IR 05000213/1980018
| ML20003E522 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 01/13/1981 |
| From: | Blumberg N, Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20003E516 | List: |
| References | |
| 50-213-80-18, NUDOCS 8104060033 | |
| Download: ML20003E522 (16) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 50-:" 3/80-18
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Docket No. 50-213 License No. DPR-61 Priority Category C
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Licensee:
Connecticut Yankee Atomic Power Company P.O. Box 270 Hartford, Connecticut Ud101 Facility Name:
Haddem Neck Plant Inspection at: Hadasu, Connecticut Inspection cond ted: October 6-10, 1980
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Inspectors:
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N.Blumbyg,ReactorInppector
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Approved by:
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E. G. Greenman, Chief, Nuclear date signed
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l Support Section No. 2, RO&NS Branch
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Inspection Summary:
Inspection on October 6-10, 1980 (Report No. 50-213/80-18)
Areas Inspected: Routine, unannounced inspection by one region-based inspector of previous inspection findings; administrative controls for surveillance procedures; surveillance testing; inservice inspection program; witnessing of surveillance test performance; and technician qualification. This inspection involved 35 inspector-hours onsite by one region-based inspector.
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- Results: Noncompliances, one in two areas and two in another area - (Infraction -
inadequate review and evaluation of test results - paragraphs 4.c and 5.c(1));
(Infraction - failure to perform surveillances within required frequency and to use procedures or document results - paragraphs 4.c(2) and (3)); and (Deficiency -
failure to obtain approval for procedure changes and test procedure inadequately documents test results - paragraphs 4.c(4) and (5)).
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DETAILS 1.
Persons Contacted
- G. Bouchard, Maintenance Supervisor
- R. Brown, Senior Engineer T. Campbell, Instrument and Control Supervisor J. Delawrence, Staff Engineer
- J. DeRoy, Staff Engineer
- R. Dilaura, Quality Assurance Technician
- R. Eppinger, Reactor Engineer
- J. Ferguson, Station Services Superintendent R. Gracie, Operations Assistant Supervisor
- R. Graves, Station Superintendent
- J. Levine, Operations Supervisor
- F. Libby, Jr., Quality Assurance Supervisor J. Overbaugh, Electrical Maintenance Foreman R. Thomas, Staff Engineer
- R. Traggio, Unit Superintendent USNRC
- T. Smith, Senior Resident Reactor Inspector The inspector also interviewed other licensee employees including reactor operators and instrument and control technicians.
- Denotes those attending the exit interview.
2.
Licensee Action on Previous Ins,oection Findings
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l (0 pen) Unresolved Item (78-07-04): Pressure and flow requirements for Core Cooling System Pumps stated in Technical Specification 3.6 are inconsistent i
with Core Cooling System Pumps surveillance requirements stated in Technical Specification 4.3.
The licensee previously stated that the two sections were not inconsistent in that the flows and pressures stated in T.S. 3.6
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were rated values and that the pressures specified in T.S. 4.3 were shutoff l
head values.
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During the 1980 refueling outage the licensee developed and perfomed Special Test 10.7-104, "High Pressure Safety Injection System Pump Degradation Check and System Runout Test". Based on these test results, the licensee
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stated that the shutoff head surveillance tests adequately tests pump operability. The licensee also stated that a chang 2 to Techn1 cal Specification 3.6, stating that pump flows and pressures are rated parameters, would be submitted to the NRC by ' December 15, 1980. This item remains open pending completed NRC action for this Technical Specification change.
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(Closed) Unresolved Item (213/79-10-03): QA 9epartment not reviewing completed test data as required by procedure OA 1.2-11.2.
The licensee to
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review the requirements of QA1.2-11.2 to determine if change is reqvired.
During this inspection, the inspector determined that procedure QA 1.2-11.2 still requires a QA review of all completed test data s ubsequent to its review by the Department Head.
Further, the licensee s.ated that it was the intent of QA 1.2-11.2 to require that the-QA Department review all completed test data. QA Department representatives stated that they review all test data forwarded to them; and provided to the inspector records of
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such review. The inspector determined that records of surveillance tests
.were being maintained in the Operations Department and were not forwarded
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to the QA Department in a timely manner.
