IR 05000424/1986117
| ML20211P348 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 02/12/1987 |
| From: | Shymlock M, Linda Watson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20211P244 | List: |
| References | |
| 50-424-86-117, IEIN-86-080, IEIN-86-80, NUDOCS 8703020346 | |
| Download: ML20211P348 (59) | |
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Report No.: 50-424/86-117 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket No.: 50-424 License No.: CPPR-108 Facility Name: Vogtle 1 '
Inspection Conducted: November 17 - 21 andl December 1 - 12, 1986 Inspector: M uL[3/d b - // 97 L."J.Watsf6,TeamLeader_ Date'Sidned Team Members: F. R. McCoy M. S. Lesser P. B. Moore B. R. Bonser N. Merriweather M. B. Shymlock A. R. Long C. L. Vandernett T. J. O'Connor B. A. Wilson W. K. Poertner G. Nejfelt H. E. P. Krug Approved By: 7T #f/h/4M AJ M aa M 987 M. B. Shymlokk, Section Chief Date SignecV Operational Programs Section Division of Reactor Safety SUMMARY
Scope: This routine, announced inspection was c aducted in the areas of surveillance program administrative controls and implementation, maintenance program administrative controls and implementation, Technical Specifications applicability to as-built systems, control room activities and plant procedure The purpose of this inspection was to assure the adequacy of programs and procedures used to implement the operation;s, surveillance, and maintenance programs at Vogtle Unit 1. The inspection verified that operating, maintenance and surveillance activities met the applicable regulatory requirements and that implementing procedures were complete and technically soun PDR ADOCK 05000424 G PDR
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Summary of Inspection and General Conclusions: The inspection was conducted over the three week period of November 17-21, December 1-5, and December 8-12, 198 The inspection team observed the performance of maintenance work and surveillance tests and observed control room activities. The inspection team reviewed abnormal operating procedures, annunciator response procedures, surveillances associated with power distribution limits and reactivity control, unit operating procedures for startup and shutdown, administrative procedures for control room activities and plant administrative procedures. In addition, the inspection team reviewed procedures and performed system walkdowns for the following systems:
Auxiliary Feedwater System Hydrogen Mitigation Nuclear Service Cooling Water RCS Head Vent Chemical and Volume Control System Safety Injection Containment Spray System Containment Air Cooling System Component Cooling Water Residual Heat Removal System Reactor Coolant System Control Room Ventilation Electrical Systems including the Emergency Diesel Generators Reactor Vessel Level Indication System The inspectors found that operating procedures in the categories reviewed were better than average. The inspectors did, however, identify several discrepancies in the operating procedure The findings included the failure to provide adequate administrative controls for the implementation of the independent verification program, unit operating procedures which did not adequately address monitoring of subcooling margin, errors in system lineup procedures, discrep-ancies in unit operating procedures, discrepancies in the identification and implementation of procedures which provide triggering mechanisms for the performance of special condition surveillances, inadequacies in reactor vessel level indication surveillance procedures, weak procedure prerequisites, and inadequacies in the annunciator response procedure Discussions with the j licensee indicated that these findings would be corrected prior to fuel load.
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The inspectors concluded that the procedures were substantially complete and l
technically adequate and, upon correction of the identified discrepancies, would l adequately support plant operation. During the inspection, the inspectors did observe that the plant operations staff was enthusiastic and dedicated and that l moral was very high.
! The review of the surveillance and maintenance administrative controls indicated that the administrative controls, as documented in procedures, were adequate
(with the exception of those findings identified in this report) to implement the
! surveillance and maintenance programs at the plan However, the inspectors found that these programs had not been fully implemented at the time of the l
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review except on a small number of systems which had been accepted by the Operations Department. The review of the surveillance program and maintenance program is documented in paragraphs 7 and 8, respectivel Several concerns including some procedure deficiencies were identified during the surveillance procedure revie These concerns included the use of pre-operational tests to meet TS surveillance requirements and the completion of surveillance procedure prerequisites. The inspectors noted cases where system configuration control had not been implemented by the Operations Department at the time of test performance and therefore questioned the adequacy of the administrative controls to assure validity of the surveillance test Also concerns were identified in regard to the adequacy of the control of twelve hour surveillances, adequacy of key control for safety related cabinets and the provisions to assure completion of procedures required for mode 6 surveillance The review of surveillance procedures is documented in paragraph In the TS applicability review, two TSs were identified that did not clearly reflect the plant design. These TSs were 3/4.6.1.7, Containment Ventilation Systems, and 3/4.7.5, Ultimate Heat Sink. The discrepancies identified are discussed in paragraphs 7.f and 7.a, respectively. Additional differences were noted but these were attributed to the fact that reviews of recent TS changes were still in progres The review of maintenance procedures indicated that the implementing procedures were basically sound with appropriate QC hold points, provisions for independent verification, and provisions to implement vendor recommendations. Few MW0s completed under the operational maintenance program were available for review, therefore, no conclusion was reached on the adequacy of implementation of the program. The inspectors noted that the preventive maintenance program was detailed and comprehensive but had not been completely implemented. The review of maintenance procedures is documented in paragraph A review of administrative controls established for the management of those plant and control room activities conducted under the direction of licensed operators indicated that implementation was not complet One concern related to the physical location for the balance of plant operator to perform his/her activities was discussed with the license This review is documented in paragraph 1 The licensee was informed at the exit that additional inspection would be conducted to confirm implementation of the surveillance program, maintenance program and administrative requirements for the control of licensed operator activities. The licensee confirmed that audits of the maintenance and surveil-lance program would be conducted to verify implementation of the programs and that licensee management would advise the NRC of the implementation dates for the program The licensee further agreed to take appropriate action to address the findings of this report and complete any corrective action necessary to support Mode 6 operatio . , . - - ...
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Results: No violations or deviations were identifie Thirty three Inspector Followup Items (IFI) were identified. These IFIs are listed below. IFI 424/86-60-10, which was reviewed during the inspection and left open, is also liste IFI Number Description / Reference Paragraph 424/86-117-01 Administrative controls for independent verification of the restoration and testing of plant equipment did not conform to the guidance of NRC IE Notice 84-51 (paragraph 6.a.1)
424/86-117-02 Venting followup items including high point vents on AFW and procedure revisions for system venting (paragraph 6.a.2.a)
424/86-117-03 Procedure revisions to include adequate subcooling margin requirements (paragraph 6.a.3)
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424/86-117-04 Correction of valve identification and system lineup discrep-ancies (paragraph 6.a.4)
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424/86-117-05 Correction of technical concerns in Unit Operating Procedures (paragraph 6.a.5)
424/86-117-06 CLOSED - Correction of discrepancies in the control of performance and documentation of surveillance tests triggered in U0Ps (paragraph 6.a.6)
424/86-117-07 Correction of discrepancies on labeling of valves and equipment (paragraph 6.a.7)
424/86-117-08 CLOSED - Revision of procedures for shutdown outside the control room to include SI initiation criteria (paragraph 6.f.3)
424/86-117-09 Correction of discrepancies in RVLIS surveillance procedure and followup on vendor recommendations (paragraph 6.a.8)
424/86-117-10 Procedure revision to include check of equipment actuation on Control Room ventilation start (paragraph 6.b.12)
424/86-117-11 Procedure prerequisites are general and not well understood by operators (paragraph 6.a.9)
424/86-117-12 Clarification of cleanliness levels (paragraph 6.c)
424/86-117-13 Review of events covered by Abnormal Operating Procedures (paragraph 6.f)
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424/86-117-14 Licensee to review annunciator response procedures for technical adequacy, walkdown ARPs and revise ARPs involving annunciators on the main control board, as appropriate, prior to fuel load. Remaining ARPs to be reviewed within 90 day (paragraph 6.d)
424/86-117-15 Resolution of ISI test data for CCW pump (paragraph 6.e)
424/86-117-16 Resolution of acceptance criteria for RHR differential pressure on recirc flow (paragraph 6.e)
424/86-117-17 Resolution of water hammer in NSCW ESF chillers (paragraph 6.a.2.b)
424/86-117-18 Review of implementation of the surveillance program administrative controls and tracking system (paragraph 7)
424/86-117-19 Review of test control and configuration control for surveillances performed prior to release to the Operations Department (paragraphs 7 and 7.1)
424/86-117-20 Revise procedures to clarify use of Staggered Test Basis for determining frequency of test (paragraph 7.1)
424/86-117-21 Review of the justification for the use of pre-operational tests to meet surveillance test requirements (paragraph 7)
424/86-117-22 Corrective action to assure control of twelve hour surveillances (paragraph 10)
424/86-117-23 Resolution of various technical issues in regard to surveillance procedure adequacy (paragraphs 7.c, 7.e, 7.f, 7.g, 7.h, 7.1 and 7.j)
424/86-117-24 Licensee to implement operational phase corrective and preventive maintenance program (paragraphs 8.a and 8.b)
424/86-117-25 Resolution of Technical Specification 3/4.7.5 wording in regard to availability of the Ultimate Heat Sink (paragraph 7.b)
424/86-117-26 Corrective action for locking or system lineup verification of boron injection flowpath valves (paragraph 7.e)
