, and conduits in the
ceiling space c. eates a false ceiling effect, which in turn
creates an area of heat collection below the lowest level of
cable trays and conduits, thereby ensuring timely actuation of
the sprinkler system.
As noted above, this was not officially brought to the attention of
the NRC prior to the inspection documented in report 50-346/83016.
In response to the findings of inspection report 50-346/83016, the
licensee provided justification for the deviations from the
requirements of NFPA 13, in their September 13, 1983 submittal to
the NRC (R. P. Crouse-TED to D. G. Eisenhut-NRC, Serial No. 986).
Additional information on this subject was provided in an August 28,
1984 letter from the licensee to the NRC. In both submittals, in
addition to the justification provided by the AE, the licensee makes
reference to a Union Carbide test that was conducted for the NRC.
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The inspectors noted that this test was conducted to determine the
feasibility of installing sprinklers three feet below the ceiling, not
as much as approximately fifteen feet below the ceiling as is the
case in some configurations at Davis-Besse. Although some of the
sprinkler configurations tested resulted in acceptable actuation
times for fast developing fires, the test summary points out that
not all fires envisioned in the test occupancy would begin as rapidly
as the test fire. Any slow buildup of heat due to smaller fires would
result in a delay of sprinkler actuation. Figure II of the test
report indicates that in some of the tested sprinkler configurations,
delayed sprinkler actuation averaged more than seven minutes. More
significant is the fact that the room or enclosure configuration used
in the test had a three foot wide opening in the ceiling running the
length of the enclosure which created a chimney effect. The inspec-
tors did not observe this type of room or enclosure configuration at
the Davis-Besse facility. The complexity of piping, fixtures, and
structural interferences that initiated the Union Carbide test was
not described in the test report; therefore, there is no clear
correlation between the configuration at Davis-Besse and that of
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the Union Carbide test.
Because of the apparent inconsistencies discussed above, it is not
clear that the NRC has formally accepted the licensee's justification
for this deviation from NFPA 13. During this inspection, the licensee
indicated that although their position is that NRR approved this
deviation, an independent fire protection consultant has been employed
to provide a documented technical evaluation of the sprinkler
installations in question, which will include recommendations
concerning adequacy. Purchase Order No. 035-F-87391-A-MB verified
the licensee's procurement of the fire protection consulting firm's
services for this purpose.
This item will remain open pending NRC review of the licensee's
reevaluation of system adequacy.
g. (0 pen) Unresolved Item (346/83-16-17): The post indicator valves and
fire hydrants throughout the plant yard are accessible to mechanical
damage from vehicular traffic. No permanently affixed physical
barriers (concrete or steel post) are installed to protect these fire
protection features from such damage as required by National Fire
Protection Association (NFPA) Standard 24.
The licensee provided additional information in letter Serial No. 986,
dated September 13, 1983, and in the " Fire Protection Activities
Summary," dated September 3, 1984, and concluded that hydrants
identified during the 10 CFR 50 Appendix R audit are located within
the protected area where vehicular traffic is held to a minimum. In
addition, all post indicating valves and hydrants are of the breakaway
type.
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In a telephone conversation between Regian III and NRR during the
week of October 14, 1985, NRR indicated that permanent affixed
physical barriers should be installed to protect the post indicator
valves and fire hydrants as required by NFPA 24.
Also during the week of October 14, 1985, the licensee was notified
of the results of the telephone call between Region III and NRR
regarding the physical barriers for the post indicating valves and
fire hydrants.
In a telephone conversation on October 31, 1985, between the
licensee and Region III, it was discussed that the licensee
consnitted to installing physical barriers for the post indicating
valves and fire hydrants and that the work is presently in
progress.
This unresolved item will remain open pending verification of
installed physical barriers for the post indicating valves and
fire hydrants.
h. (0 pen) Unresolved Item (346/83-16-18): Approved pressure reducing
devices on standpipe hose station outlets are required where the
water pressure exceeds 100 psig according to Chapter 4, Section 4-7
of NFPA 14 The inspectors observed the static pressure on automatit:
sprinkler and standpipe hose stations to be at or above 150 psig.
Examination of hose stations indicated there were no pressure reducers
installed on standpipe hose stations throughout the plant as required
by NFPA 14.
