IR 05000346/1989005

Insp Rept 50-346/89-05 on 890116-0228.Violations Noted.Major Areas Inspected:Licensee Action on Previous Insp Findings, Operational Safety,Maint,Surveillance,Lers,Licensee Events & Fire Protection

ML20246N777
Person / Time
Site:	Davis Besse
Issue date:	03/22/1989
From:	Defayette R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20246N762	List: IR 05000346/1989005 ML20246N758 ML20246N765
References
50-346-89-05, 50-346-89-5, IEB-79-27, IEB-87-002, IEB-87-2, NUDOCS 8903280035
Download: ML20246N777 (16)

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U. S. NUCLEAR REGULATORY COMMISSION .

REGION III

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l Report No. 50-346/89005(DRP)

Docket No. 50-346- Operating 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, Ohio Inspection Conducted: January 16 through February 28, 1989 Inspectors: P. M. Byron E. R. Schweibinz D. C. Kosloff J. S. Stewart J. M. Ulie J I. Ahmed j R. McCormick Approved By: R De Reactor Projects Section'3A M (f f Dated

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Inspection Summary 3

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Inspection on January 16 through February 28, 1989 (Report No. 50-346/89005(DRP))

Areas Inspected: Routine, unannounced inspection by resident inspectors 3 of licensee action on previous inspection findings; operational safety; i maintenance; surveillance; licensee event reports; licensee events; fire protection; bulletins; independent safety engineering; and quality assuranc Results: Of the ten areas inspected no violations or deviations were identified in seven areas. Two violations were identified in the areas of failure to have two operable radiation monitors (Paragraph 2g); and failure to perform T.S. required tests (Paragraph 3). There was an 1 unresolved item regarding an insufficient fire hose length (Paragraph 8).

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' 8903280035 890322 gDR ADOCK 05000346 PDC

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DETAILS . Persons Contacted Toledo Edison Company (TED)

D. Shelton, Vice President, Nuclear L. Storz, Plant Manager W. Johnson, Plant Maintenance Manager

• R. Flood, Plant Operations Manager

• E. Salowitz, Planning and Support Director

• L. Ramsett, Quality Assurance Director S. Jain,. Independent Safety Engineering Manager-I G. Grime, Industrial Security Director P. Hildebrandt, Engineering Director i J. Gates, Systems Engineering Manager V. Watson, Design Engineering Manager J. Kasper, Operations Superintendent

• G. Honma, Compliance Supervisor

• R. Schrauder, Nuclear Licensing Manager T. Haberland, Electrical Superintendent C. Daft, Technical ~ Planning Superintendent i J. Moyers, Quality Verification Manager 1 C. Bramson, Document Systems Manager j G. Skeel, Nuclear Security Operations Manager

• R. Gaston, Licensing Engineer

• T. Anderson, Maintenance and Outage Management Manager 4

• J. Syrowski, Acting Nuclear Training Manager

• S. Wise, Nucioar Operations Program Supervisor

• W. F11ppin, Senior Engineer, Nuclear 1 USNRC

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• P. Byron, Senior Resident Inspector  !

• Kosloff, Resident Inspector I E. Schweibinz, Reactor Inspector -

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l J. Stewart, Resident Inspector, Kewaunee J. Ulie, Reactor Inspector 1 J. Ahmed, NRR R. McCormick, EG&G INEL A. Yudy, EG&G, INEL

• Denotes those personnel attending the March 7, 1989, exit meetin . Licensee Action en Previous Inspection Findings (92701) (Closed) Violation (346/82003-06): It was determined that a lack of depth of Quality Assurance audits was being performed for the fire protection program' for audits conducted during 1979, 1980, and 198 The audits did not utilize the fire protection requirements contained in the licensee's operating license as part of the audit basi )

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By letter' dated September 7, 1982, the licensee committed to upgrade

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the quality assurance program to include the review of regulatory 1 requirements and commitments into the audit program. The nuclear Quality Assurance Manual (NQAM) was revised to include the' upgraded requirements. This item is close _

b. { Closed)UnresolvedItem(346/84010-01(DRS)): Questions were. raised regarding the adequacy of the illumination levels of emergency .

lighting installed to satisfy Section III.J of Appendix R.t CRF Part 5 As discussed in Inspection Report No. 50-346/84010(DRS), a long-term review had been initiated which included an evaluation of the adequacy j of illumination of the existing emergency lighting units in all areas needed for operation of safe shutdown equipment. This evaluation of.