424/86-117-27 Followup on surveillance procedures which have not been identified as complete on the Technical Specification /
procedure cross reference tracking list. Review of completed cross reference tracking list (paragraphs 7 and 7.j)
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424/86-117-28 Procedure revision for consistent definition of surveillance test completion date and time (paragraph 7)-
424/86-117-29 Review of implementation of special triggering mechanisms to assure completion of special condition surveillances (paragraphs 6.a.6 and 7)
424/86-117-30 Controls on location of 80P operator (paragraph 10)
424/86-117-31 Verification of key control and access to plant equipment by operations staff (paragraph 7.h)
424/86-117-32 Revise TS and procedure for 18 month check of reactor trip breaker UV and shunt coil trip (paragraph 7.h)
424/86-117-33 Resolution of miscellaneous technical concerns on operating procedures (paragraphs 6.b.6, 6.b.7, 6.b.9, 6.b.10, 6.b.11 and 6.c)
424/86-60-10 Adequacy of shift turnover procedures (paragraph 10)
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REPORT DETAILS Persons Contacted Licensee Employees
- P. D. Rice, Vice President, Project Engineering
- G. B. Bockhold, General Manager, Nuclear Operations
- H. P. Walker, Operations Assistant to Senior Vice President
- T. Greene, Plant Manager
+#*C. W. Hayes, Vogtle Quality Assurance Manager
+#*C. E. Belflower, QA Site Manager
+#*M. A. Griffis, Maintenance Superintendent
+#*J. F. D' Amico, Manager, Nuclear Safety and Compliance
+#*W. C. Gabbard, Senior Regulatory Specialist
+#*P. M. Kochery, Plant Engineering Supervisor
- R. W. McManus, Assistant Project Construction Manager
- G. S. Lee, Operations Supervisor
- C. E. Felton, Vogtle Coordinator, Nuclear Operations
- F. Ray, Shift Supervisor
- P. D. Rushton, Plant Training and Emergency Planning Manager
- +W. E. Burns, Nuclear Licensing Manager
+#*R. M. Bellamy, Plant Support Manager
+T. A. Seitz, Corporate Nuclear Office of Quality Assurance
+J. E. Swartzwelder, Deputy Manager, Operations
+*H. A. Jaynes, Maintenance Engineering Supervisor
+A. L. Mosbaugh, Assistant Plant Support Manager
+M. L. Hobbs, Instrument and Controls Superintendent
- R. E. Conway, Senior Vice President and Project Director
- J. A. Edwards, Senior Regulatory Specialist
- W. F. Kitchens, Manager, Operations
- L. Russell, Operations Procedure Coordinator
- C. Meyer, Superintendent, Operations
- A. Caudill, Superintendent, Operations
- H. Varnadoe, Plant Engineering Supervisor Other licensee employees contacted included engineers, technicians, operators, mechanics, and office personne NRC Resident Inspectors
- J. F. Rogge
- R. J. Schepens
+*H. Livermore
- Attended exit interview on November 21, 198 # Attended e:<it interview on December 5,198 + Attended exit interview on December 12, 198 ,
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2 Exit Interview The inspection scope and findings were summarized on November 21, December 5, and December 12, 1986 with those persons indicated in para-graph I above. The inspectors described the areas inspected and discussed in detail the inspection finding No dissenting comments were received from the license Although proprietary material was reviewed during the inspection, no proprietary material is contained in this repor . Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspectio . Unresolved Items No unresolved items were identified during the inspectio . List of Abbreviations ACCW(S) Auxiliary Component Cooling Water System AFW Auxiliary Feedwater System AOP Abnormal Operating Procedure ARP Annunciator Response Procedure ASME American Society of Mechanical Engineers BIT Boron Injection Tank BOL Beginning of Life B&PV Boiler and Pressure Vessel CBCS Containment Building Cooling System CCP Centrifugal Charging Pump CCW(S) Component Cooling Water System CSS Containment Spray System CVCS Chemical and Volume Control System ECCS Emergency Core Cooling System (s)
EDG Emergency Diesel Generators E0P Emergency Operating Procedure ESF Engineered Safety Feature F Degrees Fahrenheit FSAR Final Safety Analysis Report HVAC Heating, Ventilation and Air Conditioning HX Heat Exchanger IEN NRC Office of Inspection and Enforcement Notice IFI Inspector Followup Item LP Lineup Procedure MDAFW(P) Motor Driven Auxiliary Feedwater (Pump)
MLB Monitor Light Board MOV Motor Operated Valve
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MSIV Main Steam Isolation Valve MTC Moderator Temperature Coefficient NRC Nuclear Regulatory Commission NSCW Nuclear Service Cooling Water System P&ID Piping and Instrumentation Diagram PORV Power Operated Relief Valve PRZR Reactor Coolant System Pressurizer QA Quality Assurance RCS Reactor Coolant System RHR Residual Heat Removal System RNO Response Not Obtained RVLIS Reactor Vessel Level Indication System RWST Refueling Water Storage Tank SI Safety Injection SIS Safety Injection System SG Steam Generator SOP System Operating Procedure SSMP System Status Monitoring Panel TCP Temporary Change to Procedure TDAFW(P) Turbine Driven Auxiliary Feedwater (Pump)
TS Technical Specification UOP Unit Operating Procedure VCT Volume Control Tank
$. Review of Operations Procedures (42450B)
The review of operations procedures consisted of a detailed technical review of selected portions of operating procedures, general operating procedures, abnormal operating procedures, and annunciator response procedures associated with thirteen randomly selected system These systems were the auxiliary feedwater system, residual heat removal system, class 1E electrical system, containment ventilation system, nuclear service cooling water system, reactor vessel level indication system, safety injection system, chemical and volume control system, component cooling water system, containment spray system, control room ventilation system, post accident hydrogen mitigation system and the reactor coolant syste This review also encompassed a technical review of general operating procedures associated with normal plant heatup and normal plant shutdow Additionally, a review of operations work procedures was conducte The inspectors reviewed procedures to determine that the important safety requirements were satisfied and that the procedures contained the necessary prerequisites, precautions, limitations and checklists. Provisions to fill, drain, vent, startup, shutdown, change from one operating mode to another, and identify abnormal conditions were audite .- . _- -
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The inspection emphasized the technical adequacy of the procedures to safely control normal and abnormal system configurations and operations. Integral
to the inspection were comparisons between the FSAR, Technical Specifica-tions, process and instrumentation diagrams, system lineup procedures, normal and abnormal operating procedures and the actual installed hardware including the control board switches, instruments and labels. The condi-
. tion, cleanliness, lagging and labeling of the equipment and its associated
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spaces were also observe Portions of the following procedures were reviewed during the operating procedure inspection:
00001-C Plant Organization and Managerial Staff Responsibility and Authority 00002-C Plant Review Board.- Duties and Responsibilities 00003-C Shift Relief ,
- 00004-C Plant Communications 00005-C Overtime Authorization 00006-C Recall of Off-Duty Personnel
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00007-C Independent Verification
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00008-C Plant Lock and Key Control
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00204-C Control of Special Processes 00208-C Control of Measuring and Test Equipment 00254-C Plant Housekeeping and Cleanliness Control
- 00300-C Authority to Startup and Shutdown Reactors
- 10011-1 Operations Procedure Preparation and Review Guidelines
11001-1 Reactor Coolant System Alignment fcy Startup and Normal F Operation
- 11003-1 Reactor Coolant Pump Alignment for Startup and Normal Operation
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11006-1 Chemical and Volume Control System Alignment for Startup and Normal Operation
, 11011-1 RHRS Alignment
! 11105-1 SIS Alignment for Startup and Normal Operation i 11115-1 CSS Alignment for Startup and Normal Operation 11120-1 CBCSs Alignment for Startup and Normal Operation 11145-1 Diesel Generator Alignment for Startup and Normal Operation 11146-1 Diesel Generator Fuel Oil Transfer System Alignment for Startup and Normal Operation c 11301-C Control Building Control Room Normal and Essential HVAC
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System Alignment for Startup and Normal Operation 11405-1 125V DC IE Electrical Distribution System Alignment for Startup and Normal Operation
' 11420-1 13.8KV AC Electrical Distribution System Alignment for
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Startup and Normal Operation
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11427-1 4160V AC 1E Electrical Distribution System Alignment for Startup and Normal Operation 11429-1 480V AC 1E Vital Electrical Distribution System Normal Lineup 11431-1 120V AC IE Vital Electrical Distribution System Alignment for Startup and Normal Operation 11510-1 Remote Shutdown Panel Lineup 11601-1 Steam Generator and Main Steam System Lineup 11715-1 CCWS Aligno.ent 11716-1 ACCWS Alignment 11882-1 Outside Areas Rounds Sheet 11885-1 Diesel Generator Operating Log 12000-1 Refueling Recovery 12001-1 Unit Heatup to Hot Standby 12002-1 Unit Heatup to Normal Operating Temperature and Pressure 12003-1 Reactor Startup 12004-1 Power Operations 12005-1 Reactor Shutdown to Hot Standby 12006-1 Unit Cooldown to Cold Shutdown 12007-1 Refueling Entry 13001-1 Reactor Coolant System Filling and Venting
'13003-1 Reactor Coolant Pump Operation 13005-1 Reactor Coolant System Draining 13006-1 Chemical and Volume Control System Startup and Normal Operation 13007-1 VCT Gas Control and RCS Chemical Addition 13008-1 Chemical and Volume Control System Excess Letdown 13011-1 Residual Heat Removal System 13105-1 Safety Injection System 13115-1 Containment Spray System 13120-1 Containment Building Cooling System 13145-1 Diesel Generators 13150-1 Nuclear Service Water System 13301-C Control Building Control Room Normal and Essential HVAC System 13416-1 Diesel Generator Fuel Oil Transfer System 13405-1 125V DC IE Electrical Distribution System 13415-1 Reserve Auxiliary Transformer 13420-1 13.8KV AC Electrical Distribution System 13425-1 4160V AC Non IE Electrical Distribution System 13426-1 4160V AC Common Non IE Electrical Distribution System 13427-1 4160V AC 1E Electrical Distribution System 13428-1 480V AC Common IE Electrical Distribution System 13429-1 480V AC IE Electrical Distribution System 13430-1 480V AC Non IE Electrical Distribution System
