IR 05000317/1990002

Insp Repts 50-317/90-02 & 50-318/90-02 on 900101-0210.No Violations Noted.Major Areas Inspected:Outage Activities, Events Occurring During Insp Period,Radiological Controls & Maint Activities on Emergency Diesel Generator

ML20012B432
Person / Time
Site:	Calvert Cliffs
Issue date:	02/27/1990
From:	Cowgill C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20012B427	List: IR 05000317/1990002 ML20012B426
References
50-317-90-02, 50-317-90-2, 50-318-90-02, 50-318-90-2, NUDOCS 9003140390
Download: ML20012B432 (25)

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g-U.S. NUCLEAR REGULATORY COMMISSION

REGION I

50-317/90-02 Report Nos.:

50-318/90-02 DPR-53 License Nos. :- DPR-69 Licensee:-

Baltimore Gas' and Electric Company Post Office Box 1475'

Baltimore, Maryland -21203-

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Facility:-

Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Inspsetion at: Lusby, Maryland Inspection conducted:-

January 1, 1990 -~ February 10, 1990 Ihspectors:

James E. Beall, Senior' Resident Inspector

' Andra 'A. Asars,. Resident Inspector, Haddam Neck

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Donald L. Caphton, Sr. Technical Reviewer, DRS Alan E. Finkel, Sr. Reactor Engineer, DRS Tae K. Kim, Resident Inspector Larry E. Nicholson, Resident Inspector, Surry-H.~ Kirke Lathrop, Reactor' Engineer,.DRP

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William Oliveira, Reactor Engineer, DRS Stephen M. Pindale, Resident Inspector, Salem Approved by:

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Curtis' J. Co i 1,zChief Date

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Reactor Proje Section No. 1A Division of Reactor Projects-Inspection Summary:

Areas-Inspected:

This was a routine safety inspection by resident and special-ist inspectors.

Areas reviewed included outage activities; events occurring

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during-the inspection period; radiological controls; maintenance activities on '

No. 12-Emergency. Diesel Generator;. outage surveillance activities; modifica-tions to' the Safety Injection-Tank (SIT) level and pressure indication system; electrical cable separation deficiency corrective actions; Plant Operations and

- Safety Review Committee meetings; written reports submitted to the NRC;' correc-tive actions on~ previous inspection findings; and actions taken to resolve'

items required to be corrected before the restart of Unit 1.

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Inspection Summary (Continued)

Results:

No Violations were identified.

One Unresolved Item was identified

with respect to certain radiological events (Sections 2.3.1 and 2.3.2).

Good

- worker performance was noted during observations of maintenance activities (Section 4.1) on the No.12 Emergency Diesel Generator (EDG) although the root cause of the December 15, 1989 EDG trip was still not fully understood.

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neering activities were reviewed with respect to a SIT level and pressure sys-

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tem modification with no inadequacies identified.

Engineering support to cor-recting cable separation problems was reviewed and no deficiencies were iden-tified, although the licensee's program was still in an early phase.

Generally good performance was observed for the newly created POSRC Procedures Subcom-mittee (Section 7.1). Certain observations of potential weakness were identi-fied to:the licensee for review.

Substantial inspection effort was given to reviewing items identified by the NRC as requiring resolution prior to Unit I restart (Section 9).

In all but one case, the actions taken by the licensee were adequate to resolve the iden-tified concern. The exception was the item involving incorporation of surveil-lance certifications into the mode change checklist of the startup procedure (Section 9.10).

The inspector reviewed the licensee's actions, identified a.

deficiency and stopped the review. This item will require reinspection follow-f ing additional corrective actions by the licensee.

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L TABLE OF CONTENTS PAGE 1.

Summa ry of Facil i ty Activi ti es ( 71707)*..............................

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Plant Operations (71707, 71710, 93702)...............................

2.1 Operational Safety Verification.................................

I 2.2 Engi neered Sa f ety Features System Wa1 kdown......................

2.3 Followup of Events Occurring During the Inspection Period.......

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Radi ol og i cal Con t rol s ( 71707)........................................

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MaintenanceandSurveillance(61726,62703,71707)...................

4.1 Maintenance Observation.........................................

4.2 Surveillance Observation........................................

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Security (71707)...................................................

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Engineering and Technical Support (37700, 37828, 71707)..............

6.1 Safety Injection Tank (SIT) Level and Pressure System Design Modification..................................................

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6.2 Electrical-Cable Separation Deficienci es........................

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Safety Assessment and Quality Verification (40500, 71707, 90712, i

92700).............................................................

.I 7.1 Plant Operations and Safety Review Committee....................

7.2 Review of Written Reports.......................................

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Followup of Previous Inspection Findings (61726, 92702)..............

l 8.1 Eme rg e n cy D i e s e 1 ~ Gen e ra to r Fa 11 u re s............................

8.2 Intent Changes to Procedures....................................

8.3 Inappropriate Use of General Supervisor-Nuclear Operations Standing Instructions.........................................

8.4 Failure to Perform Safety Tag Audits............................

8.5 Inadequate Handling of Safety Tag Discrepancies.................

8.6 Root Cause and Problem Identi fication Systems...................

8.7 Lack of Independent Design Review...............................

8.8 Failure to Recognize that the Halon System was Inoperable and Failure to-Take Corrective Action.............................

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Table of Contents (Continued):

PAGE 9.. Followup of Restart Issues (42700, 92702)............................

9.1 Upgrade of CCI-101, Implementing Procedure Development and Control.......................................................

12-9.2-Lack of Procedures for Quality Control Inspection Activities....

9.3 Communication of Managemer,t Goals and Expectations in Adherence to Procedures, Work Control and Priorities....................

9.4 Review of Open Quality. Assurance Findings for Restart Applicability.................................................

9.5 Review of POSRC Open Items for Restart Applicability.............

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,9.6 Verification of Technical Specification Surveillance-Requirements..................................................

9.7 Revision of A0P-1A..............................................

9.8 Specification of Boration Flow Path Valve Position..............

9.9 Determine and Correct the Root Causes of Procedural Noncompliances................................................

9.10 Incorporation of Surveillance Certifications into Mode Change Checklist.....................................................

9.11 Use of General Supervisor-Nuclear Operations Standing Instructions.................................................. 20

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9.12 Control of System Status

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9.13 Intent Changes to Procedures....................................

9.14 Review and Demonstration of Operating-Procedures............... 23 9.15 Lack of Control of Measuring and Test Equipment (M&TE).......... 25 10. Exit Meeting (30703)..................................................

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• Each applicable report section lists the NRC Inspection Manual procedure or temporary instruction that was used as inspection guidance.