l the existing emergency lighting was walked down by a survey team which i included members of the licensees operating staff. However, as specified by.the licensees letter of September 30, 1988,- the required modifications are in various stages of implementation, but are )

scheduled for completion no later than restart from the sixth 5 refueling outag This schedule has been discussed with the-NRC and has been documented by NRC letter dated November _7, 1987 (DeAgazio to Shelton). Also, additional guidance covering the acceptable illumination levels for emergency. lighting has been addressed in Generic Letter 86-1 Consequently, since another inspection report item (50-346/83016-05) is tracking the adequacy of the overall emergency lighting area, and a future inspection following the completion of the lighting area modifications will be conducted, this item is being close c. (Closed) Unresolved Item (346/87004-07(DRP)): This 1 tem regarded examples of inadequate fire watch program implementation.

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Based on the review of Licensee Event Report which included .

l those examples of inadequate fire watch program implementation  !

l having been addressed in Inspection Report No. 50-346/88028,.

Paragraph 3, this item'is considered closed, d. _

( Closed) Violation (346/87027-06): As of October 23, 1987, 4 Fire Detection Zone FDZ-A208 had not been restored to an operable status, nor had a Special Report been submitte By letter dated November 6, 1987, the licensee submitted a Special '

Report regarding the inoperable fire detection instrumentatio The licensee indicated that the Special Report was not submitted within the required time limit due to a personnel error in failing-to follow Procedure Number NG-QA-0702. As corrective action'for the late Special Report, all Shift Supervisors were being required to review this incident to improve their understanding of the proper mechanism for ensuring that such incidents are reviewed and reported appropriately. This was accomplished by required reading for Shift Supervisors which has been completed. This item is close ;

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- (Closed) Unresolved Item (346/88007-01(DRp)): Low temperature in component cooling water (CCW) pump room. On February 13, 1988, a malfunction of ventilation damper HV-5444C allowed the temperature in the CCW pump room to drop to about 25 degrees Normal temperature in the room was restored about 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> later after actions were taken to prevent cold outside' air from passing through HV 5444C. Section 9.4.2.1.2.5 of the Updated Safety Analysis Report (USAR) states that the ventilation ". . . system is designed to maintain the CCW pump room temperature between 60 degrees F and 104 degrees F year round." The inspectors reviewed the licensee's evaluation of this event and its corrective action The licensee's evaluation indicated that the event had minor safety significance because of the immediate corrective actions taken by operations and maintenance personne The corrective actions included additional instruction to operators, an engineering evaluation of affected equipmtnt, surveillance testing of affected equipment and an operations department' review of the methods for detecting low room temperature. Unresolved item

_(346/88007-01(DRP)) is closed because the completed corrective actions appear adequate to prevent recurrence of this even The inspectors also reviewed procedure SP 1104.12 (DB-0P-06262),

" Component Cooling Water System Operating Procedure." Step 2.11 of SP 1104.12 includes a table that shows the normal readings and alarm setpoints for the computer points that indicate CCW pump and motor temperature The normal minimum bearing temperature listed is 40 degrees F, the same temperature as the alarm setpoint and 20 degrees lower than the normal room temperature stated in the USA It appears that the procedure would be more accurate if the normal minimum bearing temperature was higher than 40 degrees F. The inspectors discussed the normal minimum temperature with the procedure writer who will

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review i The timeliness of the initiation of the licensee's corrective action is discussed in Paragraph 1 (Closed) Unresolved Item (346/88015-05(DRP)): Slide links found fused (tack-brazed) closed and an uncontrolled vendor document used during maintenance activity. The vendor concluded that the slide links had been tack-brazed closed early. in plant life by an off site support organization. As a result of unrelated corrective actions, programs are now in place to prevent uncontrolled plant modifications such as thi The inspectors reviewed licensee memorandum DSS-88-10390 dated September 20, 1988, "LCTS 4793." This memo confirmed that it was technically correct for the slide links to be tack-brazed shut and stated that the uncontrolled vendor document had been found packaged with the material and had not been used. The packing of vendor information with material is a common practice. The inspectors discussed uncontrolled vendor information with several licensee managers. Uncontrolled vendor information packed with material is now prevented from reaching the field by personnel in the

