IR 05000277/1979012
| ML19254E083 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 08/17/1979 |
| From: | Baunack W, Blumberg N, Kister H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19254E071 | List: |
| References | |
| 50-277-79-12, 50-278-79-14, NUDOCS 7910310057 | |
| Download: ML19254E083 (18) | |
Text
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSDECTION AND ENFORCEMENT
"
50-277/79-12 Report No.
50-278/79-14 bU-d//
Docket No.
50-278 DPR-44
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License No. DPR-56 Priority
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Category C
Licensee:
Philadelphia Electric Company 2301 Market Street
_
Philadelphia, Pa.
19101 Facility Name:
Peach Bottom Atomic Power Station, Units 2 and 3 Inspection at:
Delta, Pennsylvania Inspection conducted: May 21-24,1979 A
f /7
'J $
Inspectors:
,r 4L J. Blumberg, Reactor Inspector 4d tes igned b
&
[]
'
. H. Bauna'ck, Reactor Inspector
' date signed date si ned Approved by:
sD
7 7f
'H. B. Kister, Chief, Nuclear Support Section date signed No. 2, R0&NS Brt ch Insoection Summary:
Insoection on fiay 21-24, 1979 (Report No. 50-277/79-12 and 50-278/79-14)
Areas Inspected: Routine unannounced inspection by two regional based NRC inspectors of licensee action on previous inspection findings; administrative control of safety related calibrations; surveillance calibrations of safety related components and equipment required by Technical Specifications; calibrations required by Technical Specifications of components and equipment associated with safety related systems and/or functions; witnessing of calibrations; calibration and control of test equipment; administrative control of safety-related maintenance; review of safety related maintenance; technical qualifications; and a facility tour.
The inspection involved 64 inspector-hours onsite by two regional based NRC inspectors and 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> onsite by one NRC supervisor.
1235 031 Region I Form 12 (Rev. April 77)
79103100
Results: Of the ten areas inspected, no items of non-compliance were found in seven areas; one item of noncompliance was found in one area (infraction-Failure to perform Primary Containment Isolation Logic System Functional Test within required six month time interval-paragraph 4.c); one item of noncompliance was found in a second area (infraction-failure to adequately implement calibration program of instruments associated with safety related equipment -paragraph 5.c);
and one item of non-compliance was found in a third area (infraction - Inadequate control of Maintenance request fonns and Maintenance status - paragraph 10.c)
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P DETAILS 1.
Persons Contacted C. Andersen, Operations Supervisor L. Baker, Surveillance Test Coordinator J. Clupp, Engineer Electrical Production
- J. Davenport, Quality Assurance Engineer T. Donaghy, Shift Superintendent
- R. Fleischmann, Assistant Station Superintendent
- A. Fulvio, Instrument and Calibration Engineer R. Jianniney, Document Checker
- S. Roberts, Results Engineer J. Spencer, Maintenance Engineer S. Spitko, Assistant Maintenance Supervisor
- T. Ullrich, Station Superintendent K. Voigt, Instrument and Calibration Engineer, Susquehanna Test Branch A. Wargo, Shift Supervisor J. Webster, Control Operator
- J. Winzenried, Technical Engineer USNRC E. Greeruan, Resident Reactor Inspector
$9. Kister, Chief, Nuclear Support Section No. 2, R0&NS Eranch The inspector also interviewed other licensee employees, including members of ?.a engineering staff, I&C personnel, maintenance personnel, reactor operators, and general office personnel.
- denotes those present at the axit interview.
2.
Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (277/78-08-01 and 278/78-10-01): Periodic review requirements not specified for Annunciator Response Procedures (Alarm Cards).
The inspector verified that procedure A-36 has been revised to include periodic review requirement for Alarm Cards.
This item is closed.
1235 033
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(Closed) Unresolved Items (277/78-08-02 and 278/78-10-02): The procedure history file for the Reactor Building Cooling Water System (S.9.5) could not be located.
