IR 05000309/1979014
| ML19257A072 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 10/10/1979 |
| From: | Blumberg N, Kister H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19257A064 | List: |
| References | |
| 50-309-79-14, NUDOCS 8001020042 | |
| Download: ML19257A072 (14) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 50-309/79-14 Docket No. 50-309 License No. DPR-36 Priority Category C
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Licensee:
Maine Yankee Atomic Power Company 20 Turnpike Road Westborough, Massachusetts 01581 Facility Name:
Maine Yankee Atomic Power Station Inspection at:
Wiscasset, Maine Inspection conducted: September 18-21, 1979 Inspectors:
7-
/0 ['7[7 f N. Blumberg, Reactor Inspector date signed date signed date signed Approved by:
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H. Kister, Chief, Nuclear Suppgrt Section date ' signed No. 2, RO&NS Branch Inspection Summary:
Inspection on September 18-21, 1979 (Report No. 50-309/79-14)
Areas Inspected:
Routine, unannounced inspection by a regional based inspector of licensee action on previous inspection findings; administrative controls for facility procedures; conformance to Technical Specifications; temporary and permanent changes in conformance to Technical S dures; changes in procedures to 10 CFR 50.59(a)pecifications and licensee proce-and (b) requirements; checklists and related forms for currency to latest changes; and, control room observations.
The inspection involved 28 inspector-hours onsite by one regional based NRC inspector.
Results: Of the seven areas inspected, no items of noncompliance were identified in five areas, and two items of noncompliance were identified in two areas (Deficiency - failure to accomplish periodic procedure review and failure to perform adequate periodic procedure review, see Paragraph 4.b(1); and, Deficiency -
failure to properly distribute and post procedure changes, see Paragraph 4.b(2)).
1664 350 Reg'.on I Form 12 (Rev. April 77)
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DETAILS 1.
Persons Contacted P. Anderson, Administrative Supervisor
- R. Arsenault, Plant Day Shift Supervisor R. Forrest, Fire Protection Coodinator
- C. Frizzle, Assistant Plant Manager
- J. Hebert, Plant Engineering Quality Assurance Group Head W. Paine, Operations Department Superintendent R. Prouty, Maintenance Department Supervisor R. Radach, Instrument and Contro'. Department Supervisor
- S. Sadowsky, Yankee Atomic Operations Quality Assurance (0nsite)
D. Sturniolo, Chemistry and Health Physics Supervisor
- E. Wood, Plant Manager USNRC
- W. Lazarus, Reactor Inspector The inspector also interviewed other licensee employees during the inspection, including reactor operators, technical support, administrative, and clerical personnel.
- denotes those present at the exit interview.
2.
Licensee Action on Previous Inspection Findinas (Closed) Infraction (309/79-02-01): Seven examples of failure to adhere to facility administrative controls:
a.
Surveillance record sheets not being prepared for the daily reactor coolant system leakage evaluations.
Daily reactor coolant system leakage evaluation is incorporated into Surveillance Procedure 3.1.19.
The inspector verified by review of recent log sheets that daily reactor system leakage evaluation is being accomplished.
b.
Master Surveillance Schedule maintained by PEQAG has not been kept current, and daily reactor coolant system leakage evaluation is not included on the Master Surveillance Schedule. Administrative Procedure 0-10-2, " Surveillance Tests and Records," Revision 5, has been issued to delete the requirement for PEQAG to maintain a master surveillance schedule. The inspector observed that all departments performing surveillances were scheduling their own surveillance.
The adequacy of these schedules will be the subject of future NRC:RI inspections.
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c.
Documentation associated with ECCS routine testing and CIS trip valve testing were compieted in such a manner that verification of equipment acceptability could not be determined.
The inspector verified that surveillance procedures 3.1.2, "ECCS Routine Testing," Revision 11, July 6, 1979, and 3.1.20, "CIS Trip Valve Testing," Revision 6, July 6,1979, now include specific acceptance criteria within the procedures.
d.