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warehouse. Material is received initially in the warehouse and I checked by Nuclear Material personnel. They are required by procedure DB-MD-00003, Revision 1, " Material Control," dated December 2, 1988, to remove any uncontrolled vendor information i found with material and send it to the appropriate organizatio l Material is then receipt inspected by Quality Assurance ,

personnel. This is a more detailed inspection which should ,

uncover any. uncontrolled vendor information not found in the d initial inspection.-

The inspectors reviewed Document Change Request (DCR) 89-0049 dated January 23, 1989, and discussed its content with the

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cognizant system engineer. DCR 89-0049 requests that Westinghouse drawing MGM 775-05 be changed to show the.:lide link screws for CT circuits tack-brazed shut. Unresolved item (346/88015-05(DRP)) is closed because the corrective actions taken appear adequate to prevent recurrence and to correct the j drawin The timeliness of the initiation of the licensees corrective action is discussed in Paragraph 1 g. (Closed) Unresolved Item (346/88021-03(DRP)): Licensee maintenance personnel installed jumpers in preparation for a calibration to be performed in accordance with procedure IC 2005.15, " Process Radiation i Monitor HRH Calibration." Installation of the jumpers rendered Station Vent Stack Radioactivity Monitor RE 4598 BA inoperable. The shift supervisor was not informed,'at that time, that RE 4598 BA was inoperable and did not become aware that RE 4598 EA was-inoperable until 1:12 p.m. on August 8, 1988. At about 9:00 a.m. on August 2, 1988, during the period that RE 4598 BA was inoperable,' RE 4598 AA was found to have a high voltage failure. At this time both channels of radioactive gaseous effluent monitoring instrumentation were inoperable and remained so until 3:27 p.m. on August 8, 1988, when RE 4598 AA was restored to operability. -The plant was in violation (346/89005-01(DRP)) of technical specification limiting condition for operation 3,3.3.10 whenever radioactive gas releases were made between August 2 and August 8, 1988. Six radioactive gas releases were made during this period. The licensee's records of these releases indicate that no regulatory limits were exceeded and that the offsite dose from the releases was negligible. Although the monitors were inoperable during the time of the releases the-indicating and local alarm functions of the monitors were still available. No alarms were received. The licensee issued LER 88-018 to report this event. The inspectors' review of the LER indicated that the corrective actions listed in the LER appear to be adequate, '

therefore no further response is required for this violation at this time. The inspectors will verify the licensee's completion of the corrective actions identified in the LER in a future inspectio h. (Closed)UnresolvedItem(346/88026-04): Improperly supported electrical cables in Manholes MH-3041 and MH-3042. The licensee concluded that the cables were improperly installed during

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initial construction more than eleven years ago. As a result of unrelated corrective actions, programs are now in place to prevent improper installation of electric cable The manholes are limited access locations with the covers normally bolted closed and the as-found condition did not deviate significantly from the required condition. T5erefore, this condition is of negligible safety significance. The inspectors reviewed the licensee's engineering evaluation of the condition and the proposeo corrective actions appear adequate. This item is closc The timeliness of the initiation of the licensee's corrective action is discussed in Paragraph 1 One violation was identified in this are . Operational Safety Verification (71707)

The inspectors observed control room operations, reviewed applicable logs and conducted discussions with control room operators during the months of January and February. The plant remained at full power until January 18, 1989, when an intermittent electronic failure caused a reactor trip during reactor trip breaker testing. The plant was restarted on January 23 and escalation to full power was ccmpleted on January 2 With the exception of minor power reductions the plant emained at full power for the remainder of the inspection period. The inspectors verified the operability of selected emergency systems, reviewed tagout records and verified proper return to service of affected component The inspectors increased their observation of control room activities in this inspection period as a result of earlier observation The inspectors consider that control room operations were adequate. Communications in the control room were formal when required but this is an area in which the licensee could improve. Paperwork burdens on the shift supervisor continue to be a problem and the inspectors did not note significant reductions from previous observations. The maintenance and implementation of the equipment status board are areas to which the licensee needs to devote attention. The inspectors observed that the operators are not effectively utilizing operator aids and frequently use substitutes. As an example of this, the operators do not always use shift turnover sheets but use 3"x5" cards as a substitute and do not always pass on the information contained on the turnover sheet. A slight decline in control room housekeeping was observed. The inspectors will continue to observe control room operation While observing control room operations the inspectors reviewed a Potential Condition Adverse to Quality Report which the licensee had used to document a failure to implement Technical Specification (TS) 6.8.4. That requires implementation and maintenance of a program to reduce leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident. The licensee's program is controlled by procedure DB-SP-00001, " Radioactive Fluid Leak Reduction Program Outside Containment," Revision 00, April 23, 198 l