The inspector verified that Reactor Building Cooling Water procedure history file was subsequently located and is currently on file. This item is closed.
(Closed) Unresolved Item (277/78-07-01 and 278/73-08-01) - Incomplete implementation of procedures for calibrations of components associated with safety related systems required by ANSI N18 7 - 1972 and Appendix "A",
USNRC R.G.1.33, November 1972.
During this inspection, the inspector noted that this program has been inadequately implemented and was determined to be an item of noncompliance. This unresolved item is closed; see paragraphs 5.b and 5.c concerning further actions.
(Closed) Item of Noncompliance (277/78-20-01 and 278/78-25-01):
Completed surveillance procedures not in the master file; completc. pro-cedure not logged in the master test schedule as having been completed; completed surveillance tests not promptly reviewed; and tests listed in the Master Test Schedule as complete but not filed in the Master File. The inspector verified that surveillance procedures denoted in this item have been properly filed and logged and that the Station Master Files are kept locked as stated in the licensee's reply.
Additionally, the inspector sampled additional proceduras in the Master file and logged in the Master Test Schedules.
No additional problems were identified. This item is closed.
(Closed) Unresolved Item (277/78-11-01 and 278/78-15-01):
Improvement in Maintenance Request Form Documentation. The licensee documented corrective actions which would be taken in Plant Operations (PORC)
Review Committee Meeting Minutes 78-48. All actions committed to in PORC Minutes 78-48 were verified to have been implemented by the licensee.
These actions included a revision to Administrative Procedure A-26, Procedure for Corrective Maintenance, an independent Quality Assurance (QA) review of all completed Maintenance Request Forms, a revision to maintenance procedures, and the issuance of a policy statement by the station superintendent. This item is closed.
1235 034
3.
Administrative Control of Safety Related Calibrations The inspector reviewed the licensee's administrative procedures relating to the performance of calibrations of safety related components as a basis for reviewing test procedures and calibration data sheets.
The following administrative procedures were reviewed:
A-2, Procedure for Control of Procedures, Revision 14, March 26,1979.
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A-3, Procedures for Temporary Changes to Approved Procedures, Revision 5,
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January 18, 1979 A-43, Surveillance Testing System, Revision 11. Marct. 23, 1979.
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A-32-A, Procedure for the Review, Approval, and Implement tion of
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Te...porary or Pemanent Setpoint Changes, Revisian 2, Apri. 24,1979.
A-36, Periodic Review of Procedures, Revision 2, May 2, 1978.
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No items of noncompliance were identified.
4.
Surveillance Calibrations of Safety Related Components and Equipment Required by Technical Specifications a.
The inspector reviewed calibration procedures and associated data sheets on a sampling basis ta verify the following:
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Calibration frequeticy requirement; have been met.
Applicable system status during component calibration was M
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confomance with the Technical Specification limiting conditions of operation.
Procedure fomat provided detailed stepwise instructions.
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Procedure review and approval were as required by Technical
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Specifications.
Trip points of calibrated components were in conformance with
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Technical Specification requirements.
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Technical content of procedures was sufficient to result in satisfactory component calibration.
1235 035
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b.
The following completed calibration procedures were selected for the above review:
UNIT 2 RCIC Steam Line Low Pressure - ST 2.1.10 (Cal.) A-D, Calibration
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Check of P-2-13-87 A-D, Revision 3, June 20,1975.
Data reviewed for calibrations performed on January 3, 1979; March 5, 1979; and April 3, 1979.
RCIC Steam Line Low Pressure - ST 2.1.10 (Func.) A-D, Functional
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Check of PS-2-13-87 A-D, Revision 1, August 1,1974.
Data reviewed for functional check performed on February 2, 1979.
Containment system Subcooling - ST 1.6.1, RHR Logic A System
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Functional Test, Revision 1, June 28, 1978.
Data reviewed for functional tests performed on July 26, 1978 and October 15, 1978.
