IR 05000220/1980005
| ML17053C275 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 08/27/1980 |
| From: | Blumberg N, Greenman E, Shaub E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17053C269 | List: |
| References | |
| 50-220-80-05, 50-220-80-5, NUDOCS 8102050738 | |
| Download: ML17053C275 (36) | |
Text
U.
S.
NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION I
Report No.
50-220/80-05 Docket No.
50-220 License No.
DPR-63 Priority Licensee:
Nia ara Mohawk Power Cor oration 300 Erie Boulevard Mest S racuse New York 13202 Category C
Facility Name:
Nine Mile Point Nuclear Station Unit 1 Inspection At:
Scriba New York Inspection Conducted:
" Ma 19-23 1980 Inspectors:
um e g, ac or ns ec or a
e au
,
eac nspec or Approved by:
reenman, ie
,
uc ear uppor Section No. 2, R088S Branch axe S'-A 7-8'0 a e Ins ection Summar
ns ec son on a
19-23 1980 (Re ort Number 50-220/80-05)
reas ns ec e
ou one, unannounce snspec ion y
wo regional based inspectors o
licensee ac ion on previous inspection findings; administrative controls for facility procedures; conformance to Technical Specifications; temporary and per-manent changes in conformance to Technical Specifications and licensee procedures; changes in procedure to 10 CFR 50.59(a)
and (b) requirements; checklists and re-lated forms for currency to latest changes; and plant tour and control room ob-servations.
The inspection involved 65 inspector-hours by two regional based NRC inspectors.
Results:
Of the seven areas inspected, no items of noncompliance were noted in tour areas.
Four items of. noncompliance were identified in three areas [infrac-tion - failure to maintain written procedures, paragraph 4.c. (1)]; I:infraction-Inadequate access controI.to a vital area, paragraph g.a..(Z)]
[i fnr acjton-Region I Form 12 S~OSOSO>
(Rev. April 1977)
e
failure to wear necessary protective clothing into containment area, paragraph 9.a.(l)j and fdeficiency - failure to properly implement and have SORC review of standing orders, failure to maintain control room procedures updated, and failure to document temporary changes, paragraphs 4. c(2), (3) and (4) p-'
DETAILS 1.
Persons Contacted
- T. Perkins, General Superintendent Nuclear Generation
"T. Roman, Station Superintendent
"R. Abbott, Operations Supervisor
,
"M. Drews, Reactor Analysis Supervisor
"K. Dahlberg, Maintenance Supervisor
"R.
Raymond, Fire Protection Coordinator M. Chambers, Security Investigator, Nuclear
~G.
Leskiw, gC-O, Acting, gC Supervisor
"A. Kovac, Associate gC Engineer M. Jones,
.Reactor Outage and Modification Coordinator B.
Eastman, Reactor Analyst Technician The inspectors also interviewed other licensee employees during the inspection, including reactor operators, technical support, administrative and clerical personnel.
- denotes those present at the exit interview
.
Licensee Action On Previous Ins ection Findin s
(Closed)
Unresolved Item (78-18-01):
The following procedures required revision as a result of Technical Specification (TS) Amendments or periodic reviews:
OP-21, "Fire Protection System",
Revision 1, January 6, 1976, did not recognize later TS changes in this area and the valve number for the Cardox System supply valve was left blank.
The inspector verified that OP-21 has been revised to reflect, operation of fire systems as a result of TS changes.
However, the valve lineup checkoff list in OP-21 failed to'nclude the Cardox System supply valve and Cardox System supply valve bypass valve; this has been identified as an example of an item of noncompliance further detailed in paragraph 4..c.(l) of this report.
"Local Power Range Monitor - Average Power Range Monitor",
Revision 3, 1975, should be revised as a result of comments generated as a result of licensee periodic procedure review.
OP-38C was revised January 1979.