This is an example of an item of I
noncompliance which is detailed in paragraph 4.c(1) (213/80-18-01).
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(Closed) Unresolved Item (213/79-10-04): Procedure SUR 5.1-15, Fire Protection System Tests, would be revised to record fire protection system pump run time. The inspector verified that SUR-5.1-15 has been revised to record fire system pump run times and ensures that the pumps are run at least i
fifteen minutes.
(Closed) Unresolved Item (213/79-10-06): Licensee unable to establish j
reference flow rate or reference differential pressure as recuired by IWP-L 3100 because of variable operating conditions which could not be controlled.
j In a letter dated June 29, 1979, the licensee proposed, as an alternative, that referenced hydraulic curves of pump dynamic head.versus flow be established and used for evaluation of pump performance. This alternative was approved
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i by the NRC on an interim basis in a letter dated July 24, 1980.
The impecto verified that such curvas have been. developed by the licensee l
for the charging pumps arid are currently in use for evaluating ISI pump performance. The inspector observed that these curves are referenced in
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. SUR 5.7-10, Inservice Inspection Pump Analysis and Documentation" but have
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not been established as part of the procedure nor have they been reviewed by the-PORC.
Further, they could be changed by the ISI engineer without fomal review or approval based on future pump data. The inspector informed the licensee that curves used for evaluation of pump performance must be PORC reviewed and receive formal approval. The licensee stated that curves
used for evaluation of charging pumps would be incorporated into SUR 5.7-10
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by December -15,- 1980. This item is unresolved pending licensee action and subsequentNRC:RIreview(213/80-18-06).
F (Closed) Unresolved Item (213/79-10-07):
Licensee.to test service water pumps by operating pumps at shutoff head on a monthly basis.
In a letter
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dated June ~29,.1979, the licensee stated that hydraulic performance curves of pump dynamic head versus flow would be developed and used for evaluation
.of-pump performance.'.-This method was approved by the NRC, on an interim
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basis, in a letter dated July 24, 1980.
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The inspector verified that such curves have been develo;ad by the licensee for the service water pumps and are currently in use for evaluating ISI pump performance. The inspector observed that these curves are referenced in SUR 5.7-10, " Inservice Inspection Pump Analysis and Documentation" but are not established as part of the procedure nor have they been reviewed by the PORC.
Further, they could be changed by the ISI engineer without formal review or approval based on future pump data. _The inspector informed the licensee that curves used for evaluation of pump performance must be PORC reviewed and receive fomal approval.. The licensee stated that curves used for evaluation of service water pumps would be incorporated into SUR 5.7-10 by December 15, 1980.
This item is unresolved pending licensee
actionandsubsequentNRC:RIreview(213/80-18-07).
(0 pen) Unresolved Item (213/79-10-08):
Licensee to review pump ISI program for compliance with Subsection IWP-4000, Methods of Measurement, in the following areas:
Instrument Tap locations;
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Instrument ranges less than four times reference values;
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Effective calibration program for test instruments; and
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Vibration measurements on Service Water Pump Supports with respect l
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to resilient mount separation of pump support structure from the pump l
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The inspector verified that the licensee has evaluated instrument tap locations and found them to be acceptable; determined that instrument ranges were less than four times reference values; and revised SUR 5.1-103
to provide for verification before each test by the ISI engineer that test instruments were within calibration. The inspector verified on a sampling basis that the licensee evaluations were acceptable and that SUR 5.1-103 had been revised.
The licensee had detemined that the physical configuration of the Service Water pumps prevents direct vibration measurements of the pumps.
Currently vibration measurements are taken from the pump motor upper and lower bearings and pump motor base.
To provide a more accurate vibration measurement of
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l the pump, the licensee has authorized the purchase of a proximity probe and keyphaser which are expected to be in place by December 31, 1981. This item remains open pending completion of licensee action.