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Containment System Subcooling - ST 1.7.1 RHR Logic B System Functional Test, Revision 2, October 11, 1978, and Revision 0, March 27,1978.
Data reviewed for functional tests performed on June 2,1978 (R-0) and October 16,1978 (R-2).
Reactor Power - ST 3.3.3, APRM Flow Bias Signal Calibration,
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Revision 7.luly 8, 1974.
Data reviewed for calibration instruments FT-2-2-110 A-D performed on September 21, 1978.
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Drywell Ventilation - ST 4.8.1, Drywell Ventilation Radiation Monitor Calibration, Revision 5, June 13, 1978, Revision 4, March 30,1978, and Revision 3, November 17, 1975.
Data reviewed for calibration of radiation monitor instruments RIS-4130, RIS-4131, and RIS-4132 performed on January 31,1978 (R-3); May 3,1978 (R-4);
August 1,1978 (R-5); and November 15, 1978 (R-5).
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Reactor Power - ST 3.3.1, APRM Functional and Calibration Test (Scram and Rod B1Mk), Revision 13, May 2,1978.
Data reviewed for APRM Channels A-F functional tests performed on March 19, 1979; March 26,1979; April 2,1979; April 9,1979; Ap. I 17, 1979; and April 23, 1979.
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Turbine Condenser Low Vacuum - ST 2.1.01 A-D, Functional Test of PS-2-5-11 A-D, Revision 2.
Data reviewed for functional tests performed on January 2, 1979; January 17, 1979; February 5,1979; February 20,1979; March 5,1979; Parch 21,1979; April 2,1979; and April 17, 1979.
1235 036
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H?CI Steam Supply Low Pressure - ST 2.1.09 A-D (Funct.),
Functional Test of PS-2-23-68 A-D, Revision 1, August 6, 1974.
Data reviewed for functional tests performed on January 17, 1979; February 20, 1979; and April 20, 1979.
HPCI Steam Supply Low Pressure - ST 2.1.09 A-D (Cal.), Calibration
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Check of PS 2-23-68 A-D, Revision 3, August 22, 1975.
Data reviewed for calibration check performed on ihrch 20, 1979.
UNIT 3 Main Steam Isolation - ST 9.7, MSIV Partial Closure and RPS
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Input, Revision 7, October 16, 1978.
Data reviewed for functional tests performed on April 16,1979; April 23,1979; April 30,1979; and May 7, 1979.
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Turbine Control (EHC) - ST 9.14, Turbine Control Valve Fast Closure Scram Functional, Revision 12, December 31, 1978.
Data reviewed for functional tests perfomed on March 10, 1979 and April 21, 1979.
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Reactor Power - ST 3.3.2, Calibration of the Average Power Range Monitoring (APRM) System to Core Thennal Power, Revision 1, October 12, 1978.
Data reviewed for calibrations performed on April 16,1979; April 18,1979; April 19,1979; April 21,1979; April 23,1979; April 27,1979; April 28,1979; April 29,1979; April 30,1979; May 4,1979; May 7,1979; May 9,1979; and May 10, 1979.
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Containment Isolation - ST 1.3, PCIS Logic System Functional Test, P.evision 3, May 9,1979 and Revision 2, September 5,1975.
Data reviewed for functional tests perfonned on February 2,1978 (R-2) and August 11,1978 (R-3).
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Emergency Power - ST 12.4.13, ST 12.4.23, ST 12.4.33, and ST 12.4.43, 4KV Emergency Power System Voltage Relay Calibration, Revision 0, May 2, 1978.
Data reviewed for calibration perfomed by each procedure on October 11, 1978.
Turbine Control - ST 2.11.01 A-D, Calibration Check of PT/PI/PS
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2-S-11 A-D, Revision 3, September 15, 1978.
Data reviewed for calibration check performed :n October 8,1978.
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c.
As a
.. t.
f the above review the following item was identified.
..)
ST i.3 (Vnit 3) whi.
accomplishes the Primary Cnntainment
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1 solation Systems Logic System Functional test was last performed on August
'l, 1978.
