ML20213E308

Insp Rept 50-346/86-28 on 860930,1001-03,07-09 & 14-17. Violation Noted:Failure to Provide Documented Instructions Per 10CFR50.17.2.5

ML20213E308
Person / Time
Site:	Davis Besse
Issue date:	11/07/1986
From:	Choules N, Jablonski F, Wharton L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20213E281	List: ML20213E278 ML20213E292 ML20213E308
References
50-346-86-28, NUDOCS 8611130097
Download: ML20213E308 (8)

See also: IR 05000346/1986028

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-346/86028(DRS)

Docket No. 50-346 License No. NPF-3

Licensee: Toledo Edison Ccapany

Edison Plaza, 300 Madison Avenue

Toledo, Ohio 34652

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Facility Name: Davis-Besse 1

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Inspection At: Oak Harbor, Ohio

Inspection Conducted: September 30 and October 1-3, 7-9, and 14-17,1986

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Inspectors: Ned C. h 'l es Da/_I-la-bg

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Approved By: rank Ji/J b onski, Chief //- 6- d b

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Quality Assurance Programs Section Dite'

I_nsp_e,ction Summary

Inspection on__ Sept _ernber 30 and October 1-3 7-9 and 14-17 1986

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(Report No. 50-34 6/ 86028[0'RS))~~~ ~ ~~ ~ ~ ~ ~ ~~ ,~~~ ,~~ " ~ ~ ~~",~ ~ ~ ~ ~

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'A~eas Tn'sj~ic~tFd:~~~ RoIKiiie, announced inspection of licensee actions on previous

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inspection TiiRIings (92701, 92702), employee concerns (99014), maintenance work

requests (62700), and facility change requests (37700).

Results: Of the thirteen findings reviewed, five were closed. Of the other

three areas inspected, one violation was identified in one area (failure to

provide documented instructions - Paragraph 3),

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PDR ADOCK 05000346

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DETAILS

1. _P_e_r_ sons Contacted

Toledo Ed_ iso _n_Cpmpany

L. Storz, Plant Manager

• S. Smith, Assistant Plant Manager, Maintenance

• P. Hildenbrandt, Engineering General Director

• E. Salowitz, Assistant Plant Manager, Outage

• L. Ramsett, QA Director

• L. Wade, QC Supervisor

• J. Moyers, Quality, Verification Manager

• H. Witcomb, Preventative Maintenance Program Manager

• D. Mominee, Engineering Assurance Supervisor

• R. Nougrod, Corporate Nuclear Review Board Administrator

• V. Sturdavant, Licensing Specialist

C. Daft, Operations QA Manager

W. Bass, Consultant

USNRC

• Paul Byron, Senior Resident Inspector

D. Kosloff, Resident Inspector

Other licensee personnel were contacted during the" course of the

inspection.

• Denotes those attending the exit interview on October 17, 1986.

2. Licensee Action on Previous Inspection Findings

a. (0 pen) Open Item (346/84009-04): Lack of equipment failure history

and trending program. The licensee was working on an equipment

trending program and estimates that it is 15 to 20% complete. This

item will remain open pending completion and implenientation of the

trending program,

b. (0 pen) Open Item (346/84009-05): Excessive backlog of Maintenance

Work Orders (MW0s). The licensee was still in the process of

completing work and documentation for MW0's implemented during the

current outage. On October 12, 1986, there were 2363 open corrective

MW0s. The licensee determined that 931 of the corrective MWOS needed

to be closed prior to restart of the plant. This item will remain

open pending further review during a subsequent inspection.

c. (0 pen) Open Item (346/84009-13): Large backlog of facility change

requests (FCRs) and installed jumpers. On September 30, 1986,

180 FCRs were in closecut, 224 were being implemented, and

approximately 500 were being evaluated for future work. The nurrber

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of FCRs in closecut and implementation shcws a reduction from the

backlog reported in Inspection Report No. 346/86002. The licensee

anticipates that approximately 200 of the 500 FCRs being evaluated

will be implemented during the 1988 outage.

During this inspection the inspector determined that 20 jumpers

installed prior to the kr.e 9, 1985, event were still in place, and

103 had been installed after the event. The licensee plans to remove

two of the 20 jumpers and all of the 103 jumpers prior to restart of

the plant. This item will remain open pending further review.

d. (0 pen) Violation (346/84009-17): Significant backlog of nonconformance

reports (NCRs). In Inspection Report No. 346/86002 it was reported

that 16 NCRs identified prior to 1984 remained open. Nine of those

remained open at the time of this inspection. A combined total of 18

NCRs identified in 1984 remained open. The licensee was continuing

efforts to close the NCRs. This item will remain open pending

further review during a subsequent inspection.

e. (0 pen) Unresolved Item (346/84019-05): Procurement and Purchasing

department procedures were ineffective. The licensee has written a

Nuclear Mission Prccedure (NMP-NA-400, " Material Management") for the

control of procurement and purchasing which will supersede previous

related procedures. The procedure was in final draft and personnel

were being trained in use of the procedure. Ti.is item will remain

open pending approval and issuance of the procedure,

f. (0 pen) Violation (346/85001-02): Procedures were not provided

for calibration of instrumentation to verify compliance with the

Technical Specifications, and for calibration of measuring and test

equipment (M&TE). As reported in Inspection Report No. 346-86002,

the licensee had determined the need for approximately 600 instrument

calibration procedures and 125 procedures for calibration of M&TE.

