IR 05000327/1987019

Insp Repts 50-327/87-19 & 50-328/87-19 on 870212-13.No Violations or Deviations Identified.Major Areas Inspected: Surveillance Instruction Review

ML20205Q153
Person / Time
Site:	Sequoyah
Issue date:	03/18/1987
From:	Mccoy F, Linda Watson, Zech G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20205Q075	List: IR 05000327/1987019 ML20205Q073
References
50-327-87-19, 50-328-87-19, NUDOCS 8704030453
Download: ML20205Q153 (15)

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NUCLEAR REGULATORY COMMISSION

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,j 101 MARIETTA STREET, t ATLANTA. GEORGI A 30323 V

'+9 . . . . . ,o Report Nos.: 50-327/87-19 and 50-328/87-19 Licensee: Tennessee Valley Authority 6N38 A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801

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Docket Nos.: 50-327 and 50-328 License-Nos.: DPR-77 and DPR-79 Facility Name: Sequoyah 1 and 2 Inspection Conducted: Februar 12-13, 1987 Inspectors: -

t// ,A .3 87 F. R. McCoy, /Xe'qdaystrTection Chief Da'te Signed

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rWOM&r Engineer L. J. Wafson, Re 3ll9l27 Date S4 ned -

Approved by: ./ (4A 3 N d- 7

!n G. G. Zech, Assistant Director D(te'S'igned Inspection Programs, Division of TVA Projects

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Office of Special Projects SUMMARY Scope: This routine, special announced inspection was conducted in the areas of surveillance instruction revie Results: No violations or deviations were identified.

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REPORT DETAILS Persons Contacted Licensee Employees

• H. Abercrombie, Site Director

• L. Nobles', Plant Manager

• B. Patterson, Maintenance Superintendent

• R. Fortenberry, Technical Support Manager

*D. Craven, Quality Assurance Manager -

• C. Martin, Site Quality Assurance Manager

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• R. Denise, Project Manager, Procedures

• R. Buchholz, Office of Nuclear Power Site Representative

• B. Willis, Power Plant Superintendent

• F. Kabiri, Manager Site Systems

• G. Kirk, Compliance Licensing Manager

• J. Walker, Assistant Manager Operations Group

• H. Rankin, Manager of Projects

• J. Sullivan, Supervisor - Plant Operations Review Staff

• W. Mackay, Mechanical Test Supervisor

• H. Elkins, Instrument Maintenance Supervisor

*H. Rogers, Supervisor Plant Reporting Section

• M. Cooper, Licensing Engineer

• S. Childers, Operations

• J. McGriff, SI Review Coordinator i *G. Boles, Mechanical Maintenance Outage Supervisor

• J. Klein, Mechanical Maintenance Engineer

• A. Ritler, Engineering Assurance Engineer, DNE

< *C. Wood, Quality Assurance Supervisor

• R. Smith, Quality Inspection Supervisor

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• G. Shell, Division of Nuclear Quality Assurance Surveillance Section 1 *B. Schofield, Licensing Engineer l' *F. Siler, Supervisor, Instrument and Control Section

• R. Gladney, Instrument Maintenance Technical Supervisor

• J. Kelly, Engineering Assurance Engineer, DNE

• G. Gantt, Reactor Engineer

• L. McCormick, Regulatory Licensing Engineer

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Other licensee employees contacted included. engineers, technicians, operators, contractor employees and office personne I NRC Resident Inspectors

• K. Jension

• Attended exit interview

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. 2 2. Exit Interview The inspection scope and findings were summarized on February 13, 1987, with those persons indicated in paragraph 1 abov The inspectors described the areas inspected and discussed in detail the inspection findings listed belo No dissenting comments were received from the license The inspector reviewed proprietary information during the course of this inspection; however, this information is not included in the repor . Licensee Action on Previous Enforcement Matters

(0 pen) Unresolved Item 327, 328/86-32-0 Control Building Emergency Ventilation System Testing. A review of this item reflects additional resolution is required to determine operability of the chlorine detection system and adequacy of surveillance testing of this syste Refer to paragraph 5.b.(5).