As discussed with the licensee, pressure reducing devices should be
installed. As an alternative. solution, the licensee could train the
fire brigade on the maximum pressure that will be encountered when
utilizing fire hose stations. Additionally, the licensee would have
to clearly indicate to all employees that the fire hose stations are
-for use by the trained fire brigade only. Finally, signs indicating
that the fire hose is for fire brigade use only, would have to be
located at the fire hose station.
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In a telephone conversation on October 31, 1985 between the
licensee and Region III, the licensee conunitted to utilizing the
alternative solution.
This unresolved item will remain open pending review of licensee's
actions by Region III.
i. (0 pen)OpenItem(346/83-16-19): Technical Specification 3.3.3.8
specifies, "With the number of operable fire detection instrument (s)
less than the minimum of operable requirement of Table 3.3.14...."
Throughout the licensee's FSAR and FHA, the coninitment was made
to install fire detectors in accordance ..th NFPA 72D. NFPA 72D
requires that fire detectors be installed in accordance with NFPA 72E.
NFPA 72E specifies minimum installation and spacing requirements for
fire detectors.
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In the " Fire Protection Activities Summary" dated September 3,1985,
the licensee indicated that the rationale as to why the minimum number
l of detectors in Table 3.3-14 of the Technical Specifications is less
! than the total number of detectors required for some zones is the
conservative design approach which was used in their layout. The
design exceeded the minimum spacing requirements of NFPA 72E-1978,
which created areas of overlapping protection. This overlapping pro-
tection is why one or more detectors, as long as no two are adjacent,
can be out of service and still provide protection to the zone being
protected.
In discussions with the iicensee, it appeared that several areas did
not have adequate coverage with the minimum number of fire detectors
operable as indicated in the Technical Specification 3.3.3.8, because
l of the pocket beam criteria, it was also discussed that when two
adjacent detectors are out of service, adequate detection may not be
provided even though the minimum number of fire detectors as indi-
cated in Technical Specification LC0 3.3.3.8 has been achieved.
In a telephone conversation on October 31, 1985 between the
licensee and Region III, the licensee coomitted to review each fire
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area against NFPA 72E and revise the Technical Specification that
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when the minimum number of detectors are out of service, adequate
detection will be available.
This item will remain open pending Region III's review of the
licensee's actions.
- j. (0 pen)OpenItem(346/83-16-20)
- The 1980 Fire Protection Audit by
l Professional Loss Control Inc., Section 3.3.3, identified the possi-
bility of cold soldering of sprinkler heads due to water curtain and
sprinklers installed at elevation 657 feet in the heater bay area.
(Cold soldering occurs when water from one sprinkler cools down the
heat sensitive element in another sprinkler which prevents operation
of the sprinkler being wetted.)
The licensee's " Fire Protection Activities Summary", dated
September 3,1985, stated that the suppression at the 657 foot
elevation is comprised of two independent systems. The first system
has its sprinkler heads located between the roof's beams near the
roof underside surface. The second system has its sprinkler heads
uniformly distributed under the roof's beams to provide coverage of
the area of interest below.
This type of design is described in NFPA 13-1978 under Section 4-2.3.
which gives permissible locations of sprinkler heads either under
beams or under a roof or ceiling. A combination of these two posi-
tions is permissible provided the clearance and positions outlined
in Section 4-2.4 and 4-3 are followed. In addition, the licensee's
internal memorandum of August 20, 1981, Item 5, indicates that
Grinnell Fire Protection Systems Company, Inc., performed a design
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review of these systems and the design was modified to eliminate the
possibility of cold soldering of sprinkler heads. The licensee also
has a contract with Professional Loss Control to provide an evaluation
on the effects of cold soldering and develop recommendations (Toledo
Edison Purchase Order 035-F-87391A-MB). This item will remain open
.pending review of the documentation of an evaluation on the effects
of cold soldering.
k. (0 pen) Violation (346/83-16-22): Failure to Develop Adequate
. Surveillance Test Procedures, Administrative Controls and Quality
Assurance.
(1) (0 pen) Noncompliance (346/83-16-22a): Fire pump testing
procedures are inadequate.
(a) The electric and diesel annual fire pump flow test
procedures for 1980, 1981, 1982, and 1983, did not specify
a " shutoff" (no flow) test as required by NFPA 20.