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DETAILS

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Summary of Facility Activities

. Unit I remained in cold shutdown for the duration of the inspection period for maintenance activities and resolution of management and safety issues.

Unit =2. remained defueled for the extended Cycle 8 refueling outage with-

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the fuel in the spent fuel pool.

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Plant Operations

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2.1 Operational Safety Verification

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The inspectors ~ observed plant operation and verified that the plant was operated safely and in accordance with licensee procedures and regulatory requirements.

Regular tours were conducted of the foi -

lowing plant areas:

-- control room

-- security access point

-- primary auxiliary building

- protected area-fence

-- radiological control point

-- intake structure

-- electrical switchgear rooms

-- diesel generator rooms

-- auxiliary feedwater pump rooms -- turbine building

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Control room instruments and' plant computer indications were observed for correlation-between channels and for conformance with technical specification (TS) requirements.

Operability of engineered safety

feature:;, other safety related systems and onsite and offsite power sources was verified.

The inspectors observed-various alarm con-

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ditions and confirmed that operator response was in accordance with.

plant operating procedures. Routine operativas - surveillance-testing was also -observed.

Compliance with TS and implementation of appropriate action statements for equipment out of service was in-spected.

Plant radiation monitoring system indications and plant stack traces were reviewed for unexpected changes. Logs and records were reviewed to determine if entries were accurate and identified equipment status or deficiencies.

These records included operating logs, turnover sheets, system safety tags, and the jumper and lifted

' lead book.

Plant housekeeping controls were monitored, including control and storage of flammable material and other potential safety hazards.

The inspector also examined the condition of various fire-

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protection, meteorological, and seismic monitoring systems.

Control room and shift manning were compared to regulatory requirements and portions of shift turnovers were observed. The inspectors found that control room access was properly controlled and a professional atmosphere was maintained.

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In addition to normal utility yorking hours, the review of plant operations was routinely conducted during portions backshifts (evening shifts) and deep backshifts (weekend 'and midnight shifts).-

Extended: coverage was provided for 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> during backshif ts and '35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br /> during deep backshifts.

Operators were alert and displayed no

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signs of-inattention to duty or fatigue.

2.2 Engineered Safety Features System Walkdown In addition to routine observations made during regular plant tours, the -inspectors conducted walkdowns of the accessible portions of-selected safety related systems. The inspectors verified operability of the Emergency Diesel Generators through reviews of valve lineups, i

control room system prints, equipment conditions, instrument cali-

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brations, surveillance test frequencies and results, and control room

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indications, n

2.3 Followup of Events Occurring During Inspection Period Du. ring the inspection period, the inspectors provided onsite coverage and follow-up of unplanned events.. Plant parameters, performance of safety systems, and licensee actions were reviewed.

The-inspectors confirmed that the required notifications were made to NRC.

During event follow-up, the inspector reviewed the corresponding CCI-118N-(Calvert Cliffs Instruction, " Nuclear Operations Section Initiated Reporting Requirements") documentation, including the event details, root cause analysis, and corrective actions taken to prevent recur-rence. The following events were reviewed.

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2.3.1 Improper Radiation Area Entries L

During this report period, two violations of high radiation

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area entry requirements were identified by IPensee radi-ation safety technicians.

On January 17, two contractor

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employees entered a high radiation area without a radiation

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monitoring device which continuously indicated the dose rate.in the area.

The requirement to use a monitoring device was. specified on the Special Work Permit (SWP) and is also required by plant technical specification 6.12.1.a.

On February 6, a similar incident occurred when a plant operator entered a posted high radiation area in Unit I containment without the required exposure rate meter.

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both -cases, the area was posted as a high radiation area due to hot spots within the area and not based on general area dose rates.

None of the personnel involved received any detectable radiation exposure (as indicated on the self-reading dosimeters)

as.a result of the events.

Actions necessary to prevent recurrence were under review by the licensee at the close of the inspection period.

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2.3.2 Auxiliary Building Contamination On February 1, areas of the - auxiliary building became-contaminated during maintenance work on the chemical and volume control filter.

There were no - personnel internal contamination problems incurred as a result of this event.

The areas were subsequently decontaminated and tht work activity was stopped until a root' cause analysis htd been

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performed and corrective actions to prevent recurrence had been. implemented.

.The licensee actions regarding these three events (Sections 2.3.1 and 2.3.2) will be reviewed in a future report. This item is Unresolved pending review of the licensee's cor-

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rective actions (50-317/89-02-01; 50-318/89-02-01),

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Radiological Controis-During routine' tours of the accessible plant areas, the -inspectors ob-served -the implementation -of selected portions of the licensee's Radio-logical' Controls Program.

The utilization and compliance with special work permits (SWPs)^ were reviewed to ensure detailed descriptions of radiological conditions were provided and that personnel adhered to SWP requirements, The inspectors observed controls of access to various radiologically controlled areas and use of personnel monitors and frisking methods upon. exit.from these areas.

Posting and control of radiation-areas, contaminated areas and hot spots,- and labelling and control of containers holding radioactive materials were verified to be in accordance with licensee procedures.

During this inspection period, radiological controls for the following activities were observed.

' Unit 2 fuel inspection,

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L Auxiliary Building decontamination.

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U Health Physics technician control and monitoring of these activities were l

determined to be adequate.

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Maintenance and Surveillance i

4.1 Maintenance Observation o

The inspectors observed various maintenance and problem investigation E

activities for compliance with procedures, TS, and applicable codes and standards.

The inspector also verified the appropriate quality assurance department (QA)

involvement, safety tags, equipment alignment and use of jumpers, radiological and fire prevention con-trols, personnel qualifications, post-maintenance testing, and re-portability.

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The inspector observed maintenance on the ~ No. 12 Emergency Diesel-Generator (EDG) being performed under MD 209-207-672A per. procedure-STP M 20-0 (Revision 15, approved October 10,1989). The licensee's inspection found' that the EDG blower gear's backlash measurements exceeded the maximum tolerance of 0.008 inches by 0.001 inch, The o

blower housing required realignment to bring the blower gears within the backlash tolerance.

The inspector observed the realignment of the blower gears and the installation of a new alignment dowel.

This-K realignment. and doweling work was observed to be done under a separate work order (M0 209-214-799A) initiated to cover this added scope of work. The inspector discussed and reviewed with the main-tenance mechanics other corrective / preventive maintenance identified during the EDG inspection.

For example, a cracked weld on a cooler bracket-and lack of full length thread engagement (short screws) for attachment bolting of the EDG blower housing to the EDG engine block

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was identified for repair.

The inspection visually examined the bolting for the blower housing to EDG engine block on the No.11 and No. 21. EDGs and confirmed that a similar bolting problem did not exist.

