IR 05000346/1998006
| ML20248M313 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 06/09/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20248M306 | List: |
| References | |
| 50-346-98-06, 50-346-98-6, NUDOCS 9806150283 | |
| Download: ML20248M313 (15) | |
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l l U.S. NUCLEAR REGULATORY COMMISSION j i i i
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REGIONlli '
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! l l Docket No: 50-346 License No: NPF-3 l 1 l
! Report No: 50-346/98006(DRS) l I
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Licensee: Toledo Edison Company !
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Facility: Davis-Besse Nuclear Power Station l
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' Location: 5501 N. State Route 2 I
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Oak Harbor, OH 43449 I
[ Dates: April 22 - May 7,1998 f
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I l Inspector: K. GreenBates, Reactor inspector l
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Approved by: J. A. Gavuta, Chief, Engineering Specialists Branch 1 l
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Division of Reactor Safety '
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[ PDR ADOCK 05000346
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EXECUTIVE SUMMARY Davis-Besse Nuclear Power Station NRC Inspection Report 50-346/98006 This routine inspection focused on the conduct of inservice inspection (ISI) activities at
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Davis-Besse. The inspection included aspects oflicensee Code repairs of the main steam isolation valve and nondestructive examination of control rod drive housing, main steam nozzle and decay heat system welds, as weil as the reactor vessel head, reactor coolant pump flywheels and steam generator. The following specific observations were made:
Maintenance
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The licensee adequately demonstrated the ability to properly implement ISI and flow assisted corrosion programs (FAC), including eddy current examinations of the steam generator tubes (Sections M1.1 and M1.2).
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In general, licensee personnel and contracted personnel involved in FAC and ISI efforts appeared knowledgeable, well trained, and competent (Sections M1.1 and M1.2).
- Code repair work performed on the main steam isolation valve was well implemented with active technical vendor oversight (Section M1.3).
- One violation of 10 CFR 50, Appendix B, Criterion XVI was identified pertaining to the lack of corrective action for an event which took place during maintenance work on the steam generator. Although personnel became aware that unauthorized equipment was used, the lack of procedural adherence was not documented and the occurrence was not entered into the licensee's corrective action program for evaluation (Section M7.1).
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Technically, the most current technology and dispositioning protocols were used to assess and disposition the steam ge'ierator tubes. Although not required until 1999, many of the good practices recommended by Electric Power Research Institute (EPRI)
Pressurized Water Reactor Steam Generator Examination Guidelines, Revision 5, were implemented. The examination data was found to be in accordance with the applicable ISI procedures and American Society of Mechanical Engineers (ASME) Code requirements (Section M1.1).
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Consistent with the components importance to safety, the licensee demonstrated an aggressive assessment of vendor code repair and ISI contractor supplied procedures to assure that applicable ASME and regulatory requirements were met (Section M3.1 and M3.2 ).
- The addition of a ' data patrolman' to the steam generator eddy current examination team, in order to provide an additional quality assurance layer, demonstrated a thorough and rigorous effort to obtain quality data in this area important to safety (Section M1.1).
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REPORT.. DETAILS l- :
p ( The Davis-Besse Nuclear Power Station Unit 1 second 10 year inspection interval commenced on September 21,1990. The plant was in their 11th Refueling Outage (RFO 11) and the third >
period of the current inservice inspection (ISI) interval. During this interval, the ISI program is l~ committed to meet the requirements of Section XI of the ASME Boiler and Vessel Code,1986 i Edition for Class 1,2, and 3 components and Section XI of the ASME Code 1992 (as modified j by 10 CFR 50.55a), for Class MC components.
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l M1 Conduct of Maintenance M1.1 Steam Generator ISI
' Insoection Scone (73753. 73755)
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Inspectors observed the licensee's contracted personnel from Framatome Technology Inc. acquiring eddy current (ET) examination data for the reactor coolant system l pressure boundary portion of the steam generators (SGs). The analysis of ET data was l conducted off-site; however inspectors reviewed the licensee's disposition of ET indications identified from this analyzed data, j' ~ Observations and Findinas l: ET Acquisition l.
