ML20205J700
| ML20205J700 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 10/24/1988 |
| From: | Danielson D, Kniceley J, Schapker J, Ulie J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20205J669 | List: |
| References | |
| 50-346-88-34, NUDOCS 8810310461 | |
| Download: ML20205J700 (9) | |
See also: IR 05000346/1988034
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U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-346/88034(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 Nuclear Power Station
Inspection At:
Davis-Besse Site, Oak Harbor, OH
Inspection Conducted: September 12-16, and October 3-5, 1988
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Inspectors /M.F.Schapker
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Date
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J. R. Kniceley'
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Approved By:
D.
. Danielson, Chief
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Materials and Processes Section
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Inspection Sunnary
Inspection on September 12-16, and October 3-5, 1988 (Report No. 50-346/88034(DRS)
' Areas Inspected:
Special safety inspection into allegations made by a former
employee of a Toledo Edison Company contractor, who was employed in the
installation of fire dampers and other related duct work and who indicated
that certain quality and safeguards requirements were violated during
installation.
Results: No violations or deviations were identified.
The inspection concluded that the licensee and its contractors
(General Electrical and Mechanical (GEM) and subcontractor VM
Systems (VMS))actedinaccordancewiththeapplicablequality
program requirements.
Visual examination of the alleged deficiencies and review of
quality and installation records did not substantiate the
allegations.
The licensee was informed of the same or similar concerns
expressed by the alleger and others through the Ombudsman
Program.
The licensee's action taken in response to these
concerns was not sufficient to resolve the specific issues
dddressed.
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DETAILS
1.
Persons Contacted
Toledo Edison Company (TED)_
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- L. Ramsett, Quality Assurance Director
- E. Salowir, Planning and Support Director
- G. Honma. Supervisor, Nuclear Licensing
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- B. Shingleton, Licensing Engineer
- D. Lightfoot, Facility Modification Manager
- C. Fosnaugh, Senior Planner and Scheduler, FMD
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- A. Pryor, Modification Coordinator, FMB
S. Zunk, Ombudsman
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J. Sturdarant, Licensing Engineer
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R. Schrauder, Nuclear Licensing Manager
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C. Miller, Licensir.g Engineer.
J. Moyer, Quality Verification' Manager
G. Stoner, Quality Auditor
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C. Ashworth, Quality Auditor
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Nuclear Regulatory Commission (NRC)
P. Byron, Senior Resident Inspector
The NRC inspectors also contacted other licensee and contractor personnel.
- Denotes those attending the ft al exit meeting on October 5,1988.
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2.
Allegation Followup
RIII-88-A-0057: On May 3,1988, a contractor employee, fonne.aly
employed at the Davis-Besse plant, contacted the NRC with conce. ens involving
tne improper installation of fire dampers and stainless steel duct work in
the containment; violations of security barriers; and fire watch po+rol
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activities.
In addition, on November 25, 1987, the licensee provideo the
NRC with three concerns which had been brought to their attention through
the Ombudsman Program which were either identical or related to the concerns
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addressed to the NRC. These concerns were reviewed by Region III inspectors
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onsite with the following results:
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a.
Concern No. 1
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During fire dam >er installation work in the Boric Acid Room, two
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sheet metal worcers were instructed by a contractor supervisor to
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cut into the wrong sheet metal duct.
The alieger si.ated that the
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two sheet metal workers were later directed to leave the area at
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which time a contractor supervisor and other workers made repairs to
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the incorrectly cut sheet metal duct without informing TED personnel.
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(1) NRC Review:
In evaluating this concern, the NRC inspector reviewed the
Technical Specification for Heating and Ventilating and Air
Conditioning, 12501-M-420-N, Revision 2; Technical Specification
for Operational Phar.e for Heating and Air Conditioning,
12501-M-410-Q, Revision 4; TED Quality Assurance Manual
Section 3 Revision 2, "Design and Modification Control";
Quality Control inspection Procedure (QCIP) -048, Revision 1;
"Fire Damper Installation Inspection", Modification Package;
Maintenarte Werk Order (MWO) 2-84-094, Supplements 00, 01,
and 02; fire damper installation FD1192; and fire damper
installation drawing 12501-M-413, Revision 0.