4. Unresolved Items Unresolved items were not identified during this inspectio . Inspection of TVA's Surveillance Instruction Review Program

. This inspection was conducted in ord u to ascertain the licensee's.readi-ness for NRC inspection of surveillance instructions; evaluate the licensee's method of review, revisicn, and performance of surveillance instructions which had been previously performed prior to surveillance

instruction review and which are expected to be current with respect to performance frequency at startup; and to assess again whether the licensee was currently addressing NRC inspection findings identified at Watts Bar in the areas of surveillance instruction i Summary of the Licensee Surveillance Instruction Review Effort The licensee presented a brief summary of their surveillance instruction review effort. The licensee stated that as a result of NRC concerns with surveillance instruction inadequacies such as safety injection manual actuation testing, molded case circuit breaker testing, and essential raw cooling water system (ERCW)

testing implementation concerns, the licensee established a

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surveillance instruction review team led by Mr. C. LeFever, in the spring of 1986, to compare existing surveillance instructions to Technical Specification surveillance requirements and to determine if the surveillance requirements were covered by the surveillance instructions. The licensee stated that the scope of this review did not include an evaluation of test methodology to verify proper imple-mentation of the surveillance requirements. The licensee stated that as a result of this review effort a large quantity of potential

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. 3 reportable occurrences (PR0's) were generated describing deficiencies and that from these PR0's approximately 15 licensee event reports (LERs) were issued reporting problems with inadequate implementation

of surveillance requirements. The licensee stated that, deficiencies were being identified in their CATS tracking system and that, where deficiencies applied to a procedure required for restart, the tracking system would assure resolution prior to restar Following initiation of this review effort, an enforcement conference-was conducted with the licensee concerning surveillance instruction inadequacies. At this enforcement conference, the licensee committed to accomplish a technical review of all surveillance instruction The licensee stated that this review was identified as the phase I review which commenced in July 1986 and which included review of test methodology to assure proper surveillance requirement implementatio Additionally, this phase I review was programmed to review documents that were tiered to the basic surveillance instruction. The licensee stated that an SI-1 appendix F checklist based on a previously established Watts Bar surveillance instruction checklist was utilized in accomplishing the phase I review. Part I Technical Adequacy, and, if applicable, Attachment I, Operability Evaluation were to be satisfactorily completed in order to implement the phase I revie The NRC conducted an inspection in July 1986, as documented in NRC inspection report 50-327, 328/86-44, to determine the adequacy of the phase I surveillance instruction review program and identified further technical deficiencies with surveillance instruction Subsequent to this phase I inspection, a quality assurance audit of the surveillance instruction review effort was conducted. This audit

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also identified major technical deficiencies with reviewed su.veillance instructions. Although individual deficiency reports were issued for specific deficiencies a compilation of these defi-ciencies reports was issued as a corrective action report (CAR).

This CAR, which was issued on November 18, 1986 concluded that programmatic problems were associated with the surveillance instruc-tion review, which was approximately 82% complete at the time the CAR was issued. As a result the licensee identified as corrective action that a revised SI-1 appendix F checklist would be used to review a minimum of five elements for previously reviewed procedure '

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Additionally documents not previously reviewed would be reviewed to the revised checklist. In December, 1986, the licensee established a project manager for procedures, Mr. R. Denise, to coordinate the entire 31 review effort. The licensee stated that in addition to the reviews, and re-reviews, and revisions being conducted by the cognizant section staff reviewers, an independent review group (IRG)

, had been established to independently review finalized instructions prior to PORC approvcl and that this IRG would technically review 25%

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of all surveillance instructions. The licensee stated that IRG had reviewed 146 procedures, but that approximately 111 of these were not valid reviews of a finished section staff produc Consequently,

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only 35 procedures were considered by the licensee to have been satisfactorily IRG reviewed and IRG would be required to review an approximate 165 additional procedures to fulfill their review obliga-tions. Additionally, the licensee stated that quality assurance would also be independently assessing technical adequacy of 10

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percent of the surveillance instructions. The licensee stated the l

quality assurance commitments would be addressed as deficiency reports but that IRG comments were to be handled by memorandum. The zl inspectors noted that a formal . mechanism for IRG to assure closure did not appear to exist.