The time interval for performing this sur-veillance is in excess ot' the six months plus 25% stated in Technical Specification Tables 4.2.A, 4.2.B, 4.2.C, and 4.2.D and Section 1.0.
This is considered to be an item of noncompliance at the infraction level (278/79-14-01).
(2)
During review of ST 2.1.01 the inspector noted that acceptance critaria is given for the Turbine Condenser Vacuum Gage at each increment of calibration, however, 'he gage readings are not recorded. The licensee representative concurred that vacuum gage data should be recorded and stated that the procedure would be changed.
This area will be reviewed during a subsequent in-spection.
5.
Calibrations Required by Technical Specifications of Components and Equipment Associated with Safety Related Systems and/or Functions The inspector reviewed, on a sampling basis, the program established a.
for calibration of components associated with safety related systems required by ANSI 18.7 - 1972 and Appendix "A", USNRC Regulatory Guide 1.33, November 1972.
These components are used to monitor system parameters to comply with safety limits, limiting conditions of operation and/or meet the surveillance requirements of the Technical Specifications.
b.
The following components were selected at random from Unit 2 and 3 surveillance tests and/or the Technical Specifications and checked ingainst the li_censee's procedures to determine completeness of the program. Additionally, calibration procedures which were identified in unresolved item 277/78-07-01 and 278/78-08-01 as needing to be accomplished were also reviewed to determine if these procedures were implemented.
Procedure Sample Selected for this Inspection fiPCI Flow - T 2.25.3.2 (Unit 2), Calibration of FT-2-23-82,
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Revision 0, September-28,1977.
Data. reviewed for calibration performed on September 29, 1978.
Reactor Vessel Temperature - ST 2.18.22 (Unit 3), Calibration
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of TR-3-2-3-d9, Revision 0, September 8,1977.
Data reviewed for Calibration performed on February 15, 1978.
1235 03B
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Containment Oxygen - ST 9.11 (Unit 3), Containment Oxygen Analyzer
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Calibration, Revision 4, November 30, 1977.
Data reviewed for calibration perfonned on February 9,1979.
RCIC Pump Flow - T/S 4.5.D.1 (d) requires surveillance of RCIC
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Pump Flow.
To date no procedure has been issued to calibrate instruments required for this surveillance.
ST 2.25.4.2 has been identified by the licensee to perform this calibration and according to a licensee representative is curently undergoing PORC review.
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Containment Air Dilution (CAD) - T/S 4.7. A 6.b requires surveillance of the CAD Liquid Nitrogen Tank Level.
To date no procedure has been written to calibrate instruments measuring this level.
Fire Protection System Pump - T/S 4.14.A.l.c requires surveillance
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of fire protection system pump flow and pressure.
To date no procedure has been written to calibrate instruments associated with this surveillance.
Fire Protection System Diesel Fuel - T/S 4.14. A.1.e (1) requires
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surveillance of level in fire pump diesel fuel storage tank.
To date no procedure has been written to calibrate the tank level instrument.
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Fire Protection C02 - T/S 4.14.B.l.a requires surveillance of CO2 storage tank pressure and level.
To date no procedure has been written to calibrate instruments associated with this surveillance.
Review of Calibrations Previously Identified in URI 277/78-07-01 and 278/78-08-01
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RHR Pressure and Flow - ST 2.25.1 (Unit 2), Calibration of DPT 2-10-91 A-D, PI 2-10-106 A-D, FT 2-10-111 A,B, PS-2-10-118, DPIS 2-10-121 A-D, and PS 2-10-122 A,B, Revision 0, October 17, 1977.
Data reviewed for calibration accomplished from July 5, 1978 to January 30, 1979.
HPCI Pressure - ST 2.25.3.1 (Unit 2), Calibration of PT 2-23-83,
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PT 2-23-39, PT 2-P.3-95, and PT 2-23-100.
Procedure was performed during last refueling outage.