l Eddy current examinations were conducted on all accessible tubes, along the full tube
! length of the once through steam generators (OTSG). A bobbin coil was used to l perform the standard ASME Code examination for defect detection and sizing. A Plus Point probe and motorized rotating pancake coil (MRPC) were employed to supplement bobbin coil examination. The MRPC was also used to further characterize manufacturing burnish marks and unidentified indications found by the bobbin coil
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l l The inspector observed that a " data patrolman" was added to the ET team. The purpose of this additional member was to randomly access the computers of the data l acquisition personnel to assure that the appropriate ET parameters were being used l and that procedural requirements were continually being met by the contract personnel.
l The self police of the ongoing data acquisition process provided an additional layer of assuring that quality data was obtained in this area important to safety. The inspector considered that this demonstrated an aggressive quality assurance mind set and a conservative focus on safet L
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. ET Data Anmsis and Disposition of Indications I
During this outage, a total of 55 tubes were identified through ET examination as being tess than acceptable for cycle 12 plant operations. All indications found other than {
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those identified as wear or bumish n; arks were plugged or re-rolled. Technical Specification (T.S.) 3.4.5 required that tubes having indications exceeding 40% through wall be plugged. Because there was not an approved sizing technique available to accurately determine whether the 40% through wall limit was exceeded for the tube indications, the licensee conservatively assumed that the defec,ts were in excess of this limit and required repair prior to entering Mode 4. The steam generators were I considered inoperable and tracked in the inoperable tracking tog against T.S. 3.4. )
and T.S. 3.4.5 pending repairs (plugged y reroll).
- Technically, the most current technology and dispositioning protocols were used to
! assess and disposition the tubes. Although not required until 1999, many of the good practices recommended by EPRI PWR Steam Generator Examination Guidelines, Revision 5, were implemented. The examination data was found to be in accordance with the applicable ISI procedures and ASME Code requirement The total number of tubes in each OTSG is 15,457. The following tubes were plugged and sleeved as a result of this examination:
Steam Generator No. 2-A l
Tubes plugged this outage: 32 Total tubes plugged: 413 Tubes re-rolled this outage: 1 Steam Generator No.1-B Tubes plugged this outage: 18 Total tubes plugged: 84 Tubes re-rolled this outage: 3 Conclusions - SG ISl Technically, the most current technology and dispositioning protocols were used to assess and disposition the tubes. The licensee's approach to tube plugging was considered to be very conservative. The addition of a " data patrolman" to the steam generator ET team to provide an additional quality assurance layer, demonstrated a thorough and rigorous effort to obtain quality data in this area important to safety. The licensee adequately demonstrated the ability to properly implement ISI eddy cLrrent examinations of the steam generator tubes. Licensee personnel and contracted personnel involved in SG ISI efforts appeared knowledgeable, well trained and competent. No violations were identifie !
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M1.2 ISI of the ASME Code Class 1 and 2 System Pressure Boundarv Insoection Scoce (73753. 73755)
Nondestructive examination (NDE) activities were completed by Toledo Edison and Framatome Technologies Inc. personnel during RFO 11. The inspectors observed and had discussions with NDE personnel during various ISI work-in-progress activities and the data obtained from the examinations was reviewed. The following is a sample of the work activities that were observed by the inspectors:
Framatome personnel performing Dye Penetrant examination (PT) of control rod drive housing weld No. B14.010.0716.1 for CRD Housing and Penetration No. B53-5 Framatome personnel performing Magnetic Particle c.xamination (MT) of the reactor coolant pump motor flywheel No.1-2- Welding Services Incorporated personnel performing a MT of the main steam isolation valve MS-100 prior to weld repai David Besse personnel performing a Visual Examination (VT) of the reactor vessel head bolt hole Framatome personnel performing an Ultrasonic Examination (UT) of a 10-inch elbow to pipe weld DH-33B-CCB-6-10-SWB in the decay heat syste Contract personnel performing a UT on a Feedwater system weld for flow assisted corrosion (FAC) indication Observations and Findinas The inspectors observed ISI activities and reviewed the resulting documentation from the NDE of control rod drive housing, main steam nozzle, and decay heat system welds, as well as the reactor vessel head and reactor coolant purnp motor flywheels. In general, the inspectors concluded that licensee personnel and contracted personnel involved in ISI efforts appeared knowledgeable, well trained, and competent. The examination data was found to be in accordance with the applicable ISI procedures and ASME Code requirement MT of the reactor coolant pump motor flywheel No.1-2 2, and a PT of the bore and i