The inspectors noted that the licensee's re-review effort appeared to be in very early stages and did not appear to support current schedules for NRC review in this are The inspectors also noted that data associated with IRG review of finished section staff

procedures appeared to reflect that 15*4 of the procedures reviewed had major technical comments by IRG. The inspectors considered that this percentage of technical comments would be unacceptable during NRC review and, consequently, it too did not appear to support

. currently scheduled NRC inspection in this area. The licensee stated

at the exit interview that they would inform the NRC of an inspection readiness date in a program submittal which the licensee committed to submit to the NRC in a February 5-6, 1987 meeting. The inspectors noted, based on the licensees summary, that several areas, outside the scope of this specific inspection, would require NRC review

, during the NRC team inspection of surveillance instructions to be conducted in the near future. This would be in addition to assessing randomly selected surveillance requirements to assure that they are adequately implemented by surveillance instructions and to assure the procedures that implement those requirements are usable. These areas include:

Assess the adequacy of PRO evaluations and reportability determinations conducted by the licensee with respect- to identified concern Assess tracking and restart determination for deficiencies identified during the initial licensee revie *

Assess tracking and restart determination of deficiencies identified -by quality assurance subsequent to initiation of phase I revie Assess the adequacy of the revised checklist elements (what was to be re-reviewed) based on the quality assurance finding Assess how the licensee resolves IRG and quality assurance comments and how the IRG assures adequate resolution of their comment . - - . . ., .

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, Assess whether a revised checklist subsequent to the quality assurance CAR of November 18, 1986, exists for each procedure selected for revie Assess the adequacy of the licensee's split of the technical adequacy portion and administrative adequacy-portion of the SI-1 appendix F checklis Assess the adequacy of the licensee's surveillance instruction review program submittal currently scheduled for March 17, 198 During the course of this inspection, the licensee's Site Director

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notified the inspectors that due to recent information provided by TVA staff involved in surveillance instruction review, directed both through the line organization as well as the employees concerns program, TVA management was concerned that the perception existed with TVA staff that (1) procedures may be being . rushed in review to meet schedules rather than to develop a quality. product, and that (2) problem identification may be suppressed and discouraged. The Site Director stated that as a result of this concern, he had directed that management meet with staff and inform them of the management position with regard to surveillance instruction review as follows:

' Demand' schedules were to be discontinue *

l Sections were to provide schedules which would produce a quality i product and could be realistically supported by sectio personnel. If these schedules did not appear to support restart, then management would provide the support necessary to properly improve the schedul Suppression and discouragement of problem identification is contrary to management's position that problems be identified and corrected and that cases where this is occurring should be brought to upper management attention for resolutio The results of this meeting were noted by the inspectors to be documented in a February 18, 1987 summary of surveillance instruction review meeting on February 11, 198 The inspectors acknowledged that scheduling to develop a quality product rather than meet a demand schedule and encouraging problem

. identification were necessary steps to assuring technically correct i

and usable surveillance instructions and that the success of licensee efforts in this regard would be judged not only by the results of their own IRG and Quality Assurance reviews but also by the NRC procedure review results generated during the upcoming NRC team inspection of surveillance instruction l l

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6 Review of NRC Findings on Surveillance Program at Watts Bar In order to ascertain the status of the surveillance review program at Sequoyah, the inspectors selected eleven of the NRC findings from inspections conducted at Watts Bar and reviewed the actions taken at Sequoyah to address the findings. Due to the limited time available for the status review, the inspectors requested that the licensee provide a presentation on each of the findings by the cognizant engineer or manage These individuals provided documentation of implementation of each of the Watts Bar findings or discussed the corrective action programs underway which will assure adequate implementation. Even though time was not available to review all pertinent information, the inspectors were able to determine the status of the licensee's evaluation of each item. Each of the items reviewed is addressed below:

(1) Scaling and Setpoint Data Review and Verification The concern at Watts Bar involved the failure to perform a detailed independent review and verification of instrumentation scaling and setpoint dat Scaling and setpoint data is provided in technical instruction TI-41 at Sequoya The licensee provided the following information on the review at Sequoya The surveillance instruction review checklist in surveillance instruction SI-1, Surveillance Program, appendix F, required the reviewer to determine if the Technical Specification setpoints agree with instrument tabs, FSAR and applicable drawings. The checklist question qualification and scope definition, which is a part of appendix F, stated that for the instrument maintenance section, the instruction under review must be compared with TI-41 for consistency concerning setpoints, calculations, and tolerances. It further stated that if inconsistencies are found and it is determined that TI-41 is in e rror ,- then the inconsistency must be added to a punchlist for TI-4 The licensee stated that the review included the verification of any calculations by reperforming the calculation and comparing the data to the TI-41 data. For data in TI-41 which is correct, this calculation would be . counted as an independent review. If an error was detected, a second reviewer would independently .

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perform the calculation to complete the independent revie With regard to the punchlist, the licensee stated that upon completion of the surveillance procedure review, TI-41 would be revised to include all errors noted in the punchlist. Until ;

then reviewers were to refer to the punchlist prior to use of )

data in TI-4 '

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The licensee's presentation on this issue indicated that the instrumentation scaling and setpoint data is undergoing appropriate review Implementation of these reviews will be inspected in more detail in future inspection (2) Controls on Vendor Manuals The findings at Watts Bar (Inspector Followup Item 390/84-73-08)

concerned the adequacy of administrative controls on vendor manuals utilized for writing procedures. The licensee indicated that the short term corrective actions to provide controls on vendor manuals included the following actions. All vendor manuals, with the exception of the copy in the document control section, have been taken off the controlled copy list. Prior to use of- any vendor manual, an individual must review the manual and utilize forms provided in administrative instruction AI-23, Vendor Manual Control, to document-that the current revision is in use. The licensee provided the inspector with a proposed response to Generic Letter 83-28 which inchded a commitment to implement a long term program involving the technical review of all vendor manuals by January 31, 198 This response will be evaluated by the NRC upon formal submittal.

The inspectors determined that the licensee had established actions to assure control of vendor manuals. The inspectors consider that implementation of these actions in conducting surveillance instruction reviews should be evaluated during the NRC team inspectio (3) Testing of ESF Signals for Control Bailding Emergency Ventilation System The Watts Bar finding (Inspector Followup Item 390/84-73-09)

involved the failure to test certain ESF signals which initiate the recirculation mode of the control building emergency venti-lation syste The inspectors were provided with a copy of SI-144.1 and SI-144.2, which implemented the ESF initiation surveillance requirements of the control building emergency ventilation system in Technical Specification 4.7.7.e.2 at Sequoya The inspectors determined that the finding was

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(4) Preventative Maintenance on Reactor Cavity Seal The inspectors had determined that at Watts Bar no preventative maintenance was performed on the reactor cavity sea The inspectors were provided a copy of the maintenance instruction MI-1.2, which required preventative maintenance similar to a

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Watts Bar procedure that had been revised to address the NRC findin The inspectors noted that the Watts Bar procedure-required a check for oil contamination that was not specifically

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listed in the Sequoyah procedure. The inspectors interviewed

one of the engineers who routinely performs this inspection and determined that the engineer was cognizant of the need to avoid oil contamination and conducted the placement and removal of the i

seal in a manner which prevented oil contaminatio The inspectors also determined that the Watts Bar procedure required verification that the seal cure date be no more than four years earlier than the installation date. The inspectors noted that the Sequoyah procedure did not require a review of the seal cure date. The licensee provided information that indicated that when housed in the materials control warehouse, the shelf life of the seal was twelve ' years. The licensee stated that durometer checks were performed on the seal to assure integrity prior to placement of the seal, but.the age of the seal was not reviewed. This appeared to be due to the fact that the seal was stored between uses in the plant rather than in the materials warehouse. The inspector requested information on the material control program for storage inside the plant; however, this information was not available by the -end of the inspection. The storage of material inside the plant in regard i to controls on shelf life will be reviewed in a followup inspec-tion and is identified as Inspector Followup Item 327, 328/87-19-0 (5) Control Building Emergency Ventilation (CBEV) System Testing Three findings were identified in the area of CBEV system testing at Watts Bar. Unresolved item 390/85-21-02 involved the failure to perform response time . testing of the -CBEV syste Inspector followup item 390/84-73-09 concerned the failure to verify system realignment to the recirculation mode on all four signals required by TS 4.7.7.e(2). Unresolved item 390/85-21-03 involved verification of correct system installation and testing in light of the extremely long suction line from the sample pump

