IR 05000277/1980006

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IE Insp Repts 50-277/80-06 & 50-278/80-06 on 800317-21. Noncompliance Noted:Util Failed to Document Two Surveillance Tests & Corrective Maint & Failed to Record Tech Specs Data
ML19318C605
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 04/18/1980
From: Blummberg N, Greenman E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19318C574 List:
References
50-277-80-06, 50-277-80-6, 50-278-80-06, 50-278-80-6, NUDOCS 8007020070
Download: ML19318C605 (12)


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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

REGION I

50-277/80-96 Report Nos.

50-278/80-00 50-277 Docket Nos.

50-278 DPR-44 License Nos.

OPR-56 Priority Category C

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Licensee:

Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 i

Facility Name:

Peach Bottom Atomic Power' Station, Units 2 and 3 Inspection At:

Delta, Pennsylvania Inspection Cond cted:_

March 17-21, 1980 Inspectors:

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N.Blumberg,ReactorInspctor date

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date date Approved by:

O'C ! -8 Z, b, b 4 [/d'/Ed E. G. Greenman, Chief, Nuclear Support date Section No. 2, RO&NS Branch Inspection Summary:

Inspection on March 17-21, 1980 (Combined Report Nos. 50-277/80-06; 50-278/80-06)

Areas Inspected:

Routine, unannounced inspection by a regionally based inspector of administrative controls for surveillance procedures; surveillance testing; in-spector witnessing of surveillance testing; technician qualification; and facility tour observations.

The inspection involved 35 inspector-hours onsite by one re-gionally based NRC inspector.

Results: Of the five areas inspected, no items of noncompliance were found in four areas; one item of noncompliance was found in one area (Infraction - Failure to properly document two surveillance tests and corrective maintenance; and failure to record Technical Specification required data - see paragraphs 4.c.(1)

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and 4.c.(2))(Units 2 and 3).

Region I Form 12 (Rev. April 1977)

8007020010

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DETAILS 1.

Persons Contacted R. Betz, Electrical Supervisor R. Fleischmann, Assistant Station Superintendent A. Fulvio, Instrument and Control Engineer C. Lawletta, Training Coorcinator

  • K. Mandl, Quality Assurance Auditor
  • C. Mengers, Quality Assurance Site Supervisor
  • S. Roberts, Results Engineer
  • S. Spitko, Quality Assurance Assistant Administrative Engineer
  • T. Ullrich, Station Superintendent A. Wasong, Test Engineer J. Winzenried, Technical Engineer J. Yacyshyn, Surveillance Test Coordinator

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USNRC

  • C. Cowgill, Resident Reactor Inspector The inspector also interviewed other licensee employees including members of the technical and engineering staff, clerical personnel and maintenance and test technicians.

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denotes those present at the exit interview.

2.

Licensee Action on Previous Inspection Findings (Closed) Inspector Follow Item (50-277/79-12-04; 50-278/79-14-05):

Procedure ST 2.11.01 data sheet did not record Turbine Condenser Vacuum Gauge readings although acceptability of these readings are determined by the data sheet. The inspector verified that ST 2.11.01 series procedure data sheets have been revised to record Turbine Condenser Vacuum Gauge readings.

(Closed) Infraction (50-277/79-12-01; 50-278/79-14-02):

Calibration program for safety-related instruments not adequately implemented.

The inspector verified that procedures have been written and implemented for calibration of instruments associated with the following surveillance tests:

Emergency Service Water Discharge Pressure

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Core Spray Pump Flow

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Recirculation Pump Speed

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Diesel Fuel Oil Storage Tank

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RCIC Pump Flow

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CAV System Liquid Nitrogen Level Gauges and Alarms

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Fire Pump Flow and Pressure

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Fire Pump Diesel Fuel Oil Level

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Fire Protection CO Storage Tank Pressure and Level

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The calibration check of the diesel fuel oil tank proved to be unsatis-factory and adjustments cannot be made.