.The inspector inspected several EDG cylinder relief valve port flanges for cleanliness, observed installation of several cylinder relief valves, reviewed relief valve set point data, ~and verified torque wrench calibration and settings.

The inspector observed QC personnel to be present while work.was progressing and that QC hold points specified on STPM 20-0 were being checked. The inspector also observed. that the general supervisor for maintenance observed the maintenance work on EDG on a sampling basis.

j Non-Conformance Report No. 8983 was issued by the licensee to address

the. December 15, 1989,. trip of the EDG.

The root cause analysis

.l reported in NRC Inspection Report' 50-317/89-27; 50-318/89-28 was i

still in progress at the close of the inspection period. A residual j

ameunt of water was.found in lube oil samples ~ taken -during test runs

completed (about 0.1% of water and sediment was found;.the licensee's

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specification required less than 0.05%).

The licensee hypothesized

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that the' root cause of the trip was water in the lube oil f rom a leaking service water supply valve and condensation inside the pipes.

The oil was scheduled for replacement as part of the ongoing mainten-ance. A report of the root cause analysis findings-was scheduled for presentation to the Plant Operations and Safety Review Committee (POSRC).

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l The inspector noted the procedure STPM 20-0, Revision 15, contained a number'of-pictorials and sketches.

Discussions with the maintenance mechanics indicated that the procedure's pictorials and sketches were

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a definite aid in assisting them in their work. The inspector ob-

~ servations identified the mechanics to be interested in performing

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quality work.

Work observed reflected quality performance by the mechanics.

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No inadequacies were identified.

4.2 Surveillance Observation

The inspectors witnessed selected surveillance tests to determine.

whether properly approved procedures were in use; TS frequency and action statement requirements were. satisfied; necessary equipment tagging was performed; test instrumentation was in calibration and properly used; testing was performed by qualified personnel; and test results satisfied acceptance criteria or were properly dispositioned.

Portions of the Unit 2 fuel inspection and repair activities were reviewed.

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Prior to Unit I shutdown in May, 1989, the reactor coolant system-Iodine-131 activity was constant at about 0.07 micro Curies / milli-liter.

Based on previous history, the licensee expected to find

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about five leaking fuel rods.

Fuel inspection by ultrasonic testing was conducted and identified six potentially leaking fuel - rods in four fuel assemblies.

Reconstitution efforts including eddy current i

examination of. potentially leaking fuel rods identified-the L

following:

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Two rods severely damaged which broke into two pieces during.

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L removal from the assembly. This required transfer of the fuel j

to a new assembly skeleton, Three rods with debris damage which warranted removal from the

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reactor core, Two rods with advanced cladding wear; one with 80% clad thinning

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and one with greater than 50% clad thinning, and One rod highlighted by ultrasonic testing which eddy current

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testing determined to be satisfactory.

All eight of these rods were discharged from the reactor core and replaced with solid metal rods.

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.During-inspection of the vessel, the licensee identified a loose part which appeared to be a portion of a fuel assembly spacer grid. The part was retrieved and visual inspection.was conducted for the full.

core.

This ~ inspection identified two assemblies with grid damage.

.The part missing from one of the damaged assemblies matched - the identified loose part.

The piece missing from the other damaged assembly was found wedged lower in the assembly and retrieved.

The inspector. observed portions of fuei assembly. visual inspections and :diccussed. fuel inspection and reconstitution activities with cognizant personnel.

No' inadequacies were. identified.

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Security.

During routine inspection tours, the inspectors observed implementation.of portions of the security plan.

Areas observed included access point search equipment operation, condition of physical barriers. ' site access control, security force staffing, and. response to system alarms and de-graded conditions. These areas of program implementation were determined

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to be adequate.

6.

Engineering and Technical Support 6.1 Safety Injection Tank (SIT) Level and Pressure System Design Modification

The logic and components were modified on Unit 2 during the current.

outage with an identical modification planned for Unit I during the-next outage period. The present design uses Fisher and Porter level transmitters which have been replaced on Unit 2 with a -qualified Rosemount 1154 transmitter.

The failure mode of the ultrasonic level switches involved their electronic assemblies. The drift problem was corrected. by revising.

the maintenance procedure to-perform additional gain adjustment steps and to review the test results with established drift data.

The replacement of the electronic boards was being performed based on-failure rate data obtained from the history data on this system.

Also, the existing pressure switches (United Electric) have a dead band of 4-8 psi.

This-pressure switch is being replaced with a

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United Electric Model #J120-361 whose dead band is 1-4 psi.

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l The SIT level and pressure system modification involved the ultra-sonic level switches providing an input signal to a level alarm, while the pressure switches provide-an input to a pressure alarm.

Narrow and wide range pressure and level indication remain on the panels. The level switch alarm is the primary indicator to alert the operator if Technical Specification level limits have been violated.

If a level switch is out of service, the narrow range indicator may be used as a barkup.

This design concept also applies to the pres-sure alarms and indicators.

Unit 1 Fisher and Porter level transmitters have been rebuilt.

Engineering data indicates that both the Fisher and Porter trans-mitter and the ultrasonic level switches will retain their speci-fication tolerances for approximately a two year period.

Based on the data results, the licensee committed to recalibrate the system components prior to restart and then replace the Unit 1 equipment during the next scheduled outage with the same equipment currently installed on Unit 2.

No inadequacies were identified.

6.2 Electricci Cable Separation Deficiencies Programmatic weakness in assuring adequate separation of safety related cable was identified in a previous inspection report (50-317/89-27; 50-318/89-28).

During the current period, the in-spector reviewed a sample of the licensee's corrective actions in orogress. The licensee is conducting detailed walkdowns, evaluations and repairs, and has retained a contr6ctor company to help in assessment activities.

The inspector conducted an independent inspection of the Unit 1 Containment following the completion of licensee walkdowns.

The inspector identified examples of cable separation deficiencies and compared the findings with the results of the licensee's walkdowns.

Each of the inspector's examples was confirmed to have also been identified by the licensee for evaluation and resolution.

Portions of licensee walkdowns in areas previously inspected were monitored by the inspector.

The licensee's team appeared thorough and, upon questioning by the inspector, was knowledgeable of the applicable requirements. The personnel displayed a good questioning attitude and included several observations of potential problems of types not specifically contained in the checklists being used.

No inadequacies were identified in those portions of the ongoing corrective actions reviewed by the inspector.

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Safety Assessment and Quality Verification 7.1 Plant Operations and Safety Review Committee The inspectors attended several Plant Operations and Safety Review Committee (POSRC) meetings. TS 6.5 requirements for required member attendance were verified.

