IR 05000373/1986029
| ML20215G659 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 10/09/1986 |
| From: | Eng P, Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20215G639 | List: |
| References | |
| 50-373-86-29, 50-374-86-30, NUDOCS 8610210051 | |
| Download: ML20215G659 (11) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
i Reports No.
50-373/86029(DRS); 50-374/86030(DRS)
Docket Nos.
50-373; 50-374 Licenses No. NPF-11; NPF-18 Licensee:
Commonwealth Edison Company Post Office Box 767 Chicago IL 60690 Facility Name:
LaSalle County Station, Units 1 and 2
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Inspection At:
LaSalle Site, Marseilles IL Inspection Conducted:
July 7-11, 22-24, and September 22-23, 1986 Inspector Pat icia L. Eng d>ciaI<' T /9J (
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Approved By:
Monte i
ps, Chief (7c15 /r T / %fdI
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Operational Programs Section Date Inspection Summary Inspection on July 7-11, 22-24, and September 22-23, 1986 (Reports No. 50-373/86029(DRS); No. 50-374/86030(DRS))
Areas Inspected:
Routine, unannounced inspection of corrective action for items identified in previous inspections of licensee's inservice testing program for pumps and valves; test data associated with inservice testing and operability determination for RCIC, Unit 2; and test data associated with
inservice testing and operability determination for RHR, Unit 1.
Results:
Of the 3 areas inspected, three violations were identified in two
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areas (Failure to perform increased frequency testing - Paragraph 4; Failure to l
adhere to procedures - Paragraphs 4 and 5; Failure to implement an inservice testing program in accordance with the ASME Code - Paragraph.5).
8610210051 G61014
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gDR ADOCK 05000373 PDR
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DETAILS 1.
Persons Contacted
- G. J. Diederich, Station Manager
- R. D. Bishop, Services Superintendent
- J. C. Renwick, Production Superintendent
- D. S. Berkman, Assistant Superintendent Technical Services
- T. A. Hammerich, Assistant Technical Staff Supervisor
- P. F. Manning, Assistant Superintendent of Technical Services
- R. D. Sagmoe, IST Coordinator
- R. W. Stobert, Station Quality Assurance (QA) Supervisor D. A. Winchester, Senior QA Inspector D. A. Zoloty, ISI Engineer
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- Denotes those attending the exit meeting on September 23, 1986.
Other members of the plant staff were contacted during the course of the inspection.
2.
Licensee's Corrective Action on Previously-Identified Inspe_c_ tion Items a.
(Closed)Openitem(373/85016-04(DRS);374/85016-04(DRS)): 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> time for data evaluation not concurrent with LC0 time limits in Technical Specifications (TS). The licensee stated that pumps whose inservice testing data falls into the required action range will not
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be declared inoperable until a verification test is performed. The
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verification test will be performed within the 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> time limit specified in the inservige testing (IST) program. The inspector noted
'that as stated in a memo from Samuel Bryan to R. C. Lewis, dated March 17, 1980, which was provided to the licensee as an attachment to Inspection Reports No. 50-373/85016; No. 50-374/85016, the pump would be considered inoperable when initial test data was determined as being in the required action range and that the associated Limiting Condition for Operation (LC0) would apply. The licensee agreed that should the verification test validate the results of the initial test, pumps would be considered inoperable as of the completion of the initial test. This item is closed.
b.
(0 pen) Violation (373/85016-03(DRS);374/85016-03(DRS)): Vibration measurements not in accord with either relief request o'r ASME Code; data validity questionable. The inspector reviewed procedure changes, personnel training, and test data and determined that procedure revisions specifying vibration velocity measurement techniques to be taken at the locations specified in the American Society of Mechanical Engineers' Boiler and Pressure Vessel Code (ASME Code) were incorporated into all pertinent procedures, approved, and issued for use by January 30, 1986; however, review of test records revealed that the licensee continued to fail to take vibration measurements in accordance with the requirements of the inservice testing program.