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Section 6.1.4, " Waste Gas," of DB-SP-00001 requires;that'"The integrity of this system shall be verified by the performance of PT 5172.00, Gaseous Radioactive Waste System Leak. Rate Test." Section 6.1.5, " Primary Sampling (Post Accident Sampling) System," . require that "The integrity of this

. system shall be verified by the performance of PT 5164.04, Reactor Sample System Leak Test." PT 5164.04 and PT 5172.00 must be performed at refueling' cycle intervals or less.- Therefore PT. 5164.04 was required to~-

be performed by-August 4, 1988, and PT 5172.00.was. required to be performed by August 21, 1988. PT 5172.00 was identified on the licensee's Surveillance and Test Schedule as a Critical Periodic Test (PT). A:

Critical PT is defined by Section 4.1 of DB-DP-00013 as "those tests which are considered important to the continued safe operation of.the plant." The inspectors noted several Critical PT on the Surveillance Test Schedule that were many months' overdue. These: pts were brought to the attention of licensee personnel. The Critical PT program, as administered by DB-DP-00013 is ineffective and must be improve Failure to perform PT 5164.04 and PT 5172.00 when. required is a violation (346/89005-02(DRP)) of TS 6.8.4. When responding to this violation the licensee shall discuss how it intends to improve the-Critical PT progra '

Tours of the auxiliary, turbine, water treatment and service water buildings were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks, and excessive vibrations and to verify that maintenance requests had been initiated for equipment in need of maintenance. The inspectors by observation and direct interview verified that the. physical- security plan was ,

being implemented in accordance with the station security pla ;

The inspectors observed plant housekeeping and cleanliness conditions and verified implementation of radiation protection control During the month of January.and February, the inspectors walked down accessible portions of the Service Water, Emergency Diesel Generator, Essential 120 Volt AC, Essential 4160 Volt AC, Essential 480 Volt AC, Essential 125 Volt DC, Component Cooling Water Systems and Steam and Feedwater Line Rupture Control Systems .to verify operabilit These reviews and observations were conducted to verify that facility operations were in conformance with the requirements established under technical specifications,10 CFR, and administrative procedure The inspectors were requested by Temporary Instruction (TI) 2515/98 to provide information on high temperatures inside the containmen The inspectors met with the licensee to discuss the problem and requested selected containment temperature data. The licensee provided the information which was transmitted to. Region III on December 19, 1988. The inspectors evaluated the temperature information and consider that the sensors provide an adequate representation of containment temperatures. The inspectors consider that this action completes the required actions o TI 2515/98 and it is considered close One violation was identified in this are l i

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1 Monthly Maintenance Observation (62703)

Station maintenance activities of safety related systems and components l listed below were observed or reviewed to ascertain that they were '

conducted in accordance with. approved procedures, regulatory guides .

and industry codes or standards and in conformance with technical i specification The following items were considered during this review: the limiting _

conditions for operation were met while components or systems were i removed from service;. approvals were obtained prior to initiating the i work; activities were accomplished using approved procedures and were inspected as applicable; functional testing or calibrations were l performed prior to returning components or systems to service; .

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quality control records were maintained; activities were accomplished 1 by qualified personnel; parts and materials used were properly  !

certified; radiological controls were implemented; and fire l prevention controls were implemente Work requests were reviewed t'o determine status of outstanding jobs and to assure that priority is assigned to safety related equipment maintenance which may affect system performanc The following maintenance activities were observed or reviewed:

Setpoint changes for the low voltage switchgear rooms ventilation systems. The licensee's control of the functions of this system was weak and improvements were made after the j 1 inspectors discussed the weaknesses with the license '

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Installation of a new air compressor for the EDG air start compressed air tank *

Repair of steam valve MS 107 Repair of a piping union for the No. 2 Auxiliary Feedwater Pump Turbine cooling syste Repair of pressurizer spray valve RC *

Replacement of flange studs for the service water system associated with the No. 2 AFW pum Preventive maintenance on No. 2 CCW heat exchange Adjustment of trip throttle valve linkage for No. 2 AFW pump turbine. During the performance of this adjustment licensee personnel found that parts of the linkage were subject to unanticipated wea Normally the linkage for a trip throttle valve is rarely cycled. However, due to the critical function of the AFW turbines the AFW turbine trip throttle valves are reset many times for training purposes. The licensee's evaluation of corrective actions for the linkage wear is an open item .