The meeting agendas included procedural changes, proposed changes to the TS, Facility Change Requests. and minutes from previous meetings. Items for which adequate review time was not available were postroned to allow committee members time for further review and comment. Overall, the level of review and member participation was adequate in fulfilling the POSRC responsibilities.

On January 15, 1990, the licensee created a Procedures Subcommittee with the intent of reducing the amount of material reviewed by the full POSRC. The committee is described in CCI-103L, Organization and Operation of the POSRC, and is chartered to review procedures and procedure changes and make appropriate recommendations to the full POSRC. Subcommittee meeting minutes are subsequently reviewed during POSRC meetings; at this time POSRC members are apprised of the sub-committee's review and are given the opportunity to voice additional questions or comments. Approval of the subcommittee meeting minutes then constitutes the POSRC recommendation to the Manager-CCNPPD for procedure approval.

During this inspection period, the inspectors attended several subcommittee meetings and reviewed portions of CCI-101M, Calvert C11ffs Implementing Procedure Development and Control, and made the following observations:

CCI-101M does not prohibit the same individual from b.:ing the

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originator and reviewer of procedure changes, field changes, and

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biennial reviews.

CCI-101M does not prohibit the same individual from being the

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originator and validator for original procedures and subsequent revisions.

If the subcommmittee desires minor modifications be made to a

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procedure or procedure change, a recommendation for approval "as modified" is given.

A method for verification that ths modi-fication is incorporated accurately and as intended has not been established.

CCI-101M states that after POSRC review and Manager-CCNPPD

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approval, changes may be incorporated into the master copy by having them word processed.

There is no established method for verification that the word processing is performed accurately.

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These observations were discussed with the Alternate Chairman of the l

POSRC and Procedures Subcommittee and are currently under licensee review.

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r The inspector noted that the subcommittee members were generally well prepared for the ineetings and provided a sound technical review of the materials presented. Dissenting opinions were resolved prior to committee recommendation for approval.

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7.2 Review of Written Reports Periodic and Special Report and Licensee Event Reports (LERs) were reviewed for clarity, validity, accuracy of the root cause and safety-significance description, and adequacy of corrective action.

The inspector determined whether further information was required.

The inspector also verified that the reporting requirements of 10 CFR 50.73, Station Administrative and Operating Procedures, and Technical Specification 6.9 had been met.

The following reports were reviewed:

LER 89-22 Core Alterations Performed With Only One of Two Con-tainment Vent Valves Closed LER 89-23 Postulated Pipe Rupture in the Turbine Building Service Water System Renders Both Auxiliary Building Service Water Subsystems Unavailable.

LER 89-24 Incomplete Channel Calibration Procedure Results in Failure to Test Certain Portions of PORV Actuation Circuitry.

LER 89-25 Missed Fire Watch Tour Due to Personnel Error.

Special Report concerning an Inoperable Containment Isolation Valve for the Containment Fire Hose Station Riser, dated January 11, 1990.

Special Report concerning the Potential Inoperability of the Unit 1 Fire Suppression Water System, dated January 19, 1990.

Special Report concerning an Inoperable Fire Barrier Penetration, dated January 19, 1990.

No unacceptable conditions were identified, i

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Followup of Previous Inspection Findings Licensee actions taken in response to open items and findings from pre-vious inspections were reviewed. The inspectors determined if corrective actions were appropriate and thorough.and previous concerns were resolved.

Items were closed where the inspector determined that corrective actions

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would prevent recurrence.

Those items for which additional licensee

action was warranted remain open.

The following items were reviewed.

8.1 Emergency Diesel Generator Failures (Closed) Violation (50-317/87-23-01; 50-318/87-25-01):

Inadequate corrective action for intermittent emergency diesel generator (EDG)

failures. A subsequent NRC Inspection Report 50-317/89-03; 318/89-03 also documented continuing problems with the affected EDG cooling

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water valves.

That report also opened Unresolved Item (50-317/89-03-01; 50-318/89-03-01) concerning the broader issue of performing adequate and timely root cause evaluations to ensure safety equipment

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operates in a reliable fashion.

This item will be reviewed sepa-rately.

This report administratively closes UNR (50-317/87-23-01; 50-318/87-25-01).

8.2 Intent Changes to Procedures s

(Closed) Violation (50-317/88-01-04; 50-318/88-01-04); (Closed) Unre-solved Item (50-317/89-200-02; 50-318/89-200-02); (Closed) Special Team Inspection Item Nos. 2 and 19: Change of intent to procedures not clearly defined. The licensee has revised administrative proced-ure CCI-101, "Calvert Clif fs Implementing Procedure Development and.

Control," which provides a formal definition of intent procedure changes. The revised procedure change cover sheet includes a screen-ing test for procedure changes to assist personnel in determination of change of intent.

The inspector reviewed the appropriate CCI changes; no significant deficiencies were identified.

Minor errors

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and inconsistencies identified by the inspector were discussed with the licensee.

This item is closed.

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8.3 Inappropriate Use of General Supervisor - Nuclear Operations Standing Instructions (Closed) Unresolved Item 50-317/89-200-03:

Inappropriate Use of General Supervisor-Nuclear Operations Standing Instructions.

The licensee has incorporated the standing instrdctions into the appro-priate procedures and enhanced the administrative guidelines as discussed in Section 9.11 of this report.

This item is close uq'

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8.4 Failure to Perform Safety Tag Audits i

(Closed) Unresolved Item (50-317/89-81-01).

This item concerned the failure to perform the monthly safety tag rdits and is associated

with the items closed in Section 9.12 of tV, report.

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8.5.Inadeounte Handling of Safety Tag Discrepancies

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(Closed) Unresolved Item (50-317/89-81-02).

This item concerned the failure to formally document and resolve safety tag discrepancies.

Additionally, weaknesses in management oversight of the safety tag program were identified.

This item is associated with the items closed in Section 9.12 of this report.

8.6 Root Cause and Problem Identification Systems (0 pen)

Unresolved Item (50-317/89-03-01; 50-318/89-03-01).

The licensee has revised and is in the process of reviewing administra-tive procedure CCI-116, " Identification and Control of Non-Conforming Conditions." The revision will provide implementation procedures for handling Non-Conformance Reports (NCRs). The licensee's current plan is to implement the CCI about the end of March, 1990.

The CCI-116

revision will require implementation of a formal Root Cause Analysis

.l (RCA) Program.

The plant engineering section currently has a draft Section Guidelines PPE-06, " Routing of Root Cause Analysis NCRs".

RCA training is currently being accomplished through consultants, i

Although the procedures have not been officially implemented, three different events are currently being analyzed using the RCA proced-ures being taught. The trip of the No. 12 Emergency Diesel Generator on December 15, 1989 is one of the events being analyzed.