As part of this inspection, OP-38C was reviewed (see paragraph 4) and no discrepancies were observed by the inspecto / ~
~
I ~ l
No operating procedure issued to implement TS Amendment 24 concerning operation with less than full reactor coolant flow.'P-1, "Nuclear Steam Supply System",
was revised to include a procedure for operation with less 'than full reactor coolant flow.
TS Amendment 36 was issued August 1979, which changed the requirements for operation with less 'than full flow.
Additional instructions were issued as a
Standing Order No.
18. This is identified as an example of an item of noncompliance and is further detailed in paragraph 4.c.(2) of this report.
Nl-OP-13,
"Emergency Cooling System",
Revision 4, October 15,. 1976, did not reflect current TS surveillance requirements for inoperable equipment.
The inspector verified that Nl-OP-13, Revision 7, December 26, 1979, does reflect current TS surveillance requirements.
(Closed) Deficiency (78-21-03):
Procedure in use for crossconnecting the Unit 1 and Unit 2 fire systems which were not SORC reviewed'or were included in Procedure N1-0P-21, "Fire Protection System."
The inspector observed that the procedure for crossconnecting Unit 1 and Unit 2 fire systems has been included in a revision to Nl-OP-21.
(Closed) Infraction (79-02-01):
Containment Spray Pumps 111 'and 121 did not meet acceptance criteria for pump operability test performed per procedure Nl-ST-(6, "Containment Spray and Raw Mater Pump Operability Test,"
on November ll, 1978.
The licensee response stated that a satis-factory retest was performed on January.26, 1979 and concluded that the problem was caused by either inadequate blow down of the flow transmitter or improper recording of the test results.
The inspector reviewed test results for the test performed on January 26, 1979 and subsequent quarterly operability tests performed during 1979 and observed that Containment Spray Pumps operability test results were acceptable.
During review of the January 26, 1979 test data, the inspector observed the following discrepancies:
Prerequisite step A.4 in data sheet for Nl-ST-g6 was not signed off verifying that the required pressure gages were in calibration prior to the test and that calibration sheets were attached.
Procedure Nl-ICP-80, "Containment Spray System Flow and Pressure,"
data sheet attached to the N1-ST-g6 data sheet was incomplete for calibration of flow transmitter 80-49A, flow converter 80-49B, and flow indicator 80-49C.
The data sheet as attached indicated flow instruments may not have been in calibration at the time of test.
On file, separately, was a completed data sheet for this instrument on January 26, 1979 but it could not be determined whether or not calibration had been completed prior to performance of the surveillance tes ~p,p
~ L
The incomplete Nl-ICP-80 data sheet had been signed as completed by the technician performing the test.
Final review of test results as required by procedure APN-8 was inadequate in that the above discrepancies apparently were not observed and were not corrected.
The inspector observed that data for the flow indicator calibration was slightly out-of-calibration but that this did not effect the results of the operability test of the pump.
Failure to verify a surveillance test prerequisite; failure to assure instruments were in calibration prior to use; improper certification of completion of a calibration test; and failure to adequately review test results is contrary to Technical Specification 6.8.1; Surveillance Test Procedure Nl-ST-g6; Calibration Procedure Nl-ICP-80; and Procedure APN-8, and constitutes an example of a deficiency level item of noncompliance, other examples of which are detailed in paragraphs 4.c.(2), 4.c.(3)
and 4.c.(4) of this report.
(50-220/80-05-02)
(Closed)
Inspector Follow Item (79-02-02):=
Temporary changes were used infrequently.
The-inspector noted that temporary changes are still used infrequently, and that the need for a temporary change must be determined by the licensee on a case basis.
Proper use of temporary changes will be the'subject of continuing review during future NRC inspections.
4'Open)
Inspector Follow Item (79-06-01):
No acceptance criteria specified for visual inspection results of cold snubber piston settings.
The licensee stated that they would prefer to have an engineering evaluation accomplished on the acceptability of each piston setting rather than use a rigid set of acceptance criteria.