(346/89005-03(DRP)).  ;

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No violations or deviations were identified in this area.

l Monthly Surveillance Observation (61726)

The inspectors observed technical specification required surveillance testing on the Auxiliary Feedwater System, DB-SP-03160, " Auxiliary Feedwater Quarterly Test," and verified that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that limiting conditions for operation were met, that

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removal and restoration of the affected components were accomplished, that test results conformed with technical specifications and ,

procedure' requirements and were reviewed by personnel other than the !

individual directing the test, and that any deficiencies identified {

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during the testing were properly reviewed and resolved by appropriate management personne The inspectors also witnessed or reviewed portions of the following test activities:

DB-ME-03000, Station Batteries Weekly Test DB-MI-03363, Channel Functional Text of Anticipatory Reactor Trip System, Channel 3 Output Logic DB-MI-04555, String Check of 79A-JSR8428 Condor 411 Radiation Monitor k

DB-SC-03113, SFAS Channel 4 Functional Text

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! DB-SP-03271, Containment Integrity Verification '

l IC-2005.03, Process Radiation Monitor (Gaseous) Calibration l

ST 5080.01, Independent Off-site AC Sources Lined Up and Available No violations or deviations were identified in this are . Licensee Event Reports Followup (92700)

The following LER's were reviewed during the inspection period but could not be close (0 pen) LER 89-001: Missed Surveillance Test. Because two of the licensee's three corrective actions are scheduled to be completed in March the inspectors will review the corrective actions for this event during the next inspection perio (Open) LER 89-002: Incorrect Fire Watch Established Due to Personnel '

Error When Fire Door 422 Blocked Open. This event is being evaluated by Region III fire protection specialists in conjunction with other fire protection issues.

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b , Onsite Followup of Events (62702), (82201), (82206) and (93702)

During the inspection period, the licensee experienced several events, )

one required prompt notification of the NRC pursuant to 10 CFR 50.7 The inspectors pursued the events onsite with licensee personnel. In each case, the inspectors verified that the notification was correct and timely, if appropriate, that the licensee was taking prompt and appropriate actions, that activities were conducted within regulatory ,

requirements and that corrective actions would prevent future recurrenc l The specific events are as follows:

l January 15, 1989  !

At about 2:00 a.m. EST, the licensee began a planned electrical outage in the owner-controlled area. The Davis-Besse Administration Building (DBAB) was affected by the outage. A backup diesel generator (DG) designed to provide power to the l DBAB for seven days because emergency response facilities are l located in the DBAB. However, the DBAB DG failed at about 1 4:00 a.m., about ninety minutes after it started. The emergency loads transferred to the uninterrupted power supply (UPS) or the respective battery backup. The batteries soon were depleted resulting in the loss of power to various computer systems, DBAB emergency lights, microwave equipment and the computerized activated notification system (CANS). The licensee believes that i if an event had occurred that it could have restored the offsite I feeder to provide power to the emergency facilitie January 17, 1989 At about 9:53 a.m. EST, with the plant at full power, emergency diesel generator (EDG) 1-1 automatically started and powered its associated safety related bus (C1). The EDG start was caused by a temporary test jumper lead contacting the frame of an undervoltage (UV) test switch during surveillance test DB-ME-03040,

"SFAS Sequencer C1 Bus Undervoltage Relay Functional Test." A short circuit from the unintentional contact caused the C1 bus UV circuit l power supply fuses to blow. Although C1 remained powered from its normal source, the de-energized UV relays provided UV indication, l causing EDG 1-1 to start and Service Water (SW) pump 1-1 to trip.