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13431-1 120V AC 1E Vital Instrument Distribution System 13432-1 120V AC Non IE Instrument Distribution System 13433-1 120V AC Common Non IE Instrument Distribution System 13610-1 Auxiliary Feedwater System 13715-1 CCWS Normal Alignment 13716-1 Auxiliary Component Cooling Water System 14228-1 Operations Monthly Surveillance Logs 15150-1 Nuclear Service Cooling Water System 15431-1 120V AC IE Vital Instrument Distribution System Alignment for Startup 17006-1 Annunciator Response Procedure for ALB 06 on panel 1A2 on MCB 17007-1 Annunciator Response Procedure for ALB 07 on panel 1A2 on MCB 17016-1 Annunciator Response Procedure for ALB16 on Panel 181 on MCB 17017-1 Annunciator Response Procedure for ALB17 on Panel 1B2 on MCB 18004-1 RCS Leakage 18007-1 Chemical and Volume Control System Malfunction 18009-1 Steam Generator Tube Leak 18019-1 Loss of RHR 18020-1 Loss of CCW 18021-1 Loss of NSCW 18022-1 Loss of ACCW 18031-1 Loss of Class IE Electrical Systems 18036-1 Seismic Event 18038-1 Operation from Remote Shutdown Panels 19003-1 Natural Circulation Cooldown With Steam Void in Vessel (with RVLIS)
The discrepancies identified during the inspection of the operations procedures have been grouped into several broad categories. The categories indicate that some programmatic problem areas existed that warranted management attentio The findings were discussed with the licensee in detail during the inspections and are described below. A synopsis of the review completed for each system follows the discussion of the finding Additional isolated technical findings are identified in the synopse Findings Identified During the Operations Procedure Review l (1) Independent Verification i
l The inspection team determined that some safety related equipment
addressed by operating procedures was not independently verified l when the equipment was initially positioned or when the position l was changed by an SO . _ _ - _
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Examples of the concerns identified in the independent verifica-tion of' operability of equipment include:
(a) Procedure 13145, was used to place the diesel generators in the standby condition for operation under accident condi-tion Procedure 13145 did not incorporate independent verification when placing the diesel generators in standb The licensee agreed to incorporate independent verification l into the procedur '
(b) The inspector determined that no independent verification was required for three vent valves in the AFW syste Procedure 13610-1, steps 4.4.4.2.c and 4.4.4.2.d, which involved locking closed valves 1-1302-X4-111, 122, and/or 137, and closing and capping valves 1-1302-X4-112,121, and/or 136, for restoration from venting AFW pump (s), were not independ-ently verifie The licensee stated that independent I verification will be required for these valve (c) Procedure 13610-1, checklist 1, for AFWS alignment for startup did not require independent verification for any of the valves, pumps or controller (d) Independent verification is not required for placing the containment coolers in auto in procedure 13120- l The inspectors found that procedure 00007-C, Independent Verifica-tion, did not specify what type of verification is require The procedure did define " direct independent verification" and
" indirect independent verification", but did not address how the verification techniques were to be combine Interviews with l operators indicated that the independent verification requirements l were not understoo J The inspectors determined that 00007-C allowed an exemption from independent verification if the component was monitored by a l control room annunciator or by the Monitor Light Board (MLB). The l licensee stated that the control room annunciator could be the Safety System Monitoring Panel (SSMP) annunciator. The inspectors i determined that indications provided by the SSMP or MLB were not I diverse or positive indications in all case The licensee was informed, at the November 21, 1986 exit meeting, that the NRC's guidance on independent verification was provided in IE Notice 84-51 and that additional guidance on electrical independent verification was provided in IE Notice 85-51. The inspector stated that each component which was to be independently verified by observation of a SSMP annunciator, MLB annunciator or
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control board annunciator must be examined to assure that the verification is diverse and positive. The inspectors stated that the NRC does not consider the absence of an annunciator alarm as a positive indication. The licensee was informed that both verifications, initial and independent, must- be documented by signature of the individual. performing the verificatio The licensee stated a review of the NRC guidance on acceptable methods for implementing independent verification provided in IE Notice 84-51 would be conducted and the independent verification administrative control procedures would be revised to implement this guidanc The licensee also stated that additional retraining would be provided to operators and other individuals performing independent verification including the use of the revised administrative procedure and the proper methods to assure that the independent verification was diverse and positiv During the inspection conducted the week of December 8, 1986, the licensee provided the inspectors with a draft copy of a revision to 00007-C. The licensee stated that the independent verification methods discussed in IE Notice 84-51 had been incorporated into the procedure including the use of field ver!fication in conjunc-tion with verification at the control board as the primary maans of independent verificatio In addition, the licensee stated that training was being conducted on the requirements of 00007-C and independent verification methods. The inspectors noted that the operations surveillance and maintenance programs had not been implemented on many safety related systems since these systems had not been released to Operations and therefore independent verifi-cation had not been implemented. Review of the specific findings identified above, the approved copy of 00007-C, training in independent verification and implementation of the independent verification program is identified as IFI 424/86-117-0 No violations or deviations were identifie (2) Review of System Venting Provisions l Provisions to fill, drain, and vent safety related systems were l, audited. The following concerns were identified with the venting of safety related systems. Finding a. below is identified as IFI 424/86-117-0 Finding b. is identified as IFI 424/86-117-1 (a) The inspectors noted in the system walkdown of the Auxiliary Feedwater System that there were no high point vents on the AFW side of the first check valve between the AFW system and the main feedwater bypass line for steam generators 1 and The inspectors were concerned that any backleakage (and
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subsequent steam formation) of main feedwater through those check valves would become trapped in the highpoints and could result in water hammer upon AFW initiation. The inspectors noted that AFW piping to steam generators 2 and 3 was routed differently and that hi point vents appeared to be adequat The inspectors also noted that procedure 13610-1 provided for checking for and resolving steam binding of the AFW pump This condition would require leakage past three check valves which would also trap steam in the high points beyond the first check valve and second check valve and thus provide potential for waterhamme There were no provisions within the procedure, 13610-1, to monitor these highpoints for leakage and steam formation, nor . to take action, upon detection of steam formation, to resolve water hammer concern Resolution of concerns involving lack of vents at all high points in AFW lines to steam generators 1 and 4 and involving monitoring for and resolving steam formation at high points in AFW lines is identified as IFI 424/86-117-0 (b) During the NSCW system walkdown, the inspector noted some uncharacteristic noises coming from the CCW heat exchanger, which is_ one of the loads of the NSCW system. The sounds were loud and regular, but not periodic. The NSCW system configuration controlled air inleakage, therefore, inleakage was not considered to be a problem. The NSCW pumps take suction from the bottom of a deep pool and the system pressure is greater than that of any of the systems to which it is connected. Discussions with the test engineer for the NSCW system indicated that the sounds were due to the fact that the NSCW system uses orifice plates for flow balancing instead of flow control valves. A check of other components on the NSCW system demonstrated that this was a character-istic sound that increased in pitch and frequency as the pipe i diameter decreased.
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The inspector also noted that the licensee had identified
! water hammer problems in the ESF chillers while conducting l the Engineered Safety Features Actuation System test. The l water hammer on the ESF chillers occurred when the NSCW system was started.
. The inspector discussed this condition with the NSCW test l engineer.
, The test engineer explained that the ESF chillers were
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located approximately 30 feet above the rest of the system and when the system was shut down a vacuum developed in the return line of approximately 30 inches gauge. When the NSCW L
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system was started, the full flow of the pumps ran through the other larger diameter piping, i.e., CCW heat exchangers, faster than the supply to the ESF chillers. Aided by the vacuum in the return line, the water would flow out of the return from the CCW heat exchangers and up the return to the ESF chillers where it would meet the supply, thereby causing the water hamme The NSCW system engineer explained that the methods used to bring the NSCW system on line had been changed in order to minimize the water hammer. These changes included throttling back on the flow to the CCW heat exchangers and running the initial flow through a relief line in order to prevent water from rushing through the system all at onc The vendor conducted an analysis of the condition and determined that the water hammer was not significant enough to cause any damage to the ESF chiller The inspector reviewed the licensee's report on the NSCW water hammer during the inspection conducted the week of December 5, 1986. The report was prepared for the Vogtle Project by Georgia Power Company, Southern Company Services, and Bechtel Western Power Corporatio The title of the report is Loss of Offsite Power Transient (LOSP) Test of the NSCW Syste The report describes the problem and, via referenced correspondences, offers several solutions that fell into two categories. One solution addressed the vacuum in the return lines and how to prevent or relieve it. The other addressed methods by which the actual water hammer forces would be mitigated. The body of the report dealt with the specifics of testing the chosen solution following the LOSP test and securing the NSCW system. The test included a slow fill of the piping through a 4-inch bypass line while the NSCW tower basin return line valve was opened slowly so that the system would pressurize gradually. The report also contained tables and figures of data, and observations taken during the test runs that were used to determine the valve positions and timing sequences that would render the water
[ hammer within acceptable limits.