Problems associated with vibration measurements encountered during this inspection are discussed in Paragraphs 4 and 5 of this report. This item remains open pending
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complete implementation of the corrective actions delineated in the licensee's response to inspection report 373/85016; 374/85016(DRS)
as transmitted by letter from D. L. Farrar to J. G. Keppler dated July 2, 1985.
3.
Summary While the items identified in this report did not functionally impact equipment operability, they are indicative of programmatic deficiencies related to surveillance testing conducted by the licensee.
Although the licensee had an Inservice Inspection / Testing Coordinator, discussions with the Coordinator indicated that he rarely reviewed the status of the inservice testing program to ensure compliance with the ASME Code requirements..The Coordinator's primary duties were to ensure that program submittals to the NRC were coordinated with members of Licensing.
Discussions with members of both the plant operations department and the technical staff revealed that the staff had a limited understanding of the inservice testing program and its relationship to operability determination.
Several systems engineers stated that they were not familiar with the requirements and purpose of the program.
It was not clear to the inspector as to which of the licensee's groups held responsibility for monitoring the status of the inservice testing program and ensuring that plant practices complied with program requirements.
In addition, identification of those surveillance tests used to demonstrate component operability was extremely difficult.
This was largely due to the fact that the 1.icensee performs many LaSalle Operating Surveillance (LOS) tests without explicitly documenting the reason for their performance.
Engineering evaluations were cursory and did not specifically identify equipment deficiencies, problems or solutions.
In many cases procedure steps were signed off as being not applicable without explanation.
Despite observations made during the IST inspection conducted in 1985, the licensee at the time of this inspection had still not performed a Quality Assurance audit of the inservice testing program although such an audit was planned prior to the end of this calendar year.
Audit questions and areas of interest had yet to be developed. Weaknesses related to the licensee's inservice testing program and program implementation were discussed during the inservice testing inspection conducted in mid-1985; however, it did not appear that the procedure changes and additions made by the licensee in response to previous. inspection findings had been consistently acted on by the licensee staff. While intensive investigative efforts were able to determine that generally appropriate rationale was used to declare various components operable, available documentation did not support such determinations.
It was not clear to the inspector that the licensee appreciates the system and component inservice testing and surveillance requirements associated with verification of operability.
The licensee should evaluate the implementation of their inservice testing program, particularly with regard to vibration; clarify to members of their
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staff the relationship between inservice testing and equipment operability; review documentation associated with the evaluation of IST data; and evaluate the adequacy of management controls and checks imposed on the inservice testing program.
4..
Test Data Evaluation for_ R_C_IC Unit _2 i
In order to determine whether vibration measurements required by the ASME Code for the inservice testing of pumps were being obtained in accordance with the ASME Code, the inspector reviewed test data records for the RCIC system on Unit 2.
Data revealed that on December 23, 1985, vibration velocity data placed the RCIC pump in the alert-range.
requires licensees to verify the operational readiness of pumps and valves required for safety as specified in Section XI of the ASME Code, as does LaSalle Technical Specification 4.0.5.
For LaSalle County Station, the 1980 Edition of the ASME Code is applicable.
IWP-3230 of Section XI of
'the ASME Code requires that test frequencies for pumps in the alert range
be doubled until the cause of the deviation is determined and the condition corrected. Further review of the test records revealed that the licensee initiated an increased frequency testing request per LAP-100-12, which stated that, " vibration data will be retaken during system operability testing upon water leg pump return to service." The due date for the increased frequency inservice test was specified as-February 7, 1986 with the grace period extending the date to February 18, 1986. Since the required testing frequency was quarterly, these February dates would have.
met the requirements of IWP-3230; however, no record of RCIC pump inservice testing was found for this period. The associated engineering evaluation dated March 6,1986, states, " Vibration data was not taken on return to service. The above listed parameter value (vibration) is the first in a series of baseline data being taken...does not represent any degradation of pump performance... increased frequency testing is not required." While this was the first time that the licensee had measured RCIC pump vibration in this manner, no provision to waive corrective actions mandated by the i
ASME Code for exceeding acceptable range limits was in place.