(Closed) Unresolved Item (213/79-10-09): Only one individual had been assigned to coordinate the ISI program and to compile data. This apparently caused errors in the tran;cribing of data to the Sumary List of Pump Data.
The inspector verified that two individuals are now currently assigned to coordinate ISI inspections and review pump and valve inspection data.
In addition, the licensee stated that a new ISI engineering organization is being planned. The inspector randomly inspected ISI pump data that had been transcribed to the Sumary List of Pump Data and verified that there were no errors.
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(Closed) Unresolved Item (213/79-10-10):
The following records to be formalized and incorperated into plant procedures as required by Subsection
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IWP-6000:
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Sununary listing of all pumps covered by the program versus current
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test status. The inspector verified that procedure SUR 5.7-10, "Insers1ce Inspection Pump Analysis and Documentation", Attachment V provides a listing of pump test status.
Pump records and nameplate information; inservice test plans including
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reference values for pump testing; and records of tests including-comparison with allowable ranges of test values and analysis of deviations and requirements for corrective action. The inspector verified that SUR 5.7-10 requires these records to be retained by the ISI Engineer and, on a sampling basis, verified that these records were being maintained by the test engineer.
(Closed) Unresolved Item (213/79-10-11):
Valves under the dual scope of coverage by 10 CFR 50 Appendix J and by
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ISI Program need exemption from individual leak rate testing required bySubsectionIWV-3240(f)and(g). The inspector observed that a waiver not to test containment isolation valves per IWV-3420 (f) and (g) but to test them per requirements of Technical Specification, Containment Isolatten Valve testing, was submitted in a letter dated June 29, 1979 and received NRC interim approval in a letter dated July 24, 1980.
Several pressure isolation valves,'not under the scope of 10 CFR 50
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Appendix J, which require leak rate testing per ISI remain to be l
identified.
Pending the identification of these valves NRC:RI will review associated procedures developed for leak rate testing these
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valves.
The inspector observed that these valves were identified as SI-MOV-861A-D, Safety Injection Isolation Valves, and CD-MOV-871 A and B, Core Deluge Valves to Reactor Vessel Head, which are tested per procedure SUR 5.1-4, Hot Operational test; and RH-M0V-780, 781, 803,
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Loops-1 and 2 inboard and outboard isolation valves which are tested
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per SUR 5.1-83, ISI of RHR Inboard and Outboard Isolation M0Vs. The inspector reviewed these procedures and had no further questions.
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Category E Valves (valves which are normally locked or sealed open or
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closed to fulfill function) remain to be identified on the implementation schedule. They are however, in the program submittal.
Other valves in this category are being considered and associated procedures will have to be' developed.
The inspector observed that these valves have been identified and are tested per procedure SUR 5.1-126, Locked Valve Checklist.
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Relief valves remain to be identified in the Implementation Schedule.
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They are, however, in the program submittal. Additional valves are being considered.
Further, procedures remain to be issued incorporating the requirements of PTC 25.2 - 1966, the test procedure referenced in subsection IWV-3510.
The licensee indicated intentions of using a later version of this test procedure.
The inspector stated an exemption from the code would be warranted if a later version of the PTC were used. The licensee representative acknowledged the inspector's comments in this area.
The inspector observed that a waiver was submitted in a letter dated June 29, 1979 to perform relief valve tests in accordance with ASME PTC 25.3-1976 in lieu of PTC 25.2-1966 and received NRC interim approval in a letter dated July 24, 1980. The inspector detennined that testing of pressurizer safety valves PR-SV-584, 585, and 586 per procedure SUR 5.5-1 was not in accordance with PTC-25.3 in that reseat pressures for these valves were not determined. The licensee stated the five year
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cycle for testing of all relief valves would not be completed until January 1983 and that credit would not be taken for the ISI program for past performances of SUR 5.5-1.
The licensee also stated that reseat pressures for valves PR-SV-584,-585, and 586 would be determined when performing tests for ISI purposes. This item will be reviewed duringsubsequentNRC:RIinspections(213/80-18-04).
(Closed) Unresolved Item (213/79-10-12):
IWV 3410 paragraph (e)
requires that failsafe valves be tested by observing the operation of the valves upon loss of actuator power.