! Licensee personnel restored normal power to the C1 bus and restored the appropriate equipment to service at about 11:30 a.m. This event was almost identical to a start of EDG 1-2 that occurred on November 22, 198 January 18, 1989 At about 1:44 p.m., with the plant at full power, the plant tripped on high Reactor Coolant System (RCS) pressur The trip was caused

, by an undetected intermittent failure of the " trip confirm" logic l circuit during control rod drive (CRD) trip breaker surveillance testing. Normally a trip confirm signal is sent to various plant I components when a plant trip has occurred. The trip confirm logic

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is designed to generate a trip confirm signal when at least two-of the four CR0 breakers have tripped. During CRD breaker testing,  ;

one CRD breaker is actually tripped, creating one valid tripped i breaker logic input. At the same time, the intermittent logic ]

failure occurred, causing a trip confirm output signal when no  !

plant trip had actually occurre One function of the trip confirm I'

output is actuation of the Rapid Feedwater Reduction (RFR) controls

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associated with the Integrated Control System. The RFR controls functioned as designed, reducing feedwater flow to a target value i consistent with expected post-trip feedwater demand. The reduced .i

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feedwater flow was inadequate for full power operation which caused RCS pressure to increase to the high pressure trip setpoin January 27, 1989 I

The licensee declared auxiliary feedwater (AFW) steam generator (SG)

level control value, AF6452, inoperable when it failed open while performing its technical specification surveillanc Investigation revealed three failed transistors in the valve positioner. The positioner was replaced and the surveillance was successfully performed. The licensee initiated an action plan to determine the cause of the failures and also initiated a program to increase its capability to troubleshoot and repair the valve positioner and level controlle February 8, 1989 The licensee declared an unusual event in accordance with its emergency procedures at 9:38 a.m. when the forebay level dropped below 565 feet. High winds out of the southwest resulted in varying ,

lake levels. The lowest forebay level noted was 564.8' feet. The  !

unusual event was terminated at 2:05 p.m. when the forebay level j rose to above its emergency classification level. The licensee ,

notified the NRC in accordance with 10 CRF 50.72 and documented the event in PCAQR 89-008 ;

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No violations or deviations were identified in this are ;

Fire Protection (64704)

On February 7, 1989, the licensee was performing procedure DB-FP-03010, i

"31 Day Fire Hose Inspection" and discovered that the hose at station HCS 33 was 75 feet long rather than the required 125 feet. The procedure <

was performed to satisfy Technical Specification 4.7.9.3.a, which requires that specified fire hose stations, which includes HCS 33, shall be demonstrated operable at least once per 31 days by visual inspection of i the station to assure all required equipment is at the station. The '

discrepancy was reported to the shift supervisor at 8:34 a.m. and corrected by 9:06 a.m. This was documented in PCAQR 89-0084. This is the second documented event within two years. On November 25, 1987, the licensee replaced a section of hose which was' required to be 75 feet long with a section of hose 50 feet long. This was reported via LER 8701 ,

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'b The inspectors have discussed this issue with the-licensee and determined that hose station HCS 33 has always had 75 feet of hose, and the additional length requirement was recently determined while performing the code revie This is an Unresolved Item (346/89005-04(DRS)).

The licensee discovered during a walkdown for fire wraps that conduits 36898A and 36018A were routed differently than described in the Compliance Assessment Report (CAR). PCAQR 89-0036 was written on January 16, 1989, to document this finding. On July 15, 1988, PCAQR 88-0536 was written to document a similar finding for conduits 46209A and 36239A. The licensee implemented compensatory measures when discovered. This issue will be evaluated by a Region III specialist during a subsequent inspectio No violations or deviations were identified.

. Bulletin Followup 92703 i

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For the Bulletins listed below, the inspectors verified that the written response was within the time period stated in the bulletin, that the written response included the information required to be reported, that the written response included adequate corrective action commitments based on information presentation in the bulletin and the licensee's response, that licensee management forwarded copies of the written response to the appropriate onsite management representatives, that l

information discussed in the licensee's written response was accurate,

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and that corrective action taken by the licensee was as described in the written response.

j (Closed) NRC Bulletin 87-02, (" Fastener Testing To Determine Conformance

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with Applicable Material Specifications").

NRC Bulletin No. 87-02 required the licensee to provide information regarding receipt inspection and internal. control procedures as well as independent testing of both safety related'and non-safety related fasteners. The licensee responded to the Bulletin by letter (Serial J No. 1-781), dated February 16, 198 l Temporary Instruction 2500/26 required the NRC Inspectors to participate in the licensee's selection of fasteners to be tested as well as to review the response to the bulletin to ensure that stated programs were being implemente The inspectors obi.,erved the licensee's selection of fasteners to be tested. Subsequent review by the inspectors determined that the licensee's original sample was not sufficiently broad based and informed the' licensee- l of this finding. The licensee expanded the sample and the inspectors observed the licensee's second sample selectio ;