Diesel Generator Instrumentation -
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ST 2.25.24 A-D, Calibration of Diesel Generator Wattmeters (E-1 through E-4), Revision 0, November 4, 1978.
1235 039
ST 2.25.23 A-D, Calibration of Diesel Generator Voltage
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Meters (E-1 through E-4), Revision 0, November 27, 1978.
ST ?.25.22 A-D3 Calibration of Diesel Generator Frequency
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Meters (B-1 through E-4), Revision 0. November 27, 1978.
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(Data reviewed fnr Diesel Generator Instruments calibrations perfomed on April 30,1979.)
Standby Liquid Control Instrumentation - ST 2.25.5 (Unit 2),
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Calibration of LT-2-11-45, LS 2-11-47, TS 2-11-50, PT 2-11-52, TS 2-11-59 A-D, and TS 2796 A,B, Revision 0, September 28, 1977.
Procedure verified by the inspector to be currently in progress.
High Pressure Service Water Flow - ST 2.25.6 (Unit 2), Calibration
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FT 2-10-97 A, B, PT 2330 A-D, and PS 2380 A, B Revision 0, September 28, 1977.
Data reviewed for calibration check performed on May 1, 1979.
Emergency Service Water Discharge Pressure - scheduled to be
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performed each operating cycle in accordance with ST 2.25.7.
To date, this procedure has not been perfomed.
Core Spray Pump Flow - scheduled to be perfomed each operating
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cycle in accordance with ST 2.25.2.
To date, this procedure has not been perfomed.
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Recircultion Pump Speed - Scheduled to be performed each operating cycle in accordance with ST 2.20.22.
To date, this procedure has not been performed.
Recirculation Loop A Flow - Scheduled to be performed each
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operating cycle in accordance with ST 3.3.3.
This procedure has been perfomed and is included within the scope of paragraph 4.
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Diesel Fuel Oil Storage Tank Level - Calibration procedure has not been written.
Licensee representative stated a modification to the tank must be done before calibration of tank level indicator can be accomplished.
c.
As a result of the above review the following items were identified:
(1)
Inspection report Nos. 50-277/77-04 and 50-278/77-02 identified to the licensee in January 1977 the need to establish a program for calibration of components associated with safety related systems.
Inspection report Nos. 50-277/78-07 and 50-278/78-08 detemined that the licensee had established a program for cali-bration of components associated with safety related systems; however, the report noted as unresolved (URI's 277/78-07-01 and 278/78-08-01) that of the sample of ten items inspected, procedures had been written but not performed for eight items and procedures had not been written for two items.
1235 040
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During this inspection, it was determined by the inspector, that although a program for calibration of safety related components does exist, it has not been adequately implemented.
It was further noted that more than two years had lapsed since the problem was first identified.
The following areas are examples of inadequate implementation:
Instruments associated with Emergency Service Water Discharge
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Pr essure (ST 2.25.7), Core Spray Pump Flow (ST 2.25.2), and Recirculation Pump Speed (ST 2.20.22) were identified in URI's 277/78-07-01 and 278/78-08-01, on March 31, 1978 that the procedures are required to be performed each. grating cycle.
To date these procedures have not been accomplished.
Instrumentation associated with Diesel Fuel Oil Storage Tank
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Level was identified in URI's 277/78-07-01 and 278/78-Ot.- 01 as needing a calibration procedure.
To date a procedure has not been written ano the licensee stated a modification is needed to the tank to install a dipstick.
A procedure for calibration of RCIC Pump Flow (ST 2.25.4.2)
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has been identified by the licensee but the procedure has not been issued.
Instrumentation associated with the CAD system Liquid Nitrogen,
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Fire Pump Flow and Pressure, Fire Pump Diesel Fuel Oil Level, and Fire Protection CO storage tank pressure and level had
not been identified by the licensee as instrumentation requiring calibration and had not been included in the calibration program.
The failure to adequately implement a calibration program for safety related instruments is contrary to the requirements of Technical Specification 6.8.1, ANSI N 18.7 paragraph 5.3.6 and Regulatory Guide 1.33, Appendix "A", paragraph H.l.