-The ASME Code in IWP-3230 required that those components in the alert range be subjected to increased frequency testing until the cause of the deviation is determined and/or the condition co'rected.
In the case of r
the RCIC pump vibration, the licensee performed an evaluation in order to justify waiving the increased frequency testing requirements specified in the Code; however, insufficient evidence that the pump was performing acceptably with regards to vibration measurements was available to warrant removal of the increased frequency test requirement. As noted in inspection report 373/85016(DRS); 374/85016(DRS), valid inservice testing
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vibration' histories for pumps in the program did not exist due to the method of vibration measurement previously used by the licensee; consequently, it was not clear how the licensee could have arrived at the conclusion that values obtained were not indicative of pump degradation.
Review of past available vibration data revealed.that the RCIC pump had been in the alert range on and off since January 1985. Exemption from the requirements of the Code are allowed provided that the licensee has
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applied for and received specific relief from NRR.
The inspector noted that the acceptance criteria specified by the licensee for vibration velocity data were rejected by NRR in the Inservice Testing Safety Evaluation Report (ISTSER) for Unit 1 transmitted by memo from Elinor G.
Adensam to D. L. Farrar dated May 27, 1986.
Failure to perform the required increased frequency testing on the RCIC pump is a violation (374/86030-01(DRS)).
Determination and use of appropriate acceptance criteria for vibration velocity measurements by the licensee for their inservice testing program for both Units 1 and 2 is an open item (373/86029-01(DRS);
374/86030-02(ORS)).
Review of the data sheets for the RCIC surveillance, LOS-RI-Q3, Reactor Core Isolation Cooling System Pump Operability and Inservice Test, revealed that two partial surveillances were performed on the water leg pump, which performs the " keep fill" function for the RCIC system, during March 1986.
Discussions with members of the licensee's staff indicated that the RCIC pump suction pressure was alarming high sporadically.
Licensee personnel thought that impeller adjustments on the water leg pump would alleviate the alarm. Two surveillances were run on March 21 and March 26, 1986, to prove water leg pump operability following impeller adjustments.
Review of the March 1986 data revealed test documentation deficiencies.
The comments sections for the two March surveillances to verify water leg pump operability after impeller adjustments state that since the normal water leg pump discharge pressure gauge 2E51-R604 was pegged high, local pressure gauge 2E51-R501 was used to measure pump discharge pressure.
No temporary procedure change prescribing the use of the local pressure gauge was found.
Although a local pressure gauge was used in lieu of the gauge specified in the surveillance procedure, the fact that the acceptance criteria were based on readings taken with the normal gauge was overlooked by licensee personnel.
The inspector noted that due to the physical installation of the two gauges, the pressure reading from the local pressure gauge for the local instrument required a head correction prior to comparison with the test acceptance criteria.
The. inspector reviewed previous test data and determined that no changes
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to the reference values or to the acceptance criteria had been made.
Addition of the correction factor to the discharge pressure observed on the local pressure gauge indicated that the water leg pump differential pressure on March 21, 1986, had been in the alert range and that the differential pressure obtained on March 26, 1986, should have been noted as being in the required action range.
No record that the water leg pump or the RCIC system were declared inoperable based on the March 26, 1986, data was found in either the control room or degraded equipment logs.
LaSalle Technical Specification 6.2.A.7 requires the licensee to adhere to detailed written procedures.
Technical Specification 6.2.D specifies that temporary changes to procedures may be made provided the change is approved by two members of plant management, one of whica holds an SR0 license, is documented, and is reviewed by the Onsite Review and
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Investigative Function and approved by the Station Superintendent within 14 days of-implementation.
No evidence that use of the local pressure gauge had been reviewed and approved as a temporary procedure change as required by the Technical Specifications was found.
As a result of deviating from the test procedure, the licensee unknowingly entered a 14 day Limiting Condition for Operation.