The licensee had prepared approximately 200 instrument calibration

procedures and 98 M&TE calibration procedures at the time of this

inspection. This item will remain open pending conpletion of the

procedures.

9 (Closed) Unresolved Item (346/85007-05): No preventative maintenance

(FM) program existed for non-stock equipment. As reported in .

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Inspection Report No. 346/86002, two items remained to be accomplished

to closecut on audit findings report (AFR). These two items were the

identification of PMs for equipment in the warehouse by maintenance,

and the establishment of a system by the engineering department to

identify PMs for new equipment. The engineering department had

revised their procedures, (NES-071, Purchase Regeest for Space and

Replacement Parts; NES-070, Procurement; and NEP-070, Preventative

Maintenance) to identify PM requirements for new equipment which is

purchased and stored in the warehouse. The identification of PMs

for equipment on hand in the warehouse had been completed; however,

implementation had been delayed. During the inspection, the licensee

implemented the PMs on applicable equipment stored in the warehouse. 1

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h. (0 pen) Unresolved Item (346/85007-06): Resolution of open audit

AFR 1327-6 regarding traceability of materials listed on maintenance

work orders. This AFR was upgraded to a corrective action request

(CAR 86-03) because there wasn't any response to the AFR. In

response to the CAR, an audit was conducted involving traceability

of parts listed on MW0s compared to purchase orders. No apparent

problems were identified by the audit; however, the CAR remains

open pending the engineering department's evaluation of the audit

results. This item remains open pending closure of CAR 86-03.

1. (0 pen) Open Item (346/85007-07): Lack of a design data base. In

Inspection Report No. 346/86002, it was indicated that the licensee

planned to have system design basis documents completed by

December 31, 1986. The licensee has expanded the program to include

more information in the system descriptions and anticipates it will

take up to a year and a half to complete. One system description and

an administrative procedure for control of the program has been issued.

This item will remain open pending completion of the program,

j. (Closed) Open Item (346/85007-09): Problems in records management

as identified in the licensee's Audit No.1327 and the 1984 QA Program

Assessment. One item, reorganization of the records system, remained

to be completed to address reconnendations identified in the 1984 QA

Program Assessment Inspection Report No. 346/86002. The licensee

completed reorganization of the records system and related training

was ongoing at the time of this inspection,

k. (Closed)OpenItem(346/85007-12): Lack of effective audit report

overview by Corporate Nuclear Review Board (CNRB). In June 1986,

an Audit /QA/ Security Subconcittee to the CNRB was established. Review

of the subconmittee's monthly meeting minutes indicated that the audit

reports and audit activities were being effectively reviewed.

1. (Closed) Unresolved Item (346/85012-02): Meggering Procedure

No. 1401.36 did not specify prerequisites for connencing work

nor requirements for restoration of equipment after completion of work.

The licensee revised and approved Procedure No. 1401.36 to address

the inspector's concerns,

m. (Closed) Open Item (346/85012-03): A procedure for the control

of lubricants was needed. The licensee revised Administrative

Procedure AD 1844.04, " Control of Lubricants" to provide instructions

for control of lubricants during storage, issuing, and field use.

The inspector has no further concerns regarding this item.

3. Emp,loyee Concerns

A licensee quality control (QC) inspector, who recently resigned,

expressed concerns to the licensee and the NRC resident inspector

related to QC inspections performed during rework of Class 1E electrical

splices insulated with Raychem materials. The QC inspector's concerns

were reviewed by the NRC inspector. The review included QC checklists

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and MW0s for installations of Raychem materials; interviews with other

QC inspectors, QC supervision, engineers associated with the Raychem

work and other management personnel; and review of procedures associated

with the installations. Results of the review are as follows:

Concern 1

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Installation of Raychem insulation materials was not being performed

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in accordance with instructions and the QC inspector could not work

to verbal instruction. The QC inspector's concern was that work

should not proceed based on verbal instructions and should be stopped

until a revised engineering sketch was included in the MWO package.

Installation of Raychem insulation was accomplished in accordance with

approved MW0s and procedure MP 1410.24, " Installation and Termination

of Electrical Cables." The engineering specifications for each

installation, including dimensions, were identified on an engineering

sketch that was attached to each MW0. During implen.entation of the

MW0s, some dimensional deviations occurred that exceeded the acceptance

criteria of the engineering sketch. Based on a management decision,

when a dimensional deviation occurred work could proceed if the

engineering department verbally approved the dimensional deviation,

the deviation was within Raychi. specifications, and engineering

provided a revised sketch.

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During installation, QC utilized a checklist as the installation

proceeded. When a dimensional deviation was identified, the QC

inspector signed off the applicable checklist item as unsatisfactory

and noted the condition on the checklist. The QC inspectors were

instructed to allow work to proceed. When the engineering sketch

was revised and received the checklist was changed from unsatisfactory

to satisfactory.

