ML20151T007

Insp Rept 50-346/98-11 on 980803-14.No Violations Noted. Major Areas Inspected:Effectiveness of Corrective Action Program

ML20151T007
Person / Time
Site:	Davis Besse
Issue date:	09/03/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20151T006	List: ML20151T000 ML20151T007
References
50-346-98-11, NUDOCS 9809090192
Download: ML20151T007 (20)

See also: IR 05000346/1998011

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U. S. NUCLEAR REGULATORY COMMISSION

REGION lll

Docket No: 50-346

License No: NPF-3

Report No: 50-346/98011(DRS)

Licensee: Centerior Service Company

Facility: Davis-Besse Nuclear Power Station

Location: 5503 N. State Route 2

Oak Harbor, OH 43449

Dates: August 3-6,1998, in Region ill Office

August 10-14,1998, onsite

Inspector: M. Miller, Reactor Engineer

J. Neisler, Reactor Engineer

R. Winter, Reactor Engineer

Approved by: John Jacobson, Chief,

Lead Engineers Branch.

Division of Reactor Safety

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9909090192 990903

PDR ADOCK 05000346

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. EXECUTIVE SUMMARY

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Davis-Besse Nuclear Power Station  !

. NRC Inspection Report 50-346/98011  ;

This announced inspection reviewed the effectiveness of the corrective action program. In  !

addition, a sample of current short term corrective actions and long term corrective actions as - i

well as a sample of engineering items were reviewed. l

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Operations

. The team concluded that the corrective action process at Davis-Besse was proactive  !

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and effective. Enhancements and improvements continued to be made in identification,  !

resolution, and prevention of problems. The threshold for identifying problems was i

appropriately low and root cause evaluations were thorough.

. The operating experience program effectively assessed operating experience, informed i

the proper personnel of the assessments, generated technically sound corrective i

actions when appropriate, and correctly implemented the actions.

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.- The team concluded that the licensee effectively captured the scope of the identified i

problems and resolved issues through the Potential Conditions Adverse to Quality ,

Reports (PCAQRs). However, more consideration could be given conceming.  ;

Probabilistic Risk Assessment when categorizing PCAQRs such as the station blackout  !

breaker failure PCAQR.

. The assignment of root cause analysis responsibility to the line organization and having

management oversight early in the PCAQR process was an improvement in the root

cause evaluation process. The team found that recent root cause analysis reports were

thorough and effective.

.- The audit activities by the Independent Safety Evaluation Group and Quality Assurance

were effective, straight forward, and supported by the line organization. The issues

identified by the audit group were supported by the line management and appropriate

corrective actions were taken.

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. The team concluded that management was committed to making the corrective action

program effective. Significant management time was expended prior to meetings to

. ensure the PCAQRs addressed the full scope of each issue.' Management support for  ;

the initiation of PCAQRS was also good. i

. . The staff supported the corrective action process and recognized the program as an  ;

effective way to resolve issues. l

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Engineering

. Based upon review of selected 10 CFR 50.59 screening documents and safety

evaluations, the team concluded that performance in this area was good. The

screenings and evaluations were thorough and accurately reflected the licensee's

methodology for assuring deviations from design, as defined in the Updated Safety

Analysis Report did not impact plant safety.

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l Report Details

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l. Operations

l 07.1 Corrective Action Proaram

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a. Insoection Scoce (40500)

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The corrective action program at Davis Besse was in the process of being changed due

to licensee identified issues. The team reviewed the current program and the recent

changes.

, b. Observations and Findings

The corrective action program at Davis-Besse continued to make enhancements to the

corrective action process. Davis-Besse formed a Corrective Action Process

improvement Team to re-engineer the corrective action process. The short term actions

included forming a Management Review Committee to perform initial screening of

Potential Conditions Adverse to Quality Reports (PCAQRs), implementing a new

Corrective Action Tracking System, and developing a method to close Category 2

through 4 PCAORs that have actions substantially completed yet provided long-term  ;

tracking of follow up items on the Corrective Action Tracking System. Future planned j

changes included having the corrective action process become a line management i

function with the integration of self assessments into the process. l

Problems were identified solely through the PCAQR process, which placed all the

information into one data base and improved trend identification and tracking.

Significant corrective actions received interdisciplinary review through the PCAQR

review board, and the Station Review Board reviewed all Category 1 PCAQRs. Quality

Assurance, Quality Control, and supervisors were active in field observations to improve

problem prevention.