Thi s-i tem remains open pending implementation of the revision to CCI-116 and NRC assessment of a sample of RCA program analyses.

8.7 Lack of Independent Design Review (Closed) Unresolved Item (50-317/88-28-01: 50-318/88-28-01).

The concern involved an engineer's sign off as the independent reviewer of own work involving a Facility Change Request (FCR).

The licen-see's Design Engineering Section Procedure (DESP)

7, Design and Design Review, was revised and issued on March 9,1989.

It required

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that reviews be performed by a qualified engineer who was not in-volved in the development of the FCR.

During this inspection, the NRC inspector reviewed the revised DESP-7 and verified implementation by reviewing seven selected FCRs, a Facility Engineering Change, and

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two 1989 Quality Assurance audits.

No inadequacies were identified; this item is close )

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8.8 Failure to Recognize that the Halon System was Inoperable and Failure to Take Corrective Action.

i (Closed) Unresolved Item (50-317/89-18-02). On June 29,1989, a Fire i

and Safety Technician (FAST) disabled the Halon System for the Unit 1 Electrical Switchgear Room at the 45 foot level to allow mechanics to i

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perform hot work.

On July 20, 1989, with Unit 1 in Cold Shutdown, i

licensee personnel performing a surveillance test discovered that the solenoid was disconnected from the discharge valve. The purpose of the solenoid was to actuate the halon discharge valve.

In addition to the failure to recognize that the halon system was inoperable, the

licensee failed to establish an hourly fire watch within the one hour required by the Technical Specifications. The inspector noted during t

this inspection that the licensee issued LER 89-012, and a response to NRC on November 20, 1989.

The inspector reviewed and verified that all corrective actions in the licensee response letter were satisfactorily implemented. Actions taken included revising CCI-133, Calvert Cliffs Fire Protection Plan; surveillance test procedures STP-M-291-0. Halon System Valve Position Verification; STP-M-699-1, Functional Test of 27'and 45' Swithgear Rooms Automatic Halon Release Solenoid Circuit; and operating instruction 01 20, Fire Protection

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System.

The inspector also reviewed the STP-M-699-1 surveillances

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conducted in October and November 1989. No inadequacies were iden-tified; this item is closed.

1 9.

Followup of Restart Issues

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The licensee documented corrective actions for Unit I restart issues in packages which were presented for NRC review.

These items have been identified as Confirmatory Action Letter (CAL)-89-08 and Special Team Inspection (STI)-89-200 to correspond to identification numbers utilized by the licensee and NRC staffs for tracking purposes.

Items identified during the Readiness Assessment Team (RAT) inspection are identified by the paragraph in that report (50-317/89-81).

The following items were reviewed.

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9.1 Upgrade of CCI-101, Implementing Procedure Development and Control (Closed) CAL-14 and CAL-15. The licensee implemented a revision to CCI-101, " Implementing Procedure Development and Control," to address i

the following specific deficiencies:

1)

provide a formal definition of an intent procedure change, 2)

provide a mechanism by which procedure steps that incorporate

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licensee commitments can be identified, 1-l l

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standardize the review and approval processes for implementing

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procedures and changes thereto, and l

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provide a means to incorporate temporary procedure changes into

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procedure master copies so that the changes can become permanent.

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F The inspector reviewed CCI-101 (Revision M), interviewed licensee personnel, and reviewed selected implementing procedure changes. The

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inspector concluded that items 1, 2, and 3 have been adequately addressed.

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l During a detailed review of CCI-101M and its implementation, the

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inspector identified several minor discrepancies, which were dis-

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cussed with the licensee.

The licensee informed the inspector that the procedure was currently under review for further revision, and the items discussed would be addressed.

During a review to verify proper _ implementation of the revised CCI, the inspector identified

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that a working copy of a surveillance test procedure contained an intent change; however, the responsible Procedures Group had not been notified of the change to ensure a permanent revision as required by

CCI-101.

The licensee subsequently issued a nonconformance report (NCR), which identified and documented the potential programmatic problem. The licensee informed the inspector of the immediate and permanent corrective actions, which the inspector found to be acceptable and were completed prior to the end of the inspection.

Based on the above, the inspector found licensee resolution of-Item 4

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to be acceptable.

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The inspector reviewed the training associated with the revised CCI-101, including discussions with station personnel and reviews of the training lesson plans and student handouts. No deficiencies were identified.

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In summary, the inspector concluded that the specific issues iden-tified in CAL-14 and CAL-15 had been adequately addressed; however, during the detailed review of CCI-101M, several minor procedure and implementation deficiencies were identified.

The specific defi-ciencies were identified to the licensee. CCI-101 is included in the L

longer term improvement project for additional upgrades.

Based on l

the above, this item is closed.

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9.2 Lack of Procedures for Quality Control Inspection Activities (Closed) STI-29.

The STI identified that approved procedures or written instructions for controlling, implementing and documenting QC

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inspections were not established, contrary to the requirements

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specified in the 10 CFR 50, Appendix B, and the Calvert Cliffs

Quality Assurance Policy, Section 18.10.

This violation along with five other violations identified during the STI had been categorized

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in the aggregate as a severity level III in the Notice of Violation i

issued on November 2, 1989.

The lack of procedures and written.

instructions resulted in ineffective and inconsistent quality control

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program implementation.

Over-reliance on the inspector!s knowledge and judgement in selecting and performing QC inspections, and waiver of required inspections in some cases had been noted.

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The licensee's self-assessment in this area concurred with the STI findings and identified "QC Process Improvements" as a top priority project requiring senior management attention. The following correc-

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tive actions were subsequently implemented by the licensee:'

Developed and issued the Station QC Mission Statement defining

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the role of QC.

i Reorganization of Quality Assurance Department to strengthen QC;

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the QC section was expanded to include four subsections consis-

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ting of QC electrical and controls, QC - mechanical, QC - mod-ifications, and QC quality engineering.

The QC quality-

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engineering subsection reviews procedures and work packages, identifies and marks inspection points, prepares inspection pro-

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cedures for use by inspectors and administers the Non-Conform-ance Report (NCR) system.

The new QC Section Head position was elevated to an Assistant General Supervisor level from a Super-visor level.

The new AGS - QC position was filled with an experienced individual and the subsection supervisor positions

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were filled with individuals with strong technical and craft background.

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Quality Control Section complement was increased to 50 from 30

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personnel; several engineers were added to provide technical

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support for the QC section.

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Revision

"L" of CCI-200, " Nuclear Maintenance System," was

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issued on July 10,1989.

It placed QC in line for safety-

related, environmental qualification or welding maintenance order reviews.