The inspectors also determined that receipt' inspections of safety-related fasteners are performed in accordance with TE i procedure QA-DP-00140 (formerly QA-VQ-01301,07). The license completes a General Material Inspection Checklist to ensure inspection of manufacturer's symbol, grade designation marking, 12  ;

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fastener identification, and material certificatio Receipt inspection discrepancies are resolved by Materials Engineering prior to issuing the material for use or installatio The receipt inspection procedure was upgraded subsequent to the j bulletin to ensure that manufacturer's' symbol and grade designation are physically stamped on 1/4" or larger fasteners. The licensee segregates and controls safety-related fasteners to prevent mixing with non-safety related fastener j l

The licensee has complied with the requirements of Bulletin 87-02, i and both Bulletin 87-02 and Temporary Instruction 2500/26 are close NRC Bulletin 79-27 " Loss of Non-Class IE Instrumentation and Control Power System Bus During Operations."

An implementation audit was conducted January 24 through 27, 1989 by the NRC with contractor support. The audit considered systematic failure of a nonessential 480 Vac motor control center, a 120 Vac nonessential instrumentation and control power supply bus, and a 125 Vdc essential bus. These buses were the primary sources of -)

power supply to the majority of the instruments, controls and J indications needed by the operator to achieve cold shutdown. Each of the three cases were used to assess the plant capability to achieve cold shutdown from power operation using control room 1 indications and appropriate procedure l The audit did not identify any deficiency of immediate safet ]

concern. However, the automatic bus transfer switch (ABT) used to ,

supply back up power to one of the buse: had no test procedure or schedule for periodic testing. These findings were discussed with ,

the license i No violations or deviations were identifie . Independent Safety Engineering (ISE) (42700)

The inspectors met with ISE management on February 23 and 24,1989, to discuss the Ombudsman Program and recent operational event No violations or deviations were identified in this are . Quality Assurance (QA) (40500)

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10 CFR 50, Appendix B, Criterion XVI, " Corrective Action," requires that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. The licensee implements Criterion XVI with Section 14 of its Nuclear Quality Assurance Manual (NQAM),

" Conditions Adverse to Quality and Corrective Action." Subsection 14.4. requires that implementing procedures shall ensure that conditions adverse to quality are promptly identified, documented, evaluated for impact on plant operability, deportability and significance, and correcte _ _-

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The requirements of Section 14 of the NQAM are implemented by procedure i NG-QA-0702, " Potential Condition Adverse to Quality Reporting" and other procedures. While reviewing the current revision of NG-QA-00702, the inspectors found that the procedure does not include the HQAM Subsection 14.4.1.1 requirement for promptness. The licensee stated that a Procedure Change Request would be promptly initiated to correct that oversight. Although the promptness requirement is not stated in NG-QA-00702, the inspectors regular review of Potential Condition Adverse to Quality Reports (PCAQR) indicates that the requirement is generally understood and implemente i During previous inspections the inspectors observed plant conditions which required licensee corrective actions. Three such conditions were l tracked as unresolved items (346/88007-01), (346/88015-05) and -

(346/88026-04). The safety significance of those items and the licensee's corrective actions are discussed in Paragraph 2. The inspectors'also I evaluated the promptness of the licensee's identification and correction of the condition Because "promptly identified and corrected" is not defined the inspectors )

evaluated each condition to determine if it had been promptly identified 1 and corrected. The results of those evaluations are summarized below for I each condition: Low temperature in CCW pump room (346/88007-01), Februa'ry 13, 198 This condition was first identified by operators as a result of a computer alarm. The condition was documented in the Unit Log and immediate actions were taken to restore room temperature. The room .

temperature was lower than the room temperature stated in the USAR '

for more than thirteen hours due to a malfunction of ventilation damper HV 5444C. A PCAQR was required because it was not certain that HV 5444C malfunctioned due to normal wear and tear. Also, an engineering evaluation of the equipment in the room was required because the room temperature was outside the bounds of the USAR limits for an extended period of time, and the. ventilation system did not function as described in the USAR. These conditions were j listed in NG-QA-0702, Revision 2, as examples of PCAQs. Because of the maintenance activities and because the event was noted in the Unit Log, as required, information on the event was available to many members of the licensee's staf The event was potentially 1 safety significant because operability of safety related equipment I was potentially affected. Therefore someone on the licensee staff should have recognized the requirement to document the condition j with a PCAQR on or shortly after February 13, 1988. A PCAQR was not written until February 19, 1988, shortly after the inspectors 1