Acceptance criteria had not been established on data sheets for Cardox tank level and pressure and the boric acid tank concentration.
The inspector verified that the acceptance for Cardox tank level and pressure has been incorporated in " Control Room Log I," Revision 4, and that acceptance criteria for boric acid storage tank concentration is included in Surveillance Procedure 3.7.2, " Sampling Procedures for Chemistry Technical Specifications Surveillance Tests," Revision No.
5, August 10, 1979.
e.
The accuracy of test instruments used for Fire Pump Capacity Tesc was not verified.
The inspector verified that the instrument in question, a pitot gage, previously supplied by an outside organization which performed the surveillance, is now being maintained and calibrated by the plant.
f.
Diesel fire pump fuel quarterly surveillance for viscosity, water content and sediment was performed using an unapproved procedure.
The inspector verified that procedure No. 7.209.118, " Water and Sediment in Fuel Oils," Revision 0, February 1, 1979, and procedure No. 7.209.117,
"Kenematic Viscosity of Fuel Oil," Revision 0, February 1, 1979, have been issued to conduct the above tests and are properly approved in accordance with the plant administrative procedures.
g.
Diesel fire pump surveillance failed to document auto-start of the diesel fire pump engine as required by Technical Specification 4.12.B.5.3.b.
The inspector verified that Surveillance Test 3.1.9, " Fire Pump Testing,"
Revision 9, July 6, 1979, incorporates a test procedure for diesel fire' pump auto start.
(Closed) Unresolved Item (309/79-06-05):
Licensee identified item of noncompliance in which all four steam generator pressure reactor trip bistable setpoints were set 70 psig below the Technical Specification requirement of 485 p;ig due to a combination of personnel error and procedural inadequacy. The inspector verified that Surveillance Procedure 3-6.2.1.2,
" Protective and Safeguard Channel Calibration - System Generator Pressure,"
Revision 4, July 6,1979, has been revised to more clearly specify the pressure transmitter presssure/ output voltage in the data table.
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(0 pen) Inspector Follow Item (309/77-17-27):
Yellow tags issued for lifting leads necessitated by permanent changes and modifications, some dating back to 1972-73.
A review of the yellow tag log indicates many tags have been clearea but a few tags, some still dating back to 1972 and 1973, still remain in effect. A licensee representative stated that appropriate depart-ments have been notified to accomplish the needed modifications so that the yellow tags can be cleared.
This item remains open and will be reviewed on subsequent NRC:RI inspections.
3.
Facility Administrative Control Procedures a.
The inspector performed a review, on a sampling basis, of the below listed administrative procedures for conformance with Technical Speci-fications, Section 6, ANSI N18.7, and Regulatory Guide 1.33:
0-01-1, Design Change and Alteration, Revision 5, June 7,1978.
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0-05-1, Document Control, Revision 4, July 17,1978.
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0-06-1, Procedure Preparation, Classification and Format, Revision 3, July 28, 1979.
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0-06-2, Procedure Review, Approval and Distribution, Revision 8, December 21, 1978.
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0-10-3,MaintenanceofOperationsDepartmentLogs,Revisioni4, January 5,1978.
No items of noncompliance were identified.
4.
Review of Facility Procedures a.
The inspector reviewed facility procedures and temporary changes, on a sampling basis, to verify the following:
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Procedures, plus any changes, were reviewed and approved in accordance with the requirements of the Technical Specifications and the licensee's administrative controls.
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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."
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Checklists, where applicable, were compatible with step-wise instructions in the procedures.
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Appropriate Technical Specification limitations had been included
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in the procedures.
Temporary changes were made in conformance with Technical Speci-
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fication requirements and the licensees administrative controls.
The following procedures were reviewed:
(1) General Operating Procedures
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1-1, Plant Heatup, Revision 10, July 6,1979.