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to the control room air intake ducts. It should be noted that the Sequoyah Technical Specifications do not specifically require testing of the chlorine detection initiation signal under Technical Specification 4.7.7 as do the Watts Bar Technical Specification The actions taken by the licensee to resolve Watts Bar unresolved item 390/85-21-02 and inspector followup item 390/84-73-09 have been reviewed at Sequoyah as documented in NRC Inspection Reports 327, 328/85-46; 327, 328/86-20; and 327, 328/86-32. These reports found that the Technical Specification surveillance requirements of Sequoyah Technical Specification 4.7.7 did not specifically require verification that the system realigns to the recirculation mode on detection of high chlorin The licensee has submitted a request to NRC dated January 21, 1987, to delete the requirement for chlorine

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detection equipment from Technical Specifications since chlorine onsite had been removed and no significant chlorir; barge or railroad tank car traffic passed within five miles of the sit Inspector followup item 327, 328/85-46-06 was closed and unresolved item 327, 328/86-32-07 was opened pending resolution of the licensee's request to delete chlorine testing of the control room emergency ventilation syste The inspectors concluded at that time, that if the request was not granted, the licensee should revise the applicable surveillance instructions to require testing with chlorine and smoke signals to include timing of CREV isolation and switching of CREV to the recirculation mode. In addition, the inspectors determined at that time that a Technical Specification change request should be submitted to include the chlorine and smoke detection signals testing requirement During the current inspection, the inspectors noted that Tech-nical Specification 4.3.3.6 requires that each chlorine detection system shall be demonstrated operable by performance of a channel check at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, a channel functional test at least once per 31 days and a channel calibration at least once per 18 months. The channel functional test includes a requirement to verify operability of the system including alarm and/or trip function The inspectors questioned the licensee on the implementation of this Technical Specificatio The licensee stated that the Technical Specification had been interpreted to mean that the chlorine detector had to be tested, but that a test of control room isolation by the detector was not considered to be a required part of the functional test since Technical Specification 4.7.7, Control Room Emergency Ventilation System, did not specifically require the testin Therefore, the isolation function of the chlorine detection system had not been included in the surveillance test The licensee had tested only the operability of the chlorine detection instrumentatio Due to the . ambiguity of Technical Specifications 4.3.3.6 and 4.7.7, the inspectors consider that the Technical Specifications have been interpreted by the licensee in a narrow sense and that the licensee is testing this system within that narrow interpre-tation. After inoffice review of the Technical Specifications 4.3.3.6 and 4.7.7, the inspectors informed the licensee, by telecon (F. McCoy, NRC / G. Kirk, TVA) on March 11, 1987, that the NRC considered that final device testing was not being performed for the chlorine detection system and that lacking additional requirements, the inspectors considered that Technical Specification 4.3.3.6 required channel functional testing of the chlorine detection system in a manner that would assure that the system could isolate the control roo . .-. ..