NRC:RI to perform a more detailed technical review of SUR 5.1-116 to determine if loss of actuator power is simulated for Auxiliary Feedwater Terry Turbine
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Control valves by rapidly taking the control switches to the open (fail safe) position. The inspector reviewed drawings and determined
l that moving switches to the open position causes loss of' power to the l
Terry Turbine control valve solenoid operating valves and subsequent i
loss of air to the valves duplicating loss of actuator power and meets the requirements of IWV 3410(e).
(Closed) Unresolved Item (213/79-10-13): The following ISI records need to be formalized as required by Subsection IWV-6000:
l Summary of Covered Valves versus current status of tN Test and
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i Inspection Program.
The inspector verified that procedure SUR
5.7-11, Documentation of Inservice Testing of Valves and ISI valve test schedule issued May 7, 1979 provides this status.
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Manufacturers preoperational test and examination results or an exemption
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from this requirement, if the information cannot be located. The inspector verified that some preoperational test results were located and are maintained on record with the ISI engineer.
In a letter dated June 29, 1979 the licensee requested an exemption from the requirements of IWV-6000 for those records which could not be located because the plant had been operating ten years. Along with other waivers and exemptions, this exemption was approved by the NRC, on an interim basis, in a letter dated July 24, 1980.
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Specification of acceptance criteria based on previous test results,
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e.g. maximum valve stroke time and previous test results for trending.
The inspector, on a sampling basis, determined the above acceptance criteria has been placed in each procedure, where app?icable.
The acceptability is being evaluated by the person performing the test and later by the ISI engineer who, also performs a trend analysis.
3.
Administrative Controls for Surveillance Procedures The inspector reviewed, on a sampling basis, the below listed administrative procedures for conformance with Technical Specifications, Section 6,
" Administrative Controls", ANSI N18.7-1976 " Administrative Controls for Nuclear Power Plants" and Regulatory Guide 1.33 " Quality Assurance Program Requirements".
The following administrative procedures were reviewed:
ADM 1.1-51, Inservice Inspection Program, Revision 1, February 21,
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1980.
QA 1.2-11.1, Operational Surveillance Tests, Revision 6, March 17,
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QA 1.2-11.2, Review of Test Data, Revision 3, March 17,1980.
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QA 1.2-12.1, Control of Measuring and Test Equipment, Revision 4, June
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22, 1979.
QA 1.2-5.2, Procedure Format, Revision 3, September 13, 1979.
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QA 1.2-6.4, Temporary Procedure Change (TPC), Revision 8, July 5,
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No unacceptable items were observed.
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4.
Surveillance Testing a.
The inspector reviewed surveillance tests on a sampling basis to verify the following.
Tests required by Tecnnical Specifications are available and
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covered by properly approved procedures.
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Test format and technical content are adequate and provide satisfactory
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testing of related systems or components.
Tests have been reviewed as required by Facility Administrative
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Requirements.
Tests were performed within the time f'*equencies specified by the
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Technical Specifications and appropriate action was taken for any item failing acceptance criteria.
b.
The following surveillance tests were reviewed:
SUR 5.1-4, Hot Operational Test, Revision 9, January 25, 1978.
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Data reviewed for RHR pump operational tests performed September 5, 1980; August 7, 1980; July 16, 1980; April 3, 1980; and March 7, 1980.
SUR 5.1-7, Functional -Test of Containment Spray Valves, Revision
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No. 1, April 6, 1978.
Data reviewed for functional tests performed May 12, 1980; and February 1,1979.
SUR 5.1-8, Monthly Containment Racirculation Fan Damper Test and
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Filter Inspection, Revision No. 3, August 25, 1977. -Data reviewed for tests and inspections performed September 4,1980; August 8, 1980; September 9, 1980; May 4, 1980; and April 7, 1980.
SUR 5.1-17. Emergency Diesel Generators Manual Starting and
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Loading Test, Revision 6, July 8, 1978.
Data reviewed for monthly functional tests performed January to October 1980.