The threshold for writing a PCAOR was low and the number of PCAQRs generated was

good. Personnel interviewed indicated a willingness to identify problems. The

personnel also considered that management supported the program, that there was

process ownership at all levels of the plant staff, and that PCAORs written against their

work products or actions were not perceived negatively. Based on the sample of

PCAQRs reviewed by the team, the root cause evaluations were thorough and effective.

The team also observed several noteworthy practices regarding the corrective action

process.

. Monthly PCAQR reports noted extension requests and administrative errors.

.. The PCAOR initiator remained part of the process through feedback on the final

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. A monitoring program (STRIVE card), recently initiated by Electrical and l&C

maintenance supervisory personnel, was used to monitor job site performance 2

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c. Conclusions

The team concluded that the corrective action process at Davis-Besse was proactive  ;

and effective. Enhancements and improvements continued to be made in identification,

resoluilon, and prevention of problems. The threshold for identifying problems was  ;

appropriately low and root cause evaluations were thorough.

07.2 Operating Experience Program

a. inspection Scooe (40500)

The team evaluated the adequacy of the licensee's programs that implement operating j

experience information. Personnel were interviewed and selected records were

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l b. Observations and Findinos

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' The licensee implemented the operating experience program by dividing the information

into three categories with responsibility for each category in different departments.

Within each department's area of responsibility, a process was maintained to review and

l screen operating experience items for development of responsive action and for review

and evaluation of the effectiveness of the responsive actions taken.

. The institute of Nuclear Power Operations related documents were the -

! responsibility of the Quality Department with a coordinator in the Independent

Safety Evaluation group. PCAQRs tracked some institute of Nuclear Power

! Operations notifications that dealt with potential operability concems and the

Shift Supervisor was advised. The information was screened and routed to the

l appropriate department. The operating experience coordinator made the .

l- information available to the staff via the shared intamal computer network and a

weekly Operating Experience Report.

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. The NRC related documents were the responsibility of Regulatory Assurance

and each document was issued a PCAQR and tracked.

. The vendor information such sa Service Information Letters, Electric Power I

Research Institute reports, and 10 CFR Part 21 notifications were the

responsibility of the engineering department. Generally only Part 21 information

was tracked by PCAQRs. Some engineering staff members maintained extemal

[ > industry contacts which provided additional operating experience information.

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The effectiveness of the system was demonstrated by the following examples:

. The licensee responded to an operating experience at Fort Calhoun and

discovered the potential of a hot short on the emergency diesel generator (EDG) <

tachometer control circuit which could cause failure of the EDG speed switch. I

The failure in the speed switch would prevent the EDG from performing its  !

intended safety functioni Proactive short term actions were taken by

disconnecting and isolating the tachometer leads, and long-term plans such as

installing a separate tachometer circuit were being considered. {

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.' The licensee took prompt and appropriate corrective actions to Operating ,

Experience Reports conceming General Electric Type SBM switches that did not

spring retum to the neutral position after the handle was released. Davis Besse i

had over 200 SBM switches. The potential problem scope was narrowed by first ,

eliminating switches that did not have the spring retum feature and further i

narrowed by eliminating switches that were received prior to the manufacturing

dates associated with the problem. The remaining switches were individually

checked for date codes. No switches were fcund in the suspect date code

range. All SBM switches in stock were also examined for the cuspect date

codes. The team considered the response to this issue to be timely as the ,

PCAQR was issued within 21 days of the Part 21 being issued and corrective

actions completed within 4 months.

c. Conclusions j

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The operating experience program e'fectively assessed operating experience, informed i

the proper personnel of the assessraerits, generated technically sound corrective

actions when appropriate, and correctly implemented the actions.

07.3 PCAQR Review

a. Inspection Scone

The team reviewed and evaluated corrective actions for selected PCAQRs initiated

during the past three years,

b. ~ Observations and Findinas l

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During this inspection over 40 PCAQRs were reviewed to differing extents. The team

determined that the program had a low threshold for initiating PCAQRs and that the

program was providing appropriate resolution of the issues. Several of the reviewed

PCAQRs are discussed below.

. PCAOR 97-0127 identified that the reactor coolant pump (RCP) oil lift system

piping may not meet the requirements of 10 CFR 50, Appendix R, Section Ill.O.  !

The problem was identified during a receipt inspection on an RCP motor

retumed from the manufacturer. The licensee expanded the scope and further

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investigation found that two issues existed on all four installed pump motors:

(1) piping for the lower oil bearing level switch drain appeared to extend outside

of the oil collection enclosure and (2) the remote oil fill lines did not appear to be i

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The licensee detetrnined that the failure to extend the oil collection system over

the lower bearing level switch drain was an inadvertent omission during the

original design and installation. The remote fill lines were not included because

they had not been considered part of the RCP motors. The analysis concluded

- that the piping was of substantial construction; the piping was not pressurized; '

and that a leak in the oil drain line, while extremely f omote, would be detected by

the low level alarm. Heat detectors above each motor would alert the control  ;

room personnel and the operators could take appropriate action. Therefore, the

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lack of oil collection at the limit switch drain pipe and fill line was considered to

be of minimal safety significance.