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The report was well written and complete in its account of the methods used and data collected for the tests. The inspector, after reviewing the report, met with licensee and vendor representatives to discuss the following point Maximum peak pressure limits were first based on the ASME III Code system design pressure. The code allows this pressure to be exceeded by 20 percent for less than 1 percent of the time. Testing on Train A indicated that the reduced water I
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hammer would remain well below these limits. The reduced water hammer on Train B, however, was in excess of these limit The report then revised these limits upwards by basing them on hydrostatic pressure limits. These higher limits allowed a maximum pressure _in the Diesel Generator water jacket of 225 psig. The actual pressure measured during the testing was 220 psig. This is within 2.2 percent of the revised acceptance criteri Two water hammers were experienced during ESFAS testin These events were of the same magnitude as the pressure transients that the NSCW system was initially experiencin It is estimated that these water hammers were approximately 900 psig. Due to problems with the ESFAS testing, the LOSP test has been performed several times and there have been several water hammers on the syste The solution of breaking the vacuum on the return lines of the components that were at higher elevations was dismissed because the containment coolers would then create a possible atmospheric release path. There appeared to be no considera-tion towards breaking the vacuum on the ESF chillers alon This is the highest component in the NSCW system and may play a larger role than expecte The analysis of the water hammer events and proposed corrective action is under review by the NR This is identified as IFI 424/86-117-1 No violations or deviations were identifie (3) Precautions on Maintaining Subcooling Margin The inspectors reviewed unit operating procedures and surveillance procedures and recommended that the following procedures be revised to assure that the operator was monitoring and maintaining the appropriate subcooling margi Followup on the concerns identified below regarding subcooling margin is identified as IFI 424/86-117-0 (a) 00P 12002-1 recommended a temperature difference to be maintained between the pressurizer and RCS during heatup to normal operating temperature and pressure. The procedure, however, did not provide precautions or requirements to prevent exceeding the subcooling margin. The inspector subsequently verified that the procedure was revised with a modified pressure / temperature relationship figure which specified an operating regio The procedure required
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operation within this region thus maintaining an adequate subcooling margi This portion of IFI 424/86-117-03 is considered close (b) In AOP 18009-1, Steam Generator Tube Leak, step 5, Response Not Obtained, requires reduction of RCS temperature from 557F to 500F prior to isolation of the affected steam generator
' if the faulted generator is not immediately identifie The procedure then requires subsequent identification and isolation of the faulted steam generator and RCS depressur-ization to 25-50 psig greater than the faulted steam generator pressure. Under the conditions invoked by Step 5 RNO, when 5.CS depressurization is implemented at step 11, the RCS su3 cooling margin is reduced to approximately 5 This is substantially less than the 28F subcooling margin parameter delineated in procedure 19200-1, F-0, Critical Safety Function Status Trees, for assuring adequate core cooling in the Emergency Operating Procedure network. The inspectors also noted that there were no notes or cautions within A0P 18009-1 to ensure maintenance of an adequate subcooling margin during the depressurization evolution or to provide for securing the cold leg accumulators at 950 psig, the pressure at which they are normally secured during a normal cooldown and depressurizatio The licensee acknowledged these concerns and committed to take actions to resolve the No violations or deviations were identifie (4) Equipment Identification in System Lineups
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The following concerns were identified in regard to the identifi-cation of equipment in system lineup procedures. Followup of the correction of discrepancies identified below is identified as IFI 424/86-117-0 (a) NSCW valve 1-1202-X4-205, located on the return line of the train "A" reactor cavity cooling coil, was listed on the alignment checklist but was not on the drawing nor was it found on the line during the walkdown. A test engineer on the NSCW system indicated that the valve had been removed and should not be on the checklist. The licensee stated that the checklist would be revise (b) One NSCW vent valve, labeled as valve 419, off the CCP lube oil cooler was not on the valve verification sheet.
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(c) Three SIS vent valves, apparently installed as construction modifications, had not been incorporated into 13105-1. These valves were the SI pump suction vent 1-1204-X4-815, the SI pump miniflow line vent 1-1204-X4-827, and the CVCS charging pump suction cross connect vent 1-1204-X4-817. Two of the vent valves, 815 and 827 were noted to be in the system lineup procedure, 11105-1. During the inspection conducted the week of 12/8, the inspector reviewed a draft revision.of 11105-1 which correctly included valve 1-1204-X4-81 The licensee stated that the use of vent valves 815 and 827 had been evaluated and the valves were not needed to vent SIS piping, therefore there was no need to include these valves in the SOP. This portion of IFI 424/86-117-04 is considered close (d) Procedure 13105-1 required a blind flange to be removed on test header vent 1-1204-X4-416 during the fill and vent of the SI, however, it did not require the blind flange to be replaced. The inspector subsequently reviewed a procedure revision which addressed the replacement of the blind flange at test header vent 1-1204-X4-416. This portion of IFI 424/86-117-04 is considered close (e) The CS system alignment procedure, 11115-1, and the CS system P&ID, drawing IX4DB131, did not agre The CS drawing contained two valves, X-40 and X-127, on a flushing line downstream of the B train CS pump that were not included in the alignment procedure. The valves were verified to exist during the CS system walkdown. The drawing indicated that the valves were both normally close Also, in the same flushing connection, the CS alignment procedure showed valve U4-012 close The CS P&ID showed the valve locked open.
! (f) The SI lineup procedure, 11105-1, addressed,a controller that
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had been removed due to elimination of the BIT. The licensee will revise the procedure to delete the referenc No followup action is considered necessar (g) The inspector noted that CTB Cooling Unit Outlet Dampers are f required to be locked open per Containment Heat Removal
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System drawing IX4DB212. Procedure 13120-1 does not include L the locking requirement and the locking method. The licensee is reviewing this ite No violations or deviations were identified.
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(5) Discrepancies in Unit Operating Procedures
': The inspectors reviewed unit operating . procedures 12000-1,
- . 12001-1, 12002-1, 12003-1, 12004-1, 12005-1, 12006-1, and 12007-1 for technical conten The inspectors identified the following technical deficiencies and comments in the unit operating procedures. Followup on corrective actions for these findings is
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identified as IFI 424/86-117-0 (a) Procedure 12000-1 did not specify a pressure band to maintain for plant operation once fill and vent was complet The inspector subsequently verified that procedure 12000-1 was revised to specify the initial pressure band to be maintained by the operator after fill and vent and prior to heatu This portion of IFI 424/86-117-05 is closed.
t (b) Procedure 12001-1 allowed opening of the MSIVs while in Mode
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4 however it did not require opening the MSIV bypass valves first even though the steam generators could be pressurize The procedure was subsequently revised by the licensee to i require that the MSIV bypass valves be opened prior to opening the MSIV This portion of IFI 424/86-117-05 is ~'
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close (c) Procedure 12006-1, step 2.2.5, paraphrased a Technical Specification requiremen The paraphrase was incorrec The step should have read ". .. and at least one loop in operation with the reactor trip breakers open."
! (d) Procedure 12006-1, Section C4.1, Preparation for Continuing Unit Cooldown, required action be taken to activate protec-tion against cold overpressurizatio Only one method of cold overpressure protection was addressed, the use of PORVs.
l The procedure also should have addressed the two othar means of cold overpressure protection and a mechanism to declare which method was providing protection. The procedure should
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have addressed the implementation of the TS surveillance i requirement on the RHR relief valves which must be completed
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prior to taking credit for the RHR reliefs.
l (e) Procedure 12005-1 did not include a requirement in the Limitations section to refer to TS 3.4. I (f) Procedure 12006-1 did not include a precaution to assure that when the reactor is in the source range, positive reactivity additions will only be made by one controlled method at a
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time. This is considered a prudent operating practice. The licensee has agreed to include the precautio No violations or deviations were identified.
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(6) Review of Special Triggering Mechanisms for Surve111ances The inspector identified the following concerns during the review of UOPs in regard to the incorporation of appropriate triggering mechanisms into the UOPs for the performance of mode or condition dependent surveillances. Followup on these specific findings was identified as IFI 424/86-117-06. As noted below all the issues identified were reviewed during an inspection conducted the week of December 8, 1986 and closed. The IFI number will remain assigned to the issue to allow tracking of the findings. -A separate IFI, 424-86-117-29, was opened during the review of surveillance procedures as discussed in paragraph 7 to track inspector followup on the licensee's implementation of special triggering mechanism (a) The inspector reviewed the Technical Specification surveil-lance tracking program for mode change Several TS surveillances for unit startup were not tracked by either a UOP or the Control Room mode change binder; therefore, there was not a method to ensure the surveillances would be performe Examples included the power range, intermediate range and source range nuclear instrument analog channel operational tests and turbine trip actuating device operational test The inspector subsequently determined that the licensee had revised the procedures to include steps to ensure the power range, intermediate range and source range instrument analog channel operational tests and the turbine trip actuating device operational test are conducted prior to startup in accordance with TSs. This portion of IFI 424/86-117-05 is considered close (b) TS 4.1.3.5 requires shutdown banks to be determined fully withdrawn within 15 minutes of control bank withdrawal, however, procedure 12003-1 did not require the verification time to be recorde Records of performance of this surveillance would therefore not be maintained. During the week of December 8, the inspector verified that the procedure was revised to include a requirement for recording the time that shutdown banks were verified to be fully withdrawn to assure that the shutdown banks were withdrawn within 15 minutes of control bank withdrawal in accordance with TS 4.1.3.5. This portion of IFI 424/86-117-05 is considered close ,
(c) TS 4.1.1.4 requires Tave to be determined greater than or equal to 551 degrees 15 minutes prior to achieving criti-calit Procedure 12003-1 addressed this requirement as a precaution rather than providing acceptance criteria during startu During the week of December 8,1986, the inspector
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verified that correct acceptance criteria had been added to ensure Tave was greater than 551 degrees 15 minutes prior to criticality in accordance with TS 4.1. This portion of IFI 424/86-117-05 is considered close (d) The UOPs did not have provisions to assure that appropriate gaseous effluent sampling was conducted. 'The inspector subsequently determined that provisions had been incorporated to assure that gaseous sampling was performed after a startup in accordance with TS 4.11.2. This portion of IFI 424/86-117-05 is considered close No violations or deviations were identifie (7) Discrepancies in Equipment Labeling The inspectors walked down procedures in the control room and the plant to verify consistency with annunciators, switches, controls, indications, and labelin The inspectors identified the following discrepancies concerning the labeling of equipment during the review of procedure Followup on these concerns is identified as IFI 424/86-117-0 (a) Name tags were missing from RHR valves HV-8701B and 1205-02 (Reference drawing 1x4DB122, Rev. 18.)