The inspector observed that current snubber inspection procedures did not document results of any required engineering evaluation but that such an evaluation would be acceptable, if documented:
The licensee stated that snubber inspection procedures would be revised to document the results of engineering evaluations to determine the acceptability of snubber inspection data.
This item to remain open pending issuance of procedure revisions and further review of 'snubber inspection data.
(Closed) Deficiency (79-06-02):
Snubber inspection data sheets not properly completed and independent review of snubber inspection results was not accomplished.
The inspector. reviewed the latest snubber inspection results and observed that inspection data sheets are being completed for each snubber inspection and that snubber inspection results receive independent supervisory revie + l
(Open) Inspector Follow Item (79-06-03):
=. Technical Specifications need
.to be.revised to include listing certain safety-related snubbers located in the drywel:I.
The inspector observed that a TS change request, which listed additional drywell snubbers had been submitted April 25, 1980.
This item will, remain -'open pending approval of-this 'change.
(Closed) Infraction (79-14-02): Out-of-date valve lineup checkoff lists for Core Spray and Standby Liquid Control systems being maintained in the Control Room.
The inspector observed that the valve lineup checkoff sheets, maintained in the Control Room for the above systems are current to those, specified in the operating procedures.
In addition, valve lineup checkoff lists associated with several other system operating procedures were observed to be in accordance with the procedure.
However, during technical review of procedures during this inspection, the inspector observed that valve lineup checkoff lists in seveial procedures were either incomplete or incorrect.
This is an item of noncompliance which is detailed in paragraph 4.c.(1) of this report.
(Closed)
Unresolved Item (79-23-01):
Valve checkoff list (COL) for Inservice Vessel Hydrostatic Test was incorrectly performed in that valve positions rather than initials and dates were recorded.
The inspector observed that the valve COL for Inservice Hydrostatic Test in procedure N1-OP-1 has been revised to clarify that initials and dates are required and a signoff column for second verification has been added.
(Closed)
Unresolved Item (79-23-02):
Log suppression pool temperature more frequently than once at the end of the entire test, during testing of relief valves.
The inspector observed that Surveillance Test, N1-ST-V5,
"Suppression Pool Temperatures Monitoring During Relief Valve Operation,"
has been revised to require recording of suppression pool temperature every five minutes during relief valve testing.
(Open) Deficiency (79-23-03):
Three examples were noted concerning control rod and reactivity testing procedures:
Procedure Nl-RAP-03, "Full Core Control Rod Scram Timing Sequence,"
was improper ly completed in that a step concerning individual rod speeds was not verified and annotated as "Not Applicable."
Licensee reply to this item dated November 5, 1979 stated the deficiency was not correct in that TS 3.1. l. c.(2) would only be applicable if TS 3.1.l.c.(1)
was not satisfied.
During this inspection, the.inspector advised the licensee that TS 3. 1. 1. c.(l) specifies maximum limits on average scram insertion times for all rods while TS 3.1. l.c.(2)
specifies maximum limits on individual rod scram insertion times; and that, both limits are applicable and must be met except as noted in TS 3.1. 1.c.(3).
The licensee concurred with the inspector's comments and stated that for future data sheets, both steps will be considered applicable.
This item will remain open pending review of data for the next time this test is don ~~
~
~ ~
N1-RPSP-04,
"Reactivity Margin-Incore Loading," requires a second verification of the rod selected be made and this second verification was not documented for tests performed on June 21, 1979.
The in'spector observed that the initials of the second verifier had been added to the data sheet.
The inspector informed the licensee that this corrective action would not preclude recurrence of this problem in that the data sheet only provides for one set of verification initials.
The licensee agreed to revise the Nl-RPSP-04 data sheet to provide for initials of the second verification.
This item will remain open pending issuance of the procedure change and subsequent review of data the next time this procedure is accomplished.
Nl-RPSP-03, "Reactivity Anomalies," performed during the startup test program on July 3, 1979, did not document control rod sequence being used and a step was verified as completed when plant conditions were such that the step could not be completed.
The inspector verified that the control rod sequence had been added to the test data sheet.