The corrective action was to place administrative restrictions on the use of the oil

- lift pump and to design appropriate oil collection covers to be installed at the next

outage. The installation was completed at the next outage subsequent to the

discovery of the missing collection devices. The team concluded that

identification of this problem and expansion of the problem scope was proactive

and effective.

4 PCAQR 98-1333. This PCAQR was initiated to investigate why the initial

evaluation of PCAQR 98-1292 was not accurate. PCAQR 98-1292 was initiated

to document the failure of circuit breaker ABDC1 to close when operators

attempted to transfer buses C1/C2 supply from EDG #1 to bus B. This action

was being taken in response to loss of offsite power the plant sustained as a

result of tomado damage on the evening of June 24,1998. The !nitialincorrect

- assessment identified the breaker failure'as a procedure inadequacy. However,

the correct cause of failure was an inadequate gap between the floor cam and

the trip plunger that rides on the cam. When there was insufficient gap between

the cam and plunger, the mechanical shock of the breaker closing could cause

the breaker to trip free.

The licensee replaced and tested the new breaker to assure operability. To

prevent the occurrence of inaccurate evaluations, the licensee was enhancing

their root cause evaluation process to improve accuracy. The team considered

that the response to the incorrect evaluation was prompt and thorough.

. PCAQR 98-0020. This PCAQR questioned whether post maintenance testing of

the 4160 volt under voltage relays was adequate. Both the 90 percent and the

59 percent relays were tested simultaneously after reinstalling the relays in their

respective cases. The operability of the relays was not questioned since they

had passed the monthly operability tests. Since the relays were functionally

tested, the licensee concluded that an adequate post maintenance test was

performed. The team concurred with the licensee's conclusion.

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During rePw of this PCAQR, the team questioned whether the 7.5 second time

delay at 90% voltage met the intent of NRC Branch Technical Position PSB-1.

While Davis-Besse was not committed to PSB-1, the 7.5 second delay was

insufficient to allow bus voltage to recover from dips when starting certain large

loads such as an RCP or a circulating water pump. When starting one of these

loads, the operators had to bypass under voltage protection from the control ,

room to avoid an under voltage trip. Also, at minimum voltage of 70%, the high

pressure injection pump required 6.21 seconds starting time according to the

vendor manual. Actual starting time for the high pressure injection pump had not

been measured. Although use of the undervoltage relay bypass button was

approved by the NRC, the team concluded that holding the bypass button while

starting a large load introduced an unnecessary, though small, risk to plant

electrical equipment, in addition, the automatic start of large equipment could

cause an undervoltage trip.

. PCAQR 96-0778. Circuit breaker AD213, station blackout tie breaker failed to

close during the dead bus load test. Troubleshooting indicated an open contact

on relay 86X/AD213, a General Electric type HFA multicontact auxiliary relay.

The troubleshooting identified a high resistance on the contact apparently

caused by marginal contact wipe. Electricians cleaned and bumished the

contact, adjusted contact wipe and time tested the relay. The relay tested within

the proper times. This was the second failure of relay 86X/AD213 recently.

Licensee personnel stated that the same failure had occurred approximately

three weeks previously but the work order had not been implemented to correct

the problem. The team questioned why this PCAQR was a Category 3, which

was the lowest category for components important to safety, when the loss of the

station blackout diesel during a loss of offsite power was a significant contributor

to core damage frequency under probabilistic risk assessment.

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PCAQR 97-1134. This PCAQR was initiated to address recent circuit breaker

problems at another nuclear power plant. Davis-Besse uses circuit breakers

similar to those used at the other plant. The licensee initiated a review of circuit

breaker maintenance practices to determine what remedial actions were

necessary to improve circuit breaker performance. As a result of the review of

circuit breaker maintenance, the licensee began their remedial program.

Trending of breaker performance for each type breaker was initiated.

Preventive maintenance proceduo were revised to add specific guidance to

check if grease was contaminated. Specific instructions were included for

identification and replacement of hardened grease. Additional training on the

circuit breaker lubrication was being provided to electrical maintenance

personnel involved in circuit breaker maintenance. Included in their maintenance

procedures was the replacement of grease in bearings and on sliding surfaces

with light oil. The replacement of grease with oil was not one of the lubrication

practices recommended by the vendor's manuals. The licensee has used oil on

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selected breakers on a trial basis and was trending the results. The breakers will

be specifically inspected for wear at those points where the oil was used in place

of grease.