This is considered to be an item of noncompliance at the infraction level (277/79-12-01 and 278/79-14-02).
6.
Inspector Witnessing of Calibrations The inspector witnessed the performance of the llowing functional tests May 22, 1979:
HPCI Steam Supply Low Pressure - ST 2.6.09 A-D, Functional Test of
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PS-3-23-68 A-D, Revision 0, August 6, 1974.
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Reactor Protection System - ST 2.10.15, Functional Check of the
'RPS - B" Card File, Revision 2, June 19, 1978.
1235 041
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.
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Reactor Protection System - ST 2.10.17, Functional Check of the "RPS-D" Card File, Revision 3, June 19,1978.
Each functional check was performed and data recorded as required by the procedures. The procedures were adequately detailed to assure per-formance of a satisfactory functional test.
During performance of ST 2.10.15 and ST 2.10.17 several of the alarm setpoints were outside the limits specified by the procedure.
In each case the instrument setpoints were calibrated on the spot.
In no instance were Technical Specification setpoints exceeded.
In one instance an annunciator failed to alarm.
The technicians notified proper personnel of the problem and initiated steps to " troubleshoot" the problem as specified in the test procedure.
No items of noncompliance were identified.
7.
Calibration and Control of Test Eauipment The inspector reviewed the calibration and control of four pieces of test equipment used as standards in the calibrations of components identified in Paragraph 4.
Results of the review indicate measuring and test equipment are being maintained as required by Testing Section procedures.
Items verified included:
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List and description of test equipment;
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Establishment and adherence t.o a calibration schedule;
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idaintenance of calibration records identifying traceability to the National Bureau of Standards; Equipment usage history showing which calibrations were performed
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with each instrument; and,
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Storage and labeling of test equipment.
No items of noncompliance were identified.
8.
Technical Qualifications The inspector reviewed the qualification records of selected technicians who performed the surveillance calibrations identified in Paragraph 4, 5 and 6 to verify that the individual's experience level and training are in accordance with the guidelines of ANSI N18.1-1971, Selection and Training of Nuclear Power Plant Personnel.
No items of noncompliance were identified.
1235 042
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e
9.
Administrative Control of Safety-Related Maintenance The inspector reviewed the licensee's program for administrative control of safety-related maintenance activities, as described in the following administrative procedures.
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A-19, Administrative Procedure for Preparation and Distribution of Maintenance Procedures, Revision 12, April 24, 1979.
A-26, Procedure for Corrective Maintenance, Revision 18, January 5,1979.
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A-27, Procedure for Material Control System, Paragraph F, Material Issue, Revision 10, January 19, 1979.
A-30, Plant Housekeeping Controls, Revision 0, May 18,1978.
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This review was conducted as a familiarization with the licensee's pro-cedural requirements in this area and as an audit with respect to Technical Specification, Section 6, Administrative Controls, Regulatory Guide 1.33, Quality Assurance Program Requirements, and ANSI N18.7, Administrative Controls for Nuclear Power Plants.
Based on this review no itams of noncompliance were identified.
10.
Review of Safety-Related Maintenance Activities a.
The inspector reviewed safety-related maintenance conducted by the licensee on a sampling basis to verify the following.
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Limiting conditions for operation were met while equipment was out of service.
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Required administrative approvals were obtained prior to initiating the work.
An approved procedure was used where required.
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Provisions for fire protection, cleanliness, and housekeeping were included where applic:ble.
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Procedures used were adequate to satisfactorily perform the task.
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Required inspections were performed.
System / components were functionally tested and/or calibrated
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prior to return to service.
Applicable quality control records were available.
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1235 043
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The maintenance was performed by qualified maintenance personnel.
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A reportable occurrence report, if required, by Technical Specifications,
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was sutxnitted based on review of circumstances associated with the maintenance activity.
b.