QC administrative procedures were developed and issued to pro-

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vide requirements in preparation and control of QC procedures.

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v l, oh l IS The RAT concluded that the licensee's corrective actions in this area were adequate.

It was verified that safety-related and EQ-related Maintenance Orders (MO) with associated work plans were sent to the QC - Quality Engineering for appropriate QC hold point assignments and inspection procedure development prior to scheduling of the MO.

The job-specific QC inspection procedures developed by QC - Quality Engineering staff were detailed and generally of high quality.

Production delays due to the implementation of this new requirement were accepted by licensee management.

The evaluation by licensee

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management of the effectiveness of the improvements in QC is part of

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the ongoing PIP implementation program.

The inspector determined that the licensee's corrective actions to date adequately addressed the identified problems in this area.

9.3 Communication of Manaaement Goals and Expectations in Adherence to Procedures, Work Control and Priorities

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(Closed)

STI-14a.

The Special Team Inspection (50-317/89-200; 50-318/89-200) determined that:

The second tier of management, the General Supervisor (GS), was s

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effectively separated from the managers above and the workers

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below.

Rather than translating management's strategic goals and policies into work practices and expectations, the GS group was found to be the enforcers of an operating style that emphasized production over safety.

Rather than focusing management's stated goals and policies, the GS group tended to act as a filter.

Very little of the stated goals and policies had filtered down

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to the workers.

The terms and conditions under which work was accomplished in

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the organization were being developed by default at lower levels of the organization.

Persons at those levels were developing their own performance standards and expectations based on their perception of an operating philosophy which stressed production.

Teamwork was considered by the plant staff to be doing that which was necessary-to support operations rather than working toward a shared safety or performance objective.

Through the licensee's own self-assessment process, the licensee management concluded that inadequate, and sometimes confusing, com-munication from management could have contributed to misplaced priorities.. Review of recent site events (1988 through the first

half of 1989) by the licensee management also indicated that these events might have been prevented or mitigated by clearer communica-tion of work priorities, the need to control activities and the need to adhere to procedure o. 00.

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Recognizing these concerns, the licensee management utilized various

means to establish clear communications from the highest levels of I

management on the importance of procedure adherence, work control and i

priorities.

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The licensee management verified through numerous interviews with site personnel that communications had been effective in conveying i

management's expectations in relations to work priorities, control of i

activities and adherence to procedures.

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The RAT Inspection concluded that management's communications had been effective.

The knowledge of goals and expectations had been

increased at the worker level. The inspectors interviewed employees

from several levels who indicated a high degree of awareness of J

management goals and expections in relation to work priorities, control of activities and adherence to procedures.

The inspectors

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concluded that licensee personnel understanding of management goals

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and expectations were obvious.

Extraordinary efforts taken on the part of management were noted in this area.

This item is closed.

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9.4 Review of Open Quality Assurance Findings for Restart Applicability (Closed) RAT Item, Paragraph 3.5.9.

The licensee completed a review of the open QA findings for restart applicability.

Items that were determined to be restart items were verified to have an assigned NCR (nonconformance report) designated as a restart item. Procedure QAUP -

3, Audits, Revision 11 (step 6.2.6) was revised to include a re-quirement that now each audit finding be screened regarding system or component operability.

Findings that affect restart will have an NCR issued and be designated as a restart affecting NCR.

The inspector verified by a reviewing a sample of five recent findings

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that appropriate NCRs had been initiated. The QC - NCR Group had the appropriate NCRs in their NCR tracking system.

Based upon the above findings, this item is closed.

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9.5 Review of POSRC Open Items for Restart Applicability (Closed) RAT Item, Paragraph 3.5.7.

Regarding POSRC open items, before restart the licensee will add a signature in prestartup checklists to certify that the POSRC open item status is acceptable for startup.

The licensee revised OP-6, Attachment 1A in Revision 37, to incor-l-

porate under Mode 4 an item (No. 60) to require the POSRC Chairman to l

initial and date that POSRC OIs are appropriately closed and do not limit unit heatup or startup.

Based upon the actions completed by the licensee this issue is closed.

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9.6 Verification of Technical Specification Surveillance Requirements (Closed) RAT Item, Paragraph 3.5.4.

Screen through POSRC a review of the correlation between surveillance procedures and Technical Speci-fication surveillance requirements.

This is described as a first phase level I review.

The level I review did not include any Security Safeguards requirements or ASME XI requirements. ASME XI requirements are the subject of a separate L

review.

A Level 1 review on Units 1 and 2 was performed to ensure that all surveillance requirements listed in Section 4.0 of the current Unit I and 2 Standard Technical Specification had an applicable procedure that implemented the requirements of the specified surveillance with respect to the following areas:

Frequency specified

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Mode (s) specified

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Limits as listed in Section 4.0

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The results of the Level I

review which was completed on December 28, 1989, identified 61 items that were classified as follows:

S - Safety Significant R*- Procedure Change Required - should be considered prior to restart R - Procedure Change Required E - Enhancement W - Withdrawn Three of the 61 items were listed-as Safety-Significant; five were listed R* and the rest divided b9 tween ratings R and E with one W.

The above results were review by POSRC and dispositioned on January 10, 1990.

L To verify that the action taken ty the POSRC has been implemented, L

the inspector reviewed the action taken on 10 of the Technical Spec-ification' subjects listed with an S and R*.

The table below indi-cates the status verified by the inspector.

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Specification Section Action Taken S 4.4.3.1 LER issued; procedure changed

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S 4.8.2.3.2.d Procedure change not required S 4 8.2.3.2.e Procedure change not required R* :4.11.2.1.2 Chemistry procedure CP-609; to be changed during upgrade program R* 4.4.6.2.c Change STP 0-27 during upgrade program R* 4.4.9.2 Changed OP-5 to TS requirement R* 4.5.1.f Changed 01-3 to log test results R* 4.8.1.1.1.a.1 Changed STP-0-90 to verify breaker position R* 4.8.1.1.2.a.6 Change STP-0-8A-1 and 0-8B-1 R* 4.8.2.1 Change STP-0-90 to verify D/G Breakers Open The inspector determined that the 61 items identified in the STP level 1 review were reviewed and approved by POSRC.

Corrective action taken or planned has been defined and scheduled prior to restart.

This item is closed.

9.7 Revision of AOP-1A (Closed) RAT Item, Paragraph 3.5.5(1).

Abnormal Procedure AOP-IA, used for inadvertent boron dilution, did not address using-the high pressure safety injection (HPSI) pumps.

l Procedure - A0P-1A, Revision 3, was issued on November 28, 1989.

