IR 05000327/1987066

Insp Repts 50-327/87-66 & 50-328/87-66 on 871019-30. Violations Noted.Major Areas Inspected:Sys Alignment Verification,Including Observation of Licensee Accomplishment of Sys Operating Instruction Checklist

ML20237E722
Person / Time
Site:	Sequoyah
Issue date:	12/11/1987
From:	Brady J, Mccoy F NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20237E678	List: IR 05000327/1987066 ML20237E676 ML20237E698
References
50-327-87-66, 50-328-87-66, NUDOCS 8712290148
Download: ML20237E722 (20)

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UNITED STATES o NUCLEAR REGULATORY COMMISSION

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j REGION il 101 MARIETTA STREET. '* 's ATLANTA, GEORGI A 30323

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Report'Nos.: 50-327/87-66 and 50-328/87-66 Licensee: Tennessee Valley Authority 6N38 A. Lookout Place 1101 Market Street Chattanooga, TN 37402-2801-Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR-79 Facility Name: Sequoyah 1 and 2

' Inspection Conducted: October 19, 1987 thru.0ctober 30, 1987 Team Leader: $

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hM t J7B.Brady,ProffetEngineer,

/7/.3/87 Date Signed

%auoyah Inspection Programs, Division of TVA Projects Team Members: . K. Poertner, Resident Inspector G. K..Hunegs, Project Engineer, OSP R. P. Croteau, Project Engineer, Region II P..B. Moore, Reactor Engineer, Region II A. R. Long, Reactor Engineer, Region II R. P. Schin, Reactor Engineer, Region II V. F11tton, NRC Contractor F. McManus, RC Contractor Approved by: w . / /2//[77 F. R. McC6y, Chief, SequB9ah Tnspection Defte" Sicjned Programs Section-Division'of TVA Projects SUMMARY Scope: This special, announced inspection was conducted in the area of system alignment verification for Unit 2 heatup. The inspection consisted of both observation of. the licensee's accomplishment of the System Operating Instruction (SOI) checklists and independent verification of system alignmen ' Independent verification was accomplished by comparing the configuration in the

plant to the S0I checklists and the as-built drawing Conclusions: 'The team determined that the licensee's configuration control program .(completed S0I checklists combined with configuration control log entries) did not accurately reflect the status or configuration of all equipment required for mode chang This determination resulted from 1) the identification of equipment. installed in the plant that was not included on SOI checklists, 2) the identification of equipment whose status was determined to

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8712290148 871221 PDR 0 ADOCK 05000327

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be other than that documented in the completed S0I checklist or in the

_ configuration log, and 3) the identification that the instruction specifying how to accomplish SOI checklists did not require configuration control measures

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to start when the checklists were initiate Violations identified during this inspection include:

Violation 327, 328/87-66-01 is a violation of Technical Specification (TS) 6.8.1 for failure to adequately establish, implenent, and maintain written procedure Examples include: Specifying in OSLA-58 that configuration control should start when a checklist is complete rather than when it starts (paragraph 3b). Failure to consider deviations to SOI checklists as procedure change This resulted in the wrong criteria and approval levels being used to process deviations (paragraph 3a). Failure to properly transfer information from the completed working copy of SOI checklists to the final status file copy as required by AI-4 and OSLA-58 (paragraph 4h).

' Failure to record the date when deviating items on S01 checklists as required by OSLA-58 (oaragraph 4h). Failure to record the position changes in the configuration log for the RCP seal return flow control valves, the excess letdown heat exchanger supply containment isolation valve, and the three. boron injection tank recirculation valves (paragraph 5b2 and 5b3). Failure to perform a revision to SOI checklist 63.1d for valves 2-FCV-74-1 and 2-FCV-74-2 prior to clearing the valves from the configuration log (paragraph 5b3).

Violation 327, 328/87-66-02 is a violation of Technical Specification 6.8.1 for failure to have an adequate system operating instruction (S01-63) for the emergency core cooling syste Examples include: Failure to provide for the initial positioning of the root valves to the RWST level transmitters, the root valve to pressure instrument 2-63-74, and the flange downstream valves 2-63-599 and 2-74-549 (paragraph 5b3). Failure to provide for the initial positioning of the power supply breakers to control valves 2-HIC-74-16, 2-HIC-74-32, and 2-HIC-74-28 (paragraph 5b3) Failure to adequately specify the location for penetration and penetration control fuses for 2-FCV-63-67 (paragraph Sb3). '

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f REPORT DETAILS Licensee Employees Contacted

• H. L. Abercrombie, Site Director

• L. M. Nobles, Plant Manager

• A.'M. Qualls, Assistant to the Plant Manager

• B. M. Willis, Nuclear Power Plant Superintendent

" R. Harding, Licensing Group Manager  :

• J. M. Anthony, Operations Group Manager

• G. B. Kirk, Compliance Licensing Manager J. H. Sullivan, Plant Operations Review Staff Supervisor J. R. Walker, Assistant Operations Group Manager

• T. J. Arney, Quality Assurance Manager

• R. H. Buchholz, Sequoyah Site Representative

• R. Loverne, Compliance Licensing Engineer

• M. A. Cooper, Compliance Licensing Engineer

• T. L. Howard, Division of Nuclear Quality Assurance

• R. Sedlacik, Electrical Engineering Branch, DNE

• J. Watson, Electrical Engineering Branch, DNE

• A. H. Ritter, Engineering Assurance, DNE

• L. Brewer, Operations System Alignment Team Leader E. Sliger, Manager of Projects

