IR 05000346/1998006

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-346/98-06 Issued on 980609.Corrective Actions Will Be Examined During Future Inspections

ML20236Y532
Person / Time
Site:	Davis Besse
Issue date:	08/07/1998
From:	Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Jeffery Wood CENTERIOR ENERGY
References
50-346-98-06, 50-346-98-6, NUDOCS 9808120285
Download: ML20236Y532 (2)

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August 7, 1998 i

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Mr. John Vice President - Nuclear Davis-Besse Nuclear Power Station Centerior Service Company 5501 North State Route 2 Oak Harbor, OH 43449 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-346/98006(DRS))

Dear Mr. Wood:

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This will acknowledge receipt of your letter dated July 24,1998, in response to our letter dated June 9,1998, transmitting a violation of NRC requirements for the Davis-Besse Nuclear i

Power Station. The violation pertained to the untimely identification of an event which took place l during maintenance work on the steam generator. We have reviewed your corrective actions and l have no further questions at this time. These corrective actions will be examined during future

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Sincerely, t i

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Original /s/ J. A. Grobe John A. Grobe, Director Division of Reactor Safety Docket No.: 50-346 '

License No.: NPF-3 /

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. DOCUMENT NAME: G:DRS\DAV98006.TY To ,ecebwe e copy of this document, Indicate in the bos: *C* a Copy without ettechment/ enclosure *F" a Copy Wth attachment %nclosure "pr a No copy l OFFICE Rill j6 Rill a u,l jf Rlli j .lM Rlli _J l NAME Green-Bates:de@ Gavula W/) KozaBdll/ GrobeCN DATE 08/.r/98 '

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. cc: J. Stetz, Senior Vice President - Nuclear J. Lash, Plant Manager J. Freels, Manager, Regulatory Affairs M. O'Reilly, First Energy S?. ate Liaison Officer, State of Ohio

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R. Owen, Ohio Department of Health C. Glazer, State of Ohio Public Utilities Commission Distribution:

Project Mgr., NRR J. Caldwell, Rlli

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C. Pederson, Rlll

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B. Clayton, Rill SRI Davis-Besse DRP l TSS l DRS (2)

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Docket Number 50-346 l

License Number NPF-3 Serial Number 1-1168 July 24, 1998 United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555-0001 Subject: Response to Inspection Report Number 50-346/98006 (DRS)

Ladies and Gentlemen:

Toledo Edison has received Inspection Repon Number IR 50-346/98006 (Toledo Edison Log Number 1-3967) and the enclosed Notice of Violation issued on June 9,1998. The violation ,

pertains to the untimely identification of an event which took place during maintenance work on a steam generator. Toledo Edison provides the attached response to the subject violation. The submission date of this reply was extended from July 9,1998 to July 24,1998, based on discussions with the Region 111 Projects Branch Chief for the Davis-Besse Nuclear Power Station (DBNPS) following the Alert on June 24,1998, at the DBNPS; and based on discussions with the DBNPS Senior Resident inspector and the Region 111 Engineering Specialists Branch 1 Chief on July 20,1998.

Should you have any questions or require additional information, please contact Mr. James L. Freels, Manager - Regulatory Affairs, at (419) 321-8466.

Ve truly yours, i

GMW/dic

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cc: A. B. Beach, Regional Administrator, NRC Region 111 A. G. Ilansen, DB-1 NRC/NRR Project Manager i S. J. Campbell, DB-1 Senior NRC Resident inspector Utility Radiological Safety Board I

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Docket Number 50-346 License Number NPF-3 Serial Number 1-1168 Attachment Page1 Renly to a Notice of Violation (50-346/98007-01)

Alleced Violation During an NRC inspection conducted from April 22 - May 7,1998, a violation of NRC requirements was identified. In accordance with NUREG-1600, " General Statement of Policy and Procedure for NRC Enforcement Actions," the violation is listed below:

10 CFR 50, Appendix B, Criterion XVI, " Corrective Action" requires that measures be established to assure that conditions adverse to quality, such as failures, malfunctions,

- deficiencies, deviations, defective material and equipment, and nonconformances are prompt,1y identified and corrected.