1-2, Reactor Startup, Revision 8, July 6, 1979.
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1-7, Plant Cooldown, Revision 9, June 22, 1979.
1-6, Reactor Shutdown, Revision 3, October 25, 1978.
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(2) System Operating Procedures 1-13-3, Residual Heat Removal (RHR) Slip Stream Purification
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via the Letdown Purification System Startup and Shutdown, Revision 2, August 9, 1978.
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1-17-1, Spent Fuel Pool Cooling and Purification, Revision 5, March 8,1979.
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1-10-1, Reactor Coolant Loop Fill and Vent, Revision 5, October 3, 1978.
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1-10-7, Reactor Coolant Pump Operation, Revision 9, June 22, 1979.
1-104-2, Feedwater System, Revision 3, October 17, 1978.
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1-22-3, Station Service Power Operation and Breaker Operation,
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Revision 1, October 25, 1978.
1-202-1, Communication System, Revision 1, January 14, 1976.
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(3)
Emergency Procedures 2-2, Loss of Condenser Vacuum, Revision 3, September 8,
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1977.
- Reviewed for technical adequacy.
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2-40, High Wind, Hurricane or Tornado, Revision 1, March 30,
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1978.
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2-34, Loss of RHR, Revision 3, March 1, 1978.
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2-12, Loss of Reactor Coolant, Revision 5, May 7, 1979.
2-13, Major Loss of Reactor Coolant, Revision 6, May 7,
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(4) Alarm Response Procedures 2-100-1, Response to PANALARMS, Revision 4, June 22,1979.
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RH-1-1(.U), No. 1, SI Tank Pressure Hi.
RH-4-3, Safety Injection Tup Channel Loss of Control Power.
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RH-1-6, Fuel Pool Temperature Hi.
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RH-2-6, Fuel Pool Level Lo.
L-I-7, No. 3, RCP Seal Water Return Flow Law.
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L-I-4, RCP Standby Lube Oil Pump Auto Start.
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L-I-2, Reactor Coolant Flow Channel A.
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F-I-2, No. 1, SG EFC Trip Channel A.
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F-5-6, SG Feed Pump P-2A Lube Oil.
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RS-2-3, Backup Relay SS Trains, X-14.
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RS-2-1, Breake Failure (11J).
(5) Maintenance Procedures MYM 5-12, Disassembly of Reactor Coolant Pump, Revision 2,
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August 22, 1979.
MYM 5-2, Installation Procedure for Packing Reactor Coolant
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Loop Main Isolation Valves Numbers RC-M-11,12, 21, 22, 31, 32, Revision 3, October 31, 1978.
- Reviewed for technical adequacy.
- Reviewed in emergency procedure 2636 (see Paragraphs 4.b(1) and 4.b(7)).
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MYM 5-129, New Fuel Handling and Storage, Revision 6, July
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6, 1979.
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MYM 5-13, Removal of the Reactor Coolant Pump Seal Cartridge, Revision 5, June 11, 1979.
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MYM 5-16, Installation of a Reactor Coolant Pump Seal Cartridge, Revision 3, August 29, 1979.
b.
Findings (1) Emergency procedure 2-36, " Safeguards Annunciators," contains response procedures for sixty-eight control room safeguards annunciators. These same alarm response procedures are also included in the alarm response book, procedure 2-100-1, " Response to PANALARMS." Emergency procedure 2-36 was revised in December, 1977, and many alarm procedures within 2-36 were revised.
At that time, the equivalent alarms in procedure 2-100-1 were not revised.