• R. S. Akers, Comm. Specialist

• C..T. Hall, Assistant Project Engineer

• D. England, Operations Other licensee employees contacted included technicians, operators, shift engineers, and engineer * Attended exit interview Exit Interview The inspection scope and findings were summarized with the Plant Manager and members of his staff on October 30, 1987, and on a phone conference December 2, 1987. The licensee acknowledged the inspection findings and did not identify as proprietary any of the material reviewed by the inspectors during this inspection. During the inspection frequent dis-cussions were held with the Nuclear Power Plant Superintendent and other managers concerning inspection finding . Administrative Controls The inspectors reviewed the adequacy of the administrative procedures controlling system alignment verification Administrative Instruction AI-2, Authorities and Responsibilities for Safe Operation and Shutdown, specifies requirements for the configuration control of critical structures, systems, and components (CSSC) equipmen Section 3.13 of AI-2, Maintaining Cognizance of Operational Status, states that CSSC l

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i systems shall be aligned according to applicable valve, instrumentation, J and power availability checklists for the desired- mode. Deviations from these checklists are permitted af ter ascertaining the effect of deviations on Technical Specification (TS) requirements and on safety to personnel and equipmen Details of how to handle deviations are provided in Operations Section Letter OSLA-58, Maintaining Cognizance of Operational Status - Configuration Status Contro S01 Checklist Deviations The inspectors reviewed the instructions that discuss deviations to SOI checklists as specified in AI-2 and OSLA-58. ' AI-2 permits deviations after ascertaining the effect they will have on Technical Specifications (TS) and safety to personnel and equipment. AI-2  ;

further states that deviations will be handled in accordance with 0SLA-58. During the review, the inspectors considered what function the 501 checklist deviations . performe Deviations allowed a checklist to be signed off as complete without positioning the equipment in the positions specified by the S0I checklist. The inspectors consider this equivalent to processing a change to an S0I and as such should have followed the requirements of TS 6.5.1A or TS 6.8.3 for permanent and temporary changes as appropriat OSLA-58 is intended to implement the requirements of AI-2. OSLA-58 allowed the SRO to authorize deviations to the S0I checklists if they did'not impact on mode change. The approval level and criteria for deviating from S0I checklists as specified in OSLA-58 conflicted with the TS requirements for processing permanent and temporary changes to procedure OSLA-58 did not address whether deviations involved intent changes to procedures and did not provide the level of review and approval required by the TS. Administrative Instruction AI-4,

" Preparation, Review, Approval, and Use of Plant Instructions",

implements the requirements of TS 6.5.1A and TS 6.8.3. The licensee did not consider deviations as procedure changes, and therefore, did not implement the requirements of either the TS or AI-4 when process-ing SOI checklist deviation In addition, the inspectors were concerned that "the SR0". as specified in OSLA-58, was an unclear approval level since there was not a position in the operations organization denoted as the SR The inspectors observed confusion among the operators concerning the circumstances and acceptability for deviating items from SOI check-lists. Several operators told inspectors that they could deviate a complete checklist if they wanted t The inspectors considered deviating an entire checklist as an intent change to a procedur The failure to specify an appropriate method for deviating from SOI checklists that is consistent with the TS requirements for procedure changes is considered a violation. of TS 6.8.1, for failure to properly establish, implement, and maintain written procedures and is designated violation 327, 328/87-66-0 _ _ _ _ _ _ _ _ _ -

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' Configuration Control While Performing' Checklists

.The inspectors reviewed Revision 3 of OSLA-58, and identified an inadequacy in that configuration control was not required = while i checklists'are in. progress. Paragraph J of the procedure states:

The unit's- lead operator is notified that a checi,li st : is complete and that the . unit's lead 4phrator is respons%e for logging all deviations from this point for thapch7 cklis i Thus, the procedure only required a unit operator tca pake cQfigura-tion complet was log' entries from theare Checklists time he was typically in notified progressthat he SQL for about 1 tobecklip(

days or more; If an operator repositioned valves or.treakers after' ~ i i

the progress)valveandwas did verified on po$0 not enter the the checkibt tion change(while the checklist Jwas in the'Configura e

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tion Log, the completed checklist could be invalidate Thi s 'i s'-

considered an ' additional example of Violation 327, 328/87-66-01 for- <

failure to properly establish, imolement, and maintain written procedure This procedural inadequacy resulted,in an inadequate checklist. status li st . form, APPENDIX F2 of OSLA58. APPENDIX F2 is described in OSLA-58 as follows:

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l The. designated unit operator will maintain a checklist status list in front- of the ' unit's Con figuration Log BA (Appendix F2). . (, ,

Appendix F2 contains columns. for " Checklist No.", "In P og ss <

(check)," " Shift and Date Completed." It does'not include the time and date a checklist was started or the time complete For opera-tors to effectively make Configut ctf cn, Log entries for a system whose checklist was in progress, they would need to have a record of the start and completion times., In practice, the operators were recording start and completion times of a checklist, using'