The licensee was reviewing their circuit breaker refurbishment schedule. The

schedule will be based on the trending program to determine the optimum times

between refurbishments. In addition, contractors were being evaluated for

480 voit breaker refurbishment. The team considered that the circuit breaker

actions taken by the licensee demonstrated a good start toward resolving the

issues.

c. Conclusion

The team concluded that the licensee effectively captured the scope of the identified

problems and resolved issues through the PCAQRs. However, more consideration

could be given conceming probabilistic risk assessment when categorizing PCAQRs

such as the station blackout breaker failure PCAQR.

07.4 Root Cause Analysis Process

a. Insoection Scooe (40500)

The team evaluated the effectiveness of the root cause analysis process, reviewed l

selected root cause analyses associated with PCAQRs, and interviewed personnel.  !

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b. Observations and Findinos

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Davis-Besse had initiated actions to improve their root cause analysis process. Both a 1

1997 audit and the Company Nuclear Review Board had raised concems about the

consistency and depth of root cause analysis at Davis-Besse (see Section 07.5 for

details about the audit). The improvement actions included holding the department

assigned the evaluation responsible for providing an evaluator, a newly developed Root

Cause Analysis Desk Guide for consistent evaluations, and a newly formed

Management Review Committee involved in the assignment of root cause

investigations.

The team reviewed several recent root cause analysis reports to evaluate overall

effectiveness.~ Examples of the reports are discussed below.

!' i PCAQR 98-0063: After a 1985 event, Davis-Besse made a commitment to NRC

to inspect each auxiliary feed pump turbine every refueling outage. This

. commitment was not captured in the preventive maintenance program and was,

l therefore, not performed. Davis-Besse correctly expanded the root cause to

- include an evaluation of the adequacy of the commitment program. The licensee

discovered fundamental problems including the TERMS database not having a

clear wording of the actual commitment, deviating from commitments based on

undocumented justification, and personnel changing implementing documr'9s

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without researching the actual commitment. The team concluded that the  !

recommended corrective action plan was addressing the issue.

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PCAQR 98-0016: During performance of a reactor coolant system water

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inventory balance, the reactor coolant pump seal retum valve rather than the

~ adjacent domineralizer water to containment valve was inadvertently closed for ,

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several seconds. The root cause determination identified three root causes: less

than adequate work practices, verbal communications, and inadequate

supervisory methods. Each cause had thorough in-depth analysis of multiple

l contributing factors. Generic implications and previous occurrences were j

evaluated. The corrective action plan addressed individual counseling, l

management reinforcement of expectations, and operator training.  !

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PCAQR 98-0934: Written recently to evaluate the collective significance of six  ;

other PCAQRs dealing with foreign material exclusion problems in the spent fuel

pool, reactor vessel, containment, and emergency core cooling system rooms. l

The licensee proactively expanded the corrective actions and scope by creating l

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a Foreign Material Task Team for multi-discipline corrective actions that were

ongoing. The task team appropriately addressed the specific issues identified in l

the PCAQRs and planned a minor change to the foreign material exclusion  !

procedure.

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PCAQR 97-1134: Written to evaluate Davis-Besse breakers after an operating  ;

experience report of breaker problems at another site (see Section 07.3 for i

detailed discussion). The licensee expanded the depth of investigation by l

creating the Circuit Breaker Maintenance Program Review Team. The

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inspection team found the completed and proposed corrective actions to be

thorough. i

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c. Conclusions

L The assignment of root cause analysis responsibility to the line organization and having i

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management oversight early in the PCAQR process was an improvement in the root  !

cause evaluation process. The team found that recent root cause analysis reports were

thorough and effective. l

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07.5 Audit Activities  :

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a. Insoection Scoos (40500) I

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The team evaluated the effectiveness of the audit process performed by the Quality

Assurance (QA) and the Independent Safety Evaluation (ISE) groups. Selected audit

reports were reviewed , cognizant personnel were interviewed, and corrective actions

taken for identified items were evaluated.

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b. Observations and Findinas

Nine audits were reviewed for identification of issues. Although no safety significant

issues were identified, each audit identified problems that needed correction. The team

selected issues from each audit and found that appropriate corrective actions were

either completed or in progress. Examples of the issues and the correct!ve actions are

addressed below.