The Alarm Response Book (2-100-1) was reviewed in 1979 and Revision 4 was issued on June 22, 1979. This revision did not update the following alarm response procedures to conform to existing proce-dures in 2-36:
SS-1-8(U)
SS4-11 SS-5-ll SS-1-8(L)
SS-5-3(U)
G-4-6(U)
SS-2-8(U)
SS-5-3(L)
G-4-6(L)
SS-2-8(L)
SS-5-9 RH-1-1(U)
RH-1-1(L)
RH-2-1(L)
RH-2-3(L)
RH-1-2(U)
RH-2-1(L)
RH-2-5 RH-1-2(L)
RH-2-2(U)
RH-2-7 RH-1-3(U)
RH-2-2(L)
RH-3-1 RH-1-3(L)
RH-2-3(U)
RH-4-1 The review accomplished for Revision 4 to alarm response procedure 2-100-1 was apparently incomplete in that it failed to identify the existence of more recent procedures for these alarms which were already incorporated in emergency procedure 2-36.
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- Reviewed for technical adequacy.
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Per procedure 0-06-2, licensee defined Class A and B procedures require periodic review every two years, and Class C procedures require review every three years.
It was observed that the following Class A procedures had passed their scheduled review date and no action had been taken to perform a periodic review:
Administrative Procedure No.
Scheduled Review Date 0-00-3 July 28, 1979 0-00-9 July 8,1979 0-04-1 July 28,1979 0-06-1 July 28,1979 0-07-2 August 8,1979 0-08-1 April 5, 1979 0-08-3 August 8, 1979 Class B procedure 1-19-4, " Test Tank Recycle," plus associated checklist, are currently being reviewed; however, the scheduled procedure review due date was January 5,1979.
Class C procedures 1-100-1, " Vacuum Primary System," and 1-101-3, " Condensate Sample System," are currently undergoing review and revision; however, their respective scheduled review dates were August 5, 1978 and December 11, 1978.
Licensee representatives stated the above procedure reviews were overlooked due to administrative oversight and that all procedures listed above will be reviewed and revised, if required, by November 1, 1979.
The failure to identify needed procedure revisions as a result of procedure review and to initiate procedure reviews by established procedure review dates is contrary to Technical Specification 9.8.2 and administrative procedure 0-06-2; and is considered an item of noncompliance at the deficiency level (309/79-14-01).
(2)
During review of alarm response procedures, Alarm Response Book, Control Copy No.1, which contained procedure 2-100-1, Response to PANALARMS, Revision 3, March 18,1976, was observed to be located in the control room.
This book was divided into two volumes, one of which was initially observed by the inspector to 1664 357
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9 be stored in the bookcase normally used by the Control Room operators.
Concurrently in the Control Room was another Alarm Response Book, which contained procedure 2-100-1, Revision 4, June 22,1979.
A comparison between the two books indicated that there were sianificant differences between Revision 3 and Revision 4.
A licensee representative stated that only one copy of the Alarm Response Book should have been in the Control doom, and that the previous revision should have been removed when the new revision was placed in the Control Room; but was not removed due to personnel error.
When notified of this problem, the licensee removed Revision 3 from the Control Room.
Procedure Change Reports (PCR's) when written are initially posted to the procedures to which they apply. The PCR is then forwarded to the Plant Operations Review Committee (PORC) for review and to the Plant Manager for approval.
Subsequent to this review and approval, an approved copy of the PCR is to be distri-buted to control copies of the applicable procedures.
Final approved copies of PCR's were not posted to the following procedures located in the control room although sufficient time appeared to have passed to make distribution:
PCR Date Affected Procedure 79-66 July 16,1979 15-2 79-67 July 16,1979 15-3 79-64 July 9, 1979 15-4 79-63 July 9, 1979 15-6 79-69 July 31, 1979 2-12 79-78 August 24, 1979 2-6 79-70 July 31,1979 2-13 79-81 August 30, 1979 l-12-1 PCR 79-29, dated May 29, 1979, was posted to Control Room Copy of procedure 1-9-1, and PCR 79-57, dated June 5, 1979, was posted to Control Room Copy of procedure 1-5, although the PCR's are shown in the PCR log to have been cancelled on June ll,1979.