APPENDIX F2, by placing the start date in the "In Progress" column rather than using a check as required,ty,0SLA-5 >'i

' Procedure OSLA-58 requires Appendix A' ttc be maintained as a master checklist of all unit SOI checklists toYe performed. The inspector identified that Waste Disposal System SOI checklist 77.2C-1 did not g i s appear in Appendix A of . Revision 4 of 05;A-58, although the Status h\

.,. File Group had performed the power availability portio personnel confirmed- that the checklist should be in Appendix A, and Licensee .3 (

agreed to incorporate this . change in Revision 5 of OSLA-5 Additionally, Appendix A will be upgraded to list more specifically 1 F[ l

which S0I checklists are required, rather than just listing the S01s. J The omission of required che.:klists and the other proposed changes to Appendix A indicate a need for the licensee tr; thoroughly review the  !

appendix for accuracy and completenes l 1 _ _ _ _ _ _ ,

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lb Vhe inspector interv)ewed licensee personnel to determine complianc,3

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t wi3h the requirement of OSLA-58 for periodic review of the configurapon log and status file by the Operations Group Manager / >s Shift Operaticas Manager. The inspector det p ined that undocumented u views were taking place on a frequent b,ad g , . Independent Verification Procedures v [1 *

3 Licensee procedures AI-3, Revision 35, titledgearanse Procedure and AI-37, Revision 4., titled D. dependent Verifica11on, ig:luded a list of s .'

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systems for which independent verification is ,pequire The ,

inspectors identified that these lists contained seversl difference The licensee agreed that both lists should be fdendNal, and showed 5 the inspectors that a, proposed revision to AI-3 contained information which was codistent #th Al-37 but was being held up by other

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The inspectors reviewed Gemral Operating Instruction GOI-6, titled

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3, Apparatus Operation, and nt/ ed that double person verification is

, d required on the SOI nive- checklists and the SI's listed in L i sI Appendix E of OSLA-5 The inspectors observed that OSLA-58 s

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Appendix E did not c;ntainh c:i.i s li s titled double person ver y ci' Ton of SOIs and sis, but read Appendix C of OSLA-58 was

" Instruction Cancelled (Qu AI-37)." The licensee should update

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Personnel Qualificqion and'Cc-tification s

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The inspectorc sinterv h.ved some of. the TVA employees who were performing the system alignment veN fications to determine their knowledge of applicdble plant procedures y 6 equipment, and the level of related training ther had received. ,M had received recent

,- training in system alignments procedures, py appeared to have er, i

' adequate knowledge of them. Mnowledge of valves, for determining position and operability, alsc appeared to be adequat >b \

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During the interviews, a potentilli problem with job certification h ~2 t ' "

became apparen A review of selected trating records confirmed a N ,t .< lack of Sequoyah certif':atiUh for approximately 75*; of the employees b j "' \ who were performing the sysy m alignment verifications. These paople p C were operators,(Auxiliary Unit Operators or Auxiliary Operators);from

other TVA plants ,(Wey% Bar or Bellefonte). They were not certified 4 , i \

operators at Sequoyd nor were they certified in writing to perform ll double person ye ri f; ca t'i on of S0ls and sis at Sequoyah. The

q , inspectors wern inable to determine that they met the certification ,

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/ requirements of OSLA-58 paragraph VI for double person verification p Y(t of S01s'any S!s/ >

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,,, g Ameetpigwasheldwithlicenseemanagementtodiscuisthejiroblemof inadequate ctit Vication The licensee explained thitN11 of the

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, people being udeil for system alignment verifica@ns were considered

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q'ut.l i fie Hist, because of their certifications it other TVA nuclear plants, these people were ' eredited with havin? adequate genaral and hardware knowledge to conduct system alignments. Second, o 3 they had all taen given site speef fic training on all Sequoyah i

procedures pertaininb to systen alignmen On completion of this t-aining, each individual had, signed a' prepared sheet that outlined

thb1 training and acknodedged cogletion of the training as well as vi awareness of their duties and ~ responsibilities relating to system

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" alignment and configuretics .centrol at Sequoyah. The inspectors hointed out that therp.sbew;s dif not have a management signaturn on

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, them nor was it specified that they were qualified for double person j verification of S01s and si Licensee management corr & tted to documenting the oral certifications that they considered had already been give l l Prior to.the concluHor of the inspution, written certifications for  :

the system alignment personnel tA > perform double person verification

!t . of SOIs and sis were generated by the h censee with Operations Group  !

Manager approval signature on each. Also, a statement indicating prior verbal certif tcation for each was signed by the Operations l Group Manage Thele . certification records were' reviewed by the inspectors and appearea to be adequate.

i The inspectors inteniewed several Unit 2 licensed operators in the area of system aHgnment contro There mppeared to be some

j confusion over whether configuration centrol ' on systems should be

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I started when the syst.sn alignment' checklist is started or when it is complete There also appured tc, be some c.onf usion over Configuration Log requirements Hn " routine evolutions" that involve

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changing valve positions. Addit %nally, the procedure for handling I revisienc to checklists was not .vell understoo Overall, more trai c e the licensed operators in configuration control is neede , Observation Of The Licensee's system Alignant Process To verify the adequacy and the implementatun of the licensee's system i alignment program, the inspectora accor@anied licensee systems alignment teams in performing all or porti or,s of the SOI checklists for the following systems:

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Sgtem N jystem Title 3 Main and ALxiliary Feedwater

.32 Auxiliary Control Air f,5 Emergency Gas Treatment 72 Containment Spray System )

82 Diesel Generators 87 Upper Fead N ection  !

90 Rediatidn Monitoring l

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h 6 As the inspectors observed the performance of the licensee teams, they noted in particular whether ' they were able to adequately complete the p

-. checklists and whether the' checklist adequately described the items, the p item location, and the required position of the items on the checklis L Many problems were noted by the licensee '.eams and were either resolved or L the ' team stopped the performance of the checklist items in questio License personnel verified checklists against master records to assure

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, that . they were using - the latest revision Also, they verified that current drawing revisions were being use They then followed plant-procedures for determining and recording valve position and. operability.

L ' Valves deemed -inoperable (i.e. because of an air leak in the valve's .

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operating line) were so recorded and reported. . Minor maintenance itemt L- (i.e. name tags missing) were notea and work requests submitted for repair Also, some checklist - inadequacies were found and properly -

reporte Overall, the performance of the licensee's system alignment team appeared to be adequat The checklists for which alignment verification were observed, and any -

notable problems that were found, are described below: Main and Auxiliary Feedwater (System 3)-

The' inspectors accompanied a licensee valve alignment team performing SOI checklists 2.1, 3.1A-2, and 3.2 for main and auxiliary feedwate A discrepancy was identif.ied between.the number of a valve on check-

' list 3.2-and the number of that valve ~on the reference-drawing. The valve in q'uestion was the bypass for valve 2-3-835 on the line from the AA Motor Drive AFW Pump Supply to Number 2 Steam Generator. . This valve was shown as 2-3-804 on drawing number.47W803-2 Revision W and on Hold Order Number 3061. The valve tag in the field had been altered with a crayon to match the drawing. The SOI checklist shows the valve as 2-3-844, which appears to be the correct number as it follows logically from similar valves on adjacent lines supplying the other Steam Generators. The licensee was informed of this discrepanc Three instances were identified where checklists 2.1 and 3.1 A-2 contained several inconsistencies in requirements for double and single verification of the positions of valves performing similar function Each set of similar valves should have the sarae verification requirement _ _ _ _ - - _ - _ _ - - _ _ _ - _ _ -

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Example 1: Feedwater Flow Control Velves to Steam Generators Position Verification  !

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Valvg Required Required FCV-3-35, Feedwater FCV Operable double FCV-3-48, Feedwater FCV Operable single -

FCV-3-90, Feedwater FCV Operable double FCV-3-103, Feedwater FCV operable double Example 2: Recirculation Header Isolation Valves Position Verification Valve Required RequLr_ed 41-725 Closed single 41-726 Closed double 41-727 Closed single 41-728 Closed double Example 3: Feedwater Drains Downstream of Check Valves Position Verification Valve Required Required 3-504 Locked Closed double 3-502 Locked Closed single 3-508 Locked Closed single

. 3-506 Locked Closed single The licensee team accon,plished double person verification even though it was not required on the above single verification valves after the inspector pointed out the discrepanc Auxiliary Control Air (System 22) g i

Tne inspector accompanied a licensee valve alignment team during performance of 301 Valve Checklist 32.2-1, Startup and Operation of Auxiliary Air Compressor A- The team could not complete the .

procedure due to difficu', ties encountered with the checklist. The team correctly referred the procedure to their supervisor for correctio The following are examples of some procedural difficulties which were encountered:

A-A Moisture separator manual drain could not be positively identified. The valve number was shown as N/ F:oot valve to C-FI-32-75 could not be identified on the prin This was later found to be in a detail section of the prin The valve number column in the procedure listed N/ _ ____________ _O

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Purge air flow control valve could not be throttled as required due to the system being tagged out for maintenance. The valve number was shown as N/ The valve line up team indicated to the inspector that many " skid" mounted valves are listed as N/A in the valve number column of SOI cnecklists and that a long term program is in place to correct this problem. The inspector observed that maintenance equipment connected to the auxiliary control air system would have prevented operational use of the syste c. Emergency Gas Treatment (System 65)

The inspectors accompanied a licensee system alignment team during the performance of SOI 62.5B, Power Availability Checklist for the Emergency Gas Treatment System. The checklist was found deficient by the licensee in several instances. The checklist required verifying

" Control Power On" with respect to several items on the list but there was no direct indication available to determine whether control power was on or off. To determine if control power was on, a system print was obtained which showed that the indicating lights in the control room were also powered from control powe Since the indicating lights were on, it was assumed control power was o The checklist should be rewritten to specify checking the indicating lights in the control room. In addition, breaker 210 for 125 vdc Vital Battery Board III and breaker 210 for 125 vdc Vital Battery Board IV were not properly labeled, however a Maintenance Request had been submitted to properly label the breaker The inspectors accompanied licensee personnel who were performing the system alignment verification for S0I valve checklist 65.2B, Emergency Gas Treatment Syste The performance of this alignment verification appeared to be adequat d. Containment Spray (System 72)

The inspector accompanied licensee personnel during the performance of SOI valve checklists 72.1A-2 and 72.1A-1 for the Containment Spray Systems. The inspector observed adequate performance of these check-lists by the licensee tea e. Diesel Generators (System 82)

An inspector accompanied a licensee valve alignment team during performance of SOI checklist 82.1 for placing Diesel Generator 1A-A in Standby Mode. A second valve alignment team, with another inspector, was performing this procedure during the same time frame on another diesel generator. Neither team could complete the procedure due to difficulties encountered with the SOI. Both teams ccrrectly referred i

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the procedure to their supervisors for correction. The'following are examples of the procedural difficulties encountered:

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Could not positively identify the check-plug valve in step *

. Uncertainty as to the correct interpretation of what was required by step.10, " Check DC circulating lube oil pump aligned for service".