An engineering request has been submitted to install a different level indicating system for the diesel fuel oil tank. As an interim measure, an " error" curve has been developed and is being used to correct current readings.

This item is unresolved pending installation of a new calibrated level indicating system and subsequent NRC:RI review. (50-277/80-06-01; 50-278/80-06-01)

(Closed) Infraction (50-277/79-14-01): ST 1.3, Primary Containment Isolation Systems Logic System Functional Test for Unit 3 was not performed within six months plus 25% frequency interval.

The inspector verified that this test is now being performed within the correct intervals.

(Closed) Unresolved Items (50-277/78-32-03): ST 9.1-2, The Surveillance Log, ST 3.4.1, LPRM Gain Calibration, omits documenting the computer printouts from which data is extracted.

The inspector verified that ST 9.1-2, ST 9.1-3 (for Unit 3) and ST 3.4.1 have been revised to record computer printouts from which data is extracted.

(Closed) Unresolved Items (50-277/78-15-11; 50-278/78-19-11): Procedure MA-6, Procedure for Calibration and Control of Maintenance Division Measuring and Test Equipment, did not provide for traceability of test

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equipment usage or for an evaluation of the acceptability of tests which were accomplished by use of test equipment which was later found to be out of calibration as required by PBAPS, QAP, Volume III, Section 12.2.

The inspector verified that MA-6, Revision 2, March 19, 1979 now requires identifying the work for which test equipment is used and for evaluating the need for retest should a test instrument be subsequently found out of calibration.

3.

Administrative Controls for Surveillance Procedures The inspector performed an audit of the' licensee's administrative controls by conducting a sampling review of the listed administrative procedures with respect to the requirements of the Technical Specifications, Section 6, " Administrative Controls for Nuclear Power Plants," and Regulatory Guide 1.33, " Quality Assurance Program Requirements."

A-2, Procedure for Control of Procedures, Revision 15, February 11,

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1980 A-3, Procedure for Temporary Changes to Approved Procedures, Revision

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6, October 10, 1979 A-32A, Procedure for the Review, Approval and Implementation of

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Temporary or Permanent Setpoint Changes, Revision 2, April 24, 1979 A-43, Surveillance Testing System, Revision 13, July 24, 1979

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A-47, Procedure for the Generation of Surveillance Tests, Revision

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1, January 16, 1980

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A-80, Inservice Inspection, Revision 6, October 2, 1978

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A-81, Procedure for the Generation of Visual Inservice Inspection

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Surveillance Tests, Revision 1, September 27, 1978

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A-82, Inservice Inspection Surveillance Testing System (ST-ISI),

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Revision 3, September 19, 1978 No items of noncompliance were identified.

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Surveillance Testing a.

The inspector reviewed surveillance tests on a sampling basis to

veriff the following:

Tests required by Technical Specifications are covered by

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properly approved procedures;

Test format and technical content are adequate and provide

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satisfactory testing of related systems or components; Test frequency is in conformance with Technical Specification

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requirements; and, Test results of selected tests are in conformance with Technical

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Specifications and procedural requirements and have been reviewed

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by someone other than the tester or individual directing the

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test.

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The following surveillance tests for Units 2 and 3 were reviewed to verify the items identified above:

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ST 1.3, PCIS Log ~.: System Functional Test, Revision 5, August

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31, 1979. Data reviewed for tests performed May 21, 1979; and January 19, 1980 for Unit 2; and, June 30, 1979; October 5, 1979; and December 10, 1979 for Unit 3.

ST 1.8, Automatic Depressurization System (ADS) "A" Logic

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Systems Functional, Revision 8, August 23, 1979.

Data reviewed for tests performed-on November 28, 1979; and January 29, 1980 for Unit 2; and, August 14, 1979; September 7,1979; and February

21, 1980 for Unit 3.

ST 1.12, Steam Jet Air Ejector Off-Gas Line Isolation Logic

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System Functional Test, Revision 3, February 13, 1976. Data reviewed for tests performed July 25, 1979; and January 17, 1980 for Unit 2; and, July 23, 1979; and January 17, 1980 for

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Unit 3.