A subsequent surveillance test performed on April 5, 1986, prior to the expiration of the 14 day _ time limit, determined that the pump was operable using the gauge specified in LOS-RI-Q3.
Since the water leg pump affects the RCIC system operability and the licensee had unknowingly entered into a Limiting Condition for Operation, the inspector reviewed the control room logs to determine whether the High Pressure Core Spray (HPCS) System had been declared inoperable for any reason between March 26, 1986 and April 5, 1986. The control room log indicated that HPCS had been declared incperable-for surveillance testing. purposes; however, the duration of the period of inoperability did not exceed the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> LC0 which applied with both RCIC and HPCS inoperable.
Failure to adhere to the procedure by obtaining RCIC water leg pump discharge pressure from a pressure gauge other than that specified in the procedure is considered to be a violation and the first example of the licensee's failure to follow procedures (374/86030-03a (DRS) NOV No. 2a).
As previously stated, the licensee, in an attempt to alleviate the high suction pressure alarm for the RCIC system, performed impeller adjustments as described in licensee wcrk request number L55974.
The work request requires.that those portions of LOS-RI-Q3 pertaining to the RCIC water leg pump be performed following (.ompletion of the impeller adjustment.
Step 2 of LOS-RI-Q3, Revision 7 dated January 23, 1986, states that vibration be measured in the horizontal, vertical and axial direction at all accessible bearings and recorded on a data sheet which depicted the location of the pertinent bearings.
This provision and note was intended to fulfill the corrective actions specified in the LaSalle response transmitted from D. L. Farrar to J. G. Keppler dated July 2, 1985.
The data sheets for the March 21, 1986, surveillance contained vibration velocity data in the vertical direction only.
The March 26, 1986, data sheets for vibration' velocity could not be located, despite the fact that available test documentation indicated that a maximum vibration velocity had been measured somewhere.
Review of additional data sheets revealed that horizontal and axial vibration velocity data for the water leg pump had previously been recorded.
The licensee had not effectively implemented the corrective
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actions delineated in their July 2, 1985 memo.
Consequently, violation 373/85016-03(DRS); 374/85016-03(DRS)'is not closed.
Failure to perform the measurements as committed to in the July 2, 1985, response and as required by procedure LOS-RI-Q3 is an example of incomplete corrective action as related to the violation discussed in Paragraph 2, item b. and the second example of the licensee's failure to follow procedures (374/86030-03b (DRS) NOV No. 2b).
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Further review of LOS-RI-Q3 data revealed that a surveillance test performed on April 16~ 1986, indicated the differential pressure of the
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water leg pump to be in the required action range.
The water leg pump
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. discharge pressure was recorded as "> 85."
The pump' suction pressure was
calculated from the suppression pool. level as being 15.8 psi.
Based on these pressures, the differential pressure was erroneously calculated and
recorded as 69.2 psi.
Since this value fell in the required action range
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because it was-too large, a special test was performed which specified different. acceptance criteria based on the use of a local pressure gauge.
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The results of the special test appeared to be satisfactory; however, the
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. inspector noted that new reference values and associated acceptance
criteria had not' been set for use in the inservice testing program.
Establishing and proper documentation of new reference values, including vibration, for the water leg pump per the requirements of IWP-3110 through
-3112 is considered an ope'n item (374/86030-04(DRS)).
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The licensee stated that they planned to revise the surveillance requirements for the water leg pump to require only verification that the i
pump can maintain a specified pressure.
The inspector noted that this would require revision of the licensee's inservice testing program.
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The licensee.had a tendency to rely on LaSalle Special Tests (LSTs) for
information regarding operability.
The inspector stated that if LSTs are used to determine equipment operability, care should be taken to ensure
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Discussions with members of the Quality Assurance group revealed that l
audits of the inservice testing program had not previously been conducted; however, future audits were planned.
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5.
Test Data Evaluation for RHR, Unit 1
The inspector noted that none of the Unit 1 RHR pumps and their associated
water leg pumps were required to be operable until the reactor cavity was
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drained down and the unit entered Mode 5 or Cold Shutdown conditions. The i
licensee stated that the cavity was drained down on May 10, 1986, and in order to meet Technical Specification requirements, Division 2 of the Emergency Core Cooling System (ECCS), which consists of the "B" and "C" RHR pumps, was declared operable.