Muffler' room exhaust fan control switch label was inconsistent with step 11-of the procedur Operator was uncertain whether step 13, to place HS-30-41SC in standby, was correct because it required the switch be pulled to-loc The procedure did not identify the switch by number in step 1 As written, the procedure required the operator to return to the control room for steps 15,16, and 17 prior to performance of step 18 ' (check a temperature indication and verify a switch position). While not a technical _ problem, this appeared unnecessarily time consuming as the- diesel generators are some distance from the control roo The' system. alignment teams approached SOI checklist 82.1 differently

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in that initial steps 1 through 6 required verification of other sections of the procedure prior to continuing. One team verified-these steps accomplished by reviewing the required checklists.in the system line up file record The other team elected to 'actually -

perform these steps. While both approaches were satisfactory, it was disconcerting to observe two separate approaches to the accomplish-

. ment of a similar checklist being performed during the same time frame, which may indicate that a .prebrief by supervisory personnel-would be beneficia SDI checklist 82.1 is a category "A" instruction, which requires the steps be accomplished sequentially. One team performed the procedure steps in sequence, .the other team did no A meeting with the licensee revealed that the team not performing the checklist step by step had not been authorized to perform category "A" instruction That team had picked up this' folder by mistake and the checklist would not have been approved when they returne Upper Head Injection (System 87)

An' inspector accompanied a licensee system alignment team performing 3 valve checklist 87.1 Revision 22, " Normal Alignment Prior to Placing 'j Upper Head Injection (VHI) In Service". The checklist was performed i

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satisfactoril Work Requests (WRs) were submitted for valve discrepancies the operators identifie I

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g. Radiation Monitoring (System 90)

An inspector accompanied a licensee system alignment team performing S0I 90.1A-3, " Radiation Monitor Lineup for Liquid Effluent Monitor".

This procedure was completed adequately. However, one member of the valve line up team stood on a valve to check the position of one valve in the procedure. The inspector pointed out to the operator that standing on valves is a poor work practice that could result in valve damag h. Review of Completed Checklists A comparison was made between the working copies and file copies for completed S0I checklists 2.1 and 3.1A-2, Feedwater Power Availability Checklists and 68.1A, Reactor Coolant System Valve Checklist. The inspectors evaluated whether or not the initials of the plant person-nel were properly transferred to the file copy of the checklists and if deviations were properly documented and transferred to the con-figuration log. The Reactor Coolant System checklist working copy was found inadequate as follows:

(1) check marks were used for the 2nd person verification initial (2) valve 2-FCV-87-17 had the same initials for both verification (3) valves 2-FSV-68-394, 395, 396, and 397 did not have any initials for either person doing the verificatio (4) only one initial was shown for the refuelino disconnect, the vessel head vent and the vessel head vent FSV isolation valv A review of the file copy _ of checklist 68.1A did not show these discrepancies. OSLA-58 authorizes the use of working copies (white copies) as outlined in AI-4 for this checklist process. AI-4 allows the use of verified copies from which the information is transferred to another verified copy after completion of work. In this instance, the final copy did not represent a transfer of information from the working copy as required by AI-4 and OSLA-58. Licensee personnel that performed this checklist told the inspector that each individual had checked all valves. This is considered another example of Violation 327,328/87-66-01 for failure to properly establish, implement, and maintain written procedure In reviewing whether the deviations identified on the checklists were properly documented, the inspector discussed the note on the check-list for valve 2-68-583. Valve 2-68-583, Relief Valve Discharge Header Drain Isolation was not initialed on the working copy and the working copy indicated that a work request was needed to place a cap down-stream of the valve per the checklis However, this valve was signed off on the file cop The inspector accompanied plant personnel to verify the valve was in the proper position and cappe The valve was labeled 2-68-5835 rather than 2-68-583, but it was in the correct position with a flange installed downstream of the valv The failure to initial the working copy of the checklist was later N _______ _ __ D

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discussed with the licensee personnel that performed the checklis The inspector was told by the individuals that initially they had traced out the wrong valv In reviewing the completed checklist from the system status file, the inspectors noted an additional discrepancy. The designated unit operator's . initials appeared beside items carried over to the Configuration Log, but these initials were not accompanied by a date as required by OSLA-58. OSLA-58 states:

The designated unit operator shall also place his initials and date on the status file copy in the margin beside the signoff blank to indicate his cognizance.... Note: It is imperative that the date on the Configuration Log entry matches the date beside the unit operator's initials on the status file checklis The inspectors determined that the importance of having the dates match was to identify the exact equipment status at any particular time, since deviated items on SOI checklists only identify the position the equipment was not in. This is considered an additional example of violation 327,328/87-66-01 for failure to properly establish, implement, and maintain written procedure . Independent System Alignment Verification (71710)