SilP, 5.1-18, Test of Emergency Diesel Generater, EG-2A, With
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Partial Loss of AC Coincident With Core Cooling Actuation, Revision 8, July 8, 1980.
Data reviewed for RHR pump refueling operational test performed June 9,1980.
SUR 5.2-3, Reactor Coolant Flow Trip Test, Revision 5, June 22,
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Data reviewed for test performed September 27, 1930.
SUR 5.2-52, Reactor Coolant System Pressure Channel Calibration,
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Revision No. 2, February 28, 1980.
Data reviewed for Low Pressure Overpressure Protection System (OPS) system test and calibration perfonned July 3,1980.
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SUR 5.5-13, Semi-Annual Testing of Heat and Smoke Detectors,
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Revision No. 4, February 28, 1980.
Data reviewed for test perfomed October 7, 1980.
PM 9.1-9, Fire Protection Equipment Inspection, Revision No. 4,
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February 28, 1980.
Data reviewed for monthly inspections performed January to September 1980.
c.
Findings, (1)
10 CFR 50, Appendix B, Criterion XI requires that results be documented and evaluated to assure that test requirements have
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been satisfied.
Plant procedure QA 1.2-11.2, " Review of Test Data", which implements the Appendix B requirement requires that test data be reviewed and evaluated by the Department Head; that satisfactory review be documented by Department Head signature; that unsatisfactory data be identified and clearly noted on the data sheet; and that approved test data be forwarded to the Quality Assurance (QA) Department. During inspecticn of data for monthly tests SUR 5.1-17, SUR 5.1-8, and PM 9.1-9 the inspector cetermined that the following unsatisfactory data were not reviewed and evaluated in accordance with the above requirements:
For SUR 5.1-17, " [ Emergency Diesel Generators 2A and 28]
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Manual Starting and Loading O st", performed monthly January 1980 to October 1980, there are 169 instances in which various parameters were recorded out of the normal range specified on the data sheet and two instances in which data sheet entries were omitted without being identified or evaluated on the data sheet.
In each instance the data sheet had been reviewed and signed by the Department Head (except for EG2A test performed May 1, 1980 which was not
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signed by the Department Head). Some but not all instances,
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are detailed as follows-The diesel fuel oil storage tank required to be between
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3750 and 4300 gallons was maintained at 3450 to 3500 gallons for the test performed August 5, 1980.
The enghe oil cooler expansion tank level required to
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be maintained 8" to 10" of level was maintained at 2" for tests performed May 2, 1980 and January 3, 1980 and 1.5" to 2" for the test perfomed April 2,1980.
The engine oil temperature from cooler, required to be
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maintained at 180 - 1900F, was maintained at 201 -
2050F for the test perfomed August 4,1980.
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The normal fuel rack position is 0.89 - 0.93, the fuel
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rack position at 2850 KW (high end of rated power) wts recorded as 0.85 for tests performed October 1,1980 and July 3, 1980; 0.83 for tests performed August 5, 1980 and August 4, 1980; and 0.84 for the test performed July 2, 1980.
Stopwatch calibration data required to be recorded by
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the procedure was omitted from the test performed August 4,1980; and fuel rack position at 2850KW was not recorded for tests perfomed on September 2,1980 and March 4, 1980.
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In 22 instances out of normal data was identified on various tests in that the data entries were circled; however, no entries were made on the data sheet evaluating this data to determine if it was acceptable or that corrective action would be required.
For SUR 5.1-8, " Monthly Containment Fan Damper Test and
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Filter Inspection" performed May 4,1980 there were 24 instances in which fan damper positions, filter pressure drop, anti fan motor currents were not verified by the operator for fans F-17-1, F-17-2, F-17-3, and F-17-4, yet the procedure was reviewed and signed off as satisfactorily completed by the Department Head on May 8, 1980. A licensee representative stated that the technician performing the test had been contacted, but that he had stated that he could not recall the reasons for the omissions.
SUR 5.1-4. " Hot Operational Test [ Monthly Test of
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Emergency Core Cooling Pumps]", requires that the pump discharge and leak detection pressure gauge calibration sheets be attached.