Although several surveillances'on.the Division 2 ECCS pumps were performed while the reactor cavity was flooded, test data consistently fell into the required action range.
Comments made on the test summary sheets for those tests performed.while the suppression pool level was low stated " Test Sat due to suppression pool level."
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Review of'the pertinent surveillance proce'dures, LOS-RH-Q1, " Residual Heat.
Removal System and RHR SW System Operability and Inservice Test," and LOS-LP-Q1, " Unit 1 Low Pressure Core Spray System Inservice Test for Operating Condition 1,2,3,4, and 5," revealed that both surveillances required minimum suction and discharge pressures for both the main RHR pumps and their associated water leg pumps.
Since the unit was in refueling, the reactor cavity was flooded and the suppression pool was
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lower than normal operating levels.
Since the surveillance procedures
required-a minimum discharge pressure and the suction pressure would be directly affected by the suppression pool level, it was logical _for the differential pressure 1to be high.
Onsite Review and Investigative Function Committee. meeting minutes for
April 18,,1986, associated with the Unit 1 Status Review for Reload for Cycle 2 notes that "LOS-RH-Q1 for RHR "B" and."C" pumps performed with
... low pool level... caused pumps to have higher DP values than the
required action values specified in the surveillance.... abnormal DP readings can be attributed to the change in suppression pool level and are therefore considered operable."
The inspector agreed that although qualitatively, the phenomenon was expected, assurance that the pump would still perform acceptably on a
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quantitative basi.s was needed, i.e., verification that observed pump flow i
and differential pressures were consistent with those' established by-the manufacturer's. pump curve and/or previous test data. Objective evidence i
providing a quantitative correlation between previously defined acceptable
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. pump performance and performance following pump shaft modification and
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with normal suppression pool-levels was not found.
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Further investigations revealed that each of the RHR pumps had undergone a
major modification which entailed shortening the pump shafts to reduce pump vibration.
The licensee stated that post modification testing had
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been used to prove the pumps operable by obtaining a pump ~ curve and
subsequent comparison of the pump test curve to preoperational test data.
The-inspector reviewed the post modification test records for all three RHR pumps and noted that although pump curves were obtained, the pumps were not all tested with identical pool levels, making correlation difficult.
IWP-3111 of Section XI requires that following repair or
routine servicing, new reference values, as delineated in l
Table IWP-3100-1, be determined or the previous values reconfirmed within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> of return of'the pump to~ service.
Test records.for the "B" and
"C" RHR pumps did not contain any evidence that pump reference values were verified per the requirements of the Code following completion of
the modification and return to service.
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In addition, both the "B" and "C" RHR pump post modification tests were i
conducted with normal suppression pool level; however, a correlation of
pump performance with low pool level with pump performance with normal pool level was found for the "C" pump only.
Consequently, evidence that the "B" RHR pump would perform acceptably with the pool at normal level based on test data obtained when the pool was at the low level did not 1'
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. exist. The' inspector noted that the test records also did not contain vibration reference data taken as described in the licensee's memo dated
- July 2, 1986. As a result, the licensee did not have sufficient evidence
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to support the determination that Division 2 of ECCS was operable with regards to inservice: test. data.
The licensee stated that the tests performed with the reactor cavity flooded and the-suppression' pool at.a low. level were for information only and that since the pumps were not required to be operable by the Technical Specifications until'the cavity was drained down and the suppression pool level returned to normal, an inservice test was performed for each pump after pool level returned to normal for the purpose of demonstrating pump operability. Test records indicated that.surveillances were performed on May 23 and June 17, 1986 for "C" and "B" RHR pumps, respectively.. Test.
results were satisfactory; however, IWP-3400 states that those pumps which are not inservice tested during shutdown periods shall be tested within one week after return to normal operation.
Since the licensee stated that the tests performed with low suppression pool level were for information only, the test requirements specified in IWP-3400 apply.
Failure to verify reference values for for all three RHR pumps.after modifications and failure to perform inservice testing on the Division 2 ECCS pumps within one week after return to service is considered to be a violation (373/86029-02(DRS)).
The.. inspector noted that had the licensee either quantitatively correlated pump performance with low pool level with existing-acceptance criteria, or run the inservice test within the time constraints imposed by Section XI of the ASME Code,~the operability requirements as they-relate to surveillance testing would have been satisfied.
Although testing of the associated RHR water leg pumps is required in the surveillance test procedures for the inservice' testing of the RHR pumps, and the water leg pumps themselves are included in the inservice testing program, no test records to demonstrate water leg pump operability-following the shaft modification or to verify operability with low suppression pool level could be found.
Establishment and verification of reference values for the water leg pumps which perform the " keep fill" t
function for the ECCS is considered to be an open item (373/86029-03(DRS)).
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The "A" RHR pump underwent the same modification during the 1986 outage.
Review of test records dated April 29, 1986, for the "A" RHR pump revealed that a pump curve was derived for the pump with :;uppression pool level lower than normal; however, as in the case of the "B" and "C" pumps, no inservice testing data to verify reference values was found.
Further investigation of the ECCS system component records revealed that surveillances were performed on Division 1 components during the same time frame.
Division 1 consists of the Low Pressure Core Spray (LPCS) and "A"
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RHR pumps.
The licensee stated that surveillances on both the LPCS and
"A" RHR pumps before and after cavity drain down were conducted to characterize pump performance.
Review of the test data indicated that prior to cavity drain down, the LPCS water leg pump, which also serves as the keep fill pump for the
"A" RHR pump, had been tested and fell into the required action range.
Further investigation of the operability determination of the LPCS water leg pump revealed that the water leg pump was rebuilt and subsequently tested by LST 86-043 on June 2,1986.
The purpose of LST 86-043 was to obtain new baseline reference data; however, the inspector noted that no vibration measurements had been taken.for inser'vice testing purposes.
No record that the LPCS system had been declared inoperable for the purposes of this test and subsequently returned to service was found.
Determination by the licensee of the dates of return to service for the LPCS water leg pump'and Division 1 of the ECCS, and identification of the inservice test' data which demonstrates system operability in support of post cavity drain down is considered to be an unresolved item (373/86029-04(DRS)).
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In addition, LOS-RH-Q1 surveillance test data taken on the "C" RHR pump on March 9, 1986, was obtained using gauges other than those specified in the procedure. The comments section of the surveillance does not explain why different gauges were used and no temporary procedure change could be found which prescribed use of different gauges.
It is not clear whether use of different gauges impacts the acceptability of the test data, i.e.,
if due to relative locations of the gauges, a head correction factor must be applied.
As~previously discussed, the licensee's Technical Specifications require that temporary procedure changes be reviewed and approved as specified in TS sections 6.'2.A and 6.2.D; however, no evidence that use of gauges other than those specified in LOS-RH-Q1 was reviewed and evaluated per Technical Specification requirements.
This is the third example of the licensee's failure to adhere to procedure changes (373/86029-05(DRS) - NOV No. 2, Item c).
6.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whethcr they are acceptable items, open items, deviations, or violations.
An unresolved item disclosed during the inspection is discussed in Paragraph 5.
7.
Open Items Open items are matters which have been discussed with the licensee, which will be reviewed by the inspector, and which involve some action on the part of the NRC of the licensee or both.
Open items disclosed during the inspection are discussed in Paragraphs 4 and 5.
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8.
Exit Interview The_ inspector met with the licensee representatives denoted in Paragraph 1 at the~ conclusion of the inspection on September 23, 1986.
The inspector summarized the scope and results of the inspection and the likely content
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of this inspection report.
The-licensee acknowledged the information and did not indicate that'any of the information disclosed during the
. inspection could be considered proprietary in nature.
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