. The Reactivity Management Assessment (QAD-97-70209), performed by ISE,

identified that very little emphasis had been placed on reactivity management

concepts for personnel involved with maintenance activities. The assessment

recommended that sensitivity training should be provided for personnel in groups

involved with trouble shooting and other maintenance activities. In response to

this issue, a list of reactivity sensitive systems had been generated and an

administrctive procedure was being written. Training was to follow the

completior; Of the procedure.

. The same assessment identified that training for operators had not placed much

emphasis on reactor theory, heat transfer, or fluid flow in recent years. A

potential weakness in these areas had been documented through a knowledge -

survey. During training cycle 98-02, heat transfer and fluid flow were covered as

part of the training. Reactor theory was scheduled to be addressed in training

cycle 98-03.

. The QA audit of the Testing and Calibration Program (AR-97-TSTCA-01)

identified four examples where evaluations were not performed for lost,

damaged, or out of calibration radiation measuring and test equipment. This was )

a repeat problem from 1994 and 1996 audits. Following both of the earlier l

audits, the follow-up reviews by QA verified temporary compliance with

procedural requirements. The auditors determined that more aggressive root

cause assessment and corrective actions were needed to prevent additional l

recurrences. Radiation Protection evaluated the issue and determined that the l

root causes included unclear expectations for standards and procedures; a "not i

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my job" attitude on the part of the testers assigned to use the instruments, when

it came time to do the documentation process; inadequate supervision of the

documentation process; and inadequate review and oversight of the process by

technical staff personnel. Corrective actions incluoed a 100% audit of all

radiation instrument history files, procedure changes, tailgate sessions to define

procedural expectations for out of service equipment logging and documentation,

and required rereading of applicable procedures for all radiation protection  !

testers. ,

. The QA audit for the corrective action program (AR-97-CORAC-02) found that

the depth of the root cause evaluations for PCAORs not associated to Licensee

Event Reports (LERs) were more comprehensive. The less in-depth root causes

for PCAQR associated with LERs were partially due to delayed assignment of

the root cause evaluation until shortly before the deadline dates required by the

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LFR process. In addition, there was a limited number of individuals assigned to

perform root cause evaluations. The supervisor of ISE was responsible for

assigning the evaluation; however, he had control of those individuals only

directly under his supervision. This resulted in most of the evaluations being

performed by ISE members which caused a backlog and detracted from other

ISE activities. The issue was corrected by increasing the number of root cause

evaluators and holding the department assigned the evaluation responsible for '

finding an evaluator within that department. A management review committee

was formed that reviewed PCAQRs three times a week and assigned a specific

department responsibility for the root cause evaluation. The new process has

improved the root cause quality and allowed ISE to retum to normal activities.

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During interviews with site personnel, the team determined that the auditors were well

received by the audited organizations and gNen proper support. The auditors indicated  !

that individuals were frank in discussing issues concoming their department. In addition,

personnel appeared to recognize the advantage of having an extemal group perform an

audit.  :

c. Conclusion ,

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The audit activities by 13E and QA were effective, straight forward, and supported by the

line organization. The issues identified by the audit group were supported by the line j

management and appropriate corrective actions were taken. j.

07.6 Management and Staff sunoort of the Corrective Action Prooram l

a. Inspection Scope (40500)

The team evaluated the commitment of management and staff to the corrective action

program through attending management meetings associated with the program. Staff

support for the program was evaluated through interviews with the staff.

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b. Observations and Findings

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Three times a week the Management Review Committee met to review new PCAQRs.

The committee recommended appropriate categorization, due dates, the need for

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corrective actions to prevent recurrence, the level of root cause evaluation required, and

the department responsible for performing the root cause evaluation. The meeting were

conducted in an efficient manner and persons involved appeared knowledgeable of the

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issues.

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l Twice a week the PCAQR Review Board met to review Category 2 PCAQRs and all

PCAQRs that involved applicable NRC Information Notices. The board's function was to

concur with the initial PCAQR assessment, obtain resolution, escalate conflicts to the ,

Management Review Committee for resolution, or send the PCAQR on to the closure

process. The team observed approximately 20 PCAQRs that were dispositioned within

l 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. The team noted that the efficiency of the meeting was due to participants

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having read all the PCAQRs and having prepared commen;s prior to the meeting. The

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team observed good interaction between the board members with no hesitation to raise

differing positions. Issues raised were appropriately resolved with some PCAQRs being

rejected, some sent back for further review, and others approved.

The Station Review Board met once a week to review Category 1 PCAQRs, safety - ,

evaluations, and other technical specification required reviews. The purpose of the ,

meeting was similar to the purpose of the PCAQR Review Board. The team again  !

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noted that the board members were well prepared and the meeting progressed 1

efficiently. The board members presented good insights and concems, had good  !