The inspectors independently verified the alignment of all or portions of the following systems:

System N System Title 30 Ventilation 62 Chemical and Volume Control 63 Emergency Core Cooling 72 Containment Spray The independent inspection was accomplished by comparing applicable portions of the as-built reference drawings to the SDI checklists and the plant configuration The comparison determined whether all equipment within a particular system was included on the SOI checklists and whether the drawings actually reflected the as-built configuration of the plan Review of Checklist Reference Drawings A number of difficulties were encountered by the inspectors in using the licensee drawing syste The only set of drawings that l accurately reflected the as-built configuration of the plant were in l the control room. This makes review for adequacy of procedures, ;

instructions, and checklists difficult. The licensee should consider l updating the official as-built prints at a more frequent basis to ensure that decisions made based on the actual as built configuration of the plant are soun l i

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The '. inspectors ~ noted some' difficulties _in using the prints i relation' to. verification of . breaker location and fuse types and

/, locations. The inspectors expressed a concern to the licensee that-the identification of fuses on drawings was not accomplished in a

.sufficiently uniform manner that would prevent misinterpretation of the drawings. For. example the ' fuse identifiers were. not consistent between drawings'45N765-14 and 45N779. The inspectors were informe by licensee electrical engineers that Engineering Change Notice.(ECN)

L5880 addresses problems associated with fuse identification for 1E fuses -on drawings schematics, procedures, and equipment (identification by use of a unique identifier). This ECN is not complete. even though the work package ~was issued prior to 1984. In addition, . the inspector was informed that drawings 45N765-14 and 45N779 are included in ECN L5880 under work plan 12052. The licensee should consider reviewing all SOI power availability checklist reference drawings to ensure that adequate identification of equipment and position are specifie The inspectors noted the following minor discrepancies in the system flow diagrams and identified them to the licensee for resolution:

(1) Drawing 47W811-1 showed valve 2-62-500 (RWST to refueling water purification pump) normally open (N.0.). Drawing 47W809-1 showed valve normally shut (N.S.).

(2) Drawing 47W811-1 listed charging pump 18-B suction vent valve as 2-62-511. Drawing 47W809-1 listed the valve as 2-62-51 (3) Drawing 47W810-1 showed valves 2-74-522, 2-74-523, 2-74-532 and 2-74-533 (local sample points) as N.S. The associated checklist-required the valves to be ope (4) Drawing 47W810-1 (RHR Flow diagram) did not show the following vent and drain valves: 2-63-660, 2-63-659, 2-63-667, 2-63-661, 2-63-503, 2-63-501 or 2-63-50 These valves were shown on drawing 47W811-1 (safety injection system).

(5) Drawing 47W810-1 showed a drain valve, 2-74-552, . installed between 2-FCV-74-1 and 2-FCV-74-2. This valve was not installed l- in the plan (6) Drawing 47W811-1 showed valves 2-63-614, 2-63-615, 2-63-616 and i

2-63-617 - (Cold Leg Accumulator sample valves) as N.S. The checklist required these valves to be ope (7) Drawing 47W812-1 showed drain valve 2-72-517 and 2-72-518 as The checklist required these valves to be shu (8) Drawing 47W810-1 listed valves 2-FCV-74-12 and 2-FCV-74-24 RHR Pump A-A and RHR Pump B-B as normally open. The associated checklist required these valves to be shu _-_-_____O

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- (9)L Drawing 47W810-1 listed test valves 2-FCV-63-158, 2-FCV-63-111, and 2-FCV-63-112 as normally open. The associated valve check-list required these valves to be shu (10) Drawing 47W811-1 listed manual sample valves 2-63-569 and 2-63-578. as normally . shut. The associated checklist required -

these valves to-be ope Independent System Walkdowns The inspectors independently walked down all or portions of the selected systems to assess checklist adequacy and implementatio During the. review of the SGI checklists, the inspector observed that the format of. the checklists was ' not consistent. The inspector-recommended to the licensee that a standardized format for S0I checklists be adopte (1) Ventilation (System 30)

.The ' inspector walked down portions of valve checklist 30.5C- .No discrepancies were foun (2) Chemical and Volume Control (System 62)-

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The inspectors walked down portions of the chemical and volume L

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control system (CVCS) and reviewed the checklists completed by the licensee alignment teams. SOI checklist 62.1B-1, "Wormal

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Alignment for CVCS", listed the = required position for the I

following valves ~as open:

• - 2-FCV-62-9, #1. Seal Return Flow Control Valve for Reactor -

l Coolant Pump #1;

L 2-FCV-62-22, #1 Seal Return Flow Control Valve for Reactor !