The procedure provides direction for boration in the event of inadvertent dilution and also provides pressurization limits on the HPSI mass addition in the event this path is used. A " Caution" note was added i

to the procedure when borating with the HPSI pump. Also the state-ment, " Slowly throttle open (maintaining the handswitch in Pull to Override position)," has been added to the procedure.

Inspector review of drawings60-730, Operations During Chemical and Containment Spray Systems, OM-74, verified the valve alignment settings described in A0P-1A, Revision 3, November 28, 1989.

This item is closed.

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9.8 Specification of Boration Flow Path Valve Position

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(Closed) RAT Item, Paragraph 3.5.5(2). Clarify acceptance criteria of procedure STP-0-62-1 for boration flow path valve position sur-

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veillances.

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Surveillance procedure STP-0-62-1, Revision 28, was revised to define l

the valve positions for each plant operating mode for the safety

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injection boration flow path.

The inspector reviewed the changed procedure and verified that it defined the valve position for specific plant modes.

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This item is closed.

9.9 Determine and Correct the Root Causes of Procedural

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Noncompliances (Closed) STI-14b.

The licensee had performed individual event in-

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vestigations to evaluate the specific causes of the various proce-dural noncompliances and to identify any common causes. The licen-see's overall root causes for the numerous events were determined to be insufficient in the attention to detail with regard to procedural adherence, and worker accountability with regard to procedural adherence.

The licensee also determined that common contributing causes for several of the events included the failure to properly supervise, lack of attention to detail, and human factors weaknesses with procedures.

The inspector reviewed and evaluated selected events, interviewed station personnel, and reviewed the licensee's evaluation results.

The inspector found that the licensee's post-event evaluations properly assessed the root causes.

Several mechanisms to communicate the licensee's proposed short term corrective actions have been implemented by the licensee (STI-14a; see Section 9.3 of this report).

Longer term corrective actions l

currently planned by the licensee include continued emphasis on

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procedure compliance through the existing Performance Improvement Plan and the Procedures Upgrade Program.

Through extensive observation of plant activities in the areas of Operations, Maintenance / Surveillance and Safety Assessment / Quality Verification, the. RAT concluded that there was a notably heightened-awareness level throughout the station of the importance of, and requirements for, procedural adherence. The inspector also observed selected activities and held discussions with personnel, and con-cluded that the licensee's corrective actions with respect to pro-

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cedural compliance has been effective. This item is closed.

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1 9.10 Incorporation of Surveillance Certifications Into Mode Change Checklist

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(0 pen) RAT Item, Paragraph 3.5.2.

Before startup, the licensee will incorporate into mode change checklists of procedure OP-6 completion certification signatures for surveillances in area outside the pro-gram consolidated under the STP coordinator.

To address the_ subject commitment, the licensee issued revision 37 to OP-6, " Pre-Startup Checkoff." The inspector reviewed the licensee's e

l actions and interviewed the surveillance test program manager. Dur-

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ing the review of the revised OP-6, Pre-Startup Checkoff Procedure, the inspector found no completion certification signature or checkoff-for TS 3.6.1.2 relating to the acceptability of the Containment Inte-

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grated Leak Rate Test (CILRT) or other certification that containment leakage met TS 3.6.1.2.

Based upon. this finding, the inspector con-cluded that the revision to procedure OP-6 did not yet satisfy the comraitment. The inspector noted that the licensee's own review pro-cess failed to identify the CILRT omission from OP-6, This item remains open pending the licensee's additional corrective action and NRC reinspection.-

9.11 Use of General Supervisor - Nuclear Operations (GS-NO) Standing Instructions (Closed) STI-3, STI-4, STI-5, and STI-6. The Special Team Inspection 50-317/89-200 identified concerns that the use of GS-N0 Standing L

Instructions were used as a means of providing directions for oper-ator actions rather than including those directions in an approved procedure.

Three examples were identified where standing instruc-tions provided directions that should have been included in a pro-

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cedure.

In addition, there was no established administrative guid-ance to prevent this problem from-recurring.

Subsequent inspections (50-317/89-23 & 81) reviewed the licensee actions regarding this issue.

The inspector reviewed the standing instructions that are currently in effect and concluded that instructions were in agreement with the standards prescribed in Regulatory Guide 1.33, " Quality Assurance Program Requirements (Operation)."

In addition, the licensee added administrative guidance to CCI-114 stating that GS-N0 Standing In-structions shall not be used as a substitute for procedures.

The inspector reviewed the revised guidance and confirmed that adequate administrative control had been implemented.

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9.12 Cor, trol of System Status (Closed) CAL Items 2,

3, 4,

5, 6,

7, 8,

10, and 13; (Closed)

Unresolved Item 50-317/89-81-01; (Closed) Unresolved Item 50-317/

89-81-02.

CAL Items 2-8,10, and 13 were developed as part. of the licensee's response to the STI.

The RAT inspection noted improve-ments in the area of control of system status, but found that sig-nificant weaknesses existed in management oversight of the safety tagging organization and in the identification and resolution of deficiencies.

While some items were immediately addressed by the licensee, several programmatic deficiencies were identified.

CAL Items 2-8,- 10 and 13 were related to the general issue of the control of plant systems status.

The two unresolved items deal'

specifically with weaknesses noted during the RAT Inspection: failure to complete required tag audits and the informal documentation and resolution of tagging discrepancies.

Both items represented weak-nesses in the licensee's management oversight of the safety tagging organization.

The inspector reviewed the licensee actions taken to resolve the above items and determined that the safety tagging organization and operation would support the safe operation of the facility. Specifi-cally, 1.

CCI-112

" Safety Tagging," was revised with the following improvements noted:

Clearer delineation of organizational duties and responsi-a.

bl11 ties, b.

Clarification and strengthening of the controls over work which may be performed on high energy systems or system troubleshooting without the issuance of a clearance, c.

Improved documentation of tagout reviews for both main and supplementary clearances, d.

The use of laminated drawings to depict tagging boundaries, which was found to be of limited value during the RAT in-spection was discontinued, and e.

The required audit of all tagouts over three months old and weekly audits of the clearance index were formally docu-mented with discrepancies and related corrective actions noted and submitted for review to two levels of management.

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Vertical communications within the tagging group were strength-

ened.

A middle-level supervisory position (deleted in early 1989) was restored with oversight responsibilities focused

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J strongly on tagging activities.

Significant effort was evident

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by management at all levels to clearly define expectations. The M

tagging group fostered a team spirit through the use of focus

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and tailgate meetings, supervisory performance objectives and an emphasis on safety and quality.

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3.

A review of the monthly audit of tagouts older than three months performed since November 1989 indicated that the audits were being performed in accordance with the requirements of CCI-112.