(b) The inspector noted that the main control board switches for the SI pumps were labeled train A and B while procedure 11105-1 referred to the pumps as 1 and The remote shutdown panel labeled the A train SI pump as 3. The inspector subsequently verified that procedure 11105-1 had been revised to correct these errors, with the exception of the B train controller at the remote shutdown panel. This pump was still labeled as 4. This portion of IFI 424/86-117-07 remains ope (c) The TDAFW panel SG level gauge was not labeled wide range or narrow range. The procedure did not indicate the range. The inspector believes that the labeling should be provided. An AFW to SG bypass flow gauge was not labeled with engineering unit It is presumed to be gpm, but should be labele (d) In procedure 11105-1, accumulator nitrogen fill valves 1-HS-8875 (series E F G H) were incorrectly referred to as 1-HS-8875 (series P S V). The inspector subsequently verified that these errors were correcte This portion of IFI 424/86-117-07 is close L
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- (e) UOP 12001-1 refers to containment spray pumps as 1 and 2 ;
although the main control board labels indicated A and '
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The procedure was subsequently revised to correctly refer to CS pumps A and B. This-portion of IF.I* 424/86-117-07 is-close S w
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(f) _During the w'eeli of November 17, 1986, the_ inspector noted ,
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that engineering units were not displayed on strip chart recorder scales ' fors main steam temperatura and other recorders. The inspec. tor subsequently. reviewed labeling of main control board syrip chart recorders for engineering units during the week'of December 8,1986. Although the main steamtemperaturehadibeencorrectlylabeledbythelicensee; , ,
other recordert still' had no units. Particularly confusing -
was a recordsr, for low pressure turbine exhaust pressure i
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which was labeled as~ vacuum with a scale of 30 to 0 left to .
right. The inspector was told the scale was in psia however . ,=
no units were shown on the recorder. This portion of IFI 424/86-117-07 remains ope t , s (g) The inspettof noted that remote handwheels in the CVCS system including.BI? valves and charging crossover were not labele The applicant stated that handwheels had been installed recently and labeling was planned but had not been complete (h) The CS alignment' procedur$,_ 11115-1, lists two sets of 120V AC CS MOV space " heater breakers. - A check of the 120V AC breaker panels (IAYD1 and 1BYD1) identified the breakers as, being labeled " spares." The applicant is determining if these breakers are utilized for the MOV space' breaker (1) The inspector noted that valve 1-1204-X4-288, SI. RCS hot leg loop FE-0985RT isolation-valve,- had two labels, one of which
- was an incorrect valve" number. During the week of December '
j 8, the inspector verified that ths incorrect tag had been removed. This portion of IFI 424/26-117-07 is close ,
No violations or deviations were identili,e '
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The inspector reviewed the RCS fill and vent procedure, 11001-1, *
which iricludes the fill and vent of RVLIS and identified no problemn The inspector also reviewed procedure 14228-1,
- Operations Monthly Surveillance Leas; TS Table 3.3-8; E0P 19003-1, Natural Circulation Cooldown With Steam Void in Vessel (with RVLIS); Westinghous6 ' Manual B-003E3, RVLIS Manual; and, P&ID l_
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1X4DB113, RTD Bypass Reactor Coolant System. Further review of
/ the concerns identified during the procedure review and field 7 walkdown of RVLIS, discussed below, is . identified as IFI- 424/86-117-09'.~
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The inspector interviewed an operator in the plant and in the (7 ~
control room to determine the adequacy of the procedure The
' inspector noted that the operator had some difficulty with nonenclature and instrument numbering. There were three RVLIS ranges that are called Upper, Wide, and Narrow on some documenta-tion but were labeled Upper, Dynamic and Full, respectively, on other document Control room recorder ILR-1310 was labeled with the former set of names as is drawing IX4DB113, while the SPDS
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computer display and E0P 19003-1, used the latter set of name The operator was also unable to determine which range of RVLIS g instruments to check when using the monthly surveillance
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instrument checklist of 14228-1. The operator attempted to use TS Table 3.3-8 to determine the required instruments, however, this
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table does not identify the specific instruments require The Westinghouse manual recommends that a control room annunciator be provided for the hydraulic isolators in each train of the level sensing lines to alert the operators to an out of calibration condition. The manual also recommends that the locally indicating
" null meters" for these isolators be routinely checked for fluid leakage in the event of temperature compensation problems. The licensee was unable to show where either of these recommendations
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was followed or provide justification for not following the There are four manual isolation valves that must be opened during plant heatup to ensure the PVLIS is operable. The inspector determined that the valves are properly listed on procedure 11001-1 and were able to be located by the operato No violations or deviations were identifie (9) Procedure Prerequisites
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The inspectors identified that some of the prerequisites in SOPS and surveillance procedures were too general . Interviews with licensee personnel indicated that it was not clear to them what was required to be verified to satisfy selected prerequisite The licensee explained that the prerequisites were purposely made general, and that this is sufficient in most casos due to the training of the operators. The licensee agreed that some of the prerequisites should be more specifi ,
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During the week of December 8,1986, the inspector interviewed several operators concerning the implementation of prerequisites in system operating procedures and surveillance procedures. In ,
general, the operators stated that if the plaat were operating at power, operator knowledge of plant status gained during turnover and by normal conduct of business would be relied upon to determine if a prerequisite was satisfied. The operators stated that standard practice would be to go to a P&ID and review the lineup and equipment and determine which equipment was require The answers on how specific prerequisites would be verified were not consistent and varied from sending an individual to the field location to verify operability to relying solely on operator knowledge of the system conditio In some cases the inspectors noted that the operator was not certain as to the required action The' inspectors discussed the interviews with the licensee and the if censee stated that prerequisites would be reviewed and enhanced by clarifying exactly the actions required to satisfy the prerequisite by fuel load. In addition, the licensee stated that the prerequisites would be reviewed in the normal two year review cycle to assure that prerequisites for each procedure were appropriate and comprehensiv Followup on the actions taken to improve procedure prerequisites is identified as IFI 424/86-117-1 ,
No violations or deviations were identifie b. Description of Operating Procedure Review by System A description cf the review completed for operating procedures by system is provided belo Findings which did not fall within a category listed above are identified in the review descriptions provided belo (1) Nuclear Service Cooling Water System The review of the Nuclear Service Cooling Water (NSCW) system consisted of detailed examinations of the operating procedure, 13150-1; and the abnormal operating procedure, 18021-1; the P&ID's; and, the NSCW system alignment checklist. A walkdown of the "A" train of the NSCW system was performed using the alignment checklist and the P&ID's. The procedures, drawings and alignment checklists were compared to each other for consistenc The walkdown was performed tc-verify that the drawings, procedures and checklists were consistent with the final desig ,
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Procedure 15150-1, Rev. O, Nuclear Service Cooling Water System, was the current procedure reviewed at the time of the inspectio The inspector began to note numerous inadequacies in the procedure and requested to see the revision file for this procedure to see if these items had been note The inspector found procedure 15150-1, Rev. O, to be lacking in directions for filling and venting the NSCW system. In addition, the system alignment checklist was discrepant with respect to the P&ID's. A review of the revision file revealed that procedure 15150-1, Rev. O, was to be superseded by procedure 13150-1, Rev. Procedure 13150-1, Rev. 1, was an adequate procedure for governing the operation of the NSCW system. The procedure satisfactorily addressed the problems that were noted in procedure 15150-1. The procedure was easy to follow, contained appropriate cautions, had a specific table of contents, correctly referenced valves and switches by their identification nomenclature, contained values that had earlier been left blank, stated where independent verification was required, and gave specific directions for filling and ven t ' .ag the system under different condition Procedure 13150-1 contained a revised system alignment checklist that was more informative and better organized. Two discrepancies were identified by the inspector concerning the references to valve 1202-X4-205 and CCP lube oil cooler vent valve 419 which had not been corrected in procedure 13510-1. These discrepancies are included in IFI 424/86-117-04 discussed in paragraph 6.a.4 of this repor The following P&ID's were used in the walkdown and in determining the correctness of the procedures: 1X4DB133-1, Re ;
1X4DB133-2, Rev. 21; 1X4DB134, Rev. 17; 1X4DB135-1, Rev. 20; IX4DB135-2, Rev. 1 Procedure 18021-1, Rev. 1, Loss of Nuclear Service Cooling Water, was the A0P for the NSCW system. The inspector determined that this procedure was adequate and properly organized. Identifica-tion nomenclature accompanied all of the instruments and valves and the most limiting Technical Specification was referenced appropriately. The procedure also included a table that listed NSCW loads by trai The inspector performed a walkdown on the "A" train of the NSCW system. The inspector found no discrepancies between the P&ID's and the actual system configuratio The inspector identified one IFI, 424/86-117-17, to follow the corrective actions for water hammers in the NSCW syste This issue is discussed in paragraph 6.a.2.b of this repor No violations or deviations were identifie . - .