The licensee stated the reason for discrepancies on power level is that N1-RPSP-03, which is normally done at operating power levels, was used as a substitute for a startup test.
The licensee further stated that a set of startup procedures are being developed and will be in use for the next refueling startup test program.
This item will remain open pending issuance of the new startup test procedures and review of their use.
(Closed} Inspector Follow Item (79-23-04):
Procedure Nl-RPSP-07 does not provide for returning the Average Power Range Monitors to normal.
The inspector observed that Nl-RPSP-07 has been revised adding a step VIII, which returns the APRMs to their normal position.
(Closed) Inspector Follow Item (79-23-05):
Revise N1-RPSP-04 to reference temperature correction for determining shutdown margin.
The inspector observed that Nl-RPSP-04 has been revised to reference a shutdown margin curve in which the temperature correction has been incorporated.
(Closed) Inspector Follow Item (79-23-06):
The acceptance criteria in procedure Nl-RPSP-01 for the Linear Heat Generation Rate (LHGR) did not take into account the power spiking factor of 2.2X.
The inspectors ob-served that the acceptance criteria for LHGR in Nl-RPSP-Ol has been revised to account f'r the 2.2X spiking factor.
3.
Facilit Administrative Control Procedures The inspectors performed a review,, on a sampling basis,. of the below listed administrative procedures for conformance with Technical Specifications, Section 6, ANSI N18.7 and Regulatory Guide 1.33:
APN-1, Procedure for Administrative Controls, Revision 3, Oecember 1978
gas
~ a
APN-2, Composition and Responsibilities of Site Organization, Revision 2, May 1980 APN-2A, Conduct of Operation and Compos'ition and Responsibilities of Station or Unit Organization, Revision 2, December 1979 APN-2B, Special or Emergency Operations, Revision 0, December 1979 APN-3, Operations Experience Assessment, Revision 0, February 1980 APN-4, Security Procedure, Revision 2, September 1979 APN-5, Procedure for Control of Procedures, Instructions, Orders and Drawings, Revision 4, December 1979 APN-6, Preparation of Procedures, Instructions and Orders, Revision 2, December 1978 APN-7, Procedure for Control of Equipment Markups, etc.,
Revision 1, August 1979 APN-9, Procedure for Station Modifications, Revision 1, January 1979 APN-19, Communications Systems, Revision 0, October 1977 No items of noncompliance were noted.
4.
Review of Faci lit Procedures The inspectors reviewed the facility procedures and temporary changes, on a sampling basis, to verify the following:
Procedures, plus any changes,'ere reviewed and approved in accordance'ith the requirements of Technical Specifications and the licensee's administrative controls.
The overall procedure format and content, were in conformance with the requirements of the Technical Specifications and ANSI N18.7, "Administrative Controls for Nuclear Power Plants."
Checklists, where applicable, were compatible with step-wise instructions in the procedures.
Appropriate Technical Specification limitations had been included in the procedures.
Temporary changes were made in conformance with Technical Specification requirements and the licensee's administrative control I
b.
The following procedures were reviewed:
(1)
S stem 0 eratin Procedures and Associate Alarm Procedures
"(a)
N1-0P-l, Nuclear Steam Supply System (NSSS),
Revision 10, October 1979.
'Panel F, Annunciator Fl-37; Main Steam Line Automatic Depressurization Timing Panel F,. Annunciator Fl-38; Main Steam Line Break Area Temperature High (b)
Nl-OP-10, Reactor Building Heating, Cool'ing and Ventilation System, System Number 202, Revision 3, December 1979.
Panel L, Annunciator L1-6, Emergency Ventilation
=System Flow-Low Filter Differential Pressure Panel L, Annunciator L1-14, Emergency Ventilation System Temperature High
"(c)
Nl-OP-12, Liquid Poison System, Revision 7, 1979.