In no instance, for monthly tests performed January to October 1980 were the calibration sheets attached, although the test checklists were signed by the Department Head as satisfactorily completed.
A licensee representative stated it was no longer-intended to attr.ch calibration sheets to the procedure but orly to verify that calibrations had been accomplished as specified by the procedure; and further that a procedure change would be issued to delete this requirement.
PM 9.1-9, " Fire Protection Equipment Inspcction (Monthly],
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for inspections perfomed April,1980; May,1980; and June 1980. The completed inspections were not reviewed and signed by the Fire Hazards and Housekeeping Chairmar as requir0d by the procedure. Additionally, the May, 1980 and June,1980 completed inspections were not reviewed and signed by the Operations Supervisor as required by the procedure.
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Numerous surveillance test data and inservice inspection
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test data for tests performed during 1979 and 1980 were being maintained by the Operations Department and had not been forwarded to the OA Department. The licensee stated that the intent of procedure QA 1.2-11.2 is for the GA Department to review all test data to ensure satisfactory accomplishment.
Because of thd above retention, test records were not being rev'ie<ed by the OA Depa,teent.
Failure of the Department Head to review test results; his approval.
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of unsatisfactory test results without further evaluation; and,
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failure to forward test results to the 0A Department for review is contrary to Technical Specification 6.8.1, and plant procedure QA 1.2-11.2 paragraphs 5.1, 5.3, 6.2, 6.4, and 7.1 and constitute an item of noncompliance (213/80-18-01).
(2) Technical Specification (T.S.) 4.15.B.1.b, effective February, 1978 requires, in part, that a flow test be performed on the Fire Pro':ection CO2 System Headers every 18 months + 25% to assure no ble:kage. This would have required this flow Test to be completed by December 22, 1979.
The inspector determined that, as of Cetober 10, 1980, a flow test had not been accomplished for the Primary Auxiliary Building (PAB) Charcoal Filters. Since this was in excess of 18 monti:s +25%, the CO2 system for the PAB filters could no longer be considered operable. After beinn informed of this, the licensee established a fire watch at the PAB Charcoal Filters as required by Technical Specification 3.22.B.2.
During the 1980 refuWo outage The Fire Protection C02 System for the Cable Vault w:
Sdified. As a result of this modification, C02 system flow test fa rhe Cable Vault was performed per Special Maintenance Procedure SPL 10.7-72'on June 16, 1980. This procedure met the requirements of T.S. 4.15.B.1.b for CO2 flow test but was accomplished in excess of the 18 months plus 25% requirement.
Failure to perform the PAB Charcoal Filter CO2 System Flow Test and performance of the Cable Vault Flow Test in excess of 18 months plus 25% is contrary to Technical Specifications 4.15.B.1.b and is example of an item of noncompliance (213/80-18-02). An additional example is detailed-in paragraph 4.c(3) below.
(3) Technical Specification 4.15.F.b.1 requires that every 18 months
+ 25% a functional test of automatic actuation of the Fire Protection -
Ypray and/or Sprinkler Systems be perfonned. Additionally, T.S.
4.15.F.b reouires that the spray headers be visually inspected to verify integrity and that each spray nozzle' be inspected to verify no blockage.
These requirements were established October 3, 1978 and testing would need to be completed by August 19, 1980.
The licensee stated that a functional tett of the spray / sprinkler
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system automatic actuation and system integrity was perfomed every six months by fire insurance company inspectors but that a visual inspection of each nozzle had not yet been performed. The inspector also determined that the tests and inspections were not performed using a plant approved procedure nor were their results documented and retained by the licensee.
Failure to perform visual inspection of Spray /Spri.nkler System
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nozzles is contrary to Technical Specification 4.15.F.b.3; failure to perform spray / sprinkler system tests using an approved procedure is contrary to Technical Specification 6.8.1, and Regulatory Guide 1.33, Appendix A, Paragraph H.2; and failure to retain documentation of surveillance tests required by Technical Speci-fications collectively constitute an example of an item of noncompliance (213/80-18-02). An additional example is detailed in paragraph 4.c(2)above.