Audit results were being reviewed by appropriate management, e

4.

Additional resources were allocated to the tagging organization,

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including personnel to assist in the preparation of tagouts and.

to assist the safety tagging supervisor in administrative

matters.

5.

The inspector observed a heightened emphasis on the part of supervisors and management for a meticulous attention to detail in all facets of safety tagging.

6.

Supervisory personriel in the operations department conducted a series of job observations of safety tagging activities.

The results were reviewed and items noted were included in the

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l licensee's operations commitment management system for evalua-

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tion and corrective action, as appropriate.

7.

Tagging deficiencies are being properly reviewed by appropriate levels of management and are being formally documented.

A recent discrepancy noted during a supervisory walkdown of a tagout boundary for a service _ water system leak repair where a red danger tag on valve 1-SRW-376 had been erroneously cleared and the valve opened.

The discrepancy was immediately brought i

to the attention of the tagging group.

The tagout was re-l searched, corrected and an NCR (No. 9022) and near miss incident

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report generated.

A human performance evaluation (HPES-01-90)

was performed and recommended several tagging improvements -

rearrangement of the safety tagging clearance form with serial numbers at the bottom of the page and offset the second copy so the numbers are clearly visible,

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see's short term corrective actions for safety tagging had been

l implemented and the time when full implementation of long term

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actions, as described in the Licensee's Performance Improvement Plan

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(PIP) in Sections 2 and 3, is scheduled to be achieved.

The in-

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spector expressed the concern that there was a potential during this

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interim period for a lessening of management attention on tagging

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operations and issues. The licensee noted that some of the long term PIP action plans were in progress, notably the establishment of performance objectives / standards (PIP Action Plan 2.2.1), the com-mitment management system (PIP Action Plan 2.5.1), and the use of a

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site integrated schedule (PIP Action Plan 3.6.1) to improve work control and reduce schedule pressures. The licensee acknowledged the

need for continuous, rigorous attention to all aspects of safety tagging. The inspector had no further questions on this issue; this item is closed.

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9.13 Intent Chances to Procedures

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(Closed) STI-2 and STI-19.

Change of intent to procedures not t

clearly defined. This item is associated with the inspection items closed in Section 8.2 of this report.

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9.14 Review and Demonstration of Operatino Procedures The inspector reviewed selected plant operating procedures (OP's) and observed a demonstration of these procedures on the licensee's plant specific simulator.

Technical adequacy of the procedures and func-i tional performance were also assessed.

Additionally, the inspector

assessed the. adequacy of the licensee's procedure reviews as described in a

letter from the licensee to the NRC dated November 10, 1989.

The inspector selected for review and demonstration,. OP-2, " Plant t

Startup from Hot Standby to Minimum Load," Revision u May 1987, through change 90-1030, and OP-5, " Plant Shutdown from Hot Standby to Cold Shutdown," Revision 31 August 1989 through change 89-1381.

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L System operating instructions (01's), surveillance test procedures l

(STP's), and administrative procedures that support OP-2 and OP-5 i

were also reviewed.

Discussions were also held with licensed operators, training personnel, and operations management.

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The procedures contained technically adequate information to support safe conduct of the specified evolutions. Several changes were noted

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during the inspection. These changes constituted minor enhancements, clarifications, or corrections of typographical errors.

Several of i

these changes were made prior to the end of the inspection and the licensee committed to complete the remaining changes prior to startup of Unit 1.

The inspector observed that the operators followed the L

procedures verbatim and that they initiated changes when needed.

Licensee management identified that two licensed operators in addi-tion to the normal shift are needed for certain evolutions during L

plant startup per OP-2.

OP-2 specifically dedicates an additional senior reactor. operator (SRO) to control the startup, but neither

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OP-2 ' nor the administrative procedure require additional reactor operators (RO's) at the feedwater station or at the turbine control station.

Licensee management indicated that the feedwater operator is required to control steam generator level at low power where auto-

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matic control is not effective.

Due to the coordination required

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After questioning on how these additional positions were

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administratively controlled and consistently applied between opera-ting crews, the licensee initiated a change to OP-2 which will be incorporated prior to plant startup to require these additional personnel, t

The inspector noted that many procedures contained a large number of changes without the procedure undergoing a forrial revision.

For example, OP-2 was Revision 23 (May 1987) and had nine separate changes to the procedure.

OP-5 was Revision 31 (August 1989), and had 13 changes. Administrative. procedure CCI-101M, "Calvert Cliffs Implementing Procedure Development and Control" does not limit the number of changes.

Relative to the large number of changes, the

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inspector noted that the operators could not readily ascertain the latest change to a procedure.

The inspector did not identify any case where a task was performed with a procedure that did not have the current changes, Regarding the number of outstanding changes to procedures, the in-spector concluded that the facility was operating in accordance with the administrative procedures and that there were no regulatory requirements that mandated a maximum number of changes prior to incorporating the changes into a revision.

The facility has com-mitted to evaluating the areas discussed above and changing CCI-101M, as appropriate. Specific changes being considered are the inclusion of an " administrative revision" process which would allow timely l

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incorporation of outstanding changes without requiring the normal

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three to four month review cycle needed for a complete procedure

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review and the development of a mechanism for use by the control room operators to verify that the copy of a procedure in-hand is the latest issue.

Biennial reviews of OP's and 01's are up-to-date although some were reviewed af ter the required 24 months as pre-

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vlously identified to the NRC4 Summary-Based on reviews of selected procedures, the inspector concluded that the licensee had implemented technically adequate procedures that supported safe plant operation in accordance with regulatory re-quirements.

The licensee identified a need for additional personnel

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during a plant startup and has initiated measures to administrative 1y control these personnel.

Although there were a large number of changes implemented with the procedures, these were performed in accordance with the licensee -administrative guidelines.

This item is closed.

9.15 Lack of Control of Measurino and Test Equipment (M&TE)

(Closed) STI-1; (Closed) Unresolved Item 50-317/89-200-01. This item involved the lack of procedural controls for calibration of the M&TE prior to installation for testing, for receipt of returned M&TE, for recall of M&TE for recalibration, and for the reliability of the test data.

The inspector reviewed CCI-120E, Control and Calibration of Measuring-l and Test Equipment, which had been revised.

The revised procedure

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provided acceptable controls for calibration of equipment.

CCI-120E was POSRC approved with an effective date of revision of March 1, 1990.

Based on this information, the item is closed for plant restart.

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Exit Meetino During this inspection, periodic meetings were held with station manage-ment to discuss inspection observations and findings. At the close of the inspection period, an exit meeting was held to summarize the conclusions of the inspection.

No written material was given to the licensee and no proprietary information related to this inspection was identified.