Panel K, Annunciator K1-9, Liquid Poison Explosive Yal ve 11-12 Continuity Panel K, Annunciator K1-17, Liquid Poison Tank Level/Temp Hi/Low (d)
Nl-OP-17, Makeup Demineralizer System, Revision 3, February 1980.
(e)
Nl-OP-20, Service, Instrument and Breathing Air Systems 94, 95, 113 and 114, Revision 5, April 1980.
Panel L, Annunciator Ll-1-17, Instrument Air Compressor 11-12 Trip Panel L, Annunciator L2-4-8, Breathing Air Compressor Tl 1 p Panel L, Annunciator L1-2-7, Instrument Air Compressor 11-12 Discharge Air Cooling -Mater Temperature High Indicates technical content of procedure reviewed.
(Paragraph 5)
l$
(f)
N1-0P-30, 4.16KY, 600V and 480V House Service, Revision 2, October 1975.
(g)
Nl-OP-33A, 115KV System, Revision 7, January 1980.
Panel A, Annunciator A6-23, 115KV Relay Board Control Voltage Low V
Panel A, Annunciator A8-4, 115KV Bus Switch 8106 Open (h)
Nl-OP-38C, Local Power Range Monitors (LPRM); Average Power Range Monitors (APRM), Revision 4, January 1979.
Panel F, Annunciator F1-14, APRM Monitor 11-14 Off Normal Conditions Panel F, Annunciator F1-28, APRM Flow Unit 11 (i)
Nl-OP-GOA, Area Radi'ation Monitoring System, Revision 1, April 1980.
, Panel H, Annunciator H1-32, Area Radiation Monitor (j)
Nl-OP-51, Communication Systems, Revision 1, January 1979.
(2)
General 0 eratin Procedures
"(a)
Nl-OP-43, Startup and Shutdown Procedure, Revision 3, September 1979.
(3)
Emer enc Procedures
"(a)
Nl-SOP-15, Malfunction of Control Rod Orive System, Revision 2, October 1978.
(b)
Nl-SOP-16, Reactor Scram, Revision 1, August 1978.
"(c)
Nl-SOP-17, Emergency Shutdown with SLCS (Standby Liquid Control System)
Revision 2, June 1979.
(d)
Nl-SOP-23, Loss of Flux Indication, Revision 1, August 1978.
(4)
Maintenance Procedures (a)
MP-01.12, Removal and Installation of Control Rod Guide Tubes, Revision 1, February 1977.
Indicates technical content of procedure reviewed.
(Paragraph 5)
io c
"(b)
MP-01.14, Installation and Removal of Main Steam Line Plugs, Revision 1, March 1977.
"(c)
HP-03.10, Overhaul of Main Steam Warmup Valves, Revi'sion 0, March 1979.
P (d)
MP-03.9, Repair of Main Steam Line Drains, Revision, April 1977.
(e)
.MP-12.1, Overhaul of Liquid Poison Pumps, Revision 1, August 1978.
"(f)
MP-,12.4, Replacement of Liquid Poison Accumulators, Revision 1, August 1978.
(g)
MP-34.1, Maintenance of Instrument Air Compressor, Revision 1', April 1977.
"(h)
HP-34.6, Replacement of Breathing Air Filter, Revision 1, March 1977.
(i)
HP-45.18, Installation Reactor Building Emergency Venti-lation Sample Tags, Revision 1, April,1979.
l5) ~5di D d
"(a)
Standing Order 18, Recirculation Pump Operation, August 1979.
C.
"(b)
Standing Order 22, Valve Monitoring System, April 1980.
(c)
Standing Or der 23, Shift Turnover.
~Findin s (1)
During review of operating procedures, the inspectors observed deficiencies in valve lineup checkoff lists for the following procedures:
t The valve lineup checkoff list included in Nl-OP-Ol,
"Nuclear Steam Supply System," which lines,up main steam valves, failed to include valves HS No. 1-6, electromatic relief valve blocking valves, in the valve lineup.
The Final Safety Analysis Report (FSAR),Section V, requires these valves to be locked open.