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interactions, and took appropriate actions.

The team interviewed several staff members and found a willingness to initiate ,

PCAQRS. In ons case, an individualindicated that the supervisor's first question ]

regarding an issue was always "have you written a PCAQR7" This example  ;

demonstrated lower level management's commitment to the program and the staff's )

understanding of management's expectation. The staff further expressed satisfaction j

with the program in its ability to correct problems. The team also noted that the  !

corrective action program solicited feedback from the initiator of a PCAQR, to verify that

the issue was properly addressed, before closing the PCAQR. i

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The team was informed of cases where low significance peripheral issues to a PCAQR l

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were sometimes not documented in the corrective action section or evaluation section of

the PCAQRs. However, the issues had been thought through and corrective actions

had been taken. This appeared to be the result of time constraints on the staff. While j

this did not effect the overall corrective action process, it could have minor implications

in tracking and trending of problems.  !

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c. Conclusion  :

The team concluded that maragement was committed to making the corrective action l

program effective. Significant management time was expended prior to meetings to l

, ensure the PCAQRs addressed the full scope of each issue. Management support for

the initiation of PCAQRS was also good. The staff supported the corrective action  !

process and recognized the program as an effective way to resolve issues.

111. Engineering  ;

E1 Conduct of Engineering

E1 Safety Screeninas and Evaluations

a. Inspection Scope ,

The team reviewed selected safety evaluations (SE),10 CFR 50.59 screening

, documents, and associated PCAQRs. In addition, the team interviewed cognizant

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licensee personnel.

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b. Observations and Findinas

i The team reviewed four 1998 screenings performed pursuant to 10 CFR 50.59. The

following screenings were reviewed during this inspection.

. . Revision to procedure DB-MM-09320, " Emergency and Station Blackout Diesel l

Maintenance." The licensee's screening correctly determined that the revision  !

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did not represent a test or experiment as defined in the Updated Safety Analysis

Report (USAR).

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- .- Cancellation of procedure DB-FP-04051," Inspection and Maintenance of Diesel ,

Fire Pump Engine." The licensee's screening process was accurate in its  !

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determination that the procedure cancellation did not change procedures

discussed in the USAR or Fire Hazard Analysis Report.  !

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c . Alteration to Channel Calibration of 32C-1SF5059," Station Vent Flow." The

team verified that this procedure alteration was to procedure format, clarifications

to existing calculations, and to provide guidance for operability determination. It .  !

was r'ot a test or experiment described in the USAR. ,

. Revision to procedure DB-PF-03290,'" Containment Personnel and Emergency

Air Lock Doors Interlock Test." The test procedure was changed to meet

technical specification Amendment No. 223 that changed the test frequency.

The test was to verify that the door interlocks were operable by verifying that

only one door could be opened at a time. The test was not a change to the

USAR. -

The team reviewed the following safety evaluations.

. SE 98-0005," Decay Heat Exchanger Supports." During the review of the decay I

heat exchangers (E-27-1 and E-27-2) for the Seismic Qualification Utility Group

program, it was identified that loads due to attached piping were not considered

in the analysis of the heat exchanger supports nor in the seismic qualification of

the heat exchangers. PCAQR 97-1174 was initiated to address this issue.

Modification 97-0068 was developed and installed to correct this deficiency. The

purpose of SE 98-005 was to determine whether the modification that added

additional support material and welding on the decay heat exchangers supports

would increase the possibility for accident of a different type than any y cusly

evaluated in the USAR. The licensee's evaluation determined that the

installation did not adversely affect any safety related structures, systems, or

Gnponents and that an unreviewed safety question did not exist. The team

concurred with this evaluation.

. . SE 97-0032, " Safety Evaluation to Revise the Indicated Capacity for the Reactor

Coolant Drain Tank and Pressurizer Quench Tank." PCAQR 96-0476 identified

differences in the indicated capacities between design drawings and the USAR

for both the quench tank and the reactor coolant drain tank. Corrective action for

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j the PCAQR directed that drawings reflect nominal tank capacity. This SE

justified changes made in support of PCAQR 96-0476.

f The change in quench tank capacity listed in the USAR as 800 cubic feet

l ' (approximately 6000 gallons) to reflect a nominal volume of 6700 gallons had no )

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' effect on the ability of the quench tank to perform its design function as no

4 change was made to water levels maintained in the tank. The reactor coolant  ;

, drain tank change in tank capacity listed in the USAR from a usable volume of .