The licensee has incorporated the " shut-off" test as
required by NFPA 20 in the Ciesel Fire Pump Annual Flow
Test Surveillance Procedure ST 5016.12 (Davis-Besse
Temporary Modification Request dated July 3, 1985) and
in the Electric Fire Pump Annual Flow Test Procedure
ST 5016.03 (Revision 5 dated April 2, 1984). This part
of the item is considered closed based on the licensee's
corrective actions.
(b) The electric fire pump annual flow test procedure did not
specify measurement of vibration at peak load conditions
(150 percent of rated capacity) as required by NFPA 20.
Electric Fire Pump Annual Flow Test (Surveillance Test
5016.08) Section 5.3 states, " Maintenance personnel are
available to record vibration data on the pump at all
levels of flow during the test (i.e., 1250, 2500,
3750 gpm)." This part of the item is considered closed
based on the licensee's corrective action.
(c) The diesel fire pump annual flow test procedure for 1980,
1981, 1982, and 1983, did not specify measurement of pump
speed (rpm), flow to 150 percent of rated capacity at
65 percent of rated head, or measurement of vibration at
peak load conditions as required by NFPA 20.
Diesel Fire Pump Flow Capacity Test (Sheets 1, 2, 3 of
Enclosure II), of the Diesel Fire Pump Annual Flow Test
(Surveillance Test 5016.12.5) includes measurements for
pump speed (rpm) and flow to 150 percent of rated capacity
at 65 percent of rated head; however, there is no provi-
sion or specific requirement in the surveillance test to
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take measurements of vibration at peak load conditions as
required by NFPA. As previously identified in Report
50-346/83016, the licensee should specify measurement of
vibration at peak load conditions as required by NFPA.
This portion of this item remains open.
(d) The diesel and electric fire pump test results for 1980,
1981, and 1982 were not properly evaluated to determine
their acceptability. No characteristic curve was plotted
from the test result to compare with the original
manufacturer's certified shop test curve and acceptance
test curve.
The licensee has submitted characteristic curves developed
from the 1980, 1981, and 1982 diesel fire pump test;
however, it is unclear how the curves were developed since
the data sheet did not include pump speed (rpm), pressure
corrections, or suction head.
The licensee provided the inspector with the August 22,
1984 diesel fire pump test results which included a
characteristic curve; however, it is also unclear in this
test how the characteristic curve was developed because it
does not appear that the corrections for pump speed or
suction head were included. This portion of this item will
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remain open pending review of the licensee's corrective
actions.
(2) (0 pen) Noncompliance (346/83-16-22b): Contrary to the NRC
Supplemental guidance, entitled " Nuclear Plant Fire Protection
Functional Responsib111 ties Administrative Controls and Quality
Assurance" (supplemental guidance), surveillance test procedure
5016.09 did not specify verifying fire protection system valve
operability weekly, monthly, and annually as required by NFPA 26.
The licensee's " Fire Protection Activities Summary" dated
September 3, 1985 stated, "NFPA 26, 1976, Chapter 3, allows a
monthly inspection if valves in the fire system flow path are
locked or sealed open."
The inspectors reviewed NFPA 26, 1976, Chapter 3 which states
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"A systematic weekly inspection (or monthly in the case of
locked-open valves) of each valve should be made, and a report
! form used to record the condition of each valve." The licensee
is requested to conduct weekly inspections if seals are to be
utilized or monthly inspections if valves are to be locked open
as required by NFPA. This part of the Violation (346/83-1G-22) ,
will remain open pending review and acceptance of the licensee's
submittal.
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(3) (Closed) Noncompliance (346/83-16-22c): Automatic sprinkler
system test results for 1980,1981, and 1982, did not verify
simulation of actuation of the most remote sprinkler head by
opening the inspector's test valve on the system as required by
the surveillance test procedure. According to the licensee's ' *
staff, this test is not performed as required b'y NFPA 13A.
Instead only a two inch drain test is perfornied at the-base
of the sprinkler system riser.