The inspector verified by observation of valve position indication in the Reactor Building that these valves 'are open; however, that the valves were locked could not be verified during reactor operation.
The licensee stated that these valves had been locked.
Indicates techn>cal content of procedure review.
(Paragraph 5)
yt
~
The Cardox System supply valve and the Cardox System supply valve bypass valve had been omitted from the fire protection system valve lineups included in Nl-OP-21,
"Fire Protection System."
The inspector observed that the Control Room Annunciator, which would indicate that Cardox Supply valve shut, was not illuminated.
Instrument and Breathing Air Systems valve lineups included in Nl-OP-20, "Service, Instrument and Breathing Air Systems" omitted valves IA-40 and BA 114-30.
These valves were not critical to operation of the systems.
Valve BA 114-30 had been added to the Breathing Air System as a result of a recent modification.
The valve lineup sheet lines up a regulator bypass valve TCLC-97 to the "open" position.
Figure OP-20"1 of procedure N1-OP-20 indicates that this valve should be shut.
Makeup Demineralizer Valve 44, Suction Valve to Makeup Demineralizer Resin Maste Pump No. 12, was omitted from the valve lineup included in N1-0P-17,
"Makeup Demineralizer System."
The licensee stated that the Makeup Demineralizer System had not been in use for two years as demineralized water was purchased from an offsite contractor.
However, the inspector observed that the system had not been decommissioned and that procedure N1-OP-17 is being maintained as an active procedure.
Failure to include required valves on valve lineup checkoff lists; failure to align valves in the correct position; and failure to document the locked position of main steam relief valve blocking valves is contrary to Technical Specification 6.8.1; ANSI N18.7,- paragraph 5.3.4.1(1);
FSAR Section V; and procedure Nl-OP-20, Figure OP-20-1 and constitutes an infraction level item of noncompliance.
(50-220/80-05-01)
(2)
Standing Order NMPSO No. 18, "Recirculation Pump Operation,"
which provides instructions for operation with less than five recirculation pumps, issued August 23, 1979; and Standing Order NMPSO No. 22, "Valve Monitoring System,"
which provides an alarm response procedure whenever a reactor safety or relief valve lifts, issued April 25, 1980, were included in the Control Room Standing Order book.
These standing orders are, in fact, safety-related operating procedures and are outside the scope of standing orders as defined in ANSI N18.7, which specifies that standing orders are for general conduct of business.
These Standing Orders were not reviewed by the SORC prior to issue as required by TS for safety-related procedures; and, in addition, the standing orders were not reviewed by the SORC subsequent to their issu e~
Issuance of operating procedures as standing orders; failure to obtain SORC review prior to issuance of safety related procedures; and failure to obtain SORC review of Standing Orders subsequent to their issue is contrary to Technical Specifications 6.8.1 and 6.8.2; ANSI N18.7, paragraph 5.13; procedure APN-6, paragraph 3.14.1; and procedure APN-5, paragraph 5.4.1.2; and constitutes an example of deficiency level item of noncompliance.
(50"220/80-05-02).
An out-of-date controlled copy of a set of administrative pro-cedures assigned to a Senior Shift Supervisor was observed in the Control Room. This set was maintained in a standard station procedures binder and was in use concurrently with two other controlled sets of administrative procedures being maintained in the Control Room.
The other two sets appeared to be up-to-date.
Records in the document control room indicate the latest revisions had been received for this copy.
Failure to maintain up-to-date copies of administrative procedures in the Control Room; and failure to properly update controlled copies of procedures is contrary to procedures APN-1 and APN-5 and constitutes an example of a deficiency level item of noncompliance.
(50-220/80-05-02)
The examples of noncompliance detailed in paragraphs 2,
4.c.(2),
and this paragraph collectively constitute a
deficiency level item of noncompliance.
(50-220/80-05-02)
A temporary change was observed posted to procedure H-OP-43; however, the procedure change notice (PCN) was not attached to the procedure.