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The inspectors also determined that the preoperational tests o the chlorine detection system had been a detection instrumentation test and had apparently not included a test to show isolation of the control room on a high chlorine signa The inspectors obtained a commitment from the licensee _ t perform a test of the chlorine detection system to determine if the system would perform its intended function, i.e., isolate the control room in the event of chlorine concentrations in excess of 5 ppm within the time frames assumed in the analysis in FSAR sections 6.4.1.2 and 6.4. The inspectors determined that unresolved item 327, 328/86-32-07 would be left open pending licensee determination of chlorine detection system operability, establishment of appropriate testing measures for the system, and final resolution of the licensee's -request for del, tion of Technical Specification 3.3.3.6. The inspectors alt) requested the licensee to evaluate Watts Bar unresolved item 390/85-21-03 to determine if the configuration of the chiorine detection system affected operabilit The inspectors noted that licensee staff had initiated PR0's 1-86-298, dated October 20, 1986, and 1-87-20, dated January 15, 1987, on this same subject. NRC evaluation of the licensee's assessment and reportability determination will be accomplished for these PR0s as identified in paragraph 5.a. of this repor (6) Testing of RHR Heat Exchanger Outlet Air Operated Valves and Containnent Suction Flow Control Valves The concerns identified at Watts Bar involved (1) the failure to include the RHR heat exchanger ~ outlet air operated valves in a surveillance test due to the fact that-they were normally open, and (2) the failure to test the containment suction flow control valves with a valid actuation signal. The inspectors reviewed Sequoyah surveillance instruction SI- SI-9 adequatel addressed the testing of the RHR heat exchanger outlet valves and required testing of the flow control valve; by initiation of an SI signal. The inspectors determined that the licensee had addressed these concern (7) Surveillance Requirements on Boron Injection Line Heat Tracing The concern at Watts Bar -involved the failure to include appropriate circuit breaker designations for assuring power to boron injection line heat tracing in surveillance instruction The inspectors discussed this issue with the individual who performed the review of SI-8 and SI-16, the Sequoyah heat trace l surveillance instruction The individual stated that these l

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procedures had been reviewed in depth and that only one circuit number had been determined to be incorrect. This error had been corrected. The inspectors consider that the licersee had taken appropriate action on this ite (8) Cold Leg Accumulator Level Indication The issue at Watts Bar involved an error in the curve utilized by operators to determine the volume of water available in the cold leg accumulators based on control room indication. The inspectors determined that the licensee had initiated PRO 1-86-091 and had requested that Westinghouse review the cold leg accumulator curves at Sequoyah to assure adequac Westinghouse determined that the present setpoints were adequate. The licensee was also in the process of revising the curves provided in technical instruction TI-28 to assure adequacy of other curve These actions and the Westinghouse evaluation will be reviewed during the NRC team inspection of surveillance instructions. The inspectors determined that the licensee was taking action on the concerns identified at Watts Ba (9) Units for Containment Pressure Ranges The Watts Bar concern involved a discrepancy between the Tech-nical Specification high and high-high containment pressure setpoint unit (psig) and the instrumentation which measures psid. The licensee stated that this discrepancy was not considered significant since the annulus was maintained at a negative pressure making the differential pressure measured conservative to the setpoint. This item will be reviewed during the NRC team inspection to assess the licensee's conclusions.

(10) Accuracy of Test Equipment In Determining Setpoint Boundaries The concern identified at Watts Bar involved the_ effect of the errors of measurement and calibration instrumentation in determining the accuracy of IS setpoint The inspectors determined that the licensee had contracted with Westinghouse to evaluate the effect of measuring and test equipment accuracy on setpoint boundarie This item was under review by the NRC resident inspectors. The inspector determined that the licensee was taking appropriate action to resolve the issue.

(11) Venting of ECCS Pump Casings The concern at Watts Bar involved the failure to include venting of ECCS pump casings at appropriate intervals in surveillance instruction The licensee stated that surveillance instructions SI-128, SI-40, SI-129, and - SI-37 included the requirements to vent ECCS pump casings and that the vents

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utilized had been verified to be high points. The inspectors determined that the licensee was aware of the issue at Watts Bar, however did not have an opportunity to review the procedures. This item will be reviewed during the upcoming NRC team inspection of surveillance instruction The inspectors determined that, although some individuals interviewed did not always know that the above issues had been identified at Watts Bar, the licensee had initiated actions to assure that the Sequoyah procedures and programs addressed the concerns and findings identified during NRC inspections at Watts Bar. The scope of this inspection effort was not intended to assess the effectiveness with which the licensee was addressing these issues with current program review and revision of surveillance instructions as this will be accomplished during the upcoming NRC team inspection of surveillance instruction , Evaluation of Licensee's Review Process In evaluating the licensee's review process the inspectors targeted the Instrument and Control (I&C) section for review since the majority of surveillance instruction are the responsibility of that grou Interviews were conducted with the supervisors of this group and with the procedures project manage Additionally, one procedure, which was currently undergoing review and revision, was reviewed by the inspectors with the individuals who were directly responsible for review and revision of that document. The I&C section is responsible for approximately 668 surveillance instructions, 407 of which are Technical Specification relate Implementation of Technical Specification surveillance requirements under I&C section cognizance would be addressed by these 407 procedures. The I&C section had identified four priorities for the 407 Technical Specification related procedures as follows:

Priority 1 Required to be performed prior to Unit 2 startup Priority 2 Required to be performed during startup or during Mode 1 operation Priority 3 Not required to be performed either prior to or during startup or during Mode 1 operation Priority 4 Procedure to be cancelle !

The inspectors expressed concern with the approximate 83 priority 3 l procedures which were not required to be performed either prior to or during startup. The inspectors inquired as to how these procedures were to be reviewed, revised, and performed prior to startu The initial licensee's responses to this inquiry were varied and ambigu-ous, particularly with respect to review of priority 3 procedures _

that had been initially reviewed prior to issue of the quality I I

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assurance CA At the exit interview, the inspectors expressed concern that it did _not appear in all cases that the licensee staff was intending to re-review, using the revised SI-1 appendix F checklist issued subsequent to quality assurance CAR, those priority 3 procedures which had been initially reviewed prior to issue of the CA The inspector noted that this would not assure satisfactory resolution of the programmatic deficiencies associated with the CA The plant manager acknowledged this concern and stated that all surveillance instructions, including priority 3 procedures, would be reviewed to the post CAR revised SI-1 appendix F checklist, even if they had been previously reviewed prior to issue of the CA With regard to revision and performance of priority 3 procedures the licensee stated that if the review reflected technical problems associated with adequate surveillance requirement implementation, the procedure would be revised and test reperformed. If the review did not reflect technical problems with the procedure, a revision would not be issued prior to restart and if review of previous test data reflected that an acceptable test had been previously performed, the licensee did not intend to reperform the test. In a subsequent meeting on February 20, 1987, the inspector informed the licensee that there was concern that performance of priority 3 tests should be considered necessary since table top reviews would not capture problems such as the ERCW valve throttling issue identified in NRC

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inspection report 50-327, 328/86-32. The licensee acknowledged this concern and stated that their intentions, and basis thereof, for surveillance test performance would be included in their surveillance instruction review program submitta The inspectors walked through review of one procedure, IMI-99FT 6.1, Functional Test of RC Flow Channel I, R1 (Loop F414) (F68-EA), with the reviewers assigned to that procedure. The reviewers were able to effectively obtain required source materials such as drawings, instrument tabs, vendor manuals, scaling and set point document TI-41-68, FSAR sections, Westinghouse setpoints documents, and Technical Specifications in order to accomplish the walkthrough. The procedure was currently in draft form and the walkthrough reflected that the review process employed by the reviewers was an adequate process with regard to review methodology and acceptance criteria to

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assure proper Technical Specification surveillance requirement

implementation for that procedur The inspector reviewed the six elements of the revised SI-1 appendix F checklist to be used in re-reviewing documents. The section reviewers stated that the elements of the checklist being reviewed were I. A.2, I. A.3, I. A.5, I.A.11, I.B.2 and I.C.1. Any inadequate response to any of these elements would result in an operability evaluation pursuant to Attachment 1 of the appendix F checklist. Procedure IMI-99FT6.1 had been reviewed by the reviewers for those element . . . - - . . . - - - . . -~ - -. . - --- -- . __

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The inspectors noted that. in addition to table top reviews, craft

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walkdowns were to be preformed prior to submission of the procedure .

for informal PORC review. During and, in some cases, after informal-p0RC review, IRG and quality assurance independent reviews would be completed on a sample of procedures. Additionally procedure valida-

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tion was intended to be accomplished.

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Although the licensee was currently planning to validate procedures subsequent to PORC approval, they were evaluating whether current

Technical Specifications requirements would allow full validation t

(procedure performance) prior to PORC approval. The licensee stated '

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that, in any case, their plans for implementing validation would be ,

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j addressed in their' surveillance instruction review program submitta f e s t

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