Review of the above documents concluded that the fire damper's
assemblies are safety-related "Q" but the attaching HVAC duct
work was nonsafety-related. The NRC inspector did not perform
a visual inspection of the duct work specific to the allegation
as it is not important to safety and the duct work is not readily
accessible and would require scaffolding to inspect thoroughly.
A visual inspection of the accessible duct work was made with
no obvious defects observed. The above concern was turned over
to the licensee for their information since this concern involved
a nonsafety system.
(2) Conclusion
Although the above concern may have occurred as described by
the elleger, the sheet metal ducts referenced are not
safety-related and therefore, were not fabricated and installed
under the nuclear "Q" program. However, the above concern was
turned over to the licensee for their review and evaluation.
b.
Concern No. 2
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VM Systems was perfonning shoddy work on stainless steel duct
work in the can.
No other information was provided.
(1) NRC Review
The NRC inspector reviewed the Maintenance Work Order (MWO)
2-85-0207-2,
-4, and -5; and drawings 12501-M-435A and B and
verified this installation by VM Systems in the containment was
also nonsafety-related.
The duct work was fabricated and
installed in accordance with the licensee's Quality Assurance
Program. The NRC inspector visually examined approximately 50%
of the referenced duct work. The duct work observed appeared
to be in compliance with applicable drawing and visual inspection
requirements.
The overall quality of the welding appeared tu be
excellent.
The duct work inspected was the ducting and fan
installation for the Control Rod Drive Mechanism Service Structure
Ventilation System.
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(2) Conclusion
This allegation was not substantiated. -The NRC inspector observed
the duct work installation and quality documentation which
appeared to meet the applicable requirements. The stainless
steel duct work does not oerform a safety function and therefore,
would not be safety significant.
In a followup conversation
with the alleger, he stated he had no first hand knowledge of
the shoddy work but had heard this from other sources which he
declined to identify.
c.
Concern No. 3
Fire Damper Assembly No.1066 was hammered into place (af ter being
QC inspected and signed off as acceptable) which caused the welds to
break and was subsequently rewelded without being QC inspected.
(1) NRC Review
In addition to the previously referenced Technical Specifications,
the NRC inspector reviewed MWO 2-86-0206-03; Field Change
Notices No. 6242, 6358, 6693, 6426; Field Change Request 86-206;
Bill of Materials 642 512850; WM d Trt/elers; Weld Material
Issue Tickets; Fire Damper Installation Inspection 87-M-782;
Davis-Besse Nuclear Power Station Drawing M474, Sheet 85,
Revision 0; Pullman Construction Industries (PCI) drawing
178102-3, Revision A; PCI drawing 178102-1066 Revision 1;
PCI drawing 178102-FD-6, Revision 0; and PCI drawing
178102-FO-1NS, Revision 2.
The installation of the fire
dampers were installed to Q-class 01, which is a safety-related
classification.
Review of applicable drawings and specifications
concluded that the fire damper installation is safety-related.
Review of maintenance work order packages conc 1'Jded that the
installation of Fire Damper 1066 was in accordance with the
applicable quality assurance requirements for safety-related
installation.
The NRC !nspector visually examined the Fire Damper No. FD-1066
for evihnce of damage due to improper installation (hannering,
damaged welds, weld repairs, etc.).
Visual examination of the
fabrication and installation welds identified that the installation
was in accordance with the referenced drawings and the applicable
procedure requirements.
(2) Conclusion
The NRC inspector's visual examination did not reveal any
evidence of improper installation practices.
No denting of
material due to hammering was evident, and no weld repairs were
evident. The installation was re-inspected by TED engineering
and quality control at the time of the NRC inspector's
examination. This activity was documented on MWO 1-88-2379
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dated October 4, 1988. No deficiencies were identified; the
fire damper was installed in accordance with the referenced
drawings and procedures,
d.
Concern No. 4
A11eger refused to perform work activities during periods of time
when acting as a fire watch patrol in accordance with the alleger's
previous Toledo Edison training. The alleger alleged that a
contractor supervisor complainad about these periods of inactivity.
(1)
NRC Review
A review by the NRC inspector of the licensee's procedural
connitments and license requirements was conducted. The NRC
inspector was provided Administrative Procedure DB-MN-00007,
entitled "Station Open Flame Welding, Cutting and Grinding
Permit", Revision 00, dated February 5, 1988. A review of the
license requirements determined that Amendment No. 18 of the
Plant Operating License in Paragraph 2.C(4) requires the licensee
through Section B.14 of Table 1 of the Safety Evaluation to
comply with the fire protection administrative controls described
in the NRC document entitled "Nuclear Plant Fire Protection
Functional Responsibilities. Administrative Controls, and Quality
Assurance".