keyway area performed to supplement the MT determined that there were no changes 1 to the area of the bore that was previously scored in 1996 during flywheel removal. No recordable indications were found during the observed ISI activitie Conclusions - Pressure Boundarv ISI The licensee adequately demonstrated the ability to properly implement ISI and FAC programs. In general licensee personne; and contracted personnel involved in ISI and
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FAC efforts appeared knowledgeable, well trained and competent The examination data was found to be in accordance with the applicable ISI procedures and ASME Code requirements. No violations or deviations were identifie M1.3 Code Reoair of 36-inch Rockwell Main Steam isolation Valve (MSIV) Insoection Scooe (73753)
Inspectors conversed with licensee MSIV project engineers and observed the licensee's contracted personnel from Edward Valves Inc. and Welding Services Inc. (WSI)
performing various activities for an ASME Code weld repair on MSIV MS-10 Observations and Findinos i MSIV MS-100 was found to have disk ring wear in the valve bore. After examination, the valve vendor believed that the gouges may have been caused by opening up tolerances in RFO 9 when the area of concem was " smoothed" to v.sure proper strok The increased tolerance would have allowed the disc to vibrat A planned repair was performed by welding on the upper bore of the valve and the top portion of the disc guide rib. These surfaces were then machined to the original equipment manufacturers specification. The Code repair was performed by WSI personnel to the ASME Section XI,1986 Edition requirement The inspectors observed portions of the welding of the MSIV valve body and viewed the MS-100 stud drilling and tapping work-in-progress. Code repair work periormed on the valve was well organized with active technical vendor oversight in all aspects by the license Conclusions MSIV Code Reoair Code repair work performed on the MSIV was well implemented with active technical vendor oversigh M3 Maintenance Procedures and Documentation M3.1 ISI Procedures Insoection Scoce (73753. 73052)
The inspector reviewed ISI procedures for the ISI activities observed in Section M Observations and Findings All applicable ISI procedures were approved by the Authorized Nuclear inspector. The ISI procedures were found to be acceptable and in accordance with ASME Section V, 1986 Edition requirements. The licensee documentation reviewed by the inspector
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demonstrated an aggressive assessment of the ISI contractor supplied procedures was l
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being performed to assure that applicable ASME and regulatory requirements were me Conclusions - ISI Procedures The licensee demonstrated an aggressive assessment of the contractor supplied procedures to assure that applicable ASME and regulatory requirements were me M3.2 Code Reoair of Main Steam Isolation Valve Procedures Insoection Scoce (73753)
The inspector reviewed pre-weld and post weld non-destructive examination (NDE)
procedures and records, as well as the welding procedures and supporting procedure qualification records (PQR) used for the ASME Code repair of for the 36-inch Rockwell main steam isolation valve (MSIV) MS-10 Observations and Findings l
The inspector observed that the licensee had an established quality assurance program in place to examine contractor procedures, and that the vendor weld procedures for the MSIV repair had been through a licensee review circuit prior to welding. The inspector reviewed the programs evaluation of the vendor weld procedures used for the MSIV Code repair and concluded that an aggressive assessment had creen conducted to assure that all ASME Code requirements were met. The personnel performing the review revealed a high level of expertise in the areas of welding and ASME codes consistent with the components importance to safety. The valve vendor procedure review demonstrated a rigorous control of contractor services to assure quality on the part of the license The MSIV Code repair was performed to ASME Section XI,1986 No Addenda Edition requirements. Inspector review of the vendor MT procedures, POR's and weld procedures used for the repair identified no significant discrepancie Conclusions - Code Reoair Procedures Consistent with the component's importance to safety, the licensee demonstrated an aggressive assessment of the vendor code repair supplied procedures to assure that applicable ASME and regulatory requirements were me MS Maintenance Staff Training and Qualification M5.1 Personnel Qualifications Insoection Scoce (73753)
The inspector reviewed ISI personnel qualifications of licensee and contract personnel performing the ISI activities observed in Section M1. Additionally, the inspector reviewed welder qualification records for the ASME Code weld repair of MSIV, MS-10 _ _ . . - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ - - _ _ _ _
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The 12 NDE personnel qualifications records reviewed by the inspector met ASME Code, SNT-TC-1 A recommendations and NRC requirements. Recent industry ;
experience for training and testing NDE personnel demonstrated a focus on safety. In I two cases, the inspector observed that a level lli qualified person was performing level ll NDE field examination which also demonstrated a high level of expertise and good safety focu Conclusions - Personnel Qualifications !