The NRC inspector's review of this item indicated that the licensee's

handling of dimensional deviations was appropriate for this particular

situation, that is, all splices met requirements. However, there was

no procedure that allowed work to proceed after verbal approval of

a deviation. Examples where work was allowed to proceed based on

verbal instruction included: QC Checklist 86-E-673 associated

with MWO 1-86-2996-00, QC Checklist 86-E-676 associated with

MWO-1-86-3147-00, and QC Checklist 86-E-689 associated with

MWO-7-86-3177-00. This was a violation of 10 CFR 50, Appendix B,

Criterion V, which requires documented procedures for activities

affecting quality. (346/86078-01)

Prior to the end of the inspection, the licensee issued instructions

to QC inspectors that required revised sketches prior to continuing

work when unsatisfactory dimensional conditions were identified

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during installations of Raychem materials.

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Concern 2

The QC inspector was concerned that wiring diagrams were not

provided with the Raychem material installation package.

To install Raychem material, an electrical splice was disconnected

to permit the Raychem material to slide over the wires. The splice

was reconnected and the Raychem material shrunk over the termination

by a heat gun. The QC inspector felt a wiring diagram should have

been utilized to verify that the existing connections were in

accordance with the wiring diagram prior to disconnecting the wiring.

The licensee did not have reason to believe that the existing wiring

connection was unacceptable. To ensure that the wiring was not

changed, the Raychem material installation process was either

performed one conductor at a time or both sides of a connection

were positively identified before determination occurred. Also,

operational testing of equipment that could be affected by the

Raychem installation was performed. The licensee did not consider

the use of wiring diagrams necessary except for conditions where

positive identification was not maintained. The NRC inspector l

concurred with this position; the concern was unfounded. I

Concern 3

The QC inspector was concerned about some of the resolutions to

dimensional problems provided by engineering.

The NRC inspector reviewed about 400 QC inspection checklists

for installation of Raychem material. Unsatisfactory dimensional

, conditions were noted on eleven checklists. Review of the

l engineering resolutions were in accordance with instructions from

the Raychem company. The dimensional deviations were associated

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i with acceptance criteria which was more conservative than that

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specified by the Raychem instruction. The concern was unfounded.

Concern 4

l The QC inspector indicated he had been instructed by his Lead QC

Inspector not to stop work.

The QC inspector's impression to not stop work was apparen+1y

the result of the QC inspector wanting to stop work during Raychem

installations for the conditions identified in Concerns 1 and 2.

}- Based on interviews with the Lead QC Inspector, he did not feel

stop work was appropriate for those conditions. The QC supervisor

indicated that there was always the intention to stop work when

conditions warranted it. The concern was unfounded.

One violation in Concern No. I was identified.

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4. Review of Maintenance Work Orders (MW0s)

The inspector reviewed 34 recently completed MW0 packages. The VW0s

were reviewed to verify the following: proper approval, shift supervisor

approval for work to begin; instructions were adequate for the maintenance

worker to perform the task; operational testing specified and completed;

spare parts traceable to a purchase order; and a description of as found

conditions; and work performed.

No discrepancies were identified with the work requests and the

instructions were adequate to perform the work. The writeup of work

performed was very detailed and a big improvement from write ups on

MW0s previously reviewed in 1984 and 1985.

No violations or deviations were identified.

5. Reyjew pf__Facjlj_ty__ Change _Re, quest (FCRs)

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The NRC inspector reviewed seven recently completed FCR packages including

FCRs 78-0525,85-016, 85-0189, 85-0238, 85-0242,86-041 and 86-068. The

FCRs were reviewed to verify the following: proper approval, safety

evaluation performed and adequate; instructions implenenting the FCRs

adequate; testing of equipment n.odifications specified and performed;

drawings and procedures that required revision identified and revised;

training requirements identified; and parts and equipment used traceable

to a purchase order.

Some of the instructions provided for implementation of the FCRs were

marginally acceptable. FCRs 85-0189 and 85-0238 were examples where

instruction could have been better. FCR 86-041 was an example where

good instructions were provided.

No violations or deviations were identified.

C. .Suspensj_on__o_f Majntenance Training

The inspector reviewed the licensee's suspension of maintenance training.

The licensee suspended maintenance training for six weeks in order to

make 16% more of the maintenance work force available during a critical

stage of plant restoration. The six week break will allow training

instructors to devote time for development of courses and satisfaction

of items to complete INP0 accreditation of the licensee's Maintenance

Training Program. The inspector has no problem with the suspension of

training for six weeks. Maintenance trainir.g will resune November 10,

1986.

No violations or deviations were identified.

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7. Exit Interview

The Region 111 inspector met with licensee representatives (denoted in

Paragraph 1) on October 17, 1986, and sunnarized the purpose, scope and

findings of the inspection.

On October 28, 1986, the inspector discussed with Mr. Steve Smith by

telephone the likely informational content of the inspection with regard

to docun,ents or processes reviewed by the inspector during the inspection.

Mr. Smith did not identify any such documents or processes as proprietary.

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