During this inspection, the licensee indicated that the
inspector's test for the wet sprinkler systems has been
conducted since 1980 and that the previous information given
to the inspector was incorrect. The licensee explair.ed that
the individual that provided the previous inspector with the
information was not familiar with the inspector's test. The
inspector was provided with Surveillance. Test Procedure
ST 5016.07 entitled " Fire Protection System Automatic Sprinkler '
Syrtem" which requires the inspector's test to be conducted on
the wet sprinkler system. In addition, the inspector was
provided with the 1981, 1982, and 1985 inspector's tests for '
the wet sprinkler system. The licensee indicated that the 1980
inspector's test was conducted; however, test ro ults could not
be located. The upgraded procedures were reviewed and it was
verified that the inspector's test is currently being conducted ,
and also that the inspector's test has been conducted since at
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least 1981. This portion of the item is close'd.,
(4) (Closed) Noncompliance (346/83-16-22): Contrary to the NRC )"
supplemental guidance, surveillance test procedure ST 50.16.06, '
did not specify measurements of sensitivity, periodid clCaning, -
and adjustment of photo electric fire detectors as required by -
NFPA 72D and NFPA 72E. The test proceduro specified an unsafe
practice in that it required use of an "open flame" to test fire ,
detectors rather than a " puff" test as specified by NFPA 72E.
(a) Fire Protection Activities Sumary dated September 3,1985,
indicated that Surveillance Test Procedure ST 5016.06,
Fire Detector Functional Test, allows the issuance of a
Maintenance Work Order in conjunction with the conduct of
this test to document and correct any deficiencies found
while performing this test such as needed cleaning or
adjustment. This is adequate to ensure that cleaning and, ~.,
adjustment of detectors occurs. This part of violation N
(346/83-16-22d)isconsideredclosed. - ,
(b) Fire Protection Activities Summary, dated September 3, 1985,
indicates that the test procedures specified an unsafe
practice in that they specified use of an "open flame" to
test fire detectors rather than a " puff" test as specified
by NFPA 72E. The reference to the use of an "open flame"
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to test fire detectors has been removed from ST 5016.06.
In addition, the licensee further indicates that an "open
flame" has never been used at Davis-Besse to test any
detectors.
. This part of the violation (346/83-16-22) is considered closed.
(5) (Closed) Noncompliance (346/83-16-22e): Periodic Test procedure
PT 5112.01 did not specify quarterly surveillance of emergency
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lighting units, or an 8-hour discharge test and periodic
replacement of batteries in accordance with the manufacturer's
recommendations. The inspector reviewed Revision 8 of Periodic
Test Procedure PT 5112.01 titled, " Emergency Lighting System
Test," and determined that the surveillance checks noted above
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have been incorporated into the current procedure. The current
procedure includes a monthly, quarterly, and annual surveillance
test of each individual eight hour emergency lighting unit,
having the integral batteries tested on a staggered frequency.
This is to prevent a total blackout should an emergency occur.
The licensee's emergency lighting surveillance test program, as
verified by the inspector, also incorporates the lighting unit
manufacturer's recommendations. The licensee provided documenta-
tion showing that 23 new emergency lighting batteries were
installed in February 1984, replacing previously installed
batteries as part of the licensee's corrective action in main-
taining the emergency lighting units.
(6) (Closed) Noncompliance (346/83-16-22f): Contrary to the NRC
supplemental guidance, Administrative Procedure AD 1828-20, " Fire
Brigade Training," does not specify the minimum physical
requirements for fire brigade members as required by NFPA 27.
Interviews with the licensee's staff indicated that no separate
physical examinations are required for fire brigade members at
Davis-Besse Nuclear Power Station; however, Step 5.2.3 of
procedure AD 1810.00 Revision 7 indicates that fire brigade
members shall have completed the respiratory protection plan in
accordance with procedure HP 1605.02. Step 6.4 of procedure
HP 1605.02, Revisions 11 and 12, dated November 8, 1984, revised
since the July 1983 inspection, requires that each individual
being certified to wear respiratory protection equipment shall
have an initial physical examination, the results of which will
be reviewed by a physician who will, and annually thereafter,
review each certified individual's medical status. The physician
will make the recommendation in writing. The procedure identi-
fled 13 clinical conditions which the physical examination covers.
These requirements are acceptable.