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Coolant Pump #2;

l 2-FCV-62-35, #1 Seal Return Flow Control Valve for Reactor 1 Coolant Pump #3; '

i 2-FCV-62-48. #1 Seal Return Flow Control Valve for Reactor Coolant Pump #4; All _four of these valves were found by the inspector to be closed but were not listed.in the configuration log as being out of the position required by SOI 62.18- The. operators could offer no explanation as to why these valves ' were not in the configuration log. The closed position is the proper position for Mode 5 operations. This checkli st was completed on August 12, 1987. This is an example of a breakdown in the configuration control syste l L - J

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S01 checklist 62.1B-1 also required 2-FCV-70-85, Excess Letdown Heat Exchanger Supply Containment Isolation Valve, to be close During the inspectors' walkdown of the Component Cooling System board in the Control Room, it was noted that this valve switch

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was indicating ope The operators explained that while in Mode 5, it is normal to be changing the position of this valve several times a day in order to maintain pressure below 150 psig. OSLA-58 allows valves to be manipulated "for short term deviations where the function being performed is continuous and uninterrupted in nature" without making a configuration log ent r "This shall apply only if the operator is attentive to the of f-normal condition, does not leave the area of control while the deviation exists, and returns the deviated equipment to normal status before proceeding to another task." In addition, "Off-normal conditions controlled by approved procedures need not be logged in detail in the configuration log for instructions which have a completed Appendix J drop-sheet and realign the system norma For these types of off-normal conditions it will be adequate to make one entry in the configuration log at the start and completion of testing." None of these conditions are applicable to the manipulation of 2-FCV-70-8 The above examples of CVCS valve positions not being documented as required by OSLA-58 are considered an additional example of Violation 327,328/87-66-01 for failure to properly establish, implement, and maintain written procedure The inspectors noted that many of the SOI checklists are being revised to change the required position for Flow Control Valves from "open" or " closed" to " operable." All of these examples would not have occurred had this been the cas (3) Emergency Core Cooling System (System 63)

The inspectors independently verified completed SOI checklists 63.18-3 and 63.1A-5. In addition to the verifications, the inspectors compared the SOI checklists that had been completed by the Plant Configuration Group to the valve position indicators on the main control boar SOI checklist 63.1B-3 which aligns the centrifugal charging pump and boron injection tank (BIT) for safety injection standby mode was reviewed and the following discrepancies were noted:

Boron recirculation inlet isolation valve, 2-FCV-63-38; and Boron recirculation to BA tank valves, 2-FCV-63-41 and 2-FCV-63-42 were required by checklist 63.18-3 to be ope These three valves were noted in the inspectors walkdown of October 22, 1987 and on the completed checklist as close The checklist identified that the valves had been placed in the configuration log as being contrary to the SOI check-list required position of ope This log entry for l - ----- M

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the deviation was made on October 11, 1987. The configura-tion log entry showed that the valves were later opened on

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October 12, 1987. A walkdown performed on October 23, 1987, of the valve position indicators on the main control board confirmed that these valves were closed. A review of '

the plant configuration log revealed that there were no entries in the log regarding these three valves being out of position with respect to the completed SOI checklis The following. written explanation of why the valves were found out of position and unconfigured was given to the inspector by the licensee:

"On October 12, 1987, we were making preparations to put the BIT on recirculation. FCV-63-38, 41, and 42 were open and unconfigured. Due to a broken manual valve, FCV-63-38 was tagged out on October 13, 1987. On the day shift, when FCV-63-38 was released and the BIT fill was again started, it was realized that per S0I-63, the BIT had to be >165 F prior to putting acid in the tank (It was later decided not to put the BIT on recirculation and the valves were not opened again)."

"When these valves were closed, I felt that this was the normal configuration for an empty BI I failed to con-sider that the Mode 4 SOI would call for these recircula-tion valves to be opene I knew that we performed a Surveillance Instruction, SI-12, prior to Mode 4 per General Operating Instruction checklists and the fact that these valves were closed seemed appropriate and therefore configuring their position did not cross my mind."

This is an additional example of the problems and difficulties of the licensee's configuration control program. In reviewing the circumstances of the above example, it is apparent that while the operators are performing their duties adequately for Mode 5, there is a lack of respect for the system lineup program being performed and an absence of a cognitive management interface between the operators and the group performing the system alignment The failure to record the positions of the three BIT recirculation valves is considered an additional example of violation 327,328/87-66-01 for failure to properly establish, implement and maintain written procedure The inspectors independently verified RHR system valves, comparing plant records of valve positions (Status File and Configuration Log) with actual valve positions as displayed on the control room panels. Two valves, 2-FCV-74-1 and 2-FCV-74-2, ,

RHR supply from hot leg, loop 4, were found to be in a different '

position from that shown in the record Both were actually

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open on .0ctober 27, 1987, as -required by existing plant

- conditions in Mode 5. But the records of valve position showed them. to bel closed (the position required by checklist 63.10 Revision 42 in the status file). These valves had previously-been properly deviated and entered in the Configuration Log, but were' cleared when a newer revision to the checklist was receive The new SOI checklist allowed the' valves to be open when the RHR

' system is in cooling mode; however, .the revised portion of the checklist was never accomplished. OSLA-58 Revision 3, required that if a new revised checklist is issued, the revised portion i should be completed, attached to the existing old checklist, and placed in the status file. If this procedure had been followed when the new checklist was received, the actual valve position and theirecords of valve position would have been in agreemen This is considered an additional example . of- Violation ' 327, 328/87-66-01 for failure to properly establish, implement, and maintain written procedur The inspector also verified portions of system 63. valve