The documentation associated with the following safety-related main-tenance activities was reviewed:
UNIT 2 Maintenance Request Form (MRF) #2-2-M-8-103 (October 14, 1978) -
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"A" Recirculation Pump Discharge Valve.
MRF #2-3-M-9-177 (February 9, 1979) - CRD Accumulator.
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MRF #2-10-M-8-34 (June 2,1978) - C RHR Pump Suction Relief.
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MRF #2-32-M-8-8 (April 20, 1978) - RHR Hx Cooling Water Outlet Valve.
MRF #2-60-M-8-88 (August 14, 1978) - TIP Indexer No. 3.
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MRF #2-60-M-9-22 (February 22, 1979) - TIP Machine No. 5.
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PlF #2-2-L-9-23 (March 21, !979)
"A" Recirc Pump Flow Control.
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MRF #2-2-L-9-36 (May 1, 1979) - 2A Recirc Pump M/A Station.
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MRF #2-52-L-8-180 (August 28, 1979) - Fuel Oil Storage Tank Level Indicator.
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MRF #2-10-M-8-50 (June 29, 1978) - Sway Strut above M015 Hanger Anchor Bolts are Pulling Loose from Wall.
MRF #2-7-M-8-53 (July 31, 1978) - Inspect Torus Interior as
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required.
Also inspect all Pump Suction Strainers: RHR, CS, HPCI, RCIC and Torus Water Clean-up.
MRF #2-7-L-8-84 (October 27, 1978) - 0xygen Analyzing System.
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MRF #2-2-M-8-94 (April 29, 1978) - Jet Pump Flow Transmitter Valve.
1235 044
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UNIT 3 MRF #3-3-M-8-2 (January 4, 1978) - CRD Accumulator.
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MRF #3-3-M-8-109 (May 18, 1978) - HCU Solenoid Valve 13-121.
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MRF #3-7-M-8-14 (Apr.
11, 1978) - Torus CAD Exhaust.
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MRF # 3-13-M 3-24 (December 7, W78) - PCIC Steam Supply.
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MRF #3-23-M-8-55 (August 9,1978) - HPSI Gland Seal Condenser.
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MRF #3-10-M-8-92 (September 5,1978)
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MRF #3-10-M-9-ll (February 8, 1979) - RHR Pump and Piping
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Insulation.
c.
The following findings resulted from the above review.
(~l). Several instances were identified in which the requirements of Administrative Procedure A-26, Procedure for Corrective Maintenance, were not fully adhered to.
Instances in which A-26 was not fully adhered to are identified as follows:
Sten 3.A of A-26 states in part, "... Shift supervision
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'
shi l indicate the Tech. Spec. status in the appropriate check off box in Section 2, and should indicate the Tech. Spec. status in the MRF Log Book."
Contrary to the above procedural requirement, 8 MRF's were identified in which section 2 of the MRF was identified as a Tech. Spec. item with no Tech. Spec. status indicated in the MRF Log Book.
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Section 3 of Administrative Procedure A-26 specifies the flow path for the original of a MRF from its initiation to final disposition including close out in the MRF Lcg Bock.
Contrary to the above specified flow path for a MRF original, the original for the following MRF's, which were identified as open in the MRF Log Book on May 22. 1979, could not be located.
1235 045
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MRF 2-10-M-8-51 (June 29,1978) - Hydraulic Snubber, Four of Eight Anchor Bolts Loose.
MRF 2-10-M-8-50 (June 29,1978) - Sway Strut Above No.15 Hanger Anchor Bolts are Pulling loose from Wall.
MRF 2-7-M-8-53 (July 31, 1978) - Inspect Torus Interior as required.
Also inspect all Pump Suction Strainers (RHR, CS, HPCI, RCIC and Torus Water Clean-up).
MRF 2-52-L-8-181 (August 30,1978) - E-2 D/G, Determine Reason for Slow Starting Time.
MRF 2-7-L-8-84 (October 27, 1978) - 0xygen Analyzing System.