The licensee stated the PCN, which documents the status and approvals of the change, was maintained on file with the procedure master located in the document control center.
The PCN could not be located, however,,minutes of the SORC meeting dated October 19, 1979, indicated this change had been reviewed by the SORC.
This appeared to be an isolated case and the inspector had no further questions concerning this item.
Alarm response procedures are maintained in the Control Room as enclosures to Operating Procedures for systems for which the alarm is associated.
Also, alarm response procedures are being maintained separately in a two volume book and are not controlled; however, they are readily available and can be used by Control Room operators.
In one instance, when asked by the inspector to locate response procedures for several annunciators, a
Senior Shift Supervisor (SSS)
used the alarm response book rather than locate the alarms in the appropriate operating procedures.
Discussions with this SSS indicated he was not aware that the alarm response book was not controlle, ~ ~
+ ~
The inspector also observed that alarm numbering systems for the location, of the alarm in the alarm response book and for the same alarm in the operating procedure were different; and that some operators had difficulty locating alarms'enclosed to the operating procedure in that the operator may not always be initially aware of which operating procedure the alarm response may be associated with.
~ The inspector randomly reviewed numerous alarm procedures, and in no instance, were alarm procedures in the alarm response book found to be different than those in the operating procedures.
The inspector informed the licensee that if both sets of alarm procedures were to be maintained in the control room that control is required, they must be consistently numbered and a method should be developed for ease of location of alarms in the op'crating procedures if the alarm response books are deleted.
The licensee acknowledged the inspector's comments and stated that this would be evaluated and resolution obtained by November 30, 1980.
This item is unresolved pending licensee action and subsequent NRC: RI review.
(50-220/80-05-03)
(6)
Procedures Nl-OP-17,
"Emergency Shutdown with SLCS," and Nl-OP-12, "Liquid Poison System No. 41 and 42," both provide an operating procedure for the system when required for emergency operation.
The inspector observed that these procedures are inconsistent with each other and that information contained in one procedure is not included in the other.
The licensee stated that the two procedures would be evaluated and the inconsistencies corrected or one of the procedures would be deleted.
The licensee committed to completing the evaluation
'and revision by November 30, 1980.
In addition, if a procedure is deleted, pertinent information contained in the deleted procedure would be included in the remaining procedure.
This item is unresolved pending licensee action and subsequent NRC: RI review.
(50-220/80-05-04)
5.
Technical Content of-Facilit Procedures The inspectors conducted a review of facility procedures, on a sampling basis, using FSAR system descriptions, piping and instrument diagrams, and Technical Specification, where necessary, to verify that procedures were sufficiently detailed to control the operation or evolution described within Technical Specification requirements.
The procedures reviewed with respect to this are marked with an asterisk (") in Paragraph
(Review of Facility Procedures)
of this report.
One item of noncompliance was identified and is detailed in Paragraph 4.c.(1)
abov $ ~
y\\
Procedure Chan es Resultin from License Amendments License Amendments (25-37) which included Technical Specifications (TS)
changes were reviewed.to verify that applicable procedures were revised as necessary to,reflect these changes.
During this review, it was observed that two outdated pa'ges were not removed from the Bases Section in the Control Room Technical Specifications although the current pages were also posted.-
The outdated TS pages were removed on the spot.
This appeared to be an isolated case.
The inspector reviewed the remainder of the Control Room TS and it was current.
In addition, several TS pages were not stamped
"Master Copy",
as required; and the prerequisites in surveillance test ST-M-4 were not consistent with the prerequisites on the procedures s data sheet, in that the surveillance procedure didn't include a prerequisite that was included in the procedures's data sheet.
The licensee stated this discrepancy would be corrected.
Licensee corrective actions will be reviewed during a subsequent NRC:RI inspection (220/80-05-07).
No items of noncompliance were noted.
Checklists and Related Forms Operations Department procedures, including routine surveillance tests, checklists and related forms in working files, were reviewed to see that current revisions and on-the-spot changes were posted.