(4)
Plant procedure PM 9.1-9, " Fire Protection Equipment Inspection",
is performed monthly and provides instructions for inspecting all plant fire extingui:;hers, hoses, and hydrants.
For the inspection perfomed September 11, 1980, the inspector observed numerous pen and ink changes to the procedure, to reflect actual equipment found in place, without having obtained a temporary procedure change.
Some examples of changes are as follo+.s:
f In two instances extinguishers were changed from CO2 to dry
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l chemical, and in two other instances fire extinguishers from dry chemical to Halon; and in two instances fire extinguishers were deleted.
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Failure to obtain an authorized temporary procedure change to a PORC reviewed procedure is contrary to Technical Specifications 6.8.1 and 6.8.2;~and plant procedure OA 1.2-6.4, paragr ph 5.1, and constitutes an example of an item of noncompliance 213/80-18-03). A further example is detailed in paragraph 4.c 5) below.
(5) Technical Specification 4.15.B requires that CO2 system cylinters be weighed at least once per 6 months and that system automatic and manual activation of the CO2 system be accomplished at least once per 18 months. The licensee stated that procedure SUR 5.5-15, " Semi-Annual Inspection of CO2 Systems for Cable Vault and HEPA Filters and Halon System for Records Vault" provided instructions for performing these tests.
During inspection of this procedure, the inspector determined tha.t the procedure did not adequately document test results in that:
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Although the C02 cylinders are weighed, no provision is made
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j for recording weights.
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The acceptance criteria is specified as not more than 10%
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i loss. However, the base weight from which the 10% is to be I
applied is not given or recorded in the procedure. Hence, it is not possible for subsequent reviews by the Department Head and QA Department to evaluate the acceptability of test data.
Additionally, the procedure does not assure that an l
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acceptable weight is achieved as none is required.
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The procedure requires operation of pneumatic switches but
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does not clearly state the differentiation between automatic and manual operation, nor is satisfactory operation of system valves and ventilation dampers documented.
Failure to provide adequate acceptance criteria; failure to provide for recording of test data; and failure to adequately document test results for surveillance of C02 Fire Protection
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Systems is contrary to Technical Specification 6.8.1, and plant procedure QA 1.2-5.2, paragraphs 8.1.9 and 8.9 and constitutes an example of an item of noncompliance (213/80-18-03).
An additional example is detailed in paragraph 4.c(4)above.
(6)
" Administrative" Technical Specification 4.5.A.I.1 requires
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that the Diesel Generator fuel day tank be maintained at a
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minimum of 400 gallons. The inspector observed that procedure SUR 5.1-17, Monthly Operational Test of the Diesel Generators, requires the Day Tank level to be maintained between 190 and I
490 gallons and questioned whether or not this band violated the 400 gallon minimum limit and noted many instances during 1980 where recorded Day Tank levels during the test were less than 400 gallons. The licensee stated that the 400 gallon limit was to ensure initial start of Diesel Generators and did not apply while the diesel generators were operating
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but that the 400 gallon level should be re-established following completion of each test.
In addition, the licensee
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noted that the shift surveillance log ensures that the day tank level is maintained above 400 gallons., ions, the lastThe inspecto informed the licensee that on several occass reading recorded for the Day Tank was below 400 gallons and that as much as a sixteen hour period could exist before the day tank is refilled. The licensee agreed to revise SUR 5.1-17 by December 1, 1980 to ensure that the Day Tank is refilled to above 400 gallons immediately following the test. This item is unresolved pending licensee action and subwquentNRC:RIreview(213/80-18-05).
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(7) The inspector observed that the monthly test of the Containment Air Filtration System pressure drop and damper operational test required by Technical Specification 4.4.IV.A.4 and 5 was not accomplished for June 1980.