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M 4.65, Installation of Reactor Vessel Head, Revision 2, October

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17, 1979.

Procedure reviewed for installation accomplished October 28, 1979 for Unit 3.

ST 6.6, Core Spray "A" Pump, Valve, Flow, Cooler, Revision 12,

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February 26, 1980; Revision ll, January 14, 1980; and Revision 10, August 14, 1979.

Data reviewed for tests performed on December 16, 1979; January 8, 1980; February 17, 1980; and March 5, 1980 for Unit 2; and November 2, 1979; December 11, 1979; January 7, 1980; and February 16, 1980 for Unit 3.

ST 6.11, RCIC Pump, Valve, Flow, Cooler, Revision 13, February

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26, 1980; Revision 12, January 3, 1980; and Revision 11, August 16, 1979.

Data reviewed for tests performed January 29, 1980; January 30, 1980; February 11, 1980; and March 3, 1980 for Unit 2; and, December 15, 1979; January 7, 380; February 6, 1980; February 11, 1980 for Unit 3.

ST 6.16, Motor Driven Fire Pump Operability Test, Revision 2,

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March 16, 1979. Data reviewed for tests performed November 21

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1979; December 21, 1979; January 15, 1980; and February 15, 1980 for Units 2 and 3.

ST 6.17, Diesel Driven Fire Pump Operability Test, Revision 2,

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April 18, 1979.

Data reviewed for tests performed December 4, 1979; January 1, 1980; February 2, 1980; and March 7, 1980 for Units 2 and 3.

ST 6.16.1, Motor Driven Fire Pump Flow Rate Test, Revision 1,

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August 16, 1979. Data reviewed for test performed on January 26, 1980 for Units 2 and 3.

ST 7.2.3A, Conductivity and Chloride Ion Content in Primary

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Coolant During Normal Operation, Revision 2, February 26, 1980; and Revision 1, October 20, 1976.

Data reviewed for daily chemistry tests performed February 18, 1980 to March 16, 1980 for Units 2 and 3.

ST 7.2.38, Reactor Startup Chemistry (Steaming Rates Less Than

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100,000 lbs./hr), Revision 1, November 21, 1975. Data reviewed for daily chemistry tests performed March 11 and 12, 1980 for Unit 2; and March 11-17, 1980 for Unit 3.

ST 8.2, Station Battery Weekly Check, Revision 4, October 12,

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1977. Data reviewed for tests performed January 29, 1980; February 6, 1980; February 15, 1980; February 19, 1980; February 27, 1980; March 3, 1980; and March 10, 1980 for Units 2 and *

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ST 8.3, Station Battery Quarterly Check, Revision 4, November

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17, 1978. Data reviewed for tests performed for Unit 2 125 Volt Batteries, February 19, 1980, and February 27, 1980; Unit 2 250 Volt Battery, January 26,1980; Unit 2 24 Volt Batteries, July 12, 1979; October 11, 1979; and January 16, 1980; Unit 3 125 Volt Batteries, March 29, 1979; June 25, 1979; March 10, 1980; Unit 3 25 Volt Battery, January 29, 1980; and Unit 3 24 Volt Batteries, January 9, 1980 and January 16, 1980.

j ST 8.4, 125/250 Battery Discharge Test, Revision 6, August 21,

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1979. Data reviewed for test performed September 22, 1979 ("A"

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and "C" Batteries) and September 21, 1979 ("B" and "D" Batteries)

for Unit 3.

Batteries for September 27 and 28, 1978 (Procedure l

ST 8.4 not used).

ST 9.1-2, The Surveillance Log (Unit 2), Revision 12, May 23,

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1979; and ST 9.1-2, The Surveillance Log (Unit 3), Revision 17, l

November 1, 1979.

Daily Surveillance Logics from January to i

March 1980 reviewed to verify performance of daily security

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check of the Emergency Shutdown Panel and determination of river water level each shift for Units 2 and 3.