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discussed the event with licensee managers. Once the PCAQR was written adequate corrective action was taken. Failure to write a PCAQ report for this malfunction on February 13, 1988, is an example .

of a violation (346/89005-05A(DRP)) of the 10 CFR 50, Appendix B, i Criterion XVI requirement that conditions adverse to quality be promptly identified and correcte i

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b. Slide links on No.1, Startup Transformer found tack-brazed closed (346/88015-05), identified June 21, 1988. The applicable drawing does not show the' slide links tack-brazed closed. When this condition i was discovered Procedure NG-QA-0702, Revision 3, effective March 11, j 1988, was in effect and required that a PCAQ report be initiated for j nonconforming hardware items installed'in non-Q items included on i Attachment V, " List of Systems Important to Safe Operation,'" to Procedure NG-NE-0304, " Safety Review and Evaluation," Revision Startup Transformer No. 1 is listed on Attachment It appears that the only method allowed by procedure, at the time, for documenting )

this condition was a PCAQR. Although this condition may have existed  !

for several years the first known disc very of the condition by j licensee supervisory personnel was on June 21, 1988. The inspectors- J also discussed this condition with licensee management personnel on l at least two occasions in June and July. This condition had no i potential or actual safety significance because it is technically correct for the. slide links to be brazed close Drawing Change Request DCR 89-0049 requesting that the applicable drawing be changed I was written on January 23, 1989, listing "NRC Inspection Report.

( August 4, 1983" as the " initiating document." Even though this condition had negligible potential and actual safety significance,

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seven months from discovery to documentation is not promp However j because this condition had no potential or actual safety significance

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l it is not con <idered a violation.

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The inspectors review of the current revision of NG-QA-00702 revealed i that a M is not the appropriate corrective action document.for this '

conditio)., a Request for Assistance is required by procedur This  ;

weakness was discussed with the QA Directo '

c. Safety-related cables in Manholes MH-3041 and MH-3042 improperly supported (346/88026-04), identified by the inspectors on September 1, 1988. When this condition was discovered Procedure NG-QA-00702, Revision 3, effective August 1,1988, was in effect and required that a PCAQ report be initiated because the condition of these safety-related cables was a deviation from specifications. This condition appears to have existed since construction (1977 or earlier).

Since these electrical manholes are normally closed with the . covers bolted on, there was limited opportunity for the condition to be discovere However a programmatic inspection of the manholes would have identified the condition. On September 1, 1988, when the manholes were open for unrelated electrical maintenance, the inspectors observed that the improperly supported cables in the manholes appeared to be safety related. The inspectors informed the electricians at the manholes of the observed condition. The following day the inspectors returned, took photographs of the cables in one of the manholes and used the photographs to discuss the condition with licensee management personnel. On September 9, 1988, the manholes were again opened, inspected and photographed by licensee maintenance and engineering personnel investigating a fire protection concern related to the cable On September 9th, the inspectors again discussed the condition of the cables with licensee management. The condition had minor potential

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safety significance. The condition was documented in PCAQ Report 88-0732 dated September 19, 1988. Because this condition existed for about 11 years and since the licensee had opportunities to identify the condition in early September 1988, the licensee's identification of this condition was not prompt and this is an example of a violation (346/89005-05B(DRP)) of the 10 CFR 50, Appendix B, Criterion XVI requirement that deviations be promptly identified.

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Violations 346/89005-05A and 346/89005-05B are of minor safety significance and meet the criteria of 10 CFR 2, Appendix C, 1 Section V.G.1 (October 13,1988) and therefore a notice of i violation will not be issued. Also, the inspectors have observed a l continuing licensee effort to improve the reporting of conditions adverse to quality. Licensee personnel write a substantial number of PCAQRs and other corrective action documents each yea . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. The unresolved item disclosed during the inspection is discussed in Paragraph . Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspectors, and which involve some action on the part of NRC or licensee or both. An open item disclosed during the inspection is discussed in Paragraph . Exit Interview (30703)

l The inspectors met with licensee representatives (denoted in Paragraph 1)

l throughout the inspection period and at the conclusion of the inspection l and summarized the scope and findings of the inspection activities. The  :

licensee acknowledged the findings. After discussions with the licensee, l the inspectors have determined there is no proprietary data contained in this inspection repor l i

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