No violations were identified. The use of recent industry experience for training and testing NDE personnel demonstrated good safety focu M7 Quality Assurance in Maintenance Activities M7.1 Steam Generator Maintenance l Insoection Scoce (73753)
Inspectors interviewed licensee and contract maintenance staff, and reviewed corrective actions documented in condition reports for ISI related findings of ASME Code component Observations and Findings After review of steam generator studs and studhole maintenance documentation and discussions with contract and licensee personnel, the inspector concluded that a procedure to perform maintenance and ISI activities on the steam generator had not been not followed. Although both the contract personnel and licensee became aware that unauthorized equipment was used when portions of a maintenance tool were discovered within the steam generator, the lack of procedural adherence was not documented and the occurrence was not entered into the licensee's corrective action program for evaluatio For ISI preparatory cleaning and ISI activities maintenance work performed on the steam generator, Framatome Procedure No. SLG Proc-34, Document 1222097A," Field Procedure for OTSG Primary Manway and Handhole Removal, Installation, and Maintenance", Revision 6, dated February 5,1998 was used. The procedure required that primary handhole and primary manway studhole cleaning activities be performed using a stainless steel (SS) brush or a nylon bristle brush. The requirement is stated in numerous steps and notes in the procedure, as well as task equipment list On April 15,1998, Framatome contract personnel used a carbon steel (CS) brush instead of a nylon or SS brush, as specified by the procedure and equipment list, to perform maintenance on steam generator B primary manway studholes. Besides having different color bristles than the SS brush, the use of a CS brush was immediately noted
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by contract workers and their management when 75% of the brush promptly unwound and freed hundreds of individual bristles. This is a common failing of carbon steel brushes and one of the reasons it is barred from use for maintenance work where its introduction into the primary system boundary may be possible. The contractor did not report the lack of procedural adherence or the resultant equipment failur By failing to generate a Potential Condition Adverse to Quality Report (PCAQR) to place
, this event within the licensee's corrective action program, an opportunity was missed to l prevent an uncontrolled release of foreign materialinto the primary system. An evaluation as to whether the use of CS in lieu of SS would have any effect on the SG, an evaluation of a possible pathway for the introduction of CS materialinto the primary system, and an evaluation of how incorrect tools had become provisioned and available for this maintenance work would be expected for such an event on a significant safety componen As a result of not following the procedure and not promptly identifying potential conditions adverse to quality, an unknown amount of CS wire segments, each approximately 2.5 inches in length, entered into the primary system. On April 18,1998, contract personnel using a video camera to watch ET equipment, identified wire filaments (bristles) on the steam generator tubs sheet and documented the foreign material on a materials log sheet but a PCAQR was not generated. On April 19,1998, video camera contract personnel found an additional CS bristle in the lower head of the steam generator and again documented the foreign material on a materials log sheet but a PCAOR was not generate On April 25,1998, a CS bristle was found by ET to be wedged into one of the steam generator tubes. The ET evolution and analysis process brought the CS brush event to the licensee's attention. A PCAOR was generated which stated that CS wire segments were present in the SG and since the number was unknown, the concerns for the CS wire entering into the fuel, control rod drive mechanisms, pump seals and other primary systems was addressed. The PCAQR to address the front end of the problem: lack of procedure adherence, effect on the SG of using CS for a SS application and future prevention for this foreign material path into the SG was not generated by the license The SG equipment gangboxes were also immediately inspected for other procedurally proscribed CS brushes. Another two inch CS brush (used for SG manways), and three one inch CS brushes (used for SG handholes) were found. A total of two SS and two OS brushes were originally in the manway gangbox equipment supplied by the license for this maintenance work. A PCAQR was not generated to determine how the incorrect tools had become provisioned and available for maintenance work on the safety related componen On May 6,1998, the licensee issued a PCAO'1 to address the inspector findings. The lack Crompt identification of a deviation potentially adverse to safety, in order to init W, associated evaluation and corrective actions is considered a violation of 10 CFR 50, Appendix B, Criterion XVI (50-346/98006-01(DRS)).