MRF 2-2-M-8-94 (April 29,1978) - Jet Pump Flow Transmitter Valve.
The inability to locate the original of a MRF makes it difficult to definitely determine if the maintenance had in fact been completed. MRF 2-10-M-C-51, Hydraulic Snubber was initiall.y thought by a licensee representative to have been completed.
However, physical inspection, by the inspector verified that in fact the maintenance had not been completed.
After the inspector questinned the acceptability of operating with four of eight snubber anchor bolts loose, the liccnsee provided the inspector with an engineering evaluation, performed on July 11, 1978, which stated the hydraulic snubber was capable of performing its intended function with the four anchor bolts loose.
The maintenance on the snubber anchor bolts was completed on May 22, 1919.
Followup on the other open MRF's identified no safety concerns.
Step 3.H and I of Administrative Procedure A-26 specify that
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Shift supervision approval in Section 4 of the MRF, and control operator's equipment turnover in Section 5 of the MRF, be completed before actual work on equipment is undertaken.
Contrary to this procedural requirement, seven MRF's (3-7-L-9-31, 3-7-L-9-33, 2-38-L-7-85, 2-6-M-9-131, 2-1-M-9-88, 2-1-M-9-58, and 2-1-M-9-51)_ awaiting the completion of Section 7, operation verification, had their work performed without shift supervision approval in Section 4, and three of these MRF's (3-7-L-9-31, 1235 046
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3-7-L-9-33, and 2-38-L-7-85) awaiting aperation verification, had their work performed without Section 5 equipment turnover completed.
Step 3.J.6, of Administrative Procedure A-26 states in part,
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"Upon completion of the work, the lead craftsman performing the work shall inspect the work area.
His inspection shalI include, but not be limited to, cleanliness and housekeeping.
It is the responsibility of the lead craftsman to ensure the cleanup of the work area and ensure prcper housekeeping practices involving the tools, equipment and materials used in performance of the work are followed."
Contrary o this administrative requirement the inspectors, during the followup to a reportable occurrence, noted an area in the base of the plant stack where previous maintenance had obviously been performed in which stack flow transmitter water tight covers had been left adrift, a junction box cover left off, and a general lack of cleanliness and housekeeping was evident.
Failure to adhere to the requirements of Procedure A-26 is contrary to Technical Specification 6.8.1, which requires that written procedures and administrative policies be implemented.
This is considered to be an Item of Noncompliance (277/79-12-02 and 278/79-14-03) at the infraction level.
(2). During the review of Q list items in completed MRF's it was noted that not all departments were in possession of the latest revisions to Quality Assurance Diagrams (QADs).
These QADs are used in conjunction witt. the Q list to identify safety related system boundaries.
QADs were noted to exit as follows:
QAD I&C DEPT MAINT. DEPT MASTER 851 Nuclear Boiler Rev. 7 Rev. 9 Rev. 10 859 RCIC Pev. 7 Rev. 7 Rev.
861 RHR Rev. 7 None Rev.
The licensee stated this matter would be reviewed and corrective action taken.
This item is unresolved pending the completion of the licensee's action.(277/79-12-03 and 278/79-14-04).
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11.
Facility Tours On several occasions during the inspection, tours of the facility were conducted. Areas toured included the turbine building, portions of the Unit 2 reactor building, Unit 2 RHR Pump Rooms, and the Plant Stack.
During the tours, the inspectors discussed plant operations and observed housekeeping radiation control measures, monitoring instrumentation, and controls for Technical Specification compliance.
In addition, the inspectors observed control room operations for control room manning, and facility operation in accordance with administative and Technical Specification requirements.
One item of noncompliance was noted in the area of the plant stack.
This is discussed further in paragraph 10.c.
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12.
Unresolved Items Unresolved Items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations.
An Unresolved Item identified during this inspection is discussed in Paragraph 10.c (2).
13.
Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1)
at the conclusion of the inspection on May 24, 1979.
The inspector summarized the scope and findings of the inspection.
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