IR 05000387/1982020

IE Insp Rept 50-387/82-20 on 820614-18.No Noncompliance Noted.Major Areas Inspected:Emergency,Abnormal Alarm Response & Instrument Surveillance Procedures

ML20062F446
Person / Time
Site:	Susquehanna
Issue date:	07/14/1982
From:	Blumberg N, Caphton D, Pullani S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20062F422	List: IR 05000387/1982020 ML20062F418
References
50-387-82-20, NUDOCS 8208120054
Download: ML20062F446 (19)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 82-20 Docket No. 50-382 License No. CPPR-101 Priority --

Category B Licensee: Pennsylvania Power & Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Facility Name: Susquehanna Steam Electric Station, Unit 1

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Inspection at: Berwick, Pennsylvania Inspection conduct  : June 14-28, 1982 Inspectors:

N. B [um K

_ g ~ 6r Ird'pector

, React l W0W dkte signed

' ani A actor Inspector viision da'te signed Approved by:

D'.

[ 4 e (8 ///

L. Chphttif, Chief Management 7 h[fP dat6 ' signed Programs Section Inspection Summary: Inspection on June 14-18, 1982 (Inspection Report N /82-20)

Areas Inspected: Routine, unannounced inspection by two region based inspectors of licensee action on previous inspection findings and program and implementation or emergency, abnormal, alarm response, and instrument surveillance procedure The inspection involved 76 hours8.796296e-4 days <br />0.0211 hours <br />1.256614e-4 weeks <br />2.8918e-5 months <br /> onsite and 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> offsite by two region based inspector R_e sul ts : No violations were identified.

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j 8208120054 820729 PDR ADOCK 05000387 0 PDR

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DETAILS 1. Persons Contacted L. Adams, Supervisor of Operations P. Bartel, Shift Supervisor

• F. G. Butler, Instrument and Control / Computer (I&C/C) Supervisor R. Byram, Acting Supervisor of Operations

• F. Eisenhuth, Senior Compliance Engineer F. Graber, Operations Consultant (Quadrex Corporation)

J. Graham, Staff Assistant J. Green, Operations Quality Assurance (OA) Supervisor M. Johnson, Integrated Startup Group (ISG) Quality Engineer C. Meyers, Assistant Plant Superintendent - Outages D. Sitler, Senior Results Engineer P. Taylor, Operations Engineer

• D. Thompson, Assistant Plant Superintendent B. Veaszie, I&C Engineer J. Wrarton, Supervisor Nuclear Records System USNRC

• J. McCann, Resident Inspector

• G. Rhoads, Senior Resident Inspector

• denotes those present at exit intervie . Licensee Action on Previous Inspection Findings (Closed) Inspector Follow Item (81-24-05):

! Numerous administrative procedures which were approved and issued l during 1979 and 1980 are out of date in that they reference incorrect or nonexistant procedures, do not contain referenced forms as part of the procedure, or are inconsistent with more recently issued admini-strative procedure The inspector determined that all administrative procedures which required revision have been revised except for AD-00-033, "Nonconformance Control" which is in the process of revisio Based on the above, this item is close (Closed) Inspector Follow Item (387/82-09-23):

Operations Department must establish procedures for control of "satel-lite" files which are extensions of the controlled procedure " user control" system established by procedure AD-QA-101, " Procedure Program."

The inspector determined that Operations Department Instruction, 01-AD-002, " Operations Procedure Control," has been issued and establishes controls for updating and use of procedures located in various parts of the plant (satellite sites). Based on the above, this item is closed.