PCR 79-56 was posted to Control Room Copy of procedure 1-3, although 1664 358
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the PCR had been superceded by Revision 10 which was posted to procedure 1-3.
Failure to properly distribute and post procedure revisions and procedure change reports is contrary to Technical Specification 5.8.1, and administrative procedure 0-06-2; and is considered an item of noncompliance, deficiency level (309/79-14-02).
(3)
Procedure 2-100-1, Response to PANALARMS, was anotated as a Class C procedure and consequently subject to review every three years.
Procedure 0-06-1, Procedure Preparation, Classification and Format," Paragraph 5.1.2.1 states, in part, " Class A Procedures...
Actions to be taken to correct specific and foreseen potential malfunctions of systems or components involving nuclear safety, including responses to alarms..."
Paragraph 5.1.2.3 which defines Class C procedures does not address alarm response procedures.
The inspector informed the licensee representative that many of the alarms in 2-100-1 involved nuclear safety and could not be considered Class C for purposes of frequency of periodic review.
The licensee representative stated that safety related alarms were also included in emergency procedure 2-36 which is a Class A procedures and subject to periodic review every two years (see related deficiency - Paragraph 4.b(1)), and that it was not the intent of the licensee to review all alarm response procedures every two years.
In addition, the licensee representative stated that procedure 0-06-1 would be revised to clarify classification categories for alann response procedures.
This item is unresolved pending licensee action and subsequent NRC:RI review (309/79-14-03).
(4)
Regulatory Guide 1.33, November,1972, Appendix A, requires that emergency procedures be established for:
(a)
Loss of Coolant Flow (b) Mispositioned Control Rod or Rods (and rod drops)
(c)
Inability to Drive Control Rods The inspector noted that there appeared to be no licensee proce-dures concerning the above emergency conditions except for the dropped control rod.
The licensee representative stated that a special test concerning loss of coolant flow had been prepared and approved in August of 1979; and, that this special test was in the process of being converted to emergency procedure 2-9 1664 359
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which will be issued by November 1,1979.
The inspector observed the existence of the special test for loss of coolant flow and that emergency procedure 2-9 was in preparation.
The licensee representative stated that emergency procedure 2-21,
" Control Rod Drop," also included procedures for mispositioned control rods and inability to drive rods.
Based on review of procedure 2-21, the inspector does not concur with the licensees contention.
Procedure 2-21 covers only the dropped rod problem and alignment of rods associated with this problem and does not cover mispositioned control rods (except the dropped rod) and inability to drive rods.
This item is unresolved pending licensee action and subsequent NRC:RI review (309/79-14-04).
(5) Technical Specification 5.8.2 and Regulatory Guide 1.33, November, 1972, Appendix A, require that procedures for communications systems be reviewed by the PORC.
Licensee procedure 1-202-1,
" Plant Communications Systems," is not PORC reviewed. This appears to be an isolated case due to administrative oversight.
The licensee representative stated that procedure 1-202-1 would be given a PORC review. This item is unresolved pending licensee action and subsequent NRC:RI review (309/79-14-05).
(6) A review of maintenance procedures identified that the following procedures have been established as contingency procedures for repair of a reactor coolant pump:
MYM 5-12, Disassembly of RCP MYM 5-39, (Jncoupling and Removal of RCP Motor MYM 5-40, Removal of RCP Rotor from Volute MYM 5-41, Disassembly of RCP Rotor Assembly All of the above procedures are disassembly procedures.
There are no procedures established for reassembly of these components.
A licensee representative concurred that reassembly procedures should be established and stated that reassembly procedures will be prepared by June 1, 1980. This item is unresolved pending licensee action and subsequent NRC:RI review (309/79-14-06).
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(7) During review of procedures, the inspector noted several minor discrepancies that needed correction, but are not considered items of noncompliance. These were discussed with the licensee and it was agreed that corrective action would be taken.
Corrective actions will be reviewed during a subsequent NRC:RI review.