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1 655 gallons to a nominal volume of 690 gallons did not affect the tank's ability to

! collect water from plant drains. No change was made to the water level in the

j- tank which was automatically maintained. The team concurred with the i

i licensee's determination that a change to the indicated capacities of thr, quench  ;

tank and primary drain tank did not result in an unreviewed safety question. j

i-  :

. SE 98-0007, "Cooldown Following a Seismic Event / Steam Generators Fed with

Service Water, Solids Accumulation in the Steam Generators." PCAQR 96-1290

} identified a discrepancy in the USAR concoming the quantity of dissolved and j

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suspended solids that would be accumulated in the steam generators after

l injecting raw water for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The USAR listed the quantity of accumulated  ;

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solids over a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period as less than two pounds. The licensee's reanalysis  !

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l indicates that raw water feed to the steam generators would result in the

j accumulation of approximately 240 pounds of solids in each steam generator in  ;

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24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The team agreed with the licensee's evaluation that changing the  !

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USAR to Xiect more accurate solids accumulation in the steam generators did l

not constitute an unreviewed safety question and did not reduce any margin of i

safety.

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c. Conclusion  !

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Eased upon review of selected 10 CFR 50.59 screening documents and safety  :

ovaluations, the team concluded that performance in this area was good. The

screenings and evaluations were thorough and accurately reflected the licensee's

methodology for assuring deviations from design, as defined in the USAR did not impact

plant safety. '

E8 Miscellaneous Engineering issues (37550)

E8.1. (Closed) Unresolved item (50-346/95009-02): This item was opened for not having i

!

appropriate acceptance criteria for determining the condition of emergency lighting

' batteries following 8-hour surveillance discharge testing. An acceptance criteria of

5.25 volts was established and current surveillance data. demonstrated a low battery

failure rate. This item is considered closed.

E8.2 (Closed) Insoection Follow-Uo item 50-346/97201-09: This item was opened to follow

resolution of inconsistencies between various documents for the borated water storage

tank setpoint. Inspection report 50-346/98003(DRS) documented that the

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Inconsistencies had been resolved and only the completion of Calculation C-ICE-

48.01-004 remained open to allow considerations of other issues not related to this

inspection follow up item.

Revision number 5 of Calculation C-ICE-48.01-004 was approved on July 14,1998.

The team reviewed the calculation and had no further questions concerning this issue.

This inspection follow-up item is closed.

V. Management Meetings l

X1 Exit Meeting Summary

The team presented the inspection results to members of the licensee management on

August 14,1998. The team verified that no proprietary information used during the inspection

was in the possession of the team and none of the information was documented in the report.

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PARTIAL LIST OF PERSONS CONTACTED

Licensee

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M. Beier, Manager, Quality Assessment

i J. Freels, Manager, Regulatory Affairs-

R. Hovland, Senior Engineer, Plant Engineering

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D. Imlay, Superintendent, Plant Operations

J. Johnson, Supervisor, independent Safety Engineering

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J. Michaelis, Manager, Maintenance

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T. Myers, Director, Nuclear Support Services

D. Lockwood, Supervisor, Regulatory Affairs

H. Stevens, Manager, Nuclear Safety and Inspections

' F._Swanger, Manager, Design Basis Engineering

. G. Wolf, Engineer-Licensing, Regulatory Affairs

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S. Campbell, Senior Resident inspector

K. Zellers, Resident inspector

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INSPECTION PROCEDURES USED

IP 37550 Engineering

IP 40500 Effectiveness of Licensee Controls in Identifying, Resolving and Preventing

Problems

IP 37001 10 CFR 50.59 Safety Evaluation Program

,

ITEMS CLOSED

CLOSED

50-346/95009-02 URI Potential inadequate battery acceptance for emergency light test

50-346/97201-09 IFl Several inconsistencies between documents for BWST setpoint

LIST OF ACRONYMS USED

EDG Emergency Diesel Generator

IFl inspection Follow-up Item

ISE Independent Safety Evaluation

LER Licensee Event Report

GA Quality Assurance

RCP Reactor Coolant Pump

SE Safety Evaluations

PCAQRs Potential Conditions Adverse to Quality Reports

URI Unresolved item

USAR Updated Safety Analysis Report

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PARTIAL LIST OF DOCUMENTS REVIEWED

The following is a list of licensee documents reviewed during the inspection, including

documents prepared by others for the licensee. Inclusion on this list does not imply that NRC

inspectors reviewed the documents in their entirety, but, rather that selected sections or

portions of the documents were evaluated as part of the overallinspection effort. Inclusion of a

document in this list does not imply NRC acceptance of the document, unless specifically stated

in the body of the inspection report.