One unresolved item and two items of noncompliance were identified and are detailed in Paragraphs 4. c.(5), 4. c.(1),
and 4. c.(4) above.
Chan es to Procedures as Detailed in the Safet Anal sis Re ort ursuant to j.
0.
a an b
The inspector verified, on a sampling basis, that changes made to facility procedures during the, past fifteen month period were in compliance with
CFR 50.59(a)
requirements and that records of these changes were maintained in compliance with 10 CFR 50.59(b).
For the procedures reviewed, the licensee had determined that 10 CFR 50.59 safety evaluation documentation was not required (no change in procedures as described in the FSAR).
The inspector had no questions in this area.
Plant Tour and Control Room Observations During the inspection, a tour of turbine building and reactor building, and daily tours of the control room were conducted.
The inspectors obser ved plant operations, housekeeping, radiation monitoring instrumentation, and control room operations for Technical Specifications and administrative requirement ~Findin s
Technical Specification 6.11, "Radiation Protection Program" requires that procedures
'for personnel radiation protection be prepared consi'stent with the requirements of 10 CFR Part 20 and be approved, maintained and adhered to for all operations involving personnel radiation exposure.
Radiation Protection Procedure RP-l, "Access and Radiological Controls," developed pursuant to the above, states in part in Section 4.3.3, "...
Radiation areas should be entered only when necessary'to perform a specific job.
When entered, time spent should be kept to a minimum..." also Section 4.4.4 states,
"A step off pad encountered at the entrance to an area within a restricted area indicates that, as a minimum, shoe covers are required for entry..."
Radiation Protection Procedure RP-2, "Radiation Work Permit Procedure",
also developed pursuant to the above states in part in Section 5.2 "... the lead man is responsible for familiarizing personnel with all the instructions on the permit, and insuring that these instructions are strictly followed..."
During an inspector tour of the Reactor Building, on May 22, 1980, the inspector observed two licensee employees enter a
roped off and posted area across
'a step off pad with street clothes and no shoecovers, sit in the area then exit the area across a step off pad without donning or removing any shoecovers from his street shoes.
Upon review of the area postings, the inspector determined that the area was posted as a radiation and contamination area.
Further inspector review determined that the individuals had signed in on RMP 89596,
" Paint Restraints".
Review of the RMP indicated shoecovers were to be worn as required".
Inspector review of the radiation/con-tamination survey (No. 45833)'ndicated radiation level~ to 50 mill'irem/hr and contamination levels to 1,640 dpm/100cm were present in the area.
The inspector discussed the above with licensee representatives and expressed concern regarding the individuals crossing contamination boundries without utilizing the step off pad to control the spread of radioactive contamination.
Additionally, the inspector expressed concern with the licensee regarding the extent of "familiarization" given by the lead man.
Consequently the inspector indicated to licensee representative the worker's failure to utilize shoecovers as indicated on the RMP and as required by procedure constitutes noncompliance with Technical Specifications (50-220/80-05-05).
THIS PAGE CONTAINING 10 CFR 2.790 INFORMATION, NOT FOR PUBLIC DISCLOSURE, IS INTENTIONALLY LEFT BLAN ~ ~
10.
Unresolved Items I
Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items or items of noncompliance.
Unresolved items identified during this inspection are discussed in Paragraphs 4.c.(5)
and (6).
ll.
Presentation of Preliminar Findin s I'icensee management (Reference Details, Paragraph 1) was informed of
'preliminary inspection findings detailed in paragraphs 2, 4.c. (1), (2),
(3), (4), (5), (6), 9.a.(1).and (2) on May 21 and 22, 1980.
A summary of inspection findings was provided to the senior licensee representative onsite and other licensee staff members at the conclusion of the inspection on May 23, 1980.
The licensee acknowledged'he inspector's findings.
On May 30, 1980, a subsequent telephone conversation was held between Mr. N.
Blumberg and Mr. T. Perkins to further discuss the inspection finding g$a $,
'Jb