Alarm response procedure for R-1-6 was omitted from Control
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Room Copy of alarm response procedure 2-100-1, Revision 4.
PCR 75-83, dated May 9, 1975, is shown in the PCR Log as
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still in effcct.
This PCR is for surveillance procedure 3.1.16 which is no longer in effect.
Alarm response procedures for alarms SS-5-6 and SS-5-7 are
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included in emergency procedure 2-36.
These alarms are not included in alarm response procedure 2-100-1 and are no longer on the alarm panel.
Pen and ink annotations were observed posted to Control Room
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Copies of emergency procedure 2-2, Paragraph 3.7 and 2-13, Paragraph 4.7.
These annotations appeared not to be changes but could possibly be construed as such.
The licensee agreed to remove them.
(8) Technical Specification 5.8.2 requires that the Plant Manager approve procedures and procedure changes.
The inspector observed that twelve PCR's had been approved by the Assistant Plant Manager although the Plant Manager had been present at the four PORC meetings at which these PCR's had been reviewed.
The inspector stated to the licensee that the Assistant Plant Manager approval of PCR's when the Plant Manager was onsite did not meet the intent of TS 5.8.2.
The licensee acknowledged the inspectors concerns and stated they understood that the Assistant Plant Manager had procedure and procedure change approval authority only in the absence of the Plant Manager.
This item will be subject of further review on subsequent NRC:RI inspections.
5.
Technical Content of Facility Procedures The inspector conducted a review of facility procedures, on a sampling basis, using FSAR system descriptions, piping and instrument diagrams and Technical Specifications, 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 4 (Review of Facility Procedures) of this report.
No items of noncompliance were identified.
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6.
Procedure Changes Resulting From License Amendments The inspector reviewed license amendments (Amendments 36 through 44), which included Technical Specification changes, issued during the past twelve month period and verified that applicable procedures were revised as necessary to reflect these changes.
No items of noncompliance were identified.
7.
Checklists and Related Forms Operations Department procedures, including checklists and related forms in working files, were reviewed to see that current revisions and on-the-spot changes were posted. Two items of noncompliance with several examples were identified and are detailed in Paragraphs 4.b(1) and 4.b(2).
In addition, several discrepancies, which were not considered items of noncompliance, were identified and are detailed in Paragraph 4.b(7).
8.
Changes to Procedures as Detailed in the Safety Analysis Report (Pursuant to 10 CFR 50.59(a and b
The inspector verified, on a sampling basis, that changes made to facility procedures during the past twelve month period were in compliance with 10 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.
9.
Control Room Observations The inspector observed Control Room operations on both day and evening shifts for Control Room manning, shift turnover, and facility operation in accordance with Administrative and Technical Specification requirements.
The plant was in cold shutdown during the interval of this inspection.
The Control Room console contains a screen, slide projector, and slide carrousel containing slides of emergency procedure inmediate and supplemental actions.
If an emergency occurs, operators can quickly select the proper emergency procedure from a rotary switch and project it to the screen. A comparison of selected procedures in the slice carrousel revealed that slides for emergency procedures 2-1, 2-6, 2-10, 2-12, and 2-21 had not been updated to reflect revisions to these procedures; hence, an incorrect procedure could be used in responding to an emergency.
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This is considered to be a licensee identified item of noncompliance, in that this discrepancy had been previously identified in a recent licensee audit report, " Nuclear Services Division Report MY 9-1."
The licensee removed the slide carrousel from the Control Room during the course of this inspection; and will evaluate whether or not it is feasible to maintain the slides up to date.
Resolution to this item will be the subject of review during a subsequent NRC:RI inspection.
10. 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. Several unresolved items were identified and are detailed in Paragraphs 4.b(3), 4.b(4), 4.b(5), 4.b(6), and 9.
11.
Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1) at the conclusion of the inspectioi; on September 21, 1979, and sunmarized the purpose, scope, and findings of the inspection.
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