ST 9.6, Drywell-Torus Vacuum Breakers, Revision 3, June 22,

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1978. Data reviewed for tests performed Noven.ber 12, 1979; December 30, 1979; January 14, 1980; and February 23, 1980 for Unit 2; and, November 13, 1979; December 11, 1979; January 14, 1980; and, February 23, 1980 for Unit 3.

ST 9.8, Control Room Emergency Ventilation and Radiation Monitor

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Functional Tests. Data reviewed for tests performed February 10, 1980 for Units 2 and 3.

ST 10.7, Scram Insertion Times, Rod Coupling Integrity, and

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RPIS for Fill In and Fill Out Tests, Revision 3, July 21, 1975.

Data reviewed for tests performed October 6, 1977; and October 7, 1978 for Unit 2; and May 15, 1978 and October 3, 1979 for Unit 3.

ST 13.12, Emergency Shutdown Control Panel (Switch Operability),

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Revision 3, July 18, 1979.

Data reviewed for tests performed October 18, 1978 for Unit 2; and November 2, 1979 for Unit 3.

ST 13.22, Control Rod Drive 30using Support Inspection, Revision

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0, August 15, 1977; and M 3.7, Control Rod Drive Housing Support Inspection, Revision 2, December 15, 1978. Procedures reviewed for inspections performed Octobtr 6, 1978 for Unit 2; and April 27, 1978 and October 2, 1979 for Unit 3.

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ST 13.32, Safety Relief Valve Replacement, Revision 4, January

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3, 1980.

Data reviewed for tests performed for Unit 3, December 10, 1979 (relief valve 71L) and November 2, 1979 (all relief valves); and for Unit 2 January 8, 1980 (relief valves 71A and 71K).

M 1.1, Reactor Vessel Main Steam Safety Valve Replacement,

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Revision 1, December 12, 1978.

Data. reviewed for Unit 2 safety valve 2-1-70A replaced September 15, 1978.

M 1.6, Relief Valve Replacement, Revision 4, July 24, 1979.

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Data reviewed for Unit 2 relief valves 2-1-71 A-L replaced September - October 1978.

ST 16.2.1, Fire System Weekly rheck, Revision 2, November 16,

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1978. Data reviewed for CARDCA System level and pressure checks performed on January 30, 1580; February 9, 1980; February 5, 1980; February 15, 1980- February 22, 1980; February 27, 1980;

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and March 14, 1980 for Units 2 and 3.

ST 16.4, Cable Spreadin0 Room Cardox Simulated Actuation and

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Air Flow Test, Revision 0, August 6, 1979.

Data reviewed for l

test performed August 21, 1979 for Units 2 and 3.

ST 6.17.1, Diesel Driven Fire Pump, Revision 1, August 16,

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1979. Data reviewed for tests performed January 26 and 28, 1980 for Units 2 and 3.

Inspection of Torus at Peach Bottom Nuclear Generating Station

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(no station procedure).

Inspection reports reviewed for Unit 2 torus inspection performed October 3-5, 1978; ~ and Unit 2 torus inspection performed April 13-14, 1978, and October 10-12, 1979.

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Findings (1) _During the 1978 Unit 2 refueling outage, inspection and main-tenance of the Unit 2 125 volt station batteries was accomplished and documented by use af MRFs and station procedure M 57.1, 125 VDC Equipment Mair.emance.

Attached to the MRFs, for each set-of storage batteries is a Storage Battery Test Data Sheet for each 125 volt battery with final data indicating that discharge capacity of each battery was acceptable and stating that the requirements of ST 8.4 (125/250 Battery Discharge Test) were met. However, copies of ST 8.4, which provides instructions for test performance and documentation of required data and test calculations, were not attached to the MRFs.

The licensee was unable to locate completed copies of ST 8.4; and, although final capacity recorded for each battery was acceptable, there was no documentation of satisfactory performance of ST 8.4.

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In addition, no data was available documenting the recording of the specific gravity and voltages of each battery cell subsequent to the discharge test as required by TS 4.9.A.2.c and ST 8.4.