(7) (Closed) Noncompliance (346/83-16-22g): Contrary to the NRC
supplemental guidance noted above, Administrative Procedure
AD 1810-01 did not specify fire watch training, or that the fire
watch remain on the work site while the work is performed, and
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remain in the area for at least 30 minutes after the work.is
t completed. NFPA 51 and 518 require that a fire watch be trained
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and equipped to prevent and combat fires, and that the fire watch--
remain on the. work site for at least 30 minutes after the work
b is completed to check for smoldering fires. -The licensee's staff
provided no documented evidence that contractor personnel per-
. forming fire watch duty.are required. to be-trained in the use of
3 ffire protection equipment and fire prevention.
The current Administrative Procedure' covering the Fire Watch
Qualification Program is AD.'1828.19, Revision 2, dated
December 19, 1984. Steps 4 and.5 now include the minimum
instruction.an individual contractor and onsite personnel are
k to receive to. qualify as a fire watch during open flame, welding,
grinding, and cutting. operations. This instruction consists of
- .both classroom training and practical training in the use of
fire extinguishers. Fire watch requalification is required on
an annual basis. Based on the above, the inspector determined
the licensee to be meeting their commitment to NFPA SIB. In
-addition, TED has' incorporated a second type of fire watch given
the title of " Fire Barrier Watch," defined as an individual
trained in the> formal process for notification of the security
, force'and Shift ~ Supervisor that.a fire' exists. This individual
will be trained through General Orientation Training in the use
and operation of plant communication systems. The sole purpose
r of this individual:is to monitor potentially degraded fire doors,
j -dampers, barriers, and other items which degrade the adequacy
{ of the fire protection program.
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Step 4.4 of Administrative Procedure AD 1844.07, Revision 2,
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dated April 22, 1983, includes the necessary responsibilities
of personnel performing activities associated with open flame,
1- -welding, grinding, and cutting operations as described by NRC
supplemental guidance documents and NFPA SIB, including having
the fire watch remain at the work area for a minimum of thirty
, minutes after the work activity is completed to check for
smoldering fires.
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! (8) -'(Closed) Noncompliance (346/83-16-22h): . Backup fire fighting
capability from offsite fire departments. The previous inspector
verified in Report 83016 that by letter dated-August 31, 1985,
- the Assistant Fire Chief of Carroll Township. Emergency Medical _ ,
and Fire' Service, Incorporated, had agreed to provide-fire pro-
j tection in accordance with the Davis Besse Emergency Plan. The
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licensee had prepared Revision 7 (not. Revision 5 as previously
identified in Report 83016) to the Emergency Plan which indicated
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.that when answering to a call for assistance in fighting fires,
the offsite fire 3 department will operate under'the direction of.
the licensee's fire brigade. The licensee committed to complete
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the. revision by November 1, 1983.
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In the letter dated November 16, 1983 from R. Crouse, TED to
J. Keppler, R-III, the Approved Modification Request to the
-Emergency Plan concerning the offsite fire department support
was provided for commitment completion verification. This item
is considered. closed based on the corrective actions documented
in the previous letter.
(9) (0 pen) Noncompliance (346/83-16-221): Specific qualifications
and responsibilities for individuals responsible for implementing
- the fire protection program are specified in Table 4-1 (Sheet 1)
-of'the licensee's'FSAR for Davis-Besse, and in Section 2.0 of
NRC supplemental guidance document.
The following discrepancies existed in the licensee's personnel
qualification requirements for fire protection / prevention
program implementation:
(a) Interviews with the licensee staff disclosed that only the
fire protection coordinator has direct responsibility for
the fire protection program at the site. Other licensee
' staff are periodically assigned various fire protection
responsibilities a small percentage of.the time. Sufficient-
documentation was not available at the time of the inspec-
tion, including a TED Table of organization, showing the
responsible fire protection personnel'and their interface
to the fire protection program. This portion of the item
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will remain open pending further review of the licensee's
commitment and other related information.
(b) The fire protection coordinator and the-fire marshal are
the same individual, whose demonstrated knowledge of fire
protection-is vested in his training and experience as a
volunteer firefighter. Attachment No. 1 of the NRC supple-
mental guidance document describes the responsibilities of
the fire protection organition including the onsite position
commonly referred to as either the plant " fire protection
coordinator" or plant " fire marshal." According to the
guidance document, the onsite position (s) responsibilities
include. implementing periodic fire protection inspections,
training, assisting in the critique-of all fire drills,
review of proposed work activities for transient fire loads,
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- implementation of a program for contractor personnel in
- administrative procedures, and instruction of personnel on
other related fire protection topics.