Contrary to the aoove, a condition adverse to quality was not promptly identified a nd corrected, in that on April 15,1998, a Potential Condition Adverse to Quality Report (PCAQR) was not initiated after an unauthorized wire brush, used to clean steam generator B primny manway stud holes, failed resulting in the uncontrolled introduction of carbon steel wire bristies into the primary coolant system. Further, on April 18,1998, and April 19,1998, a PCAQR was not initiated when wire bristles were identified by video camera to be present on the steam generator tube sheet and bottom bowl. In addition, on April 25,1998, eddy current examinations identified a wire bristle wedged inside a steam generator tube. Although a PCAQR was initiated to address j

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the effect of the metal on the fuel, control rod drive mechanisms, pump seals and other primary system components, until prompted by the inspector, no actions were initiated to address the noncompliance with the applicable maintenance procedure which authorized only stainless steel l or nylon brushes.

This is a Severity Level IV violation (Supplement 1). I Response to Alleced Violation 50-346/98006-01 Reason for Violation When the carbon steel brush failed during use on April 14,1998, it was not realized by the worker that the wrong type of brush had been used. A carbon steel brush has the same general I appearance as a stainless steel brush, and unless a side-by-side comparison is performed, the material of the brush is not obvious. At one point in time, carbon steel brushes were exclusively used to clean the carbon steel stud holes of the steam generators et Davis-Besse. A change was l made to the applicable procedure to only use stainless steel or nylon brushes because they are l more durable. It appears that all carbon steel brushes were not removed from the steam generator tool boxes after their use was discontinued.

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Docket Number 50-346 I License Number NPF-3 Serial Number 1-1168 Attachment Page 2 It is common knowledge of the Framatome Technology, Inc. (FTI) personnel involved in this work that carbon steel brushes may fail in the manner observed and should not be used. The steam generator B manway and diaphragm were still in place at the time of the brush failure, which prevented any wire bristles from entering the steam generator at that time. The worker believed the failed brush that was taken from the steam generator tool box was of the proper i material. Another brush, this one stainless steel, was retrieved from the same tool box, and work I

was continued after cleaning up the bristles from the failed brush. Since steam generator B was not open at the time of the brush failure, no concerns about foreign material entering the steam generator existed. No procedural violation was known to have existed at this time. Per the FTl l Quality Assurance (QA) Plan in place for the eleventh refueling outage, no documentation of the failed tool was required. ,

It is believed that the wire bristles were transponed into steam generator B via the filter hose that was positioned under the stud hole to collect the debris generated during cleaning. The same filter hose was used to draw any debris out of the stud hole. Once the manway and diaphragm were removed, a shield door was installed, and the same filter hose was connected to the shield j door to ventilate the steam generator. If any of the wire bristles remained in the filter hose after i the brush failed, they could have entered the steam generator once the hose was connected to the i shield door. Any loose wire bristles remaining on the work platform could also have been introduced into steam generator B during installation of the remotely-operated eddy current equipment.

When the wire bristles were identified by video camera to be present on the steam generator B tube sheet on April 18,1998, they were entered into the FTI Open Systems Log for Steam i Generator Activities as required by the FTI QA Plan to document the as found condition. This entry ensured the wire bristles would be removed prior to closcout of the steam generator in i accordance with the FTI Field Procedure for Steam Generator Closcout. No further actions were required at this time in accordance with the FTl QA Plan. Toledo Edison personnel were infonned of the presence of the wire bristles in steam generator B on April 21,1998. A plan was i developed to obtain a sample of these wire bristles from the steam generator to identify how long )

the bristles had been in the reactor coolant system, while maintaining personnel dose as low as reasonable achievable. On April 23,1998, a sar.iple of the wire bristles was obtained and delivered to Radiation Protection personnel. On April 25,1998, after determination that the wire 1 l

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bristles had not been in the steam generator during reactor operation, meaning they were introduced dur'mg the current refueling outage, Potential Condition Adverse to Quality Report (PCAQR) 1998-0781 was initiated by Toledo Edison personnel to ensure all bristles were i