(2) On August 21, 1979, ST 16.4, Cable Spreading Room Cardox Simulated

~ Actuation and Air Flow Test, was performed which documented that three of eight Cable Spreading Room vent dampers did not close as required on Carbon Dioxide Simulated Actuation.

Attached to this procedure was a copy of a shift supervisor's log, dated September 8, 1979, stating that the vent dampers were repaired and satisfactorily retested; however, there was

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no documentation that the retest was accomplished per ST 16.4.

A licensee quality assurance auditor stated that this discrepancy was observed during a recent fire protection audit and that the corrective action was to attach a copy of the shift supervisor's log to ST 16.4.

The inspector reviewed Audit Report 79-27L, dated January 9, 1980, and noted that although ST 16.4 was reviewed no deficiencies concerning performance of ST 16.4 were

documented in this audit report.

The inspector informed the licensee that documentation of the retest per the shift supervisor's log did not provide adequate documentation for the retest.

In addition, a Maintenance Request Form (MRF) is required for corrective maintenance performed as a result of an unsatisfactory surveillance; however, no MRFs could not be located by the licensee, documenting repairs to the vent dampers.

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i The failure to use approved procedures to document the performance

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of Technical Specification surveillance tests; the failure to log battery parameters required by Technical Specification

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surveillance; and the failure.to document and control the i

performance of corrective maintenance as a result of an unsatis-factory surveillance test, identified in this paragraph and paragraph 4.c.(1) above, is contrary to Technical Specifications 6.8.1 and 4.9.A.2.c, and Station Procedure A-43 and A-47 and collectively constitute an infraction level item of noncompli-ance. (50-277/80-06-02; 50-278/80-06-02)

(3) ST 8.3, Station Battery Quarterly Check, implements the require-ments of TS 4.9. A.2.b for a measurement of individual battery cell voltages and specific gravities.

This procedure is used for the station 24 volt, 125 volt and 250 volt batteries.

During review of this test, the inspector noted the following areas needed corrrection or clarification:

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Although the procedure tests the 24, 125 and 250 volt

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batteries, the cell chart data sheet was designed speci-fically for the 125 volt batteries.

This caused technicians to make pen and ink changes to the data sheets in order to

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accommodate the additional cells of the 250 volt battery.

The inspector observed during the inspection that a procedure change had been prepared to ST 8.3 specifying three separate data sheets, one for each type of battery; however, this change had not yet been formally reviewed by the PORC or approved prior to completion of this inspection.

Step 10 of the procedure specifies the possibility of

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water addition to the battery but does not state when such water addition may be required.

Step 11 states, " Bring any 125V battery cell that is 2.15

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volts to the attention of the Electrical Supervisor for corrective maintenance." Review of data sheets indicated numerous instances in which cells were 2.15 volts or less but greater than the 1.81 minimum voltage specified on the data sheet; and in most cases, no corrective action appeared to have been taken.

Discussions with a licensee representa-tive indicates that this step is intended only as a flag to the electrical supervisor to keep closer watch on these cells and that corrective actions are not necessarily taken as the cells are within specification.

After discussions with battery and electrical technicians

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the inspector determined that the most common corrective action for low cell voltages or specific gravities is to add water and/or place an equaling charge on the battery.

The equaling charge is on a timer which times out after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

However, no retest (until the next quarterly test is performed) is made to individual cells that the corrective action was effective.

The licensee stated that each of the above areas would be evaluated and procedure changes made as required.

The licensee also pointed out that the batteries are overdesigned and that a small number of cells which are low in voltage or specific gravity should not effect battery capacity significantly, hence for a small number of cells out of specification, followup to Corrective Actions may not be required. The inspector acknowledged the licensee's comments and stated that procedures should be clarified as to when followup to corrective actions should be accomplished.