According to the licensee, three individuals now hold the
- position of." fire protection coordinator". Subsequent to
the inspection the licensee provided copies of these indi-
L viduals resumes to the inspector for review. The following
i information was derived from each individual's resume:
(1) Individual No. I currently has twelve years of combined
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nuclear fire protection experience attaining " reactor
operator" status and-lead fire protection responsibility
including emergency medical experience. Further, this
individual has attended numerous fire protection seminars
totaling in excess of six hundred and seventy five hours;
'(2)-Individual No. 2 currently has ten years of combined
nuclear fire protection experience attaining " auxiliary
operator" status, advancing through the operator qualifi-
cation program and also lead fire protection responsibility.
This individual has attended some. twenty-five fire
protection related seminars since 1975; and (3) Individual
No. 3 currently has in excess of eight years fire protection
experience including nuclear experience and an extensive
emergency medical and fire training background. This
individual has also attended numerous fire safety seminars
and is a certified Ohio firefighter satisfying the required
two hundred hour training program. According to the
resumes, each of these individuals utilize their talents
towards nuclear fire safety as part of their responsibili-
ties at Davis-Besse. Based on the above, the inspector
concluded that these individuals' academic and work experi-
ence satisfy NRC guidelines "equired of licensee fire
protection personnel. This portion of the item is
considered closed.
(c) There is no qualified fire protection engineer who is a
graduate of an engineering curriculum of accepted standing
in fire protection engineering on the licensee's staff or.
onsite as a consultant. During an NRC Fire Protection
inspection conducted during June 1984, the licensee's
position was that a qualified fire protection engineer is
on the TED staff at the Davis-Besse site. According to the
NRC supplemental guidance document, the qualifications of a
fire protection engineer should include one who is a
graduate of an engineering curriculum of accepted standing,
and who shall have completed not less than six years of
engineering competency and achievement, three of which
shall have been in responsible charge of fire protection
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engineering work. These requirements are the eligibility
requirements as a member in the Society of Fire Protection
Engineers.
At the time of the Appendix R Fire Protection / Safe Shutdown
inspection (July 1983), the individual on the licensee's
staff in the position of fire protection engineer was not a
member of the Society of Fire Protection Engineers (SFPE)
and therefore had not had his academic and work history
evaluated to be qualified as a " member" grade in the SFPE.
Additionally, this individual was'not devoted full time to
the area of fire protection.
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Since the Appendix R, Fire Protection / Safe shutdown
inspection, this individual has had his academic and work
history evaluated by SFPE's and was qualified as a " member"
grade in the SFPE in October 1983. The inspector also met
with the General Supervsior-Facility Engineer to discuss
the present scope of the fire protection engineer's job
responsibilities. The inspector was assured that since
July 1983 the fire protection engineer's sole responsibility
was fire protection and that all other non-related responsi-
bilities have been reassigned to other personnel.
This individual is a member of the Fire Task Group Team and
has been since its inception.
Further, since the June 1984 inspection, an additional fire
protection engineer as described in NRC criteria has been
added to the TED staff in the Nuclear Facility Engineering
Department. This portion of the item in considered closed.
(10) (0 pen) Noncompliance (346/83-16-13 and 346/83-16-22j): Failure
to establish a fire watch on inoperable fire dampers and an
inadequate surveillance test procedure. In the Report 346/83-16,
section entitled " Details - Part II" (pg 43), it states, "The
inspector verified that procedure ST 5016-11 had been revised
and its implementation was observed by the inspector on
September 8, 1983 and found acceptable". This portion of the
Open Item is closed.
The open item previously discussed also states "Due to the high
failure rate that occurred during the fire damper surveillance
retests, the licensee has committed to an on going testing
program of all dampers until the confidence level increases.
This program, plus the schedule completion date for the
remaining fire dampers yet to be tested, will be submitted to
Region III by November 30, 1983 after an engineering analysis
is performed on locating and evaluating any necessary work
needed to perform the surveillance test. As discussed on
October 31, 1985, the licensee committed to provide Region III
a summary or history of events and corrective actions regarding
this portion of the Item. This item will remain open pending
Region III review and acceptance of the licensee's submittal.
3. Containment Purge Valves
The containment inlet and outlet purge valves (4) were inspected, and the
general local leak rate testing method was discussed with the licensee to
ensure that no possible leakage paths were being bypassed by the testing
methods in use.