Paragraph 2.0(3) of Attachn:ent 4 of this NRC
document requires a fire watch to be provided where cutting,
welding, grinding or open flame is performed.
The NRC inspector interviewed a contractor employee who performs
the initial contractor procedure training and a licensee
instructor who teaches the Fire Watch Training Progru to both
contractor and licensee personnel. These individuals talked
through the instruction given to fire watch personnel. The
licensee instructor provided a copy of the Fire Wa:ch
QudlifiCation Training Lesson Plan. According to the Fire
Watch Qualification Training Lesson Plan, Number GEN-FIR-100.02,
Revision 2 dated April 8,1988, in Paragraph 2.0.D.5.c, a
qualified fire w tch may perform minor functions (i.e., passing
tools, work area cleanup, assisting workers, etc.) providing the
ability to contf r ually monitor for and combat fires with fire
extinguishers is not affected.
In addition, the licensee provided
other procedures having fire watch relevance including
Administrative Procedure No. AD18 28.19, Revision 3, dated
October 24, 1985; Training Procedure No. NT-ST-07043, Revision 0,
dated August 26, 1988; and Procedure No. NG-NE-0302, Revision 1,
dated June 8, 1988.
Based on the NRC inspector's review, the licensee's applicable
hot work procedures and training lesson plans were found to be
in accordance with the specified license requirements.
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The NRC inspector was informed by the Facility Modification and
Design (FMD) Department Modification Coordinator that the
particular contractor company had completed their required work
activities and were not presently onsite. Additionally, the
licensee's staff informed the NRC inspector that no hot work
activity was presently ongoing in the plant. Therefore, the
NRC inspector was unable to interview any fire watch personnel
assigned those duties while hot work activities were in
progress. The NRC inspector was able to interview a General
Electrical and Mechanical (GEM) Contractor Foreman and two
individuals employed by GEM who work as a team during welding
and grinding type activities. One of these individuals fulfills
the fire watch duties during these activities.
Each of the above
individuals' responses-to the NRC inspector's questioning was
consistent with Administrative Procedure DB-MN-00007 and the Fire
-Watch Training Lesson Plan, GEN-FIR-100.02.
(2) Conclusion
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This allegation did not specifically address the type of work
activities involved.
Further, the required work activities have
apparently been completed and the contractor has left the site.
Consequently, this portion of the allegation could not be
specifically reviewed,
e.
Concern No. 5
A contractor supervisor instructed workers to cross security
barriers without waiting for security to allow passage so as to
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cut waiting time.
(1) NRC Review
This concern was originally brought to the licensee's attention
through allegations made to the Ombudsman Program (the Davis-
Besse program which processes employees' concerns) during
employee exit interviews.
This allegation was reported
and resolved by the Ombudsman in the November 1987 time frame.
These investigations showed that the security area the alleger
was referring to was their assigned work area which was
enclosed by chain link fence and kept locked during non-working
hours. The craft foreman was in a hurry to get work started
and he did not want to wait for security to unlock the work
area. He instructed the workers to climb over the fence and
start work.
The workers refused and waited for the gate to be
opened.
On September 16, 1988, the alleger was contacted to verify that
the barrier that they were asked to breach was, in fact, their
daily enclosed work area and not a protected area or vital area
barrier. The difference between security areas and barriers
was explained to the alleger and he agreed that no breach of
NRC required security occurred. He was just attempting to use
this example to show how the craft foreman attempted to rush
the job and hurry his people.
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(2) Conclusion
The NRC review of this concern through interviews showed that
the barrier in question was not a security barrier and no
breach of security occurred. This allegation is considered
closed,
f.
Concern No. 6
The Ombudsman was informed in November of 1987 of these issues
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involving VM Systems and the foreman responsible.
In addition,
several ot.her individuals provided similar concerns to the Ombudsman
and were not getting an adequate response.
(1) NRC Review
The NRC inspector contacted the Ombudsman. The NRC inspector
diso contacted the alleger who provided the nanes of other
individuals who he referred to as having similar concerns and
had not received a reply from the Ombudsman.