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(0 pen) Inspector Follow Item (387/81-24-09):

There were no procedures written or planned for various categories in Regulatory Guide 1.33-1978. During this inspection, the inspector determined that procedures had been written or issued for the following RG 1.33 catagories which were previously identified by this item:

Category Procedure

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1.1. Access to Containment AD-QA-309, " Primary Containment Access and Control" (not issued)

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1.m. Communications System OP-99-003, " Communications"

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4.j. Maintaining Containment AD-QA-309, " Primary Containment Integrity Access and Control (not issued);

and AD-QA-302, " System Status and Equipment Control"

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4.x. Nuclear Instrument Operation of Nuclear instruments System are contained in tl.e General (a) Source Range Operating procedures (not issued)

(b) Intermediate Range (c) Power Range

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6.d. Loss of Core Coolant ON-64-002, " Loss of Reactor Flow Recirculation Flow"

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6.k. Loss of Protective E0-00-001, " Reactor Scram";

Systems Channel 0N-59-002, " Containment Isolation";

and Technical Specification requirements for loss of RPS bus, T.S. 3.3.1 and 3. .1. Mispositioned Control ON-55-001, " Stuck Control Rod";

Rod or Rods (and Rod Drops) ON-55-006, " Rod Drift"; and, ON-56-001, " Unexplained Reactivity Change" (includes rod drops)

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6.s Malfunction of ON-93-001, " Turbine EHC System Automatic Reactivity Malfunction" Control

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6.z. Intrusion of ON-00-003, " Chemistry Anomaly" Demineralizer Resin into (not issued)

Primary Systems

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1.k Call-In of Personnel AD-QA-131, " Plant Management Call Out Procedure"

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5. Safety Related Local AR-D(A-D)-521, " Diesel Generator Alarms (See also inspector ( A-D)" (Four procedures - not follow item 387/82-09-22) issued);

L AR-ES-529, "ESW Pump House (Spray Pond)" (not issued); and AR-RB-209, " Containment Sumps" (not issued)

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6.v. Plant Fires Fire pre plan procedures for each section of the plant

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6.w. Acts of Nature ON-00-002, " Natural Phenomena" Since the above procedures have been written or issued this aspect of the item is closed. For those procedures listed above which have not been issued, their issuance will be followed as part of inspector follow ite,n 387/82-09-21 concerning the need to issue all applicable procedures prior to O For RG 1.33 category 1.h Record Retention, a Station Records Management System (SRMS) procedure has not been issued concerning QA related procedures. Consistent with additional inspector follow items 387/82-09-16 and 17 concerning the maintenance of QA records, this procedure must be issued prior to initial criticality. This item (387/81-24-09)

remains open pending issuance of a PORC and station manager approved SRMS procedure concerning maintenance of QA record (Closed) Inspector Follow Item (387/82-09-22):

Alarm response procedures must be prepared for safety related remote alarm panels and issued prior to receipt of the operating license (OL). The inspector noted that the following safety related remote alarm response procedures have been identified and written but not yet issued:

AR-DA-521, Diesel Generator A AR-DP-521, Diesel Generator B

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AR-DC-521, Diesel Generator C AR-DD-521, Diesel Generator D AR-ES-529, ESW Pump Hous (Spray Pond)

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AR-RB-209, Containment Sumps The need for alarm response procedures for safety related remote alarm

, panels was also identified as part of open item 387/82-09-21 which identified the categories of procedures which must be issued by OL.

i Since remote alarm procedures have been identified and drafted, this

item is closed. The issuance of these procedures will be followed as

part of 387/82-09-21.

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(Closed) Inspector Follow Item (387/81-24-11):

, Review compliance to regulatory requirements concerning the use,

control, and accuracy of information displayed on Control Room CRT's.

t The licensee stated that controls have been established to ensure that CRT displays are updated to reflect the latest information. These controls were not verified by the inspector during this inspectio However, since this area will be reviewed during future routine inspec-

! tions, this item is administratively close l (0 pen) Inspector Follow Item (81-24-03):

Procedure AD-00-003, "PORC Procedure," does not adequately reflect the requirements of Section 6 of the current proposed Technical Specifi-

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cations for Unit 1. The inspector determined that AD-00-003 has been revised and renumbered to AD-QA-102, " Plant Operations Review Committee."

The current procedure more adequately reflects PORC responsibilities as delineated in the current proposed However, because of changes to the T.S., the inspector determined the i following PORC responsibilities have not been incorporated into AD-QA-

, 102:

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T.S. 6.5.1.6.i and j - PORC shall be responsible for submitting l recommended changes to the Security and Emergency Plans and their

! implementing procedures to the Susquehanna Review Committee; and

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T.S. 6.5.1.6.1 - PORC shall be responsible for review of changes to the PROCESS CONTROL PROGRAM, OFFSITE DOSE CALCULATION MANUAL, and radwaste treatment system This item remains open until all T.S. responsibilities for PORC are incorporated into AD-QA-10 (0 pen) Inspector Follow Item (387/82-09-25): Instrument root valves must be included in Operations Department valve lineup checkoff lists

' (COL's) and instrumentation valves are to be controlled by I&C Department procedure During this inspection, the inspector verified by a sampling review of instrument surveillance (SI) procedures that instru-ment valves are operated by procedure in a step by step manne .

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Restoration of instrument valves is also done in a step by step manne Additionally, each SI procedure contains a table for independent verification and documeatation of valve restoratio This item remains open pending inclusion of instrument root valves into valve lineup COL' (0 pen) Inspector Follow Item (387/82-09-27): $

The following deficiencies were observed in system operating and

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surveillance procedures:

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Procedures OP-83-001, " Automatic Depressurization System and Safety / Relief Valves"; S0-83-002, " ADS Valve 18-month Manual Actuation" did not adequately address the operation and use of the Accoustic Monitor Position Detection Syste The inspector verified that OP-83-001 has been revised to include an operating procedure for the Accoustic Monitor Position Detection System; and that 50-83-001 has been revised to use the Accoustic Monitor as means to verify opening of safety and relief valve Additionally, procedures SI-83-226, " Monthly Channel Functional Test of Safety Relief Valve Position Indication Channels VISH-14180Al-A8 and 14180B1-88" and SI-83-326, "18 Month Calibration of Safety Relief Valve Position Indication Channels VISH-14180 A1, A2, A3, A4, AS, A6, A7 and 14180 B1, B2, 83, B4, B5, B6, B7 and B8" have been issued for testing of the Accoustic Monitor Detection Syste Based on the above, this aspect of the item is close S0-53-001, "Standoy Liquid Control System Monthly," did not adequately identify Technical Specification acceptance criteria concerning pump operation and flow path verification. Additionally, a pump packing leakage check is accomplished by the procedure but a pump run time is not specifie The inspector verified that S0-53-001 has been revised to verify applicable Technical Specification acceptance criteri Pump run time is still not specified in the ,rocedure; however pump run time is not required by the Technical Specification for this test and the pump packing leakage test is a local requirement. Based on the above, this j aspect of the item is close l l

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S0-49-002, "RHR System Flow Verification," acceptance criteria j reaction refers to incorrect procedure paragraphs for determining l

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flow for the suppression pool cooling mode of operation and the procedure acceptance criteria specifies a test line pressure

, which has not yet been incorporated into current Technical Speci-l fication 4.5.1.1.2.

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The inspector verified that S0-49-002 has been revised to refer to l correct procedure paragraphs concerning acceptance criteria and to reference latest Technical Specification acceptance criteri This revision has not yet been issued; however issuance of this procedure will be followed as part of inspector follow item 387/82-21-09 concerning i

issuance of all required plant procedures prior to O Based on the above, this aspect of the item is close OP-13-001, " Fire Protectian System," does not yet include fire detection and alarm procedures plus associated checkoff lists.

, The licensee stated that an expiration date of June 15, 1982, had been established for this procedure to ensure that it is revised

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to include the abov The inspector determined that OP-13-001 has not yet been revised; hence, this aspect of the item remains open. . Emergency, Offnormal, and Alarm Response Procedures Review 3.1 References

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Technical Specifications Unit 1 (Proposed)

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Regulatory Guide 1.33-1978, Quality Assurance Program Require-ments (Operation)

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ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants

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SSES QAM, Procedure 7.1, Revision 7, Control and Issuance of

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FSAR Section 13.5, Plant Procedures ,

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NUREG-0716, Safety Evaluation Reports related to the operation of Susquehanna Steam Electric Station, Units 1 and 2, including Supplements 1 and 2

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NUREG-0737, November,1980, clarification of TMI Action Plan Requirements

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(Draft) Emergency Procedure Guidelines, BWR Owners' Group, Revision IB

-- PP&LLetter,May6,1982,CurtistoSchwencer,NRR,Subjectf GE Review of Emergency Procedures and Startup Test -

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3.2 Scope of Review A sampling of issued Emergency, Of fnormal, and Alarm Response procedures were reviewed to ascertain compliance with the regulatory requirements and licensee commitments referenced in Paragraph 3.1. Procedures were reviewed for:

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Administrative controls for review cnd approval

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Correct format

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Technical adequacy

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Ascertaining that adequate procedures exist for combating emergencies and correcting offnormal and alarm conditions 3.3 Emergen_cy Procedures 3. Procedures Reviewed

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E0-00-002, Loss of Instrument Air, Revision 0, October 28, 1981

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E0-00-007, Abnormal Radiation Release - Liquid, Revision 0, June 4, 1982

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E0-00-009, Plant Shutdown From Outside Controi Roem, Revision 0, March 24, 1982

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E0-00-011, Abnormal Radiaiton Release - Gaseous, Revision 0, June 4, 1982

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E0-00-014, Anticipated Transient with Failure to Scram (ATWS), Revision 0

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E0-00-021, Level Control, Revision 0, November 21, 1981

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E0-00-022, Cooldown, Revision 0, March 25, 1981

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E0-00-024, Level Restoration, Revision 0, March 25, 1981

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E0-00-025, RPV Flooding, Revision 0, March 15, 1981

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E0-00-026, RPV Pressure Reduction (Preferred Method),

Revision 0, March 25, 1981

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E0-00-027, Rapid Depressurization, Revision 0, March 25, 1981

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3. Findings 3.3. The inspector reviewed the index of Emergency Procedures against the index in RG 1.33, Appendix A, to ascertain sufficient procedures exists for combating emergencie The inspector inquired about the existence of certain emergency procedures to satisfy the requirements of RG 1.33, Appendix A, as they were not readily apparent from the procedure titles in the index. The licensee representative stated that the emergency procedures are symptom oriented and as such, the requirements of RG 1.33, Appendix A, are satisfied by the existing procedures. The specific requirements of RG 1.33, Appendix A, and the procedures satisfying these requirements are listed below:

RG 1.33, Appendix A, Paragraph Procedure 6.a loss of Coolant E0-00-021 thru 27 6.j Loss of Feedwater E0-00-024 6.n Conditions Requiring Use of Standby Liquid Control System E0-00-014 6.q Generator Trip ON-93-002 6.t Malfunction of Pressure Control System ON-93-001 The inspector reviewed the above procedures and verified that the requirements are satisfied.

3.3. The inspector noted that following Emergency Procedures l are not yet issued

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E0-00-001, Reactor Scram E0-00-003, Loss of Condenser Vacuum

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E0-00-004, Loss of All Offsite Power

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E0-00-005, Fuel Cladding Failure

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E0-00-006, Fuel Handling Accident l

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E0-00-008, Primary System Break Outside Drywell

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E0-00-023, Containment Control The licensee stated that Emergency Procedures not yet issued would be issued prior to 0 This will be followed up in a future inspection under an earlier open item (387/82-09-21) regarding required plant procedures to be issued prior to O .3.2.3 The inspector reviewed the emergency procedures against the draft Emergency Procedure Guidelines (EPG), Revision IB, submitted by BWR Owncrs' Group to NRR for review (Enclosure to the letter, September 8,1981, from T. Dente to D. G. Eisenhut). The inspector verified that the licensee's emergency procedures addressed all scenarios in the EPG as cross referenced below: e EPG Scenario Licensee's Procedure Level Control E0-00-021 Cooldown E0-00-022 and 026 Containment Control E0-00-23 Contingency 1, Level Restoration E0-00-24 Contingency 2, Rapid RPV l Depressurization E0-00-27 Contingency 3, Core Cooling Without Injection E0-00-024, Step 2.5.4

Contingency 4, Core Cooling Without Level Restoration E0-00-024, Step 2. Contingency 5, Alternate Shutdown Cooling E0-00-022, Step Contingency 6, RPV Flooding E0-00-025 l

i 3.3.2.4 The inspector also reviewed G.E. review comments on Emergency Procedures E0-00-21 through 27 and PP&L resolution of these comments (enclosures to PP&L letter, May 6, 1982, Curtis to Schwencer, NRR). The inspector noted that 7 of these comments were classified by as Category III (defined as those which could affect

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reactor safety if not incorporated). The licensee's resolution of all 7 Category III comments indicates certain licensee actions and appropriate revision of Emergency Procedures E0-00-022, 023, 024, and 02 The licensee has completed these actions and is in the process of revising the procedures. The above procedures will be further reviewed during a future inspection as a part of an earlier IE outstanding item (387/82109-14)

regarding TMI Action Item .3. The inspector expressed concern about the clarity of certain emergency procedure steps and possibility of misinterpreting these steps during an actual emergenc The steps indentified were:

Emergency Procedure Step E0-00-021 Note below Step E0-00-024 2. E0-00-025 E0-00-025 2. A licensee representative stated that the operators have a clear understanding of these steps and did not identify any problem during their simulator training and NRC:NRR walk-through of the simulator exercises of these procedures conducted on May 7, 1981. The inspector interviewed several operators and other operations personnel and ascertained that they clearly understood these step The inspector had no further questions at this tim .4 Offnormal Procedures 3. Procedures Reviewed

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ON-00-002 Natural Phenomena, Revision 0, June 9, 1982

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ON-11-001 Loss of Service Water, Revision 0, February 10, 1982

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ON-14-001 Loss of Reactor Building Closed Cooling Water, Revision 0, October 22, 1981

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ON-15-001 Loss of Turbine Building Closed Cooling Water, Revision 0, October 22, 1981

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ON-35-001 Loss of Fuel Pool Cooling, Revision 0, February 10, 1982

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ON-47-001 Loss of Feedwater Heating (Extraction Steam), Revision 0, April 16, 1982

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ON-47-002 Loss of Feedwater Heater String, Revision 0, April 16, 1982

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ON-49-001 Loss of RHR (Shutdown Cooling)

System, Revision 0, May 4, 1982

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ON-54-001 Loss of Emergency Service Water (ESW), Revision 0, October 20, 1981

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ON-55-001 Stuck Control Rod, Revision 0, October 20, 1982

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ON-55-004 RPIS Failure, Revision 0, October 22, 1981

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ON-55-006 Rod Drift, Revision 0, February 23, 1982

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ON-56-001 Unexplained Reactivity Change, Revision 0, October 22, 1981

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ON-56-002 Loss of Neutron Monitoring, Revision l

0, October 20, 1981

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ON-59-001 Loss of Primary Containment Integrity, Revision 0, October 20, 1981

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ON-64-002 Loss of Reactor Recirculation Flow, Revision 0, October 22, 1981

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ON-70-001 Loss of Secondary Containment Integrity, Revision 0, February 10, 1982

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ON-70-002 High Radiaiton in Reactor Building, Revision 0, June 9, 1982 l

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ON-83-001 Stuck Open Safety-Relief Valve, Revision 0, March 1, 1982 i

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ON-93-001 Turbine EHC System Malfunction, Revision 0, February 23, 1982

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ON-93-002 Main Turbine Trip, Revision 0, November 10, 1981 3. Finding The inspector reviewed licensee's index of Offnormal Procedures and noted the following Offnormal Procedures are not yet issue ON-25-001 Loss of Containment Instrument Gas

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ON-42-001 Circulating Water System Leak

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ON-56-004 Reactor Manual Control System Malfunction The licensee stated that Offnormal Procedures not yet issued would be issued prior to OL. This will be followed up in a future inspection under an earlier IE open item (387/82-09-21) regarding required plant procedures to be issued prior to O .5 Alarm Response Procedures 3. Procedures Reviewed AR-01-001 Alarm Response Window Box 01, Revision 1, February 12, 1982 AR-02-001 Alarm Response Window Box 02, Revision 1, February 12, 1982 AR-03-001 Alarm Response Window Box 03, Revision 1, February 12, 1982 AR-04-001 Alarm Response Window Box 04, Revision 1, February 12, 1982 AR-05-001 Alarm Response Window Box 05, Revision 1, February 10, 1982 AR-06-001 Alarm Response Window Box 06, Revision 1, May 4, 1982 AR-07-001 Alarm Response Window Box 07, Revision 1, February 10, 1982 AR-08-001 Alarm Response Window Box 08, Revision 1, February 12, 1982 AR-09-001 Alarm Response Window Box 09, Revision 1, February 10, 1982 AR-10-001 Alarm Response Window Box 10, Revision 1, February 12, 1982 AR-11-001 Alarm Response Window Box 11, Revision 1, May 18, 1982

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AR-12-001 Alarm Response Window Box 12, Revision 1, May 18, 1982 AR-13-001 Alarm Response Window Box 13, Revision 1, February 10, 1982 AR-14-001 Alarm Response Window Box 14, Revision 1, February 13, 1982 AR-15-001 Alarm Response Window Box 15, Revision 1, May 4, 1982 AR-16-001 Alarm Response Window Box 16, Revision 1, February 12, 1982 AR-17-001 Alarm Response Window Box 17, Revision 1, February 10, 1982 AR-18-001 Alarm Response Window Box 18, Revision 1, February 13, 1982 AR-19-001 Alarm Response Window Box 19, Revision 1, February 12, 1982 AR-20-001 Alarm Response Window Box 20, Revision 1, February 24, 1982 AR-21"001 Alarm Response Window Box 21, Revision 1, February 12, 1982 AR-22-001 Alarm Response Window Box 22, Revision 1, February 13, 1982 AR-23-001 Alarm Response Window Box 23, Revision 1, February 13, 1982 AR-24-001 Alarm Response Window Box 24, Revision 1, February 12, 1982 AR-25-001 Alarm Response Window Box 25, Revision 0, February 16, 1982 AR-26-001 Alarm Response Window Box 26, Revision 0, December 14, 19,82 AR-27-001 Alarm Response Window Box 27, Revision 0, January 25, 1982 AR-28-001 Alarm Response Window Box 28, Revision 0, January 25, 1982 AR-29-001 Alarm Response Window Box 29, Revision 0, April 16, 1982 AR-30-001 Alarm Response Window Box 30, Revision ), February 12, 1982 AR-31-001 Alarm Response Window Box 31, Revision 0, February 10, 1982 AR-32-001 Alarm Response Window Box 32, Revision 0, February 13, 1982 AR-45-001 Alarm Response Window Box 45, Revision 0, February 10, 1982 AR-46-001 Alarm Response Window Box 46, Revision 0, February 10, 1982 AR-47-001 Alarm Response Window Box 47, Revision 0, December 23, 1981 AR-48-001 Alarm Response Window Box 48, Revision 0, February 10, 1982

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AR-36-001 Alarm Response Window Box 36, Revision 0, Draft Note: Each of the above procedures contains a separate procedure sheet for each alarm window. These p.ocedure sheets were reviewed only on a sampling basi . Finding:

Inspector noted that setpoints for alarm actuating devices were missing in a number of these procedure The licensee explained that the information was not available at the time of writing these procedure The inspector noted that the license has a computerized tracking system for identifying these procedures and the missing information. The licensee is in the process of collecting the required data cnd revising the affected procedure The licensee stated that the affected procedures would be revised prior to OL. The inspector had no further questions at this tim . Instrumer* Surveillance Procedures 4.1 References

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Technical Specifications Unit 1 (Proposed)

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Regulatory Guide 1.33-1978, Quality Assurance Program Require-ments (Operation)

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ANSI N18.7-1976, Administrative Controls and Quality for ...

Nuclear Power Plants 4.2 Program Review The administrative procedures for plant calibration and instrument surveillance program were reviewed. Their status, including preparation, approval, issuance and conformance to the requirements of referenced documents were inspected. The following procedures were reviewed:

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AD-QA-600, Conduct of Instrument and Controls / Computer, Revision 0, February 1,1982

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AD-TY-602, I&C Surveillance Draft Procedure Surveillance Program, Revision 0, August 10, 1981

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AD-QA-605, Maintenance and Calibration of Installed Plant Instrumentation, Revision 0, December 21, 1981

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AD-QA-615, Control and Calibration of Plant Measuring and Test Equipment, Revision 0, February 3, 1982

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AD-QA-625, Control of SSES Computer System Hardware and Software, Revision 0, February 5, 1982 4.3 Implementation Review A sampling of instrument surveillance (SI) procedures were reviewed to determine compliance to the requirements in referenced documents of paragraph 4.1 and administrative procedures detailed in paragraph 4.2. Procedures were reviewed for the followir,g:

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Proper review and approval

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Correct formats

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Conformance to Technical Specification reouirements

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System status conformance with Technical Specification limiting condition for operations during component testing (where applicable)

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Accuracy of technical information provided in the procedure

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Provisions for independent review of test data

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Provisions for independent verification of valve status on system restoration

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Stepwise instructions provided in the degree of detail necessary for performing the procedure

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Provisions for use of calibrated test instruments The following SI procedures were reviewed:

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SI-16-301, 18 Month Calibration of RHR Service Water System Flow Channel FT-E11-N0078 to the Remote Shutdown Panel, Revision 0, February 2, 1982

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SI-45-301, 18 Month Calibration of Feedwater System / Main Turbine Trip System, PDT-C32-N004 A, B, C, Revision 0, March 10, 1982

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SI-49-203, Monthly Functional Test of the RHR LPCI Mode Pump Discharge Pressure-High CADS Permissive Channels PS-E11-N020

'A, B, C, D, Revision 0, December 23, 1981

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SI-49-304, 18 Month Calibration of the Reactor Vessel (RHR Cut-In Permissive) Pressure - High Channels PS-B31-N018A and PS-B31-N0188, Revision 0, February 2, 1982

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SI-50-301, Quarterly Calibration of RCIC Steam Supply Pressure Channels PSL-E51-N019 A, B, C, D; Revision 0, January 12, 1982

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SI-51-301, Quarterly Calibration of Drywell Pressure Channels

] PS-Ell-N0 11A, N0118, N011C, and N0110, Revision 0, January 12, 1982

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SI-52-308, Quarterly Calibration of Condensate Storage Tank i Low Level Channels LSLL-E41-N002 and LSLL-E41-N003, Revision 0, March 9, 1982

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SI-59-206, Monthly Channel Functional Test of Supression Pool Water Level Channels LT-15775 A&B (Narrow Range),

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Revision 0, May 4, 1982

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SI-73-301, 18 Month Channel Calibration of Primary Containment

, Pressure Channels PT-15710 A&B (Accident Monitoring Instru-

] mentation), Revision 0, January 12, 1982

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SI-80-205, Monthly Channel Functional Test of Reactor Vessel Water Level Channels LIS-B21-N024A, B, C and D, Revision 0,

March 18, 1982

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SI-80-302, 18 Month Channel Calibration of Reactor Vessel Pressure Channels PT-1N055 A&B, Revision 0, October 29, 1981 4.4 Findings 4. The inspector observed, that in three procedures,

tolerances established by the procedure could cause a trip setting in excess of that established by the Technical Specification Unit 1. The following dis-crepancies were observed

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T.S. Table 3.3.8-2 specifies the Reactor Vessel J water level high (level 8) trip set point as less that or equal to 54.5". Procedure SI-45-301

established this setpoint as 54.5 1 0.3" which

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T.S. Table 3.33-2 specifies the High Drywell trip set point as less than or equal to 1.69 ps Procedure SI-51-301 establishes the setpoint as

1.69 1 0.03 psi which could cause a setting greater than 1.69".

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T.S. Table 3.3.2-2.7.b specifies the Reactor Vessel (RHR Cut-in Permission) Pressure-High trip setpoint as less than or equal to 109 psig corrected

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for cold water head with the reactor vessel floode The licensee calculated head correction as 1 ps Procedure SI-49-304 established a 122.74 psig + 5 psi setpoint for N018B channel which could cause an actual setpoint adjustment as high as 114.04 psig (122.74 psig - 13.7 psi). The inspector noted that the N018A channel setpoint established in SI-49-304 was acceptable even with the plus tolerance applie The inspector noted that the above problem may be generic to all procedures which calibrated setpoint The licensee concurred that the above findings were generic to many procedures and resulted from misinter-pertation of T.S. limits. The licensee had incorrectly assumed that setpoints could be established in the range between T.S. allowable limit and T.S. established trip setpoint which is a T.S. range of allowable instru-ment drif The licensee agreed to review all SI procedures for proper setpoints and change procedures as required prior to fuel load or prior to procedure use which ever came first. This is an open item pending completion of licensee action (387/82-20-01).

4.4.2 The inspector observed the following discrepancies in two procedures:

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Procedure SI-80-302 contained three data tables which, in turn, contained typographical errors giving incorrect pressures for the 1138.7 psig pressure input level

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Procedure SI-59-206 data sheet note states, in part, suppression pool water level be maintained within 23 ft. The Technical Specification has recently been changed and this level is now 22 ft The licensee stated that both procedures would be corrected by fuel loa The licensee further stated that a program was in effect to have each procedure reviewed by an engineer for proper conformance to the Technical Specification prior to first field use of that procedur This is an open item pending completion of licensee action (387/82-20-02).

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4. Temporary Changes82-272, dated June 14, 1982, and 82-282, dated June 15, 1982, were issued to procedure SI-45-301. The inspector observed that the changes did

~not contain any instructions as to how to enter the change and depending on how the change was entered (e.g. page for page substitution) Change 82-282 could eliminate portions of Change 82-272 since change 82-282 was made from the original rather than previously changed procedure. In this instance, the changes were filed with a controlled copy but had not yet been poste The licensee agreed to revise administrative procedures to specify a method or several methods by which temporary changes could be entered and to assure that existing procedure changes are considered when making new change The inspector informed the licensee that this is an item required by OL. This is an open item pending completion of licensee action (387/82-20-03).

5. Management Meetings Licensee management was informed of the scope and purpose of the inspection at an entrance interview conducted on June 14, 1982. The findings of the inspection were periodically discussed with licensee representatives during the course of the inspection. An exit interview was conducted on June 18, 1982 (see paragraph I for attendees) at which time the findings of the inspection were presente