IR 05000320/1977026
| ML19220C039 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/10/1977 |
| From: | Conte R, Dante Johnson, Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19220C036 | List: |
| References | |
| 50-320-77-26, NUDOCS 7904280102 | |
| Download: ML19220C039 (55) | |
Text
U.S. tiUCLLAR REGULATORY COMMISSI0tt 0FFICE OF If15PECT1011 A:<D EtlFORCEMEfiT Region I Report fio.
77 ?6 Docket lio.
50-170 License flo.
CPPR-66 Priority
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Category nt33 Licensee:
Metrecolitan Edienn Cor,any P. O. Box 5d2 Readinc. Pennsvivania 19603
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Facility flama:
Three Mile Island Unit 2 Inspection at:
Middletown, Per.nsylvania
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Inspection condu ' d:
ne 0-24, June 30, July 1 and July 5-8, 1977 l
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9ff 77 Inspector :
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.J.ContdRe.ictorInspector date signea F.y 5 l 10 In 3%T.F.'SN'tkapeactorInspector date signed
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g/.- /,7 J.C.iiiggMs, eactor Inspector date signed
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G. flapuda6 Reactor Inspector
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J. T. Smith, Reactor Inspector date' signed W
t\\ \\s \\v A. H. Badriack, Reactor Inspector date signed W
date signed Approved by:
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D. F. Jehkon, Acting Chief, fluclear Support date signed Section 2, RO&ils Branch
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J _ 3ection Su= nary (See fiext Page)
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7904280/C2
Inscection Surmary:
Inscection on June 20-24, Jur; oJ, July I and July 5-8,1977 (Recort ho. 50-320/17-26 Areas Inscected:
Routine, ut.nounced inspection of Previous Inspection Findings; Auxiliary and Reactor Buildings; Preoperational Quality As-surance Review in the areas of preoperational test recc-ds, procurement control, receipt, storage and handling, surveillance testing and cali-bration, test and measurement equipment, and records; Scope, Format and Content of Facility Procedures; Preoperational Test Procedure Review of Containment Integrated Leak Rate Tests, Structural Integrity Test, local Leak Rate Tests and Diurnal Effect Measurement. The inspection involved 314 inspector-hours on site by six NRC inspectors.
Results: Of the areas inspected, no items of noncompliance were identi-fied.
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DETAILS 1.
Persons Contacted Metrocolitan Edison Comoany R. Bensel, Electrical Engineer
- M. Bezilla, PORC Administrator J. Brummer, Instrument, and Control Engineer G. Burns, QA Procurement Engineer W. Cotter, Supervisor, Quality Control E. Daniels, Quality Control Specialist
- J. Hilbish, Station Nuclear Engineer D. Hosking, QC Specialist E. Kellogg, Technical Analyst G. Kunder, Unit 1 Operations Supervisor
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- T. Mackey, Engineer III - Nuclear W. Varsha11, Operations Engineer K. McKently, Senior File Clerk (Records Librarian)
G. Miller, Station Superintendent / Unit 2 Superintendent
- M. Nelson, Technical Engineer R. Heidig, QC Specialist
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C. Nixdorf, Office Supervisor J. O'Hanlon, Unit 1 Superintendent W. Potts, Acting Panager, Quality Assurance W. Poyck, Coordinator of Services R. Prabhakar, Supervisor, J. Reuter, Stores Foreman, Quality Assurance Nuclear J. Roberts, Cognizant Engineer J. Seelinger, Unit 2 Superintendent of Technical Suppor D. Shoulin, Supervisor of Meintenance
- R. Toole, Test Superintendent R. Van Stry,' Administrator - Nuclear Technical Training
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United Encineers and Constructors (UE&C)
F. Kuvalik, Office Engineer - Orawings/ Specification Control
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The inspector also. interviewed six other licensee employees during the course of the inspection.
They included quality assurance /
control, I&C, technical and office staff.
denotes those present at exit interviews conducted by Mr. Cente,
NRC:1, on June 24, 1977 and July 8,1977.
denotes those present at exit interview conducted by Mr. Higgins,
NRC:1, on July 8,.1977.
2.
Action on Previous Inscection Findinas (0 pen) Unresolved Item 320/77-03-01: QA Program Effectiveness Review. The inspector reviewed procedure GP 4016 Revision (Rev. 3)
but identified that the revised nracedure still did not fully describe the methods which are to be used to assure that the quality This item remains unresolved program reviews are properly conducted.
pending appropriate licensee action.
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(Closed) Unresolved Item 320/77-03-02:
Independent Review Bodies.
The licensee representative provided the inspector with a topy of
"Three Mile Island Generating Station General Office Review Board" (G0RB) dated February 15, 1973. The licensee representative stated that this document was the charter for one of the inoependent 50-320/77-03.
review bodies that was unavailable during inspection The inspector verified that this document addressed the responsi-bilities and duties of the subject committee.
(Closed) Unresolved Item 320/77-03-03:
Corrective Action Confima-tion and Reaudits. P.ocedure GP 4016 Revision 3 now requires verification of corrective action for audit findings.
320/77-03-04.
Pipi7s and Instrument (Closed) Unresolved ItemThe licensee representative stated that it was Diagram Control.
not intended for procedure AP 1001 to itemize the various specific types of drawings and that the statement in paragraph 1, "...
control and revision of all architect engineer microfilm aperature cards...," established the requirement to control all as built ^
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drawings (e.g. detail, layout, flow diagrams, isometrics, etc.)
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(0 pen) Unresolved Item Maiatenance Activities. 320/77-03-05:
Inspection Criteria for instruction / guidance addressing this matter is in prepar item remains unresolved pending appropriate licensee actio n. This n.
(Closed Unresolved Item 320/77-03-06:
. Person p)erforming Inspection. Recording Identity of that the " Work Request Procedures" are now being notatedThe applicable " Surveillance Report" number and that the identi with the the persun performing the inspection appears on the rep of inspector reviewed several recent work requests and verified ort.
The the surveillance report number was notated on the work at that the respective surveillance reports did identify th request and performing the inspections.
e person (s)
(0 pen) Unresolved Item 320/77-03-07:
Activity.
The inspector reviewed a draft of procedure AP 1026 addressed the subject cf concern.
pending the approval and issuance of the procedureThis item remains u (0 pen Unresolved Item 320/77-03-0
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Preven)tative Maintenance Program. 8:
Assessment of Adequacy of the bility Data" system and the " Preventative Miinte The licensee representative e
a-provided the means by which to accomplish the subject asse rogram" perform the assessment was not established ssment.
o item remains unrasolved pending appropriate l nor was s ed.
This (0 pen) Unresolved Item 220/77-03-09:
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Capability to the Control Room.
Fire Watch Communication this subject in a governing procedure.The licensee has not yet addressed pending appropriate licensee action.
This item remains unresolved (0 pen) Unresolved Item 320/77-03-10:
and Modifications into Operation Training Progr Incorporating Design Changes
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Procedure AP cycle prior to approval.
_ approval and issuance of the subject procedure.This items remains review
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(0 pen) Unresolved Item 320/77-03-11:
Record Receipt Control.
Pro-cedure GP 0063, Revision 0, addresses checklists for designating required records and the recording of received records.
Procedure GP 0061. Revision 0, is in the final review process and it addresses the receiot and insoection of incoming records.
This item remai.ls unresolved pending the approval and issuance of the latter procedure.
(Closed) Unresolved Item 320/77-03-12:
Packaging and Storage of Special Processed Records.
Procedure GP 0063, Revision 0, addresses requirements for these types of records.
(Closed) Unresolved Item 320/77-03-13:
Record Storage Condensation Preventior.. Procedure GP C063 addresses _ the prevention of conden-sation in the record storage area (s).
(Closed) Unresolved Item 320/77-03-14:
Construction Phase Records Transfer, Record Retention Periods and Record Disposal.
Procedur.e GP 0063, Revision 0, addresses the areas of concern.
(0 pen) Unresolved Item 320/77-04-01: Completion of Facility Pro-cedures. Many procedures re:nain to be reviewed and approved by the
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Unit 2 Plant Operations Review Committee (PORC) and many approved procedures have data missing (including specific limits, vcive and panel numbers) or specific technical specification (TS) require-ments that differ from the proposed technical specifications or specified (TS) requirements not approved by NRR.
Detail 20 updates ccmpletion status.
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(Closed) Unresolved Item 320/77-04-02: Administrative Procedure
- 1001, Document Control, has been revised by Revision 8, dated April 12,1977, to require a 2 year periodic review schedule.
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(Closed) Unresolved Item 320/77-04-03: The licensee has written
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Superintendent Operating Memo !4, entitled " Departmental Standing Orders," that provides controls for standing ol ders.
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(Closed) Unresolvad Item 320/77-04-04:
Scope of procedural cover-ap for General Plant Operating Procedures.
The inspector verified scope of procedural coverage in areas listed under paragraphs 2.a to 2.j, Appendix A of Regulatory Guide 1.33 based on licensee issued operating procedures.
These areas covered plant startup, shutdown and operations.
Scope of procedural coverage for fuel
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handling equipment and fueling instructions (paragraphs 2.k and 2.1, Appendix A) could not be verified due to procedures being
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unavailable for review. This area is addressed in detail 13 of (
this report.
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(0 pen) Unresolved Item 320/77-04-05: The licensee revised Admin-istrative Procedure #1001 with Revision 8, dated Acril 12, 1977, The that added a new section 3.8 entitled " Procedure Usage."
inspector reviewed section 3.8 and identified items that appear to compromise the requirement for procedure adherence.
ANSI Standard H18.7-1972 defines the words shall, should, and may in section 2.2.1 as follows:
"The word 'shall' is used to denote a requirement; the word 'should,' to denote a recommendation; and the word 'may,' to deno e permission...."
' The licensee has utili ed the word "should" instead of '"shall" in the following subsections of procedure section 3.8.5 entitled "Use of and Implementation of Procedures":
3.8.5.1(a)
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3.8.5.l(b)
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3.8.5.2(a)
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3.8.5.2(b)
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3.8.5.3(a)
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3.8.5.3(b)
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3.8.5.4(a)
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3.8.5.4(b)
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The licensee also utilized the word "may" instead of "shall" in subsection 3.8.5.l(e).
The inspector also noted that the use of these words in the sub-sections identified above appears to contradict the requirement of subsection 3.8.3.1 which states in part: " Deviations from written prucedures may not be made except in emergencies."
The inspector discussed these items with the licensee and stateo
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that the use of words that provide or denote a recommendation or permission do not provide the requirement of procedu.e adherence.
The licensee agreed to review and evaluate this area to decermine if any action is necessary to ensure procedure adherence require-ments.
This is an unresolved item pending action by the licensee.
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(Closed) Unresolved Item 320/77-04-06:
Plant Staff responsibility /
authority minimun requirements not addressed in AP 1009, Station Organization and Chain of Command.
The inspector verified that the following procedure paragraphs have adequately addressed the minimum requirements of AtiSI N18.7-1972, paragraph 5.1.1, plant staff res::onsi-bilitier and authorities:
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AP 1009, Revision 2, Paragraphs 2. 8, 3. 2.1, 3. 2. 2, 3. 2. 4
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OP 2102-1.3, Revision 0, Paragraph 3.6
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OP 2102-2.1, Revision 0, Paragraph 2.3.8 (0 pen) Unresolved Item 320/77-04-07:
The licensee has revised AP 1011, Revision 12, with a Procedure Change Request (PCR #486) to require the Operations Supervisor to verify that he has not changed Leked valve positions specified in PORC approved prccedures.
The licensee does not yet have an approved copy of AP 1011 applicable to Unit #2.
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This item remains unresolved pending the inspector's review of AP 1011 approved for Unit #2.
(Closed) Unresolved Item 320/77-04-08:
Administrative Procedure
- 1012, Shift Relief and Log Entries, has been revised by Revision 7, dated June 20, 1977, to require operator review of the TCN book and defines what is considered to be a proper shift relief.
(Closed) Unresolved Item 320/77-04-09:
No acceptance criteria for parameters logged in the Reactor Building Entry List of HP 1630,
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Reactor Building Entcy. The inspector verified that adequate ac-ceptance criteria for these parameters are stated in the main body of procedure HP 1630. The inspector also verified that shift super-visor review of these parameters in reference to the acceptance criteria is required by procedure HP 1630 prior to entry.
(Closed) Unresolved Item 320/77-05-01:
Revise FSAR to provide cor-rected information for question 412.1/13.1.1.4 with respect to degrees held by personnel.
Amendment 54 to Lne FSAR, dated
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March 30, 1977, completed the required updating. This item is resolved.
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(Closed) Unresolved Item 320/77-05-02: Have individual T comolete the required FSAR training or document exceptions taken.
Amendment 54 to the FSAR, dated March 30, 1977, documented that one individual (individual T) entered the program at a coint different from the other cold license candidates and also documented the experience of that individual used to justify the differecces.
This item is resolved.
(Cloced) Unresolved Item 320/77-09-02:
Minimum documentation criteria for Certificate of Conformance.
The inspector determined that GP 4005, " Review of Procurement Documents", was revised (TCN
- 2, dated June 10, 1977) to include the required minimum documen-tation criteria for Certificates of Conformance.
(Closed) Unresolved Item '77-09-03:
Housekeeping Controls.
The inspector verified that S
..on Administration Procedure No.1008, Revision 1, was issued on May 23, 1977, which addressed Housekeeping and Housekeeping Zones.
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(0 pen) Unresolved Item 320/77-09-04:
The licensee stated that the list of components, systeas, and
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structures under the scope of the Met Ed Quality Assurance Plan for TMI 2 is currently under development.
This item remains open.
3.
Plant Tour The inspectors toured portions of the Auxiliary and Reactor Buildings shortly after arriving on site at 8:00 AM on June 20, 1977.
The inspectors observed several activities including a welding operation and a flame cutting operation, which had the required fire watches posted.
No items of noncomplic ce were identified.
4.
Precoerational Test Records
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a.
References 10 CFR 50, Appendix B, Criterion XVII
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GP 4012. " Surveillance Program, Noncomformance Reports,
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and Stop Work Orders," Revision 3 (
GP 4015, " Audit Finding Closecut Program." Revision 2
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b.
Audit Reccris The audit records listed below were selerted to verify that they were maintained in accordance with the administrative controls referenced in raragraph (a) above.
Audit Number Area Audited 77-02 Design Control 77-03 Organization 77-05 Non-conforming Material, Parts and Components 77-07 Document Control No items of nonccepliance were identified.
c.
OC Surveillance Records The QC surveillance reports listed below were selected to verify that they were maintained in accordance with the administrative controls referenced in paragraph (a) above.
OC Surveillance Reoort Numbers Evaluation Surveilled 77-95 Unit 2 Control Room Copy of Drawings77-126 Adjust Pressurizer Relief Valve Settings
.77-129 Installation of Startup Source Shroud Tubes77-137 Unit 2 Reactor Building Major Supports and Restraints77-144 Feed Pump and Turbine Alignment No items of noncompliance were identified.
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5.
Procurement Control a.
References 10 CFR 50, Appendix B, Criterion IV, VII and VIII
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GP 0013, " Evaluation and G;41?fication of Vendors and
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Contractors," Rc"sion 1
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GP 1009, " Procurement Document Control," Revision 0 GP 1011, " Preparation, Changing, Updating, and Issuance
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of Specifications and Bills of Material," Revision 1
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GP 4005, " Review of Procurement Documents," Revision 1
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GP 4010, " Approved Vendors List," Revision 1
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b.
Administrative Controls t
The inspector verified that administrative control directives, as in paragraph (a) above, are available to those preparing, reviewing, and approving procurement documents.
Procurement Document Review c.
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The inspector selected and reviewed a sample of four recently purchased safety-related items listed below to verify that:
procurement documents were prepared in accordance with admin-
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istrative controls, items were purchased frcm qualified vendors; procurement documents contained requirements for the vendor to supply appropriate documentation of quality, including cons ponent traceability.
The selected safety-related items reviewed were:
P. O. 47403 Recorders
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P. O. 47433 Digital Multimeter and Test Kit
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P. O. 47452 Multimeter 600 Amp Probe
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P. O. 47363 Ball Valves
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With respect to the referenced requirements in (a) above, no items of noncompliance were identified.
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Acoroved Bidders List The inspector verified that an approved bidders list is mz in-tained at the corporate office in accordance with the follow-ing adannistrative controls:
Acceptable t..ethods are established for " qualifying"
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suppliers; Provision has been made for the purchaser's right of
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access to supplier's facilities had documents;
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Records of supplier qualification and audit are maintained.
No items of noncompliance were identified.
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Sucolier Audit l
The ' spector reviewed the below listed supplier audi 3 to verify that the licensee is maintaining record of suoplie-qualification and audit.
Supplier Audit Number 76-23
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Babcock and Wilcox Power Generation Group Lynchburg, Virginia Supplier Audit Number 76-11
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Taledyne Isotopes Westwood, New Jersey
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Supplier Audit Number 76-12
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EIL Timonium, Maryland No items of noncompliance were identified.
6.
Receipt, Storage and Handling a.
References
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10 CFR 50, Appendix B, Criteria VII, VIII, XIII, XV and XVI (
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ANSI N45,2.2
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GP 1009, " Procurement Document Control," Revision 0
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GP 4008, " Receipt Inspection of Material and Enuipment,"
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Revisior 2 AP 1018, " Quality Control Warehousing," Revision 2
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5 tores Pr7cedure No. 4, " Material Storage"
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b.
Receiot Inscection TI.e inspector selected and reviewed a sample of six recently purchased safety-related items listed below to verify the items was conducted in accordance with the administrative control listed above.
The selected safety-related items reviewed were:
P. O. 232714 Diaphragm Valve Nuts and Studs
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P. O 226962 Gasket !!aterial
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P. O. 234072 Manway Gaskets
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P. O. 230999 Control Valve Spare Parts
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P. O. 229200 Diaphragm for Weir Type Valves
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P. O. 221656 Globe Valve Spare Parts
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With respect to the referenced requirements in (a) above, no items of noncompliance were identified.
Offsite Warehouse c.
The inspector toured the offsite warehouse located in Middletown, Pennsylvania to verify that appropriate cleanliness and environ-mental controls are maintained and that items received at thi warehouse are being sub3ected to the same receipt inspection
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No items of noncompliance were identified.
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Nonconfomina Items In the course of his tour of the offsite warehouse, the in-spector selected the following three safety-related items currently in storage that had been identified by receiving personnel to be in nonconformance with specified requirements.
NCR 77-32 (P. O. 219113)
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Required Documentation Not Received
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NCR 77-33 (P. O. 229536)
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Required Documentation Not Received
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NCR 77-142 (P. O. 47562)
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Required Certificate of Confomance Not Received The inspector reviewed these items to determine that:
parts were inspected upon delivery; parts were properly handled in accordance with measures established for control and sep-aration of confoming and nonconforming parts; and parts were supplied by an approved vendor.
t No items of noncumpliance were identified.
7.
Maintenance The inspector reviewed the extent to which the maintenance program had-been implemented.
Only one completed system (Nuclear River)
and several small portions of other systems have been turned over to the licensee.
Consequently, maintenance activity is limited and simple in nature (e.g. oil changes and equipment rotation).
The control and scheduling of maintenance tasks is incorporated into a computer program. The inspector reviewed the computer printouts and elected to verify that the maintenance for components NR-PlA, B, C and D had indeed been accomplished. The inspector revicaed Work Request 398 and NCR 77-185 which indicated that the required
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maintenance had been accomolished and necessary follow up action initiated. The inspector also determined that the established maintenance program was consistent with the status of system turnovers.
No items of noncompliance were identified.
This area will be reviewed during a future inspection.
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Desion Chances The inspector identified no instances of modifications t system or several partial systens that have been turned over t o the one licensee.
o the This area will be reviewed during a future inspection 9.
Tests and Exoeriments
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With respect to the are system and several partial syst had been conducted that were not described in the ems turned eriments the purview of 10 CFR 50.59 and the inspector identified came under instances.
no such This area wil? be reviewed during a future inspection
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10.
Surveillance Testinc and Calibration
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The licensee representative stated that the surveilla would be controlled and scheduled through a ccmouter prog nce activities would be initiated on or about July 1,1977.
ram and tive further stated that a similar computer program waThe licensee repr
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determined that the stage of program developmen s in use for m and mentation was consistent with the status of system turnove n
2 imple-rs.
This area will be reviewed during a future inspection 11.
Test and Measurement Ecuioment
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The licensee representative stated that one area had been
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for the storage of equipment but a second designated area h d established yet been turned over.
the statement. The inspecThe inspector toured both areas and verified a not ment shop was being stocke. tor noted that:
d; had been provided with shelves andthe establis cabinets; access was controlled; and cleanliness conditions we acceptable.
re This area will be reviewed during a future inspection
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Recc-ds The inspector determined that only the turnover documentation packages for one system and several partial systems and two sets (sica and corporate ofTices) of microfilm aperature cards (as b ui '.
engineering drawings) were the responsibility of the licensee.
The site sepia prints were the responsibility of the constructor, Record Storace, Retention and Retrieval a.
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The inspector noted tnat the storage of turnover records was not being acccmplished in accordance with ANSI N45.2.9 requi rements.
The licensee representative acknowledged this and presented NCR 77-195 for the inspector's review.
The inspector verified that this request for corrective action documented the storage discrepancies.
This item, Licensee Storage of Quality Related Records, is unresolved pending review of the licensee's corrective action.
(320/77-26-01)
b.
Encineerino Drawino Control The inspector reviewed engineering drawings to verify that they are being maintained in accordance with governing procedures.
The inspector-compared the site and corporate office master in-
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dices against the site sepia file and site and corporate offices microfilm aperature card files.
The selected drawings were:
2005, Revision 25, Flow Diagram Feedwater and Condensate
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2023, Revision 6, Block Diagrams 480 V MCC 2-32B Reactor
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Coolant Valves RC-VI and RC-V2 2033, Revision 19, Flow Diagram Nuclear Services' River Water
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3074 Sheet 46A, Revision 14, Reactor Building Air Cooling
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Fan AH-E-ll D 3075 Sheet 97, Revision 14, R. B. Emergency Booster Pump
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Discharge Valves
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The inspector identified that the master indices appeared to have had drawing 3074 entry for Fan D reversed with the drawing en for Fans A and B.
The inspector also identified that drawing 3075 entry on the master indices contained the word " coil" in the drawing title, which did not appear to be applicable to the drawing content.
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The licensee representative stated that ao-propriate action would be taken to correct the erroneous entries on the naster indices.
is unresolved pending review of the corrected master indic (320/77-26-02)
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13.
Facility procedures Scoce The inspector rev'iewed the licensee >s current index and file of a.
procedures to verify adequate coverage in accordance with the requirements of Regulatory Guide 1.33, Appendix A, in the fol-lowing procedural categories:
Administrative
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Procedures for Startup, Operation and Shutdown of Safety-
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Related Systems Emergency
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Abnormal and Alarm Response
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Maintenance
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Control of Measuring and Test Equipment
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Surveillance
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b.
The inspector noted that the licensee's established written pro-cedures do not cover all activities listed in Appendix A of Regulatory Guide 1.33 as. required by Technical Specification 6.8.1 in that:
(1)
Minimum Shift Complement (paragraph 1.f of Apperdiv A) and Loss of Containment Integrity (paragraph 6.f of Appendix A)
were not addressed in the facility procedures available to the inspector.
The licensee stated that the technical
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specification concerning minimum shif t remplement has not been finalized as yet and will be incorporated into the facility's administrative procedures.
In the area of Containment Integrity, the licensee is still considering how this item will be addressed.
This item is unresolved pending completion of action speci-fied by the licensee (320/77-26-03)
(2) The inspector could not verify adequate coverage since the following procedures were either unavailable or not ap-proved by Unit 2 PORC:
AP 1007, Control of TMI Records
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AP 1011, Controlled Key Locker Control
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AP 1005.16, Search of Individuals and Vehicles, Entries, Protected Area
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HP 1630, Reactor Building Entry
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OP 2104-5.4, Control Building HVAC OP 2107-1.4, Heat Tracing System
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OP 204-6.1, Fire Protection System
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Alarm List (AL) 2204-7 Series
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AL 2204-BA Series
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AL 2204-25.1 Series
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AL 2204-26 Series
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AL 2204-29 Series
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AL 2204-25.3 Series
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AL 2204-30.lB Series
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AL 2204-310 Series
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AL 2204-311 Series
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Alarm Response Panel Procedures referenced in
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AL 2204-12.Al A majority of the Surveillance, Fueling and Main-
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tenance Procedures This item is unresolved 7ending issue of the above speci-fic procedures and NRC:1 subsequent review of procedure scope in the Surveillance Fueling and Maintenance areas.
The licensee stated that completion of these proce" ares is expected by August 31, 1977. (320/77-26-04)
14. _ Facility Procedure Forrat and Content The inspector reviewed the below listed procedures on a sampling a.
basis to verify the following:
that their technical content was adequate to assure
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satisfactory performance of intended functions; that their format was in accordance with ANSI N18.7 and
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the licensee's administrative controls.
b.
The following procedures were reviewed:
Administrative Proceoures (AP)
1091 - Revision 10; June 23,1977, Docum2nt Control 1002 - Revision 9, February 23, 1977 Rules for the Protection
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of Employces Working on Electrical and Mechanical Apparatus 1004 - Revision 1, June 20, 1977, Section 12, Tornado Emergency Plan 1005.1 - Revision 6, May 24, 1977, Security Procedure 1005.4 - Revision 9, May 24, 1977, Instruction for Site Protection Force 1005.10 - Revision 8, May 24, 1977, Entry to TMI 1005.11 - Revision 7, May 24,1977, Access to and Within TMI
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i 86 021
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1007 - Revision 0, October 26, 1973 1008 - Revision 1, May 23,1977,, Control of TMI Records
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Good Housekeeping 1009 - Revision 1, March 6,1977, Station O Chain of Co, mand rganization and 1010 - Revision 10, November Surveillance Program 10, 1976, Technical Specification 1011 - Revision 12, June 6,1977, Controll d 1012 - Shift Relief and Lo9 Entries Key Lccker Control e
1013 - Revision 5, June 6,1977, Bypass of S f
.
. Jumper Log a ety Functions and 1014 - Revision 2, June 3,1975, Recall to Plant of Standby Personnel (
1016 - Revision 12, Operations Surveilla nce Program 1020 - Revision 3, November16, 1976 1021 - Revision 0. Plant Modification. Cleanliness Requir 1022 - Revision 3, June 1, 1977, Control of M
Equipment easuring and Test 1023 - Revision 2, March 14,1976,
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Test Equipmerit Recall 1026 - Revision 0, Corrective Maintenance a d M n
1027 - Revision 0, Preventative Maintenance achinery History 1028 - Revision 0, May 5,1977, Operator at th Ooeratino Procedures (0P)
e Controls 2102-1.1 -
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Revision 0, May 23, 1977
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, Unit Heatup 2102-1.2 - Revision 0, May 23, 1977
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, Approach to Criticality t
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2102-1.3 - Revision 0, May 25, 1977, Unit Startup 2102-2.1 - Revision 0,' June 17, 1977, Power Operations
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2102-3.1 - Revision 0, June 20, 1977, Unit Shutdown 2102-3.2 - Revision 0, May 17, 1977, Unit Cooldown 2102-3.3 - Decay Heat Removal VIA OTSG 2103-1.3 - Revision 0, May 31, 1977, Pressurizer Operation 2104-1.1 - Revision 0, March 11, 1977, Core Flooding System 2104-1.2 - Revision 0, May 13, 1977, Makeup and Purification
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System
.
A, B, C, D - Revision 1, May 3, 1977, Decay Heat Removal 2104-1.3 System 2104-1.4 - Revision 0, May 11, 1977. Reactor Building Spray Revision 0, April 5,1977, Emergency Feedwater
.i 2104-6.3 -
2104-12 - Revision 0, June 14, 1977, Emergency Diesel and Auxiliaries 2105-1.1 - Revision 0, May 31, 1977, Nuclear Instrumentation 2105-1.2 - Revision 0, June 12,1976, Reactor Protection System Revision 0, June 5, 1977, Safe:y Ft.ures Actuation System 2105-1.3 -
2105-1.11 - Revision 0, September 20, 1976, Communications System 2106-3.1 - Revision 0, March 18,1977, Turbine Generator 2107-1.1 - Revision 3 -April 15, 1977, BOP Auxiliary Electrical 2107-1.2 - Revision 0, December 27,1977, Class 1E Electrical System Surveillance Test Procedures (SP)_
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2301-M4 - Revision 0, December 7,1976, Remote Shutdown Instru-mentation
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2301-M5 - Revision 0, May 27,1977 RCP Seal Return Measurement 2301-M9 - Revisinn 0, November 9,1976, Building Spray Valve Line-up Verification 2301-Mil - Revision 0, November 9,1976, DHCCW Line-up Verification 2301-Q1 - Revision 0, December 3,1976, Station Storage Batteries 2302-Q1 - Revision 0, December 9,1976, Power Range Instrumentation 2302-Q2 - Revision 0, May 27, 1977, Hydrogen Analyzer Channel Calibration 2303-R4 - Revision 0, Dece..ber 16, 1976, Incore Detector Channel Calibration
,
2303-R9 - Revision 0, October 1,1976, Reactor Building Sump Level and Reactor Building Cooler Excess Condensate Level Switches Calibration 2303-M2 - Revision 0, April 13,1977, Decay Heat Removal Pump Functional Test 2303-M4 - Revision 0, December 16, 1976, Control Rod Movement
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2303-M12 A/B - Revision 0, May 5, 1977, Reactor Building Cooling Unit Operation
,
2303-M16 A/B - Revision 0, December 27, 1976, Emergency Diesel
,
Generator 2303-M27 - Revision 0, June 13, 1977, Motor Driven Emergency Feed Pump Functional Test 2303-SA3 - Revision 0, May 17, 1977, Hydrogen Recombiner Functional Test
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2303-R24 - Revision 0, June 5,1977, Pressurizer Code Safety Valve Check 2303-3D4 - Revision 0,. December lu, 1976, Fuel Canal Baron Concen-
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tration (
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2311-3 - Revision 0, June 5,1977, Rod Program Surveillance 2311-F1 - Revision 0, May 23,1977, Reactivity Anomaly 2313-SV2 - Revision 0, June 5,1977, Intermediate Range Channel Calibration 2602-R2 - Revision 0, June 15, 1977, Cecay Heat Removil low Calibration 2602-R10 - Revision 0, June 8,1977, Control Room Air Temperature Calibration 2602-R14 - Revision 0, June 8,1977, Containment Air Temperature Calibration 2602-R16 - Revision 0, May 10,1977, CSL Level Calibration Maintenance Procedures (MP)
(
1430-Y-7 - Revision 0, January 13, 1977, Temperature Indicator Repair Calibration M-82 - Revision 0, December 20, 1976, Maintenance of Idle
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Equipment
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2401-1.5 - Revision 0, March 11,1975, Use of Freeze Seals E-44 - Revisicn 0, April 9,1977, h[ Type DH-P Circuit Breaker Inspection and Testing
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2402-1.1 - Revision 0, July 18, 1976, Makeup and Purification Filter Replacement 2405-2.2 - Revision 0, November 29, 1975, 480 Volt Class lE Breaker Haintenance 2401-1.1 - Revision 0, June 30,1977, Reactor Coolant Pump Seal Inspection and Repair
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2".01-4.3 - Revision 0, March 25,.1975, 0.T.S.G. Grifice Plate
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Adjustrent (
Of
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IC-17 - Revision 0, December 10, 1976, Pressure Gauge Cali-bration IC-1 - Revision 1, December 10, 1976, Flow Loop Calibratio'
1420-LTQ-1 - Revision 1, March 19, 1977, A-Trouble Shooting Limitorque Valv? Operators and Control Circuits 1420-LTQ-1 - Revision 1, March 19,1977, B-Removal and Replacement of limitorcue Operators 1420-LTQ-2 - Revision 1, June 5,1977, Limitorque Operator
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Limit Switch Adjustment 1410-F-3 - Revision 1, May 31, 1977, Changing Reactor Coolant Letdown Pre Filter 1410-P-5 - Revision 1, May 31, 1977, Disassemble and Inspect Positive Displacement Pumps 1410-V-6 - Revision 1, May 31, 1977, Disassemble, Inspect and Repair Diaphragm Valves Emeroency/Abr.ormal Procedures (EP)
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2202-1.1 - Revision 1, June 8,1977, Reactor Trip
,
2202-1.2 - Revision 0, April 29,1977, Unanticipated Criticality 2202-1.3 - Revision 0, May 23, 1977, Loss of Reactor Ccolant/
Reactor Coolant System Pressure
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2202-1.4 - Revision 1. June 22, 1977, Loss of RC Flow /RC Pump Trip 2232-1.5 - Revision 0, March 11, 1977, Pressurizer System Failure 2202-1.6 - Revision 1, June 8,1977, High Activity in Reactor Coolant 2202-1.7 - Revision 0, August 13, 1975, Excessive Radiation 'evels
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2202-1.8 - Revision 0, October 18, 1975, Loss of Decay Heat Removal 2202-1.9 - Revision 1, June 13,1977, Loss of Intermediate Closed Cooling Water 2203-1.5 - Revision 0, February 24, 1977, Loss of R. C. Makeup o tside 2202-1.10 - Revision 1, April 4, 1977, Shutdown Frcm u
the Control Room 2202-3.1 - Revision 0, June 13,1977 Fire
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2202-2.1 - Revision 1, June 17, 1977, Station Blackout 2202-2.5 - Revision 0, January 29, 1976, Station Blackout with Loss of Diesels 2203-1.6 - Ravision 0, February 10, 1977, Nuclear Service Closed Cooling Water Failure 2203-1.7 - Revision 0, February 3, 1977, Nuclear Services River
!
Water Failure 2202-2.6 - Revision 0, June 5,1977, OTSG Tube Rupture 2202-2.3 - Revision 0. November 2,1976. ' oss of Instrument Air 2202-2.2 - Revision 0, February-24, 1977, Loss of Steam Generator Feed
.
2203-2.2 - Revision 2, February 10, 1977, Turbine Trip 2203-2.1 - Revisicn 0, June 11,1977, Load Rejection 2202-3.2 - Revision 0, May 27,1977, Flood 2202-3.3 - Revision 0, June 17, 1977, Earthquake 2203-1.1 - Revision 0, June 18, 1977, Loss of Baron (Moderator
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Dilution)
2203-1.2 - Revision 0, May 10, 1977, CRD Equipment Failure
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2203-1.3 - Revision 0, May 12,197/, CRD Malfunction Actions k
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Alarm Resoonse Procedures (AL)
Procedure Series 2204-4 (All procedures are Revision 0, January 12,1977)
4.Al RC Flow Runback 4.A3 Steam Generator A cn BTU Limit 4.A4 Reactor Master Control Statien in Manual 4.B1 High load Limit.in Effect
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4.82 Feedwater Limited by Reactor 4.83 Steam Generator B on BTU Limit
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4.B4 Steam Generator Reactor Control Station Master in Manual 4.Cl Low Load Ligit in Effect
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4.C2 Reactor Limited by Feedwater 4.C4 Feedwater A & B Control Station in fanual 4. 01 Loss of Feed Pur.p Runback in Effect 4.D2 Steam Generator A on Low Level Limit 4.04 Turbine Control in Manual 4.E4 Assymetric Rod Runback in Effect 4.E2 Steam Generator B on Low Level Limit 4.E3 Turbine Load Tncreasing 4.F1 Los's of R. C. Pump Runback in Effect 4.F3 Turbine Load Decreasing
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4.F4 ICS Cooling - Fan Failure iQ t
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Procedure Series 22C4-8 (All procedures are Revision 0, September 14, 1976 (except as noted))
8.Al Reactor Building Pressure Hi 8.A18 Fuel Storage Pool Level to 8.A33 Letdown Flow Temperature t!i 8.A40 Revision 0, June 5, 1977, 2A Diesel Fuel Storage Tank Level Hi/Lo
.
8.B4 Revision 1 June 5, 1977, 2A/2B Uuclear Service River Water Pump Trip 8.B12 2B Makeup Pump Motor Coolant Flow Lo 8.B19 Spent Fuel Coolant Filter Differential Pressure Hi 8.B26 Pressurizer Level Hi/Lc
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8.C1 2B Reactor Building Spray Pump Suction Pressure to 8.C17 2A/2B Core Flood Tank Level Hi/Lo 8.C23 Borated Water Storage Tank Level Hi/Lo 8.C28 Revision 0, June 5,1977. Reactor Coolant Total Flow to 8.D5 Revision 1, June 5,1977., 2B Nuclear Service River Water Strainer Differential Pressure Hi
.
8.D14 Intennediate Cooling Pump Trip
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8.D17 Core Flood Valve Position Abnormal (Closed)
8.D37 Makeup Pump Trip 8.E7 Revision 0, June 5, 1977, 2A Diesel Generator Ccoling Water Outlet Flow to
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8.E10 Decay Heat Closed Cooling Water Pump Trip
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8.E12 Revision 0, June 5, 1977, Seismic Recorder On 8.E32 Revision 0, flovember M,1976. Reactor Ccolant P Vibration Hi ump 8,F17 Red Channel Bypass 8.F24 Blue Channel Detector Power Supply Fault 8.F23 Revision 0, June 5,1977, Reactor Coolant Pressur Lo Lo e
8.F30 Revision 0, June 5, 1977, Reactor Ccolant Outl t Temperature Hi e
Procedure Series 2204-12 12.Al Revision 0, April 21, 1977 PJiS Trouble Procedure Series 2204-13 13.A3 Revision 0, March 29, 1977, Bypassed Safety Injection flot
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Procedure Series 2204-17 17.A7 Cold Condenser Vacuum to 17.87 Hot Condenser Vacuum to 17.C5 Revision 0. September 16, 1976 Motor Driven Emer gency Feed Pump Overload
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17.01 Revision 0, August 25, 1976, Battery Room #1 H centration Hi 2 Con-17.E7 Revision 0, January 12, 1977, Trip Condenser Vacuum Pump 17.E14 Revision 0,tiovember 2,1976, 2A Steam Generator L Hi/Lo
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evel
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17.F12 Revision 0, tiovember 2,1976 SG 2A/2B Steam Li Rupture Trouble ne t
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Procedure Series 2204-18 (All procedures are Revision 0, November 11,1976)
18.A21 480V ES Bus 2-11 E/2-21E D C Loss 18.B20 4KV ES Bus 2-1E/2-2E Main Breaker Posi? ion Switch Mismatch 18.C21 480V ES USS 2-11E/2-21E Transformer Tcmoerature Hi 18.D22 480V ES Bus 2-31E/2-41E Main or Tie Breaker Trip 18.518 Giesel Generator Switchgear 2DG-1/2CG-2 D C Loss 18.F9 Engineered Safeguard Bus Between Unit 1 and Unit 2 Overcurrent Procedure Series 2204-19 19. A4 Revision 0. November 2,1976, Vital Power Supply 2-1V Loss of Alternate Source i
19.A12 Revision 0, November 2,1976, Vital Pcwer Supply 2-1V Fuse Blown 19.B10 Revision 1, April 9.1977, Circuit Breaker 2DC-22E Tripped 19.F9 Revision 0, November 2,1976, Vital Power Supply 2-3V Low D C Voltage
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Procedure Series 2204-25 (All procedures are Ravision 0, January 6,1977 (except as noted))
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25.2A2 Control Room Supply Bypass Fan AH-E-4A, B Trip 25.287 Cable Room A Supply Filter AH-F-23A Limit 25.2C8 Revision 0, April 19, 1977, Air Intake Tunnel C12
.
Monitor AH-CIS-5484 25.4A1 Fuel Building Supply Fan 41-E-9 A/B Trip
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25.4C3 Fuel Building flew Fuel Storage Elevation 331'
Temperature Hi
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25.5A2 Diesel Generator Building Vent Fan B Trip Procedure Series 2204-200 301A.A2 Revision 0, February 24, 1977, Reactor Building Sump Level Hi 301A.C3 Revision 0, February 24,1977, 2A DM Removal Pump Room Sump Level Hi 302B.A3 Revision 0, April 13,1977, fi2 Gas to Core Flooding Tanks Pressure Hi/Lo 302B.B3 Revision 0, April 13, 1977, fl2 Make-up Core Ficod Tanks Pressure lo 102B.D3 Revision 0, April ~13,1977, fl2 Gas to Reactor Building #20 Supply Pressure Lo/Hi I
303.A5 Revision 0, March 11, 1977, 2-BA Pumps Overload Trip 306.Al Revision 0, February 2,1977, Lcw Flow (Mays Gas Analyzer)
315.C3 Revision 1, February 14, 1977 Hot Instrument Repair Shop Temperature Hi
.
317.A6 Revision 1, June 5,1977, Control Building Area Fans
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Low Flow
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518.A3 Revision 0 June 13, 1977 Evaporative Coole? E-Z-1 A Temperature Hi 318.B4 Revision 0, June 13, 1977, Reactor Building flormal Cooling Water Pumps RB-P-1A, 1B Trip 319.A6 Revision 0, April 4,1977, Air Intake Tunnel F Fire Door Closed
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320.A5 Revision 1, February 15, 1977, River Water Pump House Switchgear 2-4E Room Temperature Hi 340.A5 Revision 1. Pay 27,1977, "A" Instrument Air Com-pressor Air Discharge Tempe;ature Hi 34).A2 Revision 0, February 24, 1977, "A" Service Air Com-pressor Discharge Pressure Hi 341.C4 Revision 0, February 24, 1977, "C" Service Air Compressor Air Discharge Temperature Hi
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Procedure Series 2204-9
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9.A4 Revision 0, May 5,1977, R. C. Bleed Hold-up Tank Pressure Hi No discrepancie.i were identified with respect to format re-c.
quirements of A' 5I N18.7 and the licensee's administrative controls.
!
d.
Unresolved items noted with respect to content of the licensee's facility procedures reviewed by the inspector are specified in details 15 to 19, covering the following areas:
Adminis trative Prc<.edures, Operating Precedures Emermcy/ Abnormal Procedures, Sarveillance Procedures, Alart, Respon i 1-rocedures.
No discre-pancies with respect to content were nuted in the area of Maintenance Procedures.
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15. 1.irensee Review of Facility Procedures
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As a result of the review of facility procedures on a sampling basis the inspector noted several discrepancies which were not merely typographical errors but were errors that significantly affected the intent of the procedure. The following discrepancies were noted along with the licensee's proposed corrective action in each case:
'OP 2102-3.2, paragraph 2.2.7 states in part that if the Reactor a.
Vessel Head is to be removed " Reactor Coolant System boron concentration must be raised to refueling concentration of
_
1800 ppmB or to a K eff 1 95 whichever is least." This is ambiguous with respect to T.S. 3.9.1 which requires Reactor Coolant System boron concentration to be raised to 1800 ppmB or core K eff is to be less than or equal to.95, whichever is the most restrictive.
The licensee stated that the paragraph (
shall be revised to more accurately reflect the T.S. require-l ment.
4
f 0C
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b.
OP 2104-1.1, paragraph 4.1.1 references precaution paragraphs (2.2.2(4) and (5)) for the nitrogen pressurization of the Core Flood Tanks with Reactor Coolant 3ystem Temperature less than 275 F (the minimum pressuri:ation temcerature (MPT) limit).
The referencea paragrapns did not exist in OP 2104-1.1.
The licensee stated that paragraph 4.1.1 would be revised to adequately address precautions associated with the evolution.
SP 2301 M-9, Appendix A and B lists those valve positions in c.
the Reactor Building Spray System which are to be checked per T.S. surveillance requirenent 4.6.2.la since those valves are not locked, sealed or otherwise secured.
The inspector noted that the following valves are not locked, sealed or otherwise secured and yet they were not included in Appendix A and B:
BS-V120 A, B, BS-DPI-1405/1403 Root Valve
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BS-V121 A, B, BS-DPI-1405/1403 Root Valve
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BS-V104, Recir to BWST
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BS-V131, Drain
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BS-V134, Drain
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BS-V150, Test Connection Isolation
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BS-V151 Test Connection Isolation
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The licensee acknowledged this list and stated that SP 2301-M9 will be revised to incorporate the above valves.
d.
The inspector noted that OP 2105-1.7, Secondary Plant and Auxiliary Control System Instrumentation was not listed as a prerec;uisite in procedures governing plant heatup, startup or power operations.
Section 5.3.4.1 of ANSI N18.7 requires that startup procedures include a determination that prerequisites have been met. The licensee acknowledged this and statad that it will incorporate GP 2105-1.7 as a pre-requisite to the system operating proc ^.iure governing Main Steam Startup.
e.
OP 2103-1.3, paragraph 4.1.5.2 states that the Reactor Coolant System (RCCS) NDTT Limit is 530 psig.
B&W Technical Document
- 7-1002171-00, Item 1.0-28 confirms this value.
However, para-graph 4.1.1.1 of the same procedure states that the set 9oint initiated by the NDTT Key Switch AUTO is also 550 psib', The
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86 01
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licensee stated that this key switch reduces RCS set relief pressure to this lower setpoint for operations below MPT.
The inspector subseouently pointed cut that if the relief valve was set allowing a + tolerance it appeared the NDTTThe limit would be exceeded.
stated that the relief will be set at 500 psig and the pro-cedure would be revised to reflect this.
A, B, C (Decay Heat Removal System) references which do not exist.
The referenc?d f.
OP 2104-1.3 figures in C7 2101-3.1 figures are concern?d with operating limits of the syste:,..
21 01 - 3.1 originally was t; be The licensee stated that OP a compilation of Reactor Plant Curves and Figure The inspector noted this individual operating procedures.
paragraphs erroneous reference in the following paragraphs:in each subsection 2.2.3, 2.2.4, 2.2.5, 2.2.6 1.4.1, 1.4.2, paragraph 4.0 in subsection A; paragraphs 1.4.1, 1.4.2, 1.4.3, 4.3 1.4.3 in subsection B; par agraphsThe licensee stated that the coplicab in subsection C.
curves and graph for this system wili be incorporated into the procedure and the erroneous references will be deleted, Technical SF 2302-Q2, " Hydrogen Analyzer Calibration."
Specification 4.6.4.1 specifies that calibration be pe g.
The calibration procedures uses a test gas composed of The licensee stated that the procedure hydrogen and air.
would be revised to accurately reflect T.S. requirements, Ap-SP 2302-M2, " Decay Heat Removal Pump Functional Test."
pendix A and B valve checkoff sheets both speci.fy only one h.
sodium hydroxide tank valve be closed, when a review of P&lD's and discussions with personnel indicate that in fact The licensee stated that both valves should be closed.
the procedure would be revised to reflect both valves being closed during the test.
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035
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The inspector noted the following items with respect to the adequacy of surveillance procedure acceptance criteria:
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SP 2502-R10, No tolerance limits specified SP 2302-Ql, No tolerance limits specified
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SP 2302-R9, in reference to Containment Sump Level
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Calibration for limit switch WD-LS-1315, the tolerance on the applicable data sheet is specified as "2% of 6 foot = 1.4" but maximum error values specified as + 1.44 appears to conflict the tolerance range.
SP 2302-Q2, has acceptance criteria which states "Ac-
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ceptance of the calibration is left to the discretion of chemical supeevisor upon reviewing the accompanying data sheet and graph.
These items are contrary to 10 CFR 50, Appendix B, Criterion V which states in part:
"... I..:'Juctions, procedures, or drcwings shall include appropriate quar.titative or qualitative accentance criteria for determining that important activities have been satisfactorily accomplished."
The licensee stated that the above procedures will be revised to more accurately specify surveillance acceptance criteria.
j.
Procedure 2202-1.9 specifies to restore letdown flow in the FOLLOW UP ACTION steps 3.9 and 3.10, however, there is no indication in the SYMPTOMS or IMMEDIATE ACTION sections of the precedure that a letdown isolation has occurred.
The licensee acknowledged the inspectur's comment and stated tha+
the letdown isolation should be included in the SYMPTOMS sect.on of the procedure.
The licensee will revise procedure 2202-1.9 to include this information.
k.
Procedure 2203-1.1 specifies various paths through which demineralized water can be admitted into the reactor coolant system via the make-up pumps. The procedure also describes
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the corrective action that is required to stop the moderator dilution.
The inspector identified an additional demineralized
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water pa.th (via MU-V290) that could result in moderator dilution.
The licenree will revise 2203-1.1 to include the additional dilution path.
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1.
Procedures 2204-4.D2 and 2204-4.E2 specify in the Manual Action Required section to " Increase load if necessary." The inspector stated that increasing load with a low level condition in the steam generators appears to be in conflict with standard operating procedures.
The licensee acknowledged the inspector's concern and af ter considerable review, stated that the statement should refer to
" level" in lieu of " load."
The licensce will revise the procedure to specify -the correct action to be taken.
The inspector pointed out to the licensee that the above items
.
should have been identified and corrected by the licensee's review and approval program for these procedures in acccrdance with 10 CFR 50, Appendix B, Criterion VI which states in part:
" Measures shall be established to control the issuance of documents such as... procedurt s..
including changes thereto which prescribe all activities affecting quality.
These measures shall assure that documents, including changes are reviewed for adequacy...."
,
The licensee acknowledged this and stated that some of these errors could have been corrected during
proof reeding process besides the review process for facility procedures and changes thereto.
.
In a telephone conversation subsequent to the inspection the licensee stated that a PORC Mecting was conducted on July 11, 1977 in which emphasis was placed en " attention to detail" in reviewing procedures prior to final approval, in addition to assignments concerning the correction of the inspection findings in the facility procedures area.
Subsequently, the inspector expressed concern that approved facility procedures not reviewed during the inspection would e.xhibit similar problems.
The licensee acknowledged this and replied that the " Red-Line Program" shcu.u correct any errors in tisis area. The licensee described this program to the in-spector as a procedures verification system by Operational Personnel at the time of system turnover.
The licensee stated that this verification is to include such items as a " dry-run"
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of the p mr re, a valve panel number verification, a check foi comp'
%cility procedures with respect to missing data or fill-in type information that was not available at the time of pro-cedure review and approva'.
In addition, the licensee stated that the importance of t'.e Red-Line Program has been emphasized to Operational Pe. sonnel and will be so documented by memorandum
.
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The licensee furt!r stated that procedures identified in this detail with noted errors along with other selected important facility procedures will be reviewed by shift supervisors to correct the above errors and any other identified with respect to content.
In addition, the licensee stated that the pro-cedures reviewed by the shift supervisors will be documented on a list and will be available for flRC:I review for adequacy.
These items are unresolved pending correction of the above noted pmcedural errors, documentation by the licensee em-phasizing the Red-Line Program and completion of shift super-visor procedural review.
(320/77-26-05)
16. Administrative Procedures As a result of the inspector's review of Administrative Procedures noted in detail 14 the following unresolved items were identified:
AP 1001, Document Control a.
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(1)
Section 3.9 addresses periodic review of procedures. Sub-I section 3.9.2 specifies that Operating Procedures. Emer-o cedures be reviewed a mininum of every 2 years.gen
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Proposed Technical Specification (T.S.) 6.8.2 reouires Specification 6.8.1. periodic review of the procedures identified in 6.8.1 includes the procedures covered in subsThe procedure i
and also includes additional procedures (e.g.ection 3.9.2 Operations, etc.) that are not covered in subsect procedures
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3.9.2.
periodic review requirements.These procedures must be include
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This i'.am is unresolved.
(320/77-26-06)
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Subsection 3.9.3 through 3.9.5 specify the type of review, (2)
the review documention requirements, and the review responsibility that is necessary to meet the procedure These sections do not periodic review requirements. include a requirement for the POR review results as required in Technical Specification 6.8.2.
This item is unresolved.
(320/77-26-07)
Appendix B lists procedures that are considered to be (3)
nuclear safety-related.
During the review of this ap-2104-5.13, pendix, the inspector noted that procedureFire Pump Ho Discussion with the licensee revealed that the applica-bility of this procedure for this list is still being investigated.
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This item is unresolved pending the results of this investigation.
(320/77-26-08)
Temporary Changes to Start-up Valve Checklists are pro-(4)
vided in accordance with a note to subsection 3.6.4.1.
This provision, however, does not include a requirement to date the changes nor does it provide a requirement to cancel the change af ter a specified time period or after the temporary condition no longer exists.
The inspector noted that such conditions are specified for the Temporary Change Notices (TCN's).
.
The licensee will investigate this area and determine
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what methods will be used to cancel these changes.
This item is unresolved.
(320/77-26-09)
b.
AP 1012 The Purpose and Scope of,this procedure did not address the requirements for shif t relief even though these requirements are included in the body of the procedure.
The licensee will revise the procedure to address shift relief
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in the Purpose and Scope.
This item is unresolved.
(320/77-26-10)
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rum
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e 86 039
_
c.
AP 1022 The procedure does not specify a separate storage area for test and measuring equipment that may beccme uncalibrated or damaged during usage.
The inspector stated that this equipment should be separated from calibrated equipment to prevent its ac-cidental use and to assure it is designated for repair and/or recalibration.
.
The licensee acknowledged the inspector's ccaments and stated that the practice of separation of defective or uncalibrated equipment frcm calibrated equipment was already in effect.
The licensee further stated that procedure 1022 would be re-vised to document the performance of this practice.
This item is unresolved pending the licensee's revision to procedure 1922.
(320/77-26-11)
d.
AP 1026
.
Uses "Addendums" in section 4.3.2.2 to make changes to the maintenance procedures.
In addition the inspector noted that section 4.3.2.1
allowed PORC approval for these Addendums via the telephone.
The inspector stated that such telecon aporoval must be fol-lowed up by PORC Ccamittee approval as specified in proposed Technical Specificaticn 6.8.2.
The licensee acknowledged the inspector's comment and will in-vestigate this matter to determine how PORC Committee review will be implemented.
This item is unresolved.
(320/77-26-12)
The inspector's review of Procedure 1027 noted that the licensee e.
intends to use a Preventative Maintenance Check Sheet in lieu of a Work Request to perform preventative maintenance (FM).
With regards to this Preventative Maintenance Check Sheet the inspector had the following coccents:
(1) The check sheet does not provide a space for the Shift Supervisors / Shift For2 mans signature (as required by pro-
-
cedure 1027) to authcrize perforrance of the PM.
,
<
m
.
i I
040
-
_
(2)
There is no provision on the check sheet (nor in procedure 1027) requiring an operational test prior to returning the system to service.
(3)
The check sheet does not provide a space for Quality Contro's signatures (as required by procedure 1027) prior to perfoming the PM.
(4)
The check sheet does not provide spaces for Quality Control of the PM to authorize the return to service.and Shift The licensee will revise procedure 1027 to incorporate the above
-
coments.
,
This item is unresolved.
(320/77-26-13)
f.
The inspector's review nf the licensee's administrative process identified the use of Superintendent's Operatin addressed special operations, system turnovers,g Memos that activit'es of the PORC, and the use of Departmental Standing duties and Orders.
.
The inspector stated that this type of information falls under the pervue of ANSI N18.7-1972, sections 5.1.3 and 5.1.4 and to specify periodic review, and to provide for upd
,
,
cancellation.
.
The licensee acknowledged the inspector's coments and will Control, to address the Superintendent's Operating This item is unresolved.
(320/77-26-14)
17. Doerating Procedures
'
As a result of the inspector's review of operating procedures noted in detail 14, the following unresolved items were identified:
During the review of Operating Procedures governing plant heatup a.
approach to criticality and power operations, the inspector noted that several system prrcedures were not identified as prerequisite to these procedures.
These system procedures are:
-
OP 2105-1.8, Radiation Monitoring
-
OP 2106-1.5, Turbine Bypass
-
(
OP 2104-6.4, Hydrogen Recombiner Operations
-
86 00
~
.
..
The inspector noted to the licensee that ANSI N18.7, paragraph 5.3.4.1 requires that startup Procedures " include a determination that prerecuisites have been met including... valves pro-perly aligned... necessary system procedures completed...."
The licensee acknowledced this and stated that the above pro-cedures are verified operable by surveillance procedures as-sociated wir.h these systems ar.d these surveillance procedures are identified in the various mode to mode check lists, which are an integral part of t'.e general plant operating procedures.
However, the subject surveillance procedures have yet to be issued.
This item is unresolved pending issuance and NRC:I review of
.
these applicable surveillance procedures and inspector veri-fication that these procedures have been incorporated into the mode check list of the general plant operating procedures.
(320/77-25-15)
'
b.
During the review of the following procedures, the inspector noted that provisions for filling and venting systems were not delineated as required by ANSI N18.7, pa agraph 5.3.3:
s OP 2104-6.3, Emergency Feedwater
-
OP 2104-6.2, Diesel System
-
OP 2104-1.3,
.
Decay Heat Removal System (Jacket Ccolant)
-
The inspector noted that these procedures did include a pre-caution to ensure a pump or cooler with associated piping was filled and vented but specifics as to how this was to be accomplished, especially for the entire system and what con-trols were to be administered during the fill and vent evolu-tion were not addressed.
The licensee stated that the extent of maintenance conducted on a system would determine the extent of the detailed procedure used for filling and venting as a prerequisite to system / component operation and thereby would be delineated in the Maintenance Work Request Procedure.
.
The inspector then reviewed administrative controls in this area by reviewing AP 1026, Corrective Maintenance and Machinery History (which was a draft copy) and noted that the section concerned with the Work Request Procedure Details (paragraph
.
4.3.1.2) does not address filling and venting of mechanical systems as part of post-maintenance testing or return of the system to normal.
'
.
%
i o6 062
-
I
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licensee acknowledged this and stated that administrative The cone--ols would be specified in AP 1026 to insure mechanical sys-~~e. filling and venting procedures are delineated in
-
mar
- enance procedures.
item is unresolved pending completion of the above action
-
Th
-
by
- e licensee.
(320/77-26-16)
Frocedures 18.
Emercen E a.
As
-
result of the inspector's review of Emergency Procedures no:~.ed in detail 14, one unresolved item was identified.
'
b.
Pr :c edures 2202-2.1, 2202-1.8, 2202-2.5 and 2202-2.3 allow or-crovide for steaming to the atmosphere during certain ac-ce:ent conditions.
The inspector stated that a precaution sr-- u id be included in these procedures to assure that such ac-on is not taken if a steam generator tube leak or rupture ic-evident. The licensee concurred with the inspector's com-mer _s and stated that th; procedures will be revised to im: ude such precautions.
(
-
rriis item is unresolved pending revision of the applicable p e cedures.
(320/77-26-17)
19. Alam w oonse Procedures
'a.
/.s a result of the inspector's review of Alam Response Pro-cedures noted in detail 14, one unresolved item was identified.
b*
Procedure 2204-319.A6 specified in MA!!UAL ACTI0tl REQUIRED section, item 3, to reset and open the damper if closure occurred due to fire protection system operation.
The inspector stated that it appeared the dampers were being opened during a fire condition. The licensee stated that the fire protection system procedure 2104-6.1 was not availa-ble for review at this time so that a proper evaluation of the response action could not be made.
This item is unresolved pending review and evaluation of pro-cedure 2104-6.1 and its interface with procedure 2202-319.
(320/77-26-18)
~
.
,
i j
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Q h eM l
.
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20.
Completion Status of Facility Proced' ires (Unresolved It 04-01)
em 320/77
'
a.
The inspector obtained the following current status of cc pletion as of July 8,1977 for the facility procecures pro m-gram:
-
Procedure Cateaory
/ Procedure f_ Reviewed (PCRC)
- (%)lssued Administrative
22 18 (70)
Operating
.
116 110 Surveillance 109 (94)
193 115 Emergency / Abnormal 71 (37)
32 Health Physics 32 (100)
81 Chemistry 67 (80)
68 Fuel Handling 59 (79)
37 Security 36 (88)
7.0 Maintenance 18 (90)
28 25 (81)
b.
The inspector completed the review of the are documented in details 13 to 19 of this report.
However, the licensee's facility procedures are incompl t c.
-
therefore, the item remains open with respect to the f ll e e and
-
'
areas:
o owing (1)
missing from the approved procedure:The following OP 2105-1.11, page 24:
-
actuation of site alarmsNo panel #'s for manual OP 2102-1.1, Appendix A:
-
Facility and Industrial Wasta SystemNo procedure # for Sludge
_
OP 2102-1.1, Appendix A:
-
<
Checklist not documented Mode to Mode Surveillance i
86 044 b-
.
,
Axial Power Shaping Rod Limits not specified in fol-
-
lowing procedures:
OP 2102-1.3 (paragraph 2.1.20),
OP 2102-2.1 (paragraph 4.10', OP 2102-3.1 (paragraph 2.1.20)
Load Rate of Change Limit not specified in the fol-
-
lowing procedures:
OP 2102-1.3 (paragraph 4.1.3),
OP 2102-1.3 (paragraph 4.1.25b), OP 2102-3.1 (para-graph 4.1.22b)
OP 2102-2.1, paragraph 3.9:
Secondary Water Chemistry
-
Limits not specified OP 2102-3.2, Appendices A and B:
Blank
-
OP 2102-3.2, Figure 3:
Blank
-
OP 2102-3.1, Appendices A and B:
Blank
-
OP 2104-1.30, paragraph 4.3.1:
Location and Procedures
-
for installation of flow indicator in Mode 2 Gravity Draining of Reactor Coolant Hot Leg to Reactor Building Sump not specif Md
.
OP 2104-1.30, paragraph 4.1:
Maintenance procedure #
-
not specified for installation of temporary power supply to selected valve'in DHR System -
-
,
OP 2202-3.1, paragraph 2.2.b and Appendix B, paragraph
-
3.3.3(b):
Panel # for Manual actuation of Site Fire Alam not specified OP 2104-1.1, paragraph 2.2.3.2 and paragraph 4.1.4: Core
-
Flood Tank maximum value not specified OP 2105-1.3, paragraphs 4.1.6 and 4.1.7:
Safety Feature
-
Actuation System Panel Lamp Labels not specified for startup verification OP 2202-2.6, paragraph 2.6.2.0: Ganra Analysis Chemistry
-
Procedure nct specified OP 2103-1.3, paragraph 2.2.8:
Pressurizer Water Volume
--
minimum and maximum requirements not specified
.
s
.
I 860 hf i
_
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OP 2104-6.2, paragraph 2.1.2.2.4, paragraph 4.3.6,
-
paragraph 4.8.1.3:
Prelube Time on Diesel Startup not specified OP 2104-6.2, paragraph 2.2.3:
Diesel System Tank
-
minimum volumes not specified OP 2104-6.2, Attachment 2:
Diesel system values not
-
numbered for startup verification AL 2204-4.1-4:
Panel ! in " Manual Action" Section
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missing
-
AL 2204-8.A1:
Panel # in " Manual Action" Section
-
missing AL 2204-18.F9:
Setpoint is specified as "later"
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SP 2302-R9, paragraph 1.1:
Does not address all Techni-
-
cal Specification. paragraphs for the purpose of the surveillance test (2) The following procedures are incomplete in that T.S. re-quirements are different than those specified in the pro-cedure and the procedure limits represent proposed limits which have not been approved by NRR as yet:
OP 2102-1.3 (paragraph 4.1.3) refers to T.S. Quadrant
-
Power Tilt Limits which are less conservative than the same limits specified in OP 2102-2.1. Table 1.
The
,
i licensee has submitted a change to the proposed T.S.
reflecting the more conservative values.
g i
OP 2102-1.1 (paragraph 4.3.4) is similar to the above I
-
with the exception that Reactor Coolant System (RCCS)
l Chemistry Limits is referenced.
OP 2102-2.1 (para-
-
graph 2.26) reflect the more conservative values.
_
^
.
L
046
.
OP 2103-1.3 (paragraphs 2.2.6 and 2.2.7) state that
-
Pressurizer Code Safety Setpoint is 2450 + 1% psig while T.S. 3.4.2 states that the setpoint is 2435 +
1%.
The licensee has requested c T.S. change to tee 2450 value.
OP 2105-1.2 (paragraph 2.2.1) specifies Reactor
-
Protection System Instrumentation mininum number of operable channels one less than T.S. Table 3.3-1.
The licensee stated this issue is being discussed with NRR.
-
~
OP 2105-1.2 states that the High RCS Pressure Trip
-
'
when in " Shutdown Bypass" is < 1820 psig while T.S.
Table 2.2-1 requires < 1720.
The licensee stated this issue is being discussed with NRR.
SP 2303-M16A/B (paragraph 1.1.1) specifies a minimum
-
fuel day tank volume of 500 gallons while T.S.
3.8.1.1 requires 550 gallons.
The licensee's change
to the proposed T.S. states 500 gallons.
SP 2301-M4 Channel Check of Shutdown Panel does not
-
check control rod position limit switches per the T.S. Table (3) The inspector could not verify the adequacy of the following reviewed procedures because T.S. requirements specified in the procedure have not been approved by NRR or are not listed as yet in the proposed T.S.-
T.S.'Recuirement As soecified in Procedure Figure 3.4-2 and CP 2102-1.1 Figures 1, 2, 3
-
3.4-3 (RCS Cooldown/
OP 2103-1.3 Figures 4 and 6 Heatup Limits)
OP 2102-2.1 Figure 7 OP 2102-3.2 Figures 1, 2 OP 2102-3.3 Figure 1.S.2 Figure 2.1-1 GP 2102-2.1 Figure 1
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(RCS Pressure vs.
Temperature Limits)
_
(
.
bb
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I
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Figure 2.1-2 OP 2102-2.1 Figure 2 (Ther:ml Power Axial Power Imbalance)
-
Figure 3.1-2, 3.1-3 CP 2102-2.1 Figures 3, 4, 5 (Regulating Rod Position Insertion Limits)
T.S. Reouirement As soecified in Procedure
-
Figures 3.1-4 and 5 OP 2102-2.1 Figure C (Rod Program Limits)
Figure 3.2-1, 2, 3 OP 2102-3.1 Figure 2
-
(Axial Power Imbalance Limits)
.
-
LCO 3.1.3.5 (Rod Drop CP 2102-2.1 (paragraph 2.15)
Times)
-
LCO 3.2.2 (Axial Peak OP2102-2.1 (paragraph 2.20)
Factor)
~
LCO 3.2.3 (Thermal Peak OP 2102-2.1 (paragraph 2.21)
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(Factor)
LCO 3.4.6.2 (RCS OP 2102-2.1 (paragraph 2.25)
-
Leakage)
EP 2202-1.5 (paragraph C.3.1)
LCO 3.1.2.9bl and 2 CP 2102-2.1 (paragraph 3.23.2)
-
(Operable BWST)
LCO 3.4.4.b Minimum.
OP 2102-2.1 (paragraph 3.5.2)
-
Pressurizer Volume
.
LCO 3.4.5 (Operable OP 2102-2.1 (paragraph 3.6)
-
SteamGenerator)
LCO 3.7.13 (CCT OP 2102-2.1 (paragraph 3.11)
-
Minimum level)
'
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LCO 4.8.2.3.2bl and 2 SP 2301-Q1
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(Battery Operable)
L
{
048
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!
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. Functional Test of Motor SP 2303-M27
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Driven Emergency Feed Pump Reactor Building 2302-M12A/B
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Cooling.
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Decay Heat Removal 2303-M2 Pump Functional Test With respect to the items listed in details 20.C.(1) above, the licensee stated that the procedure verification program
-
(described in detail 15) will correct these items and those similar items in procedures not specifically addressed by the inspector.
With respect to items listed in details 20.C.(2) :nd (3) a
_
meeting with NRR is scheduled for late July 1977, with respect to the proposed technical specification for resolution of the noted issues above and that once T.S. requirements are ap-proved by NRR the applicable procedures differing from T.S.
wili be revised.
The items listed above in details 20.C.(1), (2) and (3) are considered identified under unresolved item 320/77-04-01 and remain unresolved pending approval of Unit 2 Technical Speci-fications by NRR and completion of the procedure verification program for Unit 2 Procedures.
d.
In addition the licensee stated that 100". procedure completion prior to the issuance of the operating license (OL) will not be accomplished since scme procedures will not be needed till well past the OL date, the procedures are tenned " nice to have" I
but not required for the safe operation of the facility or the l
procedures cover systems that will not be installed at the
time of OL and are not required for the safe operation of the facility.
The licensee emphasized that the manpower expended of these type of procedures at the time would better be utilized in the production of safety-related and internally required pro-cedures.
Further the licensee stated that a list of procedures that will not be issued prior to OL will be documented and will be available for NRC:I review.
lowing types of procedures:
The list will cover the fol-
-
k l
g 049
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-
-
_
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Secondary Plant Setpoints (termed " nice to have")
Secondary)S/G Chemical Cleaning (system not to be
-
installed
,
T.S. Surveillance Tests that will be covered by the
-
Startup and Test Program and will not be required until the first refueling This is unresolved pending review of the above list by NRC:1.
(320/77-26-19)
.
The licensee further stated that issuance of the rest of the
-
-
facility procedures not on the above list should be com-pleted by August 31, 1977.
21.
Preccerational Test Procedure Review a.
Containment Intearated Leak Rate Test (CILRT)
The inspector reviewed a draft copy of the procedure " Reactor
'
Building Integrated Leak Rate Test", TP 150/3, fiTX 133.4, dated
July 5,1977, for conformance with regulatory requirements and licensee commitments.
With the exception of the below open items (320/77-26-20), the inspector had no further questions on the draft procedure.
(1) Allowance for Outcassing
'
In order to ensure that outgassing from the Structural Integrity Test does not mask leakage during the CILRT
-
there must be a period of time when the containment is at a reduced pressure prior to the CILRT.
The guidance in the draft ANS 274 Standard (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at less than 85%
of Pa) is acceptable.
(2) Leak Repair The procedure currently does not contain sufficient guidance for actions in the event of leakage during the CILRT that exceeds acceptance criteria.
Section III.a.1(a) of Appendix J to 10 CFR 50, details actions to be taken.
_
.
t.
O
,
I i
86 050
_
.
(3)
Instrument Calibration In accordance with 10 CFR 50, Appendix B, ANSI N18.7 and ANSI N45.4 instrumentation used for the CILRT must be traceable to nationally recognized standards.
The procedure currently does not require traceability.
(4) Acceotance Criteria Section V.B.3 of Appendix J specifies the requirement for analysis and interpretation of CILRT results.
The inspector informed the licensee that an acceptable CILRT must meet the following criteria:
(a) Measured leakage rates must be corrected for volume
changes due to sump level increases and for isolated leakage paths (b) The corrected measured leak rate must be less than 0.75 La
-
(c) The corrected measured leak rate at the 95% upper confidence level must be less than La
.
(5) Sucolemental Test Section III.A.3(b) of Appendix J requires the perfonnance
'of a supplemental test to demonstrate the accuracy of the test methods. The inspecbr informed the licensee that the superimposed leakage rate should be between 50% and 100% of La. The procedure currently specifies 75% La and Preliminary calculations by the inspector in-j 1.4 SCFM.
dicate that 1.4 SCFM is incorrect and that the required i
flow may not be within the range of the CILRT flowmeters.
i (6) Containment Insoection Section IV.A of Appendix J recuires a containment inspection
-
prior to any CILRT. The procedure also requires the inspection but does not give guidance what to inspect, what to inspect for, or what the acceptance criteria are for the inspection.
_
!
!
M< Qc s
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i J'
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(7)
Instrument Error Section III. A.3(c) of Appendix J requires that leakage rates be calculated using absolute values corrected for instrument error.
The precedure currently has no pro-vision for effecting this correction.
(8) Test Abort If sufficient instrumentation is not available, accurate leak rates cannot be calculated.
The procedure currer.tly does not specify criteria for test abort based on instru.
ment loss. The NIS 274 draf t standard contains guidance on minimum required instrumentation.
-
(9)
Data Rejection Individual data points are sometimes erroneous for various These cannot be rejected without a definitive
'
reasons.
data rejection criteria.
The procedure presently contains no such criteria. The draft MIS 274 standard contains an acceptable data rejection criteria.
.
(10) Pressure Sources Leakage frca pressurized sources inside containment can bias CiLRT results in a non-conservative direction.
The procedure currently does not require that such pressure
-
sources either be removed or vented.
(11) Closure'of' Containment' Isolation Valves (CIV's)
Section III.A.l(b) of 19pendix J details requirements for the r-losure of CIV's for the CILRT. The procedure does not ensure that these requirements will be met.
(12)' Calculational Technioue The procedure presently does not specify the calculational technique to be used in evaluating the CILRT data. The mass point technique is the currently accepted method.
(
86 052
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..
e
(13) Ventina and Draininc Section III.A.l(d) of Appendix J requires venting and draining fluid systers that are part of the reactor coolant pressure boundary or part of systers that pene-trate containment and rupture as a result of the Cesign Basis Accident (DBA), to ensure that the CIV's will see post-DBA differential pressure.
Further, the licensee's answer to cuest'on 03.14 in Supplement 2 to the FSAR states that he will comply with that portion of Accendix J with the exception of penetrations listed in Table 03.14-1.
The inspector reviewed valve lineups for the core flood, building spray, station air and makeup / purification systecs and noted that none were properly vented and drained.
All valve lineups need review to ensure ccm-pliance with Appendix J.
.
(14) Weld Chanc.els Special channels cover portions of the containment liner welds and could form an artificial barrier to leakage during the CILRT. The proce 'ure currently does not re-i quire that these be vented.
(15) Events Log
' ANSI M45.4 requires a dated and signed events log for the CILRT. The procedure currently does not address this log.
b.
Structural Intearity Test (SIT)
The inspector reviewed a draft copy of the procedure " Reactor
-
Building Structural Integrity Test," TP 150/2, MTX 133.3, dated June 15, 1977 for conformance with regulatory requirements and licensee commitments.
As a result of this review the fol-lowing problems were identified and are carried as open item (320/77-25-21).
-
(1)
Instrument Calibration The procedure does not require that instruments be cali-brated and calibration records available prior to per-fomance of tl.e test.
.
'-
.
.
I i
g6 053
.
(2)
Environmental Data Regulatory Guide 1.18, paragraph C.8 requires various environmental conditions be monitored continuously during the test.
The prc:adure currently does not require that.
(3)
Entry in Pressurized Containment OSHA Rules and Regulations section 19.26.803 delineate precautions and decompression limits for personnel working in pressurized atmospheres.
The procedure currently specifies no precautions to be taken for personnel entry
-
or exit for the 14 psig internal containment inspection.
(4) Crack Patterns Regulatory Guide 1.lB, paragraph C.4 requires that cracks appearing before, during, or after the test be mapped.
,
The procedure currently does not specify crack maps at these three separate times.
(5) _ Radial Deflections Regulatory Guide 1.18, paragraph C.2 requires radial de-flections at six meridians and page S 2-189 of Supplement 2 to the FSAR states that radial deflections will be measured at Elevation 293' and Azimuths 0, 60, 90,
180*, 240*, and 300.
The procedure does not include measurements of radial deflection at 293' and 60'.
(6) 'Prototyoe Containment Regulatory Guide 1.18 details strain measr' aments for pro-totype containments.
The licensee does nue have instru-mentation to meet these requirements nor was he able at this time to identify which containment was the prototype to his containment, c.
Local Leak Rate Tests (1) Procedure Review The inspector reviewed the procedure " Reactor Building Iso-
-
lation Valve Leak Test," TP 151/l, MTX 133.5, dated April 21, 1977 licensee commitments.for conformance with regulatory requirements and i
lowing items are unresolved (320/77-26-22).As a result of this r j
t I
86 054
_
_
Y
(a) Acceptance Criteria The acceptance criter'a for all testable Type B and C penetrations is 0.60 La.
In the prccedure the licensee has converted this to standard cubic centi-meters per minute (SCCM); however, in his conversion a non-conservatively large building volume was used, making his acceptance criteria in SCCM too high.
(b) Test Pressure
.
The FSAR states that all preoperational local leak rate tests would be done at 60 psig vice the Appen-dix J value of Pa, which equals 56.2 psig.
The procedure specifies test pressure as 56.2 psig.
The licensee stated that the FSAR would be changed to reflect the tests at 9a.
(c) Minimum Sensitivity The licensee currently assigns a value of zero leakage to a penetration when leakage is at or below the minimum sensitivity of the flowmeter.
In order to ensure conservative test results, a procedure change requiring that the minimum sensitivity of the flowreter be recorded in such instances is nee ~ded.
(d) Bypass Flow When testing certain penetrations, the flowmeter is downstream of the CIV being tested.
.
In these instances the licensee's procedure does not ensu. e that all leakage through the CIV passes through the flowmeter and is measured, thus making test results non-conservative.
(e) i' ater Seals Appendix J,Section III.C.2(a) specifies that the test medium for leak rate test shall be air or nitrogen. The licensee's procedure does not ensure
-
that valves being tested are not watar-sealed.
055
!
.
(2)
Rotameter Calibration Data The licensee was unable to provide the inspector with the calibration data for the rotameters in use for local leak rate testing.
-
This item is unresolved.
(320/77-25-23)
(3) Test, Vent and Crain Connections Test, Vent and Draia lines, ccming off lines penetrating the containment, between the containment isolation valves, provide a path for flow to bypass containment isolation valves.
.
Valves in these lines require containment local leak rate testing.
Connections, one inch in diameter or less, having a double lea',ge barrier (2 valves, valve ani a cap, etc.),. need not be tested, if:
Both leakage barriers are in place and closed;
--
The barriers are t.nder administrative controls
--
(lock, lock wire, tag, etc.); acd, The administrative controls are' verified with at
--
least the frequency '.; local leak rate testing.
The test, vent and drain lines are not tested onder the
-
Local Leak Rate Procedure.
This item is unresalved pe1 ding review of the administrative controls set up to ensure valves are closed.
(320/77-26-24)
d.
The licensee acknowledged the inspector's comants on the pre-operational test procedures and stated that the would be reviewed and correctad where necessary. procedures 22.
Diurnal Effect Measurement The inspector discussed with licensee personnel a proposed program to measure the effect of diurnal heating and coolie 7 on the Reactor Building during the CILRT.
This program would inwi.a utilization of SIT instrumentation already in place and would capture Reactor
. Building volume variations which could then Le factored into inte-
-
grated leak rate neasurements to eliminate any diurnal bias.
t
-
056
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)
.
23.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are an acceptable item or item of noncompliance.
Unresolved items disclosed during the inspection are discussed in paragraphs 12.a.12,b, 13. b (1 ), 13. b (2), 16, 16. a (1 ), 16. a (2), 16. a ( 3 ), 16. a( 4 ),
16. b, 16. c, 16. d, 16. e, 16. f. 17. a 17. b, 18. b. 19. b, 20. d,
21.a 21.b, 21.c(1), 21.c(2), and 21.c(3)
24.
Exit Intervie(
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The inspectors met with licensee representatives (denoted in paragraph 1) on June 23, 1977, June 24, 1977, and at the conclusion of the inspection on July 8,1977. The inspectors summarized the scope and findings of the inspection, subsequent discussions of the inspection findings occurred on July 11, 1977 in d telephone call from the licensee to NRC:I and on July 12, 1977 and July 13, 1977 in a telephone call from NRC:I to the licensee.
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