The NRC inspector, r.ssisted by the Ombudsman, reviewed the exit
interview forms of e.he persons referenced.
Two had indicated
cor;cerns verbally but did not provide a written statement and
signature on the appropriate Ombudsman Program form. The
Ombudsman informed the inspector that he/she does not inforns the
concerned person of the results of the investigation unless this
portion of the form is filled in and signed.
The Ombudsman
requested assistance from the Quality Verification group to
perform a surveillance / audit into the concerns voiced by the
above individuals. The concerns provided to the Quality
Verification auditor were as follows:
0-1. A supervisor requested a welder to allow another welder
to use his certification.
0-2. Used parts and components for another job and did not
modify the paperwork.
0-3. Violated or crossing of security boundaries without
compensatory measures in place.
0-4. During fire damper installation in the Boric Acid Room,
two sheet metal workers were instructed by their
supervisor to cut into the wrong sheet metal duct, and
was later repaired without informing TED personnel.
The above concerns were given to the Quality Verification auditor
verbally and he was directed by the Ombudsman not to contact the
craf t or supervisor of the contractor in performing his audit.
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The NRC inspector reviewed the surveillance report concerning
these concerns. The content of the surveillance report is
considered proprietary by TED as it is part'of the Ombudsman
investigation. The purpose of the classification of proprietary
is to protect the identity of those individuals who brought
forth the concerns to the Ombudsman. The Ombudsman's
restriction to not contact the craft or supervisor was also
intended to safeguard the concerned person's identity.
Review of the surveillance report revealed that although the
Quality Verification auditor performed a surveillance of the
work activities, inspections, documentation, etc., the specific
issues addressed by the concerned person / persons was not adequately
investigated. This was primarily due to the ground rules of the
Ombudsman which restricted talking to the craft and foreman who
would be cognizant of the issues.
(2) Conclusion
It is necessary to protect the identity of the person who
brought forth the concerns when the person requests anonymity;
however, as in this case, the Ombudsman's restrictions negated
an adequate review of the concerns.
It was not necessary to
divulge the identity of the concerned persons to perform an
adequate review.
It is understood that when a concern is
brought to the attention of the craft or former supervisor,
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hir, identity may be jeopardized for it is likely that he had
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discussed these concerns openly with others. This possibility
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should be explained to the individual who requested anonymity
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when concerns are expressed to the Ombudsman.
The NRC inspector also identified other weaknesses in the
licensee's Ombudsman procedures. Although the Ombudsman Program
is not a regulatory requirement, when potential safety issues are
revealed to the licensee's Ombudsman, it is imperative that the
licensee makes a thorough investigation of these issues.
It is
also important to notify the concerned individual upon completion
of the investigation with the results of the investigation and
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corrective action taken (if any was necessary). This can preclude
the individual from notifying the NRC with the same concerns.
The NRC inspectors investigated concerns 0-3 and 0-4 presented to
the Ombudsman; however, 0-1 and 0-2 were not given to the NRC by
the alleger and may have been provided by another person.
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NRC inspectors could not substantiate these concerns as the
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contractors had completed their job and departed the site. The
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Ombudsman indicated that although the supervisor made the
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request for the welder to allow another to use his welder
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certification, the welder stated during his interview that he
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did not allow his certification number to be used by others.
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The licensee could not substantiate this allegation as it was
one individual's word against another's.
The licensee did not address the concern of parts and
components being substituted without proper paperwork directly.
However, the licensee did perform c.n overall quality review
of'the fire damper installation. This audit included review of
all the nonconformance reports (PCAQs), work packages for the
installation of fire dampers, including materials control, field
observations of QC inspectors, and review of QC procedures. The
overall quality of the installations was found to comply with the
applicable drawings and quality requirements,
lhe NRC inspector suggested that the licensee modify the
Ombudsman procedures to alleviate the weaknesses addressed in
this report. The licensee acknowledged the inspectors
suggestions.
3.
Exit Interview
The inspectors met with licensee representatives (denoted in Paragraph 1)
at the conclusion of the inspection on October 5, 1988. The inspector
sumarized the scope and findings of the inspection. The inspector also
discussed the likely informational content of the inspection report with
regards to documents or processes reviewed by the inspector during the
inspection. The licensee identified the "Ombudsman Program" reports and
associated surveillances as proprietary. The inspector assured the
licensee that no proprietary information would be disclosed from the
reports.
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