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removed from the steam generator. The m erial of the wire bristles was not known at this time. 1 Later that same day, eddy current examinations identified a tube in steam generator B was i obstructed, and FTl personnel initiated Nonconformance Report (NCR)98-200 as required by the FTI QA Plan. The tube obstruction was pushed into the lower bowl of the steam generator, I where it was discovered that this obstruction was a wire bristle similar to those discovered on the

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, Docket Number 50-346 License Number NPF-3 Serial Number 1-1168 Attachment Page 3

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upper steam generator tube sheet. Another wire bristle was also found in the lower bowl of the B steam generator and removed. The material of the wire bristle was then evaluated to determine the effects of any potentially undiscovered bristles on the Reactor Coolant System. When it was determined that the wire bristle was made of carbon steel, the origination of the wire bristles was traced to the wire brush that had failed during cleaning of the steam generator stud holes. At this time it was not recognized that the use of a carbon steel brush constituted a procedural violation.

The fact that a procedural violation had occurred in the use of a carbon steel brush on April 14, 1998, was not realized until FTI personnel were interviewed by Toledo Edison personnel and the j NRC inspector on May 6,1998.

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Corrective Stens Taken and Results Achieved

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When the wire bristles were identified by video camera to be present on steam generator B tube I sheet on April 18,1998, they were entered into the FTI Open Systems Log for Steam Generator f

! Activities. After determining the wire bristles had been introduced during the current refueling l

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outage, PCAQR 1998-0781 was initiated on April 25,1998. Upon discovery of a wire bristle inside a steam generator B tube and determination that the wire bristle was from a carbon steel wire brush, all steam generator tool boxes were inspected. The four carbon steel brushes discovered in the manway tool box were discarded based on the common knowledge that carbon i

steel brushes should not be used due to their likelihood of failure. All steam generator activities involving the use of wire brushes had been completed by this time, so no fmther actions were

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necessary to ensure carbon steel brushes were not used.

I A thorough video inspection of steam generator B was performed to locate all potential wire bristles in addition to the 100 percent eddy current examination cf the steam generator. All identified wire bristles were removed from the upper bowl of steam generator B. The one wire bristle discovered in the tubes of steam generator 11 was removed, and the lower bowl was l thoroughly vacuumed to remove all wire bristles. These actions were completed on l May 2,1998.

On May 6,1998, after learning that a procedural violation had occurred in the use of a carbon steel wire brush, NCR 98-218 was initiated by FTl personnel. This NCR was also tracked along with NCR 98-0200 under PCAQR 98-0781, which was revised to address the procedural noncompliance.

Corrective Ste as Taken to Avoid Further Violations The FTI procedure used for steam generator manway removal and installation will be clarified to specifically delineate that only stainless steel or nylon brushes shall be used for stud hole maintenance. Additionally, the procedure will be revised to reflect that if a brush to be used for this task is not marked, or there is no reasonable assurance a brush is of the proper material, the brush will be discarded. This procedure will be revised prior to the next refueling outage, which i

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. Docket Number 50-346 License Number NPF-3 Serial Number 1-1168 Attaciunent l Page 4 is currently scheduled for April,2000. Training on the revised procedure and proper brush material will be performed during the next refueling outage for the workers specifically involved in steam generator work. This training will reinforce that the use of the proper brush material is a procedural requirement.

Based upon the described sequence of events, Toledo Edison believes that reasonable corrective actions were taken in accordance with governing procedures, based upon the circumstances and information available. Therefore, no corrective steps are necessary in relation to the corrective action process at the DBNPS.

Date When Full Compliance will be Achieved

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Full compliance was achieved on May 6,1998, when NCR 98-218 was initiated by FTI personnel to document the procedural noncompliance of using a wire brush of the wrong material to clean the steam generator stud holes. This NCR and NCR 98-200, which was initiated on April 25,1998, to document the concern of the wire bristles inside the steam generator, are being tracked by PCAQR 1998-0781, which was also initiated on April 25,1998.

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