A test record status notation stated that the test was not done because the plant was in a refueling mode; however, Technical Specification 4.4.IV does not specify modes for which this surveillance may be applicable. Technical Specification 3.11.D requires that 3 of 4 containment recirculation fans be operational while the reactor is critical; but does not specify operability of the air filtration system. The licensee agreed.to evaluate, by February 1,1981, the required modes of operation for this test and determine whether or not a Technical Spt.cification change and/or change to procedure SUR 5.1-8 is required. This item is unresolved pending licensee action and subsequent NRC:RI review (213/80-18-08).
5.
Inservice Inspection Program a.
The inspector reviewed the in-service inspection plan and procedures on a sampling basis to verify the following:
Tests are in conformance with the in-service inspection program
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requirements.
Test frequency is in conformance with Technical Specifications
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and the In-Service Inspection Program.
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Test format and technical content are adequate and provide satisfactory
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testing of related systems or components.
Test results have been reviewed as required by facility administrative
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requirements and appropriate action was taken for results failing acceptance criteria.
Tests are performed by qualified personnel l
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b.
The following inservice inspection tests were reviewed:
SUR 5.1-103, Inservice Inspection Pump Surveillance, Revision No.
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4, February 15, 1980.
Data reviewed for pump tests performed on various dates in July, August and September, 198G.
l SUR 5.1-109, Inservice Inspection of Spent Fuel Pit Heat Exchanger
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Discharge Valve-SW-A0V-9, Revision No. 1, November 22, 1979.
Data reviewed for August 28, 1980; May 8, 1980; February 8, 1980;
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and December 14, 1979.
SUR 5.1-112, Inservice Inspection of Service Water Pump Discharge
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Check Valves, Revision 1, November 22, 1979.
Data reviewed for inspections performed August 28, 1980; June 24, 1980; and January 28, 1980.
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SUR 5.1-116, Inservice Inspection of Auxiliary Steam Generator
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Feed Pump Control Valves, Revision 1, November 22, 1979.
Data reviewed for inspections performed August 29, 1980; May 21, 1980; January 23, 1980; and December 7,1979.
c.
Findings Numerous ISI test results were being maintained by the Operations Department and were not being forwarded to the OA Department for review.
This is contrary to procedure QA 1,2-11.2 and is an example of an item ci nc..ccmpliance which is detailed in paragraph 4.c.(1)
(213/80-18-01).
6.
Inspector Witnessing of Surveillance Tests and Inservice Inspections a.
The inspector witnessed the performance of surveillance testing of selected components to verify the following.
Procedure was available and in use.
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Special test equipment required by procedure was calibrated and
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in use.
Test prerequisites were met and initial conditions were observed
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properly.
The procedure was adequately detailed to assure perfomance of a
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satisfactory surveillance or inservice inspection.
b.
The inspector witnessed the perfomance of two surveillance tests as follows.
SUR 5.1-23, Routine Control Rod fetion Check, perfomed October
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8, 1980.
SUR 5.2-8, Volume control Tank Level Channel (Pneumatic Surveillance
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Test (90 Day)), perfomed October 9,1980.
No unacceptable items were observed.
7.
Technical Qualifications The inspector reviewed the qualification records of two technicians, who perfomed tects listed in paragraph 6 above, to ensure that the personnel-
-qualifications met the minimum training and experience guidelines of ANSI N18.1, " Selection and Training of Nuclear Power Plant Personnel", Section 4.
No unacceptable conditions were identified.
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8.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items or items of noncompliance.
Four unresolved items were identified during this inspection and are detailed in paragraphs 2, 4.c.(6) and 4.c.(7).
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9.
Management Meetings
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Licensee management was informed of the purpose and s' cope of the inspection at the entrance interview, and the findings of the inspection were periodically discussed with licensee representatives as follows:
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Date Reoortable Details Covered
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Entrance Interview October 6 October 8 4.c.(1),(2),and(3)
' October 9 4.c.(4),(5),(6)and(7)
October.10 Exit Interview The inspector conducted an exit interview with licensae representatives (denoted in paragraph 1) at the conclusion of the inspection, where the
. findings of the inspection were presented and acknowledged by the licensee.
Sub equent telephone conversations concerning inspection findings were cr' acted between Mr. N. Blumberg and Mr. R. Traggio on October 22 and 23, 156.
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