Number Dated /Rev Descriotion

AR-96-CORAC-01 4/10/96 Audit - Implementation and effectiveness of the

Corrective Action Program

AR-97-CORAC-02 10/16/97 Audit for the Corrective Action Program

AR-97-JUMAA-01 1/9/98 Previous JUMA corrective action effectiveness

AR-97-MAINT-01 12/3/97 Audit of the maintenance and inspection programs

AR-97-OPSNF-01 10/31/97 Audit of Plant Operations

AR-97-TSTCA-01 1/16/98 Audit of the Testing and Calibration Programs

EN-DP-01040 1/19/98 R-3 Engineering Correspondence Control / Vendor

Document Processing

NG-EN-00333 8/4/98 R-3 Vendor Group Procedure i

NG-NA-00112 12/11/97R-1 Correspondence Control Program

NG-NA-00702 5/26/98 R-2 Potential Condition Adverse to Quality Reporting

QAD-97-70209 12/23/97 Reactivity Management Assessment

SE96-0055 R-7 Resolution to Thermo-Lag barrier deficiencies

SE 97-0032 7/18/97 Revision of Indicated Capacity for Quench Tank

and Reactor Coolant Drain i

SE 98-0005 2/3/98 Decay Heat Exchanger Supports

SE 98-0007 4/3/98 Solids Accumulation in Steam Generators l

SE98-0032 for site review Temporory isolation of air receiver moisture traps

PCAQR Number Dated Descriotion

96-0778 5/15/96 Breaker AD213 Failed to Close

96-0978 7/1/96 Boron precipitation - SBi_OCA

97-0127 1/31/97 RCP Oil Collection System

97-0137 2/3/97 Cable derating factor apparently not used

97-0423 4/1/97 Two types of grease found in fan bearing

97-1134 8/25/97 Review of breaker failures at Clinton Station

97-1222 9/15/97 SEN on 4160 volt breaker failure

97-1508 11/18/97 Safety tagging

97-1510 11/19/97 incorrect calibration tolerances

97-1610 12/10/97 IN 97-082 follow-up

97-1624 12/12/97 Hot short on the EDG tachometer circuit

97-1658 12/18/97 Follow up to hot shorts on EDG-1 tachometer

97-1678 12/22/97 Valves in boron dilution path not in locked valve

program

97-1684 12/23/97 ATC,C program problems

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98-0016 1/6/98 RCP seal retum valve inadvertently closed

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98-0020 1/7/98- Post Maintenance Testing of UV Relay

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98-0027 1/8/98 Noncompliance with commitments

98-0030 1/8/98 Post Maintenance Testing of UV Relay

-98-0063 1/14/98 Commitment for inspect AFPT not performed  ;

98-0145 1/28/98 Wrong valve weight for seismic considerations l

98-0233 2/11/98 Relief Valve lifted resulting RCS discharge l

98-0250 2/13/97 Follow up on OE for SBM switch failures l

'98-0352 3/9/98 Response to IN 98-07

98-0371 3/12/98 Incorrect calibration tolerances

98-0422 3/23/98 Inadequate testing of ICS feed and bleed interlock

98-0425 3/23/98 Extemal event review - CRDM housing leak

98-0430 3/25/98 Pressure test requirements - Class ill components

98-0551 4/13/98 MU 204 Valve failed reverse flow test

98-0555 4/13/98 Dropped polar crane control pendant

98-0641 4/17/98 Broken retaining clips on ARTS circuit cards

98-0645 4/17/98 Safety tagging  ;

98-0668 4/19/98 Ball and cable drop from polar crane l

98-0679 4/20/98 Wrong MU pump bolts tightened '

98-0681 4/20/98 Personnelinjury

98-0710 4/22/98 Extemal event follow-up - damage to RCP seal '

98-0741 4/24/98 Fuel / component status board not properly updated )

98-0761 4/24/98 East D ring contamination event l

98-0815 4/29/98 Station Battery 2N cell 60 shorted accidentally

98-0819 4/29/98 Station Battery 2N cell 60 damaged

98-0852 5/1/98 Degraded containment coatings  !

98-0934 5/5/98 Collective significance of FME issues l

98-1106 5/18/98 DH 2733 leakby was lifting DH1508 relief valve i

98-1189 5/29/98 DC control voltage drops to breakers due to cable ,

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98-1292 6/26/98 ABDC1 Fail to Close

98-1304 6/26/98 6/24/98 reactor trip

98-1309 6/26/98 Rad monitor spiking due to moisture intrusion

98-1325 6/28/98 EDG ventilation damper failure

.98-1333 6-29-98 Inadequate PCAQR evaluation

98-1524- 11/22/97 Identified hardened grease during bench testing

and follow-up on PCAQR 97-1134

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