-This item is unresolved pending licensee action and subsequent NRC:RI review. (50-277/80-06-03; 50-278/ 80-06-03)

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(4) TS 4.6.3 states, "When the reactor vessel bolting studs are tensioned and reactor is in a cold condition, the reactor vessel temperature immediately below the head flange shall be permanently recorded." The inspector observed that procedure M 4.6.5, " Installation of Reactor Vessel Head", did not require recording of the reactor vessel temperature but did specify a minimum reactor vessel temperature be verified. However, the inspector did verify that for the dates of the last stud bolt tensioning, the temperature was recorded on a control room recorder chart and that the temperature was above the minimum established in procedure M 4.6.5. The inspector informed the licensee that as a technical specification surveillance, the recording of the reactor vessel temperature should be procedurally documented. The licensee acknowledged the inspector's comment and stated that procedure M 4.6.5 or another appropriate procedure would be revised to record the reactor vessel temperature under the head. This item is unresolved pending licensee action and subsequent NRC:RI review. (50-277/80-06-04; 50-278/80-06-04).

(5) The inspector observed that ST 6.11, RCIC Pump Valve, Flow, Cooler (test), Revision B, Step 28, specified a 600 gpm minimum flow for the RCIC pump.

This conflicted with Step 38, Pump and Turbine Data Sheet, which required a 625 gpm minimum flow.

The licensee stated the 625 gpm was the correct minimum flow.

The inspector verified prior to completion of the inspection that an approved change to ST 6.11 correcting Step 28 had been issued.

(6) Technical Specification 4.7.4 requires that a visual inspection of the suppression chamber interior be made at each. major refueling outage.

The inspector reviewed past inspection reports and verified that this inspection is being accomplished for both units. Documentation of the inspection is per an inspection report letter to the licensee by the contractor performing the inspection.

There is apparently no station approved procedure for this surveillance. The absence of a procedure appears to be an isolated instance and an oversight by the licensee. The licensee stated that an approved surveillance test would be prepared for the suppression chamber inspection. This item is unresolved pending licensee action and subsequent NRC:RI review. (50-277/80-06-05; 50-278/80-06-05).

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5.

Inspector's Witnessing of Surveillance Testing a.

The inspector witnessed the performance of surveillance testing of selected components to verify the following:

Surveillance test 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.

The procedure was adequately detailed to assure performance of

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a satisfactory surveillance.

Surveillance test was performed in accordance with procedural

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requirements, b.

On March 19, 1980, the inspector witnessed the performance of Surveil-lance Test (ST) 6.12, LPCI System Valves Swing Bus A, which tests the automatic transfer of LPCI valve control power to an alternate power source.

The test was performed as required by the procedure; and the procedure was adequately detailed to assure performance of a satisfactory surveillance, when procedural requirements were followed.

No items of noncompliance were identified.

6.

Technician Qualification The inspector re0iewed the qualification records of three technicians having responsibility for surveillance testing of safety-related components and equipment to verify that the individuals' experience level and training were in accordance with the guidelines of ANSI N18.1-1971, Selection and

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Training of Nuclear Power Plant Personnel.

No items of noncompliance were identified.

7.

Facility Tour During the inspection, tours of the Unit 2 and 3 reactor building, control room, emergency cooling towers, protected area perimeter, and protected area portal radiation areas were conducted.

The inspector observed plant operations, housekeeping, radiation monitoring, and control room operations for Technical Specification and administrative requirements.

No items of noncompliance 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 noncompli-ance. Unresolved items identified during this inspection are discussed in paragraphs 2, 4.c.(3), 4.c.(4) and 4.c.(6). The licensee stated that resolution would be provided by September 30, 1980 for the above items.

For the replacement of the diesel fuel storage level instruments, September 30, 1980 is a target recognizing the lead times required for engineering changes, procurement, and installation may cause revision of this date.

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Preliminary Inspection Findings The inspector met with licensee representatives (denoted in paragraph 1)

at various times during the inspection to discuss preliminary inspection findings; and at the conclusion of the inspection on March 21, 1980, at which time, the purpose, scope and findings of the inspection were sum-marized. A subsequent telephone discussion concerning inspection findings was held between Mr. S. Spitko and Mr. N. Blumberg on March 27, 1980.

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