No violations or deviations were identified.
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4. Review of Allegations Concerning BISCO Penetration Seals
The NRC received three generic (not specifically mentioning the Davis-
Besse Plant) allegations regarding Bisco penetration seals indicating that:
(1) test data to support the penetration seals' fire resistance capability
did not exist including test data to show that the 6 inch silicone foam
fire barrier penetration seals are rated for three hours, (2) penetration
pressure seals were installed with a 2 inch overlap on the seal boot
instead of the required 3 inch overlap, and (3) Bisco procedures SP504,
SP505, SP505-1, SP505-2, and SP505-3 were deficient.
The licensee provided a comprehensive package of information pertaining
to Bisco penetration seals including NRC correspondence on this subject,
penetration seal specifications, Bisco procedures covering flexible boot
seals, TED procedures covering the Dow Corning silicone foam penetration
fire seals, and test reports of penetration seals. Resolution of the
allegations was pursued through inspector review of the documentation
provided by the licensee; a visual inspection and penetration seal
walkdown of several flexible boots and silicone penetration fire seals;
and discussions between the licensee's staff, resident inspectors and the
inspector to determine whether the allegations could be substantiated. As
a result of these activities the following findings and conclusions were
made,
a. Allegation No. RIII-83-A-0029-01: Test data to support the
penetration seals' fire resistance capability did not exist
including test data to show that the six inch silicone foam fire
barrier penetration seals are rated for three hours. In response
to this allegation the inspector reviewed two Bisco Fire Test
Reports numbered 748-57, dated November 6, 1981, and 748-42, dated
July 29, 1981, noting the test standard criteria being utilized,
penetration seal fabrication, type, and design configuration including
any penetrating items, test observations and the conclusions of the
fire test. Both tests showed that the material used as the fire seal
was Bisco SF-150NH (High Density Silicone Foam) installed to a nominal
depth of 12 inches and utilizing cable tray and conduit design config-
urations. The inspector determined that the fire seal systems tested
in the two tests met NRC guidelines and therefore are acceptable.
Section 7.2.4.e of Specification No. 7749-M-25500, dated August 11,
1983, indicates for fire barriers using low density silicone foam
that a minimum final fill depth of 11 inches is required and for
high density silicone sealant material 12 inches is required.
The test reports reviewed by the inspector regarded only the high
density silicone sealant material; however, the licensee did provide
a letter (Serial No. 284) from L. Roe, TED, to J. Stolz, NRR, dated
May 25, 1977, regarding a fire equivalency test for low density
silicone foam (SF-20 verst.s Dow Corning 3-6548). The purpose of the
letter was to inform NRR that TED planned on substituting the SF-20
product with the Dow Corning 3-6548 product due to the discontinued
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manufacture of the SF-20. The TED letter also indicated that a
three-hour fire exposure test had been performed at the Fire Research
Laboratory of the Portland Cement Association in Skokie, Illinois on
April 12, 1977. A 12 inch thick concrete slab was prepared containing
four one-foot square blockouts. Two of the blockouts were filled
with SF-20 and two with Dow Corning 3-6548 silicone foam. The report
further stated that, "Each blockout was filled to the full depth of
i 12 inches, which is the minimum depth used as a fire barrier at
Davis-Besse Unit 1."
Documentation was not available at the time of the inspection to
support the specification statement of having low density silicone
foam configurations (previously installed SF-20 or more recently
installed Dow Corning 3-6548) using a fill depth of 11 inches. This
is considered an open item (346/85028-01) pending inspector review
of test documentation demonstrating the adequacy of installed low
density silicone foam with a fill depth of 11 inches. As part of
! this open item the inspector requested the licensee to provide
l adequate assurance that no penetration fire seal located in a fire
area boundary barrier was less than 11 inches in depth. As this
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[ assurance could not be provided during the inspection, this allegation
remains open. On October 18, 1985, in a telephone call between
Region III management and TED management, it was discussed that this
assurance would be required as one of the items to be closed prior to
plant restart from the current outage.