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In addition to suppling the incorrect brush material to the contractor for the above mentioned maintenance work, the inspector noted that there appeared to be a general relaxed attitude to the control of brushes during maintenance which did not meet the aggressive quality assurance standards of the rest of the program. The brushes were not nu'mbered, there appeared to be no brush cleaning requirement or mandated disposal after use on a CS application in the procedures reviewed by the inspector, j After a SS steel brush was used on a CS maintenance application, (therefore becoming l contaminated with CS), the inspector inquired as to how the licensee controlled the brush being used for maintenance at a later date for a SS application. This would be considered a poor practice as its reuse would transfer the CS to the SS application therefore increasing the potential for corrosion of a safety componen Conclusions
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in general, the ISI program appeared to be well implemented, with a strong maintenance quality assurance mind set. However, the control of carbon steel brushes l and carbon steel contamination was considered a weakness. The untimely identification of a problem with a steam generator maintenance activity was a violation of 10 CFR 50, i Appendix B, Criterion XVI.
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lil. Engineering E2 Engineering Support of Facilities and Equipment i
E2.1 Correctivo Actions for ASME Code Comoonents l l l
' Insoection Scooe (92720)
l Inspectors interviewed licensee engineering staff and reviewed engineering documents I related to a steam generator tube in-Situ Pressure Test and SG tube re-rolls, i Observations and Findinas b.1 SG Condition Monitorina:
Based on engineering judgement, the licensee determined that the worst case defect identified in the SG's during RFO 11 was a single axial crack in the freespan section of tube 143-61 in SG 2-A. The defect was forming in a dent in this tube and was estimated to be up to 77% through wall. On April 26,1998 a full length in-Situ pressure test was performed on this SG tube as a worst case scenario. The test was to aid in the verification that the reactor pressure boundary tubing was capable of withstanding accident conditions at the end of the operating cycle. The test was performed in accordance with the safety factors detailed in NRC Draft Regulatory Guide 1.121, Revision 1. The tube was tested up to three times normal operating differential pressure and the tube did not fail. The inspector noted that this test helped to demonstrate that the plant was not operating with a SG defect which could have failed under accident conditions at the end of cycle 11,
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The inspector determined that the repair rolls in the upper tubesheet for tube 90-2 (SG A), and tubes 11-57,93-27 and 106-4 (SG B) were accomplished in accordance with T.S. 4.4.5. Conclusions - SG Condition Monitoring From the SG In-Situ Pressure Test and SG tube re-roll documents reviewed, the licensee demonstrated a conservative engineering approach with a focus on safety. All applicable ASME Code and regulatory requirements appear to have been met. No violations were identifie IV. Management Meetings X1 Exit Meeting Summary
The inspectors presented the inspection results to members of licensee management at the l
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conclusion of the inspection on May 7,1998. The licensee acknowledged the findings presented and did not identify any of the potentia' report input as proprietar I i
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i PARTIAL LIST OF PERSONS CONTACTED i
Davis-Besse l
P. Boissoneault, MSIV Engineer
! C. Daft, ISI Senior Engineer
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R. Donnellon, Director Engineering & Services l
D. ^2erren, SG System Senior Engineer, Engineering & Services J. Lash, Plant Manager D. Lockwood, Supervisor Regulatory Affairs A. McAllister, Supervisor Test and Performance l D. Munson, Plant Engineering l
M. Sheppard, ISI Senior Plant Engineer A. Wilson, Vice President i G. Wolf, Regulatory Affairs Framatome Technoloales Inc R. Herman, Level lli NDE D. Langenfeld, Supervisor, Level ill NDE B. Stallings, Outage Manager ,
L. Padtruska, SG Supervisor Edward Valves In P. Brown S. Adams NBC S. Campbell, SRI
' K. Zellers, RI l
INSPECTION PROCEDURES USED l i
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IP 49001: Inspection of Erosion / Corrosion Monitoring Programs i IP 73051: Inservice Inspection - Review of Program IP 73052: Inservice Inspection - Review of Procedures
[ IP 73753: Inservice Inspection lP 73755: Inservice Inspection - Data Review and Evaluation ;
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ITEMS OPENED, CLOSED, AND DISCUSSED ITEMS OPENED 50-346/98006-01(DRS) VIO Lack ofidentification and evaluation of a deviation /nonconformance i
ITEMS CLOSED None ITEMS DISCUSSED l
None LIST OF ACRONYMS USED ASME American Society of Mechanical Engineers ;
PWR Pressurized Water Reactor Plant j DRS Division of Reactor Safety EPRI Electric Power Research institute ET Eddy Current Examination ;
FAC Flow Assisted Corrosion l
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FME Foreign Material Exclusion GL Generic Letter ID Inside Diameter IP Inspection Procedure IR inspection Report ISI Inservice inspection !