. checklists 63.10-1, 63.1A-6, and 62.1B- During the walkdowns the inspector determined that the following valves, flanges or pipe caps were not included in the applicable system operating instruction checklists:

2-63-371A Root valve to RWST Level transmitter 2-63-46 2-63-372A Root valve to RWST Level transmitter 2-63-49 2-63-373A Root valve to RWST Level transmitter 2-63-50 2-63-374A Root valve to RWST Level transmitter 2-63-51 2-63-375A Root valve to RWST Level transmitter 2-63-52 2-63-376A Root valve to RWST Level transmitter 2-63-53 2-63-344A Root valve to Pressure Instrument 2-63-74 Flange downstream of valve 2-63-599 Flange downstream of valve 2-74-549 This is considered a violation of T.S. 6.8.1 for failing to have an adequate System Operating Instruction for the Emergency Core Cooling System and is designated violation 327,328/87-66-0 The inspectors performed an independent verification for valve checklist 63.10 Rev. 43, " Placing the Residual Heat Removal (RHR) system in standby condition for safety injection" The

inspectors noted that valve 2-74-512, the RHR pump discharge flushing connection isolation, a locked shut valve, was missing the handwheel nu The inspector observed that the handwheel and locking device could be completely removed due to the L - _ _ _ _ _ _ _ _ _ _ _

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missing handwheel nut. In addition, the inspector observed a yellow caution tag on the RHR heat exchanger bypass header vent'

that had no - signature ur instructions ~ on the tag. These items were identified to the licensee for correctio The inspectors independently verified selected portions of SDI-63.1 power availability checklist A-1 thru A-9, B-1, B-3, C-1, C-2, C-3, and D with-the-assistance of licensee personnel. The

' inspector noted on checklist A-9 that the reference ~ drawing numbers for 2-FCV-63-48, 2-FCV-63-38, 2-FCV-63-23, 2-FCV-63-41, and 2-FCV-63-68 were. incorrect. The inspector determined that the position for the circuit breakers for RHR Heat _ Exchanger con-trol valves 2-HIC-74-16, 2-HIC-74-32,'2-HIC-74-28 were not speci-

'fied on checklist 501 63.10. - This is considered an additional-example .of violation 327,328/87-66-02 for failure to have an adequate system; operating instruction for. the Emergency Core Cooling Syste Power availability. checklist 63.1A-8 did not adequately specify the location;of the fuses for 2-FCV-63-6 Drawing 45N779-29 listed the fuse locations as. compartment 2E for the penetrations fuses (FV3-63-67A) and' the penetration control fuses (FV3-63-67B). Checklist A-8 lists 'both compartment 11B and compartment 2E for'the power supply breaker and -control power breaker but does-not identify the fuse locations. The inspector found that'the fuse. holders in compartments 11B and 2E (which-were later determined to be ' abandoned fuse holders) had the exact type o f. fuses specified. - for the penetration and penetration: control fuses. Because the labels'had been-removed from these fuse holders, a' problem with' labeling was assume However after further. investigation and further discussion with licensee electrical' engineers, sit was discovered that the fuses were located in ' the back of compartment 11. The proper fuses

. were. verified' installed in _ the correct holders; however, the checklist did not adequately specify-the locations to ensure the proper fuse holders were checked. The failure. to specify the location of 2-FCV-63-67 penetration and penetration' control fuses-is considered an additional example of Violation 327,328/87-66-02 for failure to provide an adequate S0I for the Emergency Core Cooling Syste (4) Containment Spray (System 72)

The inspector performed an independent verification for valve checklist 72.1B-1, " Alignment of the RHR Spray System for Standby." The inspectors found 'two valves that did not comply with the requirement of OSLA-58, which states " items that will not be aligned normal and will not impact mode changes as determined by the SR0 may be deviated at this time". The_

inspectors observed that valves 2-FCV-72-40 and 2-FCV-72-41 (RHR spray ' header A&B isolation valves) were required by valve

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l' checklist ti 1-1 to be operable and closed. They were actually inoperable ai d losed, and were so noted in the Configuration l Lo For Mod, , operations, these valves are required to be

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operable and close Thus these valves were deviated in the Configuration Log even though they are required for mode chang This example is considered a result of the confusion caused by the conflicting criteria for checklist deviations as discussed in paragraph 3 The inspectors independently verified selected portions of power availability checklists 72.1A-1, 72.1A-2, and 72.1B-1 for the Containment Spray System. The inspector observed that for valves 2-FCV-72-40 and 2-FCV-72-41, the reference drawings were reversed on the checklis . General Plant Condition During the system walkdowns, the inspectors noted a number of material condition discrepancie These discrepancies were reviewed with operations' personnel and are listed below: Control room valve position indicator inoperable due to misaligned limit switch (FCV-63-64, cold leg accumulator nitrogen supply header flow control valve). Name tags missing on many valve Several valve handwheel nuts were noted as missin Many flexible conduits were broken or pulled away where they attached to electrical boxes, Many valves had evidence of packing leak General area cleanliness was poor around Auxilicry Air Compressor A-A and in the RHR 2B-B pump roo These conditions are similar to those noted in NRC Inspection Report 50-327,328/87-52, which you were requested to address formally. Again, this points out weaknesses in your preventative maintenance programs and in your ability to properly identify and correct maintenance deficiencie !

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