Three maintenance procedures numbered MP 1405.03.1 (Step 8.3.1),
! MP 1405.04.3 (Step 6.3.1), and MP 1405.08.0 (Step 8.3.a) each
l Indicate that the minimum depth of foam to be installed is 11 inches
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for low density silicone foam or 12 inches for high density silicone
l foam in any penetration conduit through a wall or floor, except where
the wall or floor thickness is less, then the depth is to be equal to
the thickness of the wall or floor.
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The three maintenance procedures do not differentiate between fire
barrier walls and floors and non-fire barrier walls and floors when
mentioning the amount of sealant material to install as does
Section 7.2.4.e of Specification No. 7749-M-255Q.
This is considered an open item (346/85028-02) pending inspector
review of the procedural revisions to the three maintenance proce- ,
dures to reflect Section 7.2.4.e of Specification No. 7749-M-255Q.
, b. Allegation No. RIII-83-A-0029-02 and 03: (02) Penetration seals
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were installed with a 2 inch overlap on the seal boot instead of
the required 3 inches. (03) Bisco Company procedures SP504, SP505,
, SP505-1, SP505-2, and SP505-3 were deficient. The inspector
determined that these two allegations were interrelated and as
such they are discussed together.
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The flexible Boot Seal is designed for use as a pressure barrier.
According to the licensee, procedures SP505-1, SP505-2, and SP505-3
were not being used at the Davis-Besse site. As such, that portion
of the allegation is not applicable to Davis-Besse.
Bisco's flexible boot seal fabrication procedure (SP504), step 5.3.3,
and Bisco's Installation procedure (SP5051), step 7.3, both state
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that, "A bead of the Bisco RTV Sealant is applied to the inside of
the overlap seam and spread to a minimum width of 3 inches." The
Davis-Besse site installer of flexible boot seals (installation of
the flexible boot seals is performed on an infrequer.t basis)
interpreted the two steps noted above to mean that the minimum
overlap seam is to be 3 inches.
I
Subsequently, the licensee, through Bechtel, contacted Bisco personnel
who indicated that the overlap axial seam criteria was to be based on
the diameter of the pipe penetration being sealed. The inspector
requested the licensee to provide documentation to support the
vendor's position regarding the overlap seam criteria. This is
considered on open item (346/85028-03) pending inspector review of
this documentation.
The inspector performed an inspection of seven flexible boot seals
including measurement of overlap axial seams with assistance from the
licensee's staff. Of the seven boot seals inspected, two failed to
meet the acceptance criteria as given by the Bisco personnel and five
boot seals failed to meet the acceptance criteria as given by the
plant installer. As such, this portion of allegation (02) remains
open.
The Bisco Fabrication and Installation procedures also indicate that
the RTV sealant material should be allowed to cure for a minimum of
sixteen hours before any further work is performed. No TED procedure
existed for the responsible Quality Assurance inspector on when to
inspect the boot seals' final installation so as to verify that no
slippage of the overlap seam had occurred.
The TED procedure (s) established for the installation, and fabrication
of the flexible boot seals were inadequate in that these procedures
failed to provide clear and concise installation, fabrication and
inspection instructions. The inadequacies in the flexible boot seal
procedures is considered a violation of 10 CFR 50, Appendix B,
Criterion V (346/85028-04).
5. Open Items
Open items are matters which have been discussed with the licensee, which
will be reviewed further by the inspector, and which involve some action
on the part of the NRC or licensee or both. Open items disclosed during
the inspection are discussed in Paragraph 4.
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6. Exit Interview
The inspectors met with licensee representatives (denoted in Paragraph 1)
at the conclusion of the onsite inspection on September 6, 1985, and summarized
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the scope and findings of the inspection. The licensee acknowledged the
_ statements made by the inspector. The inspector also discussed the
likely informational content of the inspection report with regard to
documents reviewed by the inspector during the inspection. The licensee
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did not identify any of the documents as proprietary.
In a telephone conversation on October 18, 1985 between Region III and
the licensee, it was discussed that (0 pen) Violation (346/83016-018)
regarding the operability of the PORV and its block valve (Paragraph 2.b.)
and Open Item (346/85028-01) regarding the adequacy of the low density
foam (Paragraph 4.a.) would be resolved prior to restart.
Also, in a telephone conversation conducted between Region III and the
licensee on October 31, 1985, items 83-16-17, 83-16-18, 83-16-20 and
83-16-22 (a, b, c, d, h, j) were discussed and are documented in this
report.
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