MRPC Motorized Rotating Pancake Coil MSIV Main Steam Isolation Valve MT Magnetic Particle Examination NDE Non-destructive Examination NRC Nuclear Regulatory Commission OTSG Once Through Steam Generator PCS Primary Coolant System PCAQR Potential Condition Adverse to Quality Report PDR NRC Public Document Room PT Dye Penetrant Examination RT Radiographic Testing SG Steam Generator UT Ultrasonic Examination VT Visual Examination WSI Welding Services In _ __ _-_-_____________ ______ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
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i PART;AL LIST OF DOCUMENTS REVIEWED Toledo Edison Administrative Procedure No. DB-PF-00104, " Inservice Inspection Program -
Engineering Test," Revision 00, dated July 30,199 Davis-Besse Procedure Development Form 97-0069," Revision to Toledo Edison Administrative Procedure No. DB-PF-00104, inservice Inspection Program Revision 00, dated July 30,1991,"
dated June 9,199 Centerior Service Company ISI Summary Report "In Service inspection Report of the Tenth Refueling Outage for the Davis-Besse Nuclear Power Station," dated August 199 Welding Services Inc. Welding Procedure Specification No.1.1.1-DB "GTA'N/ Manual,"
Revision 1, dated April 24,1998, used for the MSIV Code Repai Welding Services Inc. Welding Procedure Specification No.1.1.6-DB "GTAW/ Machine,"
Revision 2, dated April 24,1998, used for the MSIV Code Repai Welding Services Inc. Welding Procedure Specification No. HfTmi-d-2 " Revision 2, dated March 3,1998, used for MSIV Code Repa' Welding Services Inc. Procedure No. QAP 9.7 " Magnetic Particle inspection Procedure,"
Revision 2, dated February 28,1997, used for MSIV Code Repai Welding Services Inc. Procedure Qualification Record No. 00067, dated September 17,1994, used to support MSIV weld procedure Nos.1.1.1-DB and 1.1.6-D Welding Services Inc. Procedure Qualification Record HfTM1(21MH), dated March 3,1998, used to support MSIV weld procedure No. HfTm1-d- Davis-Sesse Contractor Procedure Review Form No. VPROC 98-0019-01, " Contractor Procedure Number 1.1.1-DB," dated April 24,199 Framatome Technologies Inc. Safety Related inservice Procedure No. 54-ISI-120-36,
" Ultrasonic Examination of Piping Welds and Vessels Up To Two inches Thickness,"
Revision 36, dated December 1,199 Framatome Technologies Inc. Safety Related inservice Procedure No. 54-ISI-270-36, " Wet or Dry Methods of Magnetic Particle Examination of Welds Base Materials, Studs Bolts, and Pump Motor Flywheels and Coated Surfaces of Components and Piping," Revision 36, dated November 24,199 l
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Davis Besse Potential Condition Adverse to Quality Report PCAQR No. 1998-0772, " Steam Generator Tube Degradation," dated April 26,1998 Davis-Sesse Potential Condition Aaverse to Quality Report PCAQR No. 1998-0781, " Wire Filame nts in OTSG Upper Bowls," dated April 28,199 Davis-Sesse Potential Condition Adverse to Quality Report PCAQR No. 1998-0667, "MSIV Wear,' dated April 19,199 Framatome Technologies Inc. NonConformance Report No.98-200, " Upper Primary Manway Stud f loles in SG B were Cleaned Using a Rotary CS Brush Rather than a Rotary Nylon Bristla/SS Brush as Required by Procedure," dated May 6,199 Framatome Technologies Inc. NonConformance Report No.98-218, " Reactor Operation with Loose, Foreign Matter in RCS at DB-1," dated May 2,199 Toledo Edison Administrative Procedure No. EN-DP-01301," Engineering Department Procedure Corrosion-Erosion Monitoring and Analysis Program (CEMAP)," dated February 11, 199