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(2) Hydrogen Recombiners and Hydrogen Monitors The inspector reviewed. the hydrogen monitoring and control systems. - The hydrogen recombiners are passive systems that are mounted on the upper level of the Containment Buildin The recombiners appeared to be mounted correctly in accordance with the vendor's recommendations. Technical Specification 4.6. recommended testing in accordance with the vendor's recommenda-tion The hydrogen monitors were also examined by the inspector. Each monitor appeared to be mounted properly. The air supply lines leading to them were also mounted properly. Supply air tanks were filled and at the proper pressur The inspector found no problems with the hydrogen monitoring and control systems or procedure No violations or deviations were identifie (3) Safety Injection System The inspector reviewed procedures associated with the safety injection system. These included procedures 13105-1 and 11105- The inspector walked down portions of the SIS to verify proper component installation and labeling. Several system lineup and
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equipment identification concerns were identified as described in paragraph 6.a.4 of this report and several labeling problems were identified as described in paragraph 6.a.7. No additional discrepancies were identifie No violations or deviations were identifie (4) Electrical Systems The inspector reviewed selected portions of procedures for operation of safety related electrical systems for technical
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adequacy and conformance. The procedures reviewed are listed in l paragraph 6 of this report.
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The inspector conducted a system walkdown of the Diesel Generator Air System and the Diesel Generator Fuel Oil Transfer System. The inspector conducted a walkthrough of' portions of procedure 13145, Diesel Generators. The inspector also conducted a walkdown of various electrical lineup procedures to verify that the nomen-clature used in the procedures corresponded to the nameplate data on the panels and breakers. Within this area the inspector made the following observations:
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While walking down the diesel generator Fuel Oil Transfer System, the inspector detected several discrepancies between the system drawing and the actual configuration in the field. In particular, a valve was installed on "A" diesel generator that was not shown on the system drawing and there was a discrepancy in the location of two instrument root valves relative to the flow path of the system. The inspector pointed out the discrepancies to the system engineer and the engineer stated that the valve not shown on the drawing served no purpose and would be removed and the system drawing would be updated to show the relative position of the two instrument root valves in relation to the system flowpat No followup was considered necessary for this ite No violation or deviations were identifie (5) Residual Heat Removal System Procedure 18019-1, p. 7 of 9, Loss of RHR, was reviewed. The inspector recommended that all fuel movement be suspended earlier in the procedure prior to changing RCS inventory or flow conditions. In addition, step B.5 could be changed to "available personnel" to free up an operato No followup is considered necessar No violations or deviations were identifie (6) Component Cooling Water System The following two alarm panels are not displayed above the CCW operating switches in the control room as required by 18020-1, Rev.1, under symptoms (last two items). These alarm panels are also required by ARP 17002- NSCW Train A CCW HX HI DIFF FLOW NSCW Train B CCW HX HI DIFF FLOW Followup on this discrepancy is included in IFI 424/86-117-3 In step 4.1.1 of procedure 13715-1, Re O, the procedure references procedure 15715-1. The reference should be procedure 11715-1. No followup is considered necessar No violations or deviations were identifie (7) Reactor Coolant System In procedure 18004-1, one of the symptoms was the " unexplained lowering of pressurizer level". Because of the possibility of loss of subcooling associated with leakage, the inspector
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4 requested the licensee to determine if an unexplained increase in pressurizer level should be included in the symptoms as.well. The licensee subsequently stated that an _ increase in pressurizer level was more indicative of other abnormal situations and therefore should lead the operator to other procedures. The inspector noted that step A.5 requires verification of the pressurizer level and verification that pressure is trending to program which should assure that pressurizer level is monitore In procedure 13003-1 the following comments were made. In step 4.1.2.9, which repeats a reactor coolant pump start sequence, no reference was made to the reactor coolant pump restart limitations identified by precautions 2.2.11.2 and 2.2.1 The seal injection flow shown on Figure 1 showed 6 to 8 gpm, whereas item 2.2.6 specified 8 to 13 gpm. The flow logic in the decision tree depicted in Figure 1 failed at both the " check No. 2 seal leakoff flow" block and at the " check injection and bearing temperature" block since neither block provided a logical exit from the bloc In the first item of Table 1, the inspector recommended that the word " degraded" be replaced with a more precise term such as low or decreasing. At Section 6, the inspector recommended that
" charging flow" be removed from the first three items and made into a separate item since it is considered separately in the
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symptoms section. The second item of Section 7 identifies leakage as a cause of " rising pressure at excess letdown heat exchanger outlet PI-0124." After discussion with the licensee, the
- inspector was able to identify the physical mechanism which could i
cause such a resul Item 13 should be deleted since the BIT modification has been completed. The licensee is reviewing 'these concern Followup on these items is included in IFI 424/86-117-3 The inspector performed a walkdown of the reactor vessel head vent system. The inspector utilized drawings IX4DB111, Rev.15; IX4DB112, Rev. 20; and, 1X4DB114, Rev. 21. No discrepancies were observe No violations or deviations were identified.
(8) Chemical and Volume Control System The inspector reviewed procedures and performed a walkdown of I the safety related portions of the CVCS syste The inspector reviewed procedures 13006-1, Rev. 2; 13008-1, Rev. 1; 13007-1, Rev.1; 11006-1, Rev. 2; 18007; and, the associated P& ids. No 4 discrepancies were noted except as listed below.
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While performing the walkdown, it was noted that numerous hand-wheels and valve identification tags were missing from remote manual operators. Followup on this item is included in IFI 424/86-117-07 discussed in paragraph 6.a.7. The licensee stated that tagging of remote handwheels was scheduled prior to startu The inspector noted that insulation covered a number of the vent and drain openings, making their use difficult. The licensee stated, after a review of the insulation concern, that insulation would have to be removed from a number of vents and drains to allow convenient access. No followup is considered necessar No violations or deviations were identifie (9) Auxiliary Feedwater System The inspector reviewed in detail sections of procedures 13610-1, 17016-1,17017-1,11882-1, 11601-1, and 11510-1 dealing with AFW system operation. Additionally, the inspectors walked down the AFW system. The inspectors had the following observations and comments:
The inspector identified several concerns regarding venting AFW piping and monitoring backleakage to AFW f*om Main Feedwate These concerns are discussed in paragraph 6.a.2.a. (IFI 424/86-117-02).
Precaution 2.1.7 of procedure 13610-1 states that the maximum bearing oil temperatures are 180F for the motor driven AFW pumps, 180F for the turbine driven AFW pump bearings and 160F for the turbine bearings. If the maximum bearing temperature is exceeded, the procedure states that the pump should be shutdown. There were no provisions within procedure 13610-1 to monitor for bearing oil temperatures nor was there any local or remote indication to accomplish such monitoring. Although a plant computer alarm associated with AFW bearing oil temperatures was available in the PROTEUS computer system, the licensee stated that it was for the motor driven pumps only. The inspectors noted that even if the plant computer alarm came in there were no instructions to provide for response to the alar Additionally, not all personnel interviewed were aware of the plant computer alarm for bearing oil temperature Resolution of concerns with monitoring and respond 1rg to adverse bearing oil temperatures for all three AFW pumps is included in IFI 424/86-117-3 Neither checklist 1 nor paragraph 4 (instructions) of procedure 13610-1 implemented provisions for positioning and aligning the turbine driven AFW pump overspeed test switch (HS-15130) and speed control potentiometer. Consequently, adequate provisions to
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assure that precaution 2.1.9 of procedure 13610-1 would be implemented and independently verified did not exist. Resolution of this concern is included in IFI 424/86-117-3 During a walkdown of the AFW system, the inspectors noted that the turbine driven pump gland seal leakage was approximately 3 to 5 times greater than that of the motor driven pumps and appeared to be excessive. The licensee acknowledged that the leakage was excessive and stated that action would be taken to resolve the condition. Completion of licensee actions to reduce gland seal leakage for the turbine driven AFW pump is included in IFI 424/86-117-3 Procedure 11882-1, Outside Areas Round Sheets, does not provide for a general inspection of the north main steam and feedwater valve room, the motor driven pump A pump room or the turbine driven pump pump room. Also there are no items to check for adequate pump gland seal leakage and adequate gland seal leakage drainage from the gland seal leakage reservoi Resolution of these concerns is included in 424/86-117-3 The inspector also identified several findings in regard to independent verification of restoration and system alignment of the AFW system. These findings are discussed in paragraph 6. (IFI 424/86-117-01).
During the review of procedures associated with AFW, the inspectors noted numerous cases where enhancements could be made to the procedures. The following recommendations were provided to the licensee for their evaluation. No followup is considered necessar Procedure 13610-1, step 4.1.3.7, veri fied stabilization of the turbine driven pump idle speed at 1535 rpm. The gauge used to verify this parameter reads in 100 rpm increments making verifica-tion at 1535 rpm difficul The specified value should be compatible with instrument increment Procedure 13610-1, step 4.1.3.10, places the turbine driven pump speed controller on aut The procedure should provide an expected response for this actio Procedure 13610-1, step 4.1.4.2, should check close the steam admission valve prior to opening the main steam supply to the turbine driven AFW pump turbin The venting procedure of 13610-1, step 4.4.5.7, does not vent the piping to steam generator 2 as stated in the lead off sentence of the step; instead, it vents the turbine driven piping to both
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steam generators 2 and 3. Also the venting procedure of step 4.4.5.8 does not vent the piping to steam generator 3 as stated in the leadoff sentence of the step; instead, it vents the motor driven pump piping to both steam generators 2 and It is noted that accomplishment of both steps 4.4.5.7 and 4.4.5.8 will adequately vent AFW piping to both steam generators. The inspectors considered, however, that the lead off sentences for these steps and the venting procedures should be compatible with one anothe Procedure 13610-1, steps 4.1.4.2.c and d, should be clarified to indicate the trip and throttle value to be open as well as rese Procedure 13610-1, steps 4.1.2 and 4.1.3 should include provisions to review precautions and limitations prior to starting a pum Procedure 17016-1, annunciator response procedure for ALB 17 on Panel IB2 on MCB alarm windows E03 through F06 should provide for initial operator actions to assure adequate AFW flow to maintain steam generator leve Procedure 17016-1, alarm windows E04, E06 and F06, should refer to TS 3.7.1.2 and 3.7.1.3; should specify the procedure number for transferring from CST 1 to CST 2; and, should specify that lo D/P may be indicative of a steam bound pump, in the probable cause During the procedure walkdowns, the inspectors noted that access to valves 1302-X4-156,1302-X4-259 and 1302-X4-135 was poor and could be enhanced by the use of ladders. Also caps were noted to be missing off the vent lines associated with valves 1302-X4-156, 121 and 12 No violations or deviations were identifie (10) Containment Spray System The inspector reviewed procedures 13115-1 and 11115-1 and performed a walkdown of major portions of the containment spray system. The inspector identified the following items:
Steps 2.2.1 and 2.2.2 in CS system procedure 13115-1 which addresses TS limits did not include Mode 4 in the applicable modes as required by TSs. Revision of this procedure to include the applicable modes is included as IFI 424/86-117-3 The inspector identified additional concerns regarding labeling of breakers as discussed in paragraph 6.a.7.h. (IFI 424/86-117-07).
No violations or deviations were identified.
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11. Containment Buildir.g Cooling System The inspector reviewed procedures 13120-1 and 11120-1 and performed a walkdown of major portions of the containment building cooling system. The inspector identified the following items:
Steps 2.2.1 and 2.2.2 in procedure 13120-1 did not list the applicable TS modes. Followup on this item is included in IFI 424/86-117-3 The inspector identified additional concerns regarding system lineup requirements and independent verification. These concerns are described in paragraph 6.a. (IFI 424/86-117-04) and paragraph 6.a.1.d (IFI 424/86-117-01), respectivel No violations or deviations were identifie '
(12) Control Room Ventilation The inspectors walked down the control room ventilation system and reviewed procedures 13301-C, Rev. O and 113nl-C, Rev. The inspectors noted that labeling on many breakers were not consistent with procedure name In addition, the lineup checklists were not walkdown oriented. Addition of information on the location of components would be beneficial to the equipment operator Certain dampers which are required to automatically close on the manual actuation of control room toxic gas isolation were not verified to be closed in procedure 13301-C. Licensee personnel explained to the inspector that the missing component verifica-tions were due to a design change, and a revision to the procedure is currently being prepared which will correct the problem. These procedure revisions will also address consistency in labeling and the system alignment will be made more convenient to perfor Revision of the control room ventilation procedure will be tracked as IFI 424/86-117-1 No violations or deviations were identifie c. Review of Administrative Controls Administrative procedures 00001-C; 00002-C, Rev. 5; 00004-C, Rev. 1; 00204-C, Rev. 3; 00208-C, Rev. 2; and, 00300-C, Rev. O, were reviewed with no significant finding Some editorial comments, such as typographical errors, were conveyed to licensee personne . . - -
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The inspectors reviewed procedures 00005-C, Rev.1, and 00006-C, Re , which address overtime and recall of off-duty personnel. Procedures 00005-C and 00006-C did not appear adequate to accomplish the TS objective of a 40-hour work week for operating personne Neither procedure states that adequate shift coverage shall be maintained without routine heavy use of overtime, and that substantial overtime shall be on a temporary basis as discussed in TS ~6.2.2.e. The inspector also noticed that the TSs were not consistent with the intent of NUREG-0737 TMI Action Item I.A.1.3 and NRC Generic Letter 82-12, which state that the General Manager should review all overtime and approve excess overtime in advanc The TSs and implementing procedures require only a review by the General Manager of excess overtime. This policy could encourage undesirable amounts of overtim Limiting excessive overtime for personnel performing safety related functions is addressed by TMI Action Item I.A. Clarifying administrative procedures 00005-C and 00006-C to restrict excessive overtime to special circumstances will be included in IFI 424/86-117-3 The inspector reviewed procedure 00254-C, Rev. 2, which addressed housekeeping requirement The inspector identified a need to clarify the levels of cleanliness to ensure deleterious material does not enter safety related system In particular, all open portions of the reactor coolant system should be designated cleanliness Level II. The inspector also recommended that areas adjacent to open safety-related systems be classified as cleanliness Level III rather than Level IV and include requirements for personnel and material accountabilit Clarification of the housekeeping procedure will be tracked as IFI 424/86-117-1 No violations or deviations were identifie d. Annunciator Response Procedure Review The inspector reviewed the following procedures:
10011-C Re Operations Procedure Preparation and Review Guidelines 17006-1 Re Annunciator Response Procedure for ALB 06 on panel 1A2 on MCB 17007-1 Re Annunciator Response Procedure for ALB 07 on panel 1A2 on MCB The review consisted of a comparison of the ARPs to the Annunciator Light Board (ALB) on the Main Control Board (MCB); comparison of Technical Specification related alarms to the final draf t Technical Specifications; a review of the administrative procedures in use covering the formatting, writing, and reviewing of ARPs; and, interviews with operations and supervisory personnel regarding the ARP .
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While comparing the current ARPs to the ALB, the inspector noted several discrepancies between the alarms on the MCB and their respective ARPs. These discrepancies indicated a need to more closely follow modifications made to the MCB ALB to ensure these changes are rapidly reflected in the ARPs. The inspector questioned the licensee about the discrepancies and was informed that most of the items were already identified. The licensee conducted a walkdown of the ALBS on the MCB during the last two days of the inspection thereby ensuring that all such discrepancies were identified and action had been taken to correct any proolem The inspector determined that the final draft of the Technical Specifications had some setpoint changes that had not yet been reflected in the ARPs. The inspector found the following ARP setpoints not in agreement with the final draft of Technical Specifications setpoints:
ARP-17006-1 WINDOW-A03 ACCUM TANK 1 HI/LO LEVEL WINDOW-A04 ACCUM TANK 1 HI/LO PRESS WINDOW-B03 ACCUM TANK 2 HI/LO LEVEL WINDOW-804 ACCUM TANK 2 HI/LO PRESS WINDOW-C03 ACCUM TANK 3 HI/LO LEVEL WINDOW-C04 ACCUM TANK 3 HI/LO PRESS WINDOW-D03 ACCUM TANK 4 HI/LO LEVEL WINDOW-D04 ACCUM TANK 4 HI/LO PRESS In all the above cases, the minimum level or pressure required by final draft Technical Specifications was above the alarm setpoint stated in the procedur The setpoint, of the instrumentation actuating the alarm, however, was set at the minimum value required by the Technical Specifications (level instruments calibrated in July 1986 and pressure instruments calibrated in November 1986). This indicates a failure to follow Technical Specification changes and ensure that those changes were incorporated into the ARPs. The inspector questioned the licensee regarding procedures to enture the inclusion of these changes into the ARPs and was informed that although no written procedure existed, the individual in charge of revisions to the ARPs was to ensure the changes were made. The inspector felt this was an unsatisfactory method of ensuring change inclusion as it was the inspector who brought the above listed discrepancies to the attention of the individual in charge of the ARP revisions. The inspector noted procedures were in place that appeared to ensure the inclusion of Technical Specification and design changes into the ARPs once the facility is out of the construction mode and into an operational mode. The licensee informed the inspector that all ARPs would be reviewed against Technical Specifications prior to final approval of the Technical Specification ._ - _ _
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Procedure 10011-C covers the-qualification of procedure writers, ARP writer's guide, writing technique, and required reviews. The inspector reviewed 10011-C and compared the ARPs to the requirements contained within _the procedur Several discrepancies were . discovered and discussed with the licensee. The-most important of the discrepancies was in - the area- of the initial operator action statements. -The inspector found that most of the ARPs-contained no initial operator actions even though 10011-C requires initial operator action for the following cases: preventing equipment damage or plant trip _ mitigating degradation of safety related systems responding to a personnel safety hazard The inspector interviewed personnel responsible for writing and reviewing ARPs and was informed that the decision to limit the number of initial operator actions had been made to reduce overuse of initial operator action statements in the original draft of the ARP The licensee stated that the initial operator action statements -were removed unless they met one of the following additional requirements: . required action within 1 to 2 minutes- directed the operator into an E0P or AOP
. indicated that a piece of equipment related to a Technical Specification requirement was inoperable The inspector found several ARPs that required initial operator actions because the ARP met one or more of either the'first or the first and second sets of conditions. -The following is a list of some of the ARP subprocedures where initial operator actions appeared to be needed but were not employe ARP-17006-1 WINDOW-A03 ACCUM TANK 1 HI/LO LEVEL Degradation of a safety system Inoperability WINDOW-A04 ACCUM TANK 1 HI/LO PRESS Degradation of a safety system Inoperability WINDOW-A05 ACCUM TANK 1 ISO VLV 8808A NOT FULLY OPEN Degradation of a safety system Inoperability Immediate action required by Technical Specifications WINDOW-803 ACCUM TANK 2 HI/LO LEVEL Degradation of a safety system Inoperability
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WINDOW-B04 ACCUM TANK 2 HI/LO PRESS Degradation of a safety system Inoperability WINDOW-B05 ACCUM TANK 2 ISO VLV 8808B NOT FULLY OPEN Degradation of a safety system Inoperability Immediate action required by Technical Specifications WINDOW-C03 ACCUM TANK 3 HI/LO LEVEL Degradation of a safety system Inoperability WINDOW-C04 ACCUM TANK 3 HI/LO PRESS Degradation of a safety system Inoperability WINDOW-C05 ACCUM TANK 3 ISO VLV 8808C NOT FULLY OPEN Degradation of a safety system Inoperability Immediate action required by Technical Specifications WINDOW-D03 ACCUM TANK 4 HI/LO LEVEL Degradation of a safety system Inoperability WINDOW-004 ACCUM TANK 4 HI/LO PRESS Degradation of a safety system Inoperability WINDOW-DOS ACCUM TANK 4 ISO VLV 88080 NOT FULLY OPEN Degradation of a safety system Inoperability Immediate action required by Technical Specifications ARP-17007-1 WINDOW-A03 BA TANK 1 EMPTY Degradation of a safety system (Technical Specification)
Possible Equipment damage WINDOW-D04 DEMIN INLET HI TEMP Possible Equipment damage Possible time constraint WINDOW-F06 SPRAY ADD TANK LEVEL LO-LO Degradation of a safety system (Technical Specification)
Personnel safety hazard The problem of a lack of initial operator actions was discussed at length with the licensee. The licensee stated that a decision to limit the use of initial actions in the original draft ARPs had been made, however, the licensee agreed that fundamental initial actions had not
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been incorporated. The licensee committed to review and revise all ARPs for the MCB and any other ARP needed for entry into Mode 6 in accordance with 10011-C prior to fuel loa The licensee also committed to review all other ARPs within 90 days. This item will be tracked as IFI 424/86-117-1 No violations or deviations were identifie Acceptance Criteria for ASME Code Section XI Pumps The inspector performed a partial review of the acceptance criteria for ptmps in the following systems:
Component Cooling Water Safety Injection
' Residual Heat Removal Chemical and Volume Control System Nuclear Service Cooling Water Containment Spray Auxiliary Feed Water During the review, the inspector compared the data sheets in the appropriate surveillance test procedures to the requirements of the ASME Boiler and Pressure Vessel Code,Section XI, requirements. The data sheets appeared to be adequate and capable of being used to quickly determine the operability of the tested pump upon completion of the procedur The inspector requested the reference data that would be used as the standard by which pump operability would be measured for each of the pumps in the above systems. The licensee stated that reference data was not available for NSCW, CS, AFW, or the Boric Acid Transfer pumps but that testing of these pumps would be completed prior to the operational mode for which the pumps are required to be operabl Reference data was available for the SI, RHR, CCW, and charging pumps and was provided to the inspector. While reviewing the data on the CCW pumps it was determined that the reference data points for four of the pumps fell below the manufacturer's operational curves for the pump However, those reference points were being used to determine the operability of the CCW pumps. The inspector asked to see the engineering justification that was completed to determine if the pumps were in fact meeting their intended design characteristic The licensee stated that the pre-operational test data was used to justify the reference points of the pumps in question and provided the inspector with the pre-op test data. The pre-op test consisted of a two point check of the pumps operating parameters against the manufac-turer's pump curve. One of the pre-op data points was taken at a flow
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rate of 3000 gpm. The other was taken at 5000 gpm. The second pre-op point was below the manufacturer's pump curve but above the system design point of 5000 gpm and 160 ft of discharge head for the four CCW pumps in question. The inspector noted that - the reference data was recorded at a flow rate of 4500 gpm and that there was not a clear determination of operability provided because the two tests were conducted under different conditions. The licensee committed to the inspector to provide clear engineering justification of the pumps operability prior to fuel load for the four CCW pumps. This commitment will be tracked as IFI 424/86-117-1 The inspector also reviewed the reference data for the RHR pumps and noticed that RHR pump 2 had a discharge pressure of 180 psi. Technical Specification 4.5.2.f required greater than or equal to 180 psi discharge pressure for the RHR pump. The final draft of the facility Technical Specifications, however, requires greater than 180 psi. This Technical Specification change will render the RHR pump 2 inoperable when the Technical Specifications are approved. The licensee informed the inspector that they are currently requesting a change of the Technical Specification to greater than 160 psi. When this change is made the problem with RHR pump 2 should be rectified. Resolution of this item will be tracked under IFI 424/86-117-1 No violations or deviations were identifie f. Review of. Abnormal Operating Procedures The inspectors compared Regulatory Guide 1.33 with the licensee's index of abnormal operating procedures in order to ascertain if recommended procedures were implemented by the licensee. As a result of this review, the inspectors questioned whether the following events were implemented by the licensee:
Loss of condenser vacuum Loss of containm'ent integrity Loss of feedwater Conditions requiring emergency boration Fuel cladding failure High activity in coolant or offgas Pressure control malfunction Plant fires Abnormal releases of radioactivity In each case the licensee identified a procedure that implemented the subject event; however, due to the lack of time, the inspectors were unable to confirm the accuracy of information provided by the license Confirmation that the above events are implemented by procedure is identified as IFI 424/86-117-1 ..
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The licensee stated that AOPs had been initially developed using the FSAR, vendor manuals, and other plant procedures as source materia With regard to instrument failure events, A0Ps were developed if the failure generated an integrated plant respons Following _ initial development, the AOPs were trial run on the simulator (for scenarios that the simulator was capable of handling) and feedback from this trial use was implemented by revision to the AOP Additionally, operating experience from other utilities was factored into the A0Ps where appropriat The inspectors performed a detailed review of three AOPs:
18036-1 Seismic Event 18009-1 Steam Generator Tube Leak 18038-1 Operation from Remote Shutdown Panels The inspectors had the following comments with regard to these procedure reviews:
(1) The inspector determined that procedure 18009-1 contained errors which could have allowed reduction of the subcooling margin to an inadequate valu These discrepancies are discussed in paragraph 6.a.3.b (IFI 424/86-117-03).
(2) Two editorial errors were noted in procedure 18009-1. In steps 9 and 11, the procedure title for procedure 12006-1 is incorrec The first note prior to step 9 states " step 9 thru 11 should be performed expeditiously to avoid faulted SG." As written, this note makes no sens (3) The inspectors reviewed A0P 18038-1, Operation from the Remote Shutdown Panels, and conducted a walkdown aof the remote shutdown panels and the turbine driven auxiliary feedwater pump pane Procedure 18038-1 was found to be adequate except for the consideration of casualty events such as rapid depressurizatio It is understood that the design requirements of the remote shutdown panels do not consider control room evacuation in conjunction with a design basis acciden It is significant, however, in that ECCS equipment will not automatically start upon an SI signal if that component's control has been transferred to the remote shutdown panel. The procedure provided the operator with a precaution explaining that manual action would be necessary to start component The inspector noted that the procedure should provide additional guidance for specifying when and which components must be manually started in the event of reaching SI initiation criteria. The revision of the procedure to address SI initiation criteria was identified as IFI 424/86-117-0 .
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During the week of December 8, the licensee provided the inspector with a draft revision to the procedure. The licensee proposed procedure revisions which provide the operator with guidance on the start of additional ECCS pumps, alignment of ECCS to the RWST suction and opening of BIT isolation valves in order to restore pressurizer pressure if it should lower to less than 1870 psig, the low pressurizer pressure setpoint. The inspectors noted that this proposed change did not require isolation of the volume control tank suction to the charging pumps as a precaution to prevent hydrogen binding of the charging pumps and brought this to the attention of the license The revision adequately addresses the concerns identified, therefore, IFI 424/86-117-08 is considered closed. The IFI number will remain assigned to the issue to allow tracking of the findin (4) In 18038-1, Operation From Remote Shutdown Panels, the inspectors had the following additional comments:
The procedure was not written in accordance with 10012-C, E0P and AOP Writers Guide, in that the Response Not Obtained columns were not always formatted like the Action / Expected Response column as required by step 5.1.2 of procedure 10012- The licensee's attention was directed to an example of formatting problems in step 2 and substeps of procedure-18038-1. The licensee noted the concern and stated that action would be taken to resolve i The remote shutdown panel had two different switches for a PORV block valve. One switch had positions open and closed while the other switch was for arming the cold overpressure setpoint and had positions arm and block. Both switches, however, were labeled as PORV Block Valve. The inspector considered that relabeling the switches to clearly show the function would enhance operator use of these controls and avoid confusion. The inspector was shown new nameplates for these switches which the applicant intends to install which resolves this proble The lineup procedure for the remote shutdown panel required positioning a controller for a BIT isolation valve although the controller had been removed from the panel due to elimination of the BIT. This discrepancy is included in IFI 424/86-117-04 discussed in paragraph 6. The A train motor driven auxiliary feedwater pump switch was labeled 3 although procedure 18038-1 referred to it as A. The turbine driven auxiliary pump panel steam generator water level gauge was not labeled as either narrow or wide range, nor did procedure 18038-1 indicate the range. Four AFW to SG bypass flow gauges were not labeled with engineering flow units. These items are noted as part of IFI 424/86-117-07 in paragraph 6. No violations or deviations were identifie .
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36 Surveillance Program and Procedure Review and Evaluation of Technical Specification Applicability (424508, 42451B)
An ins'pection of the implementation of the surveillance program administra-tive controls and an inspection of the adequacy and implementation of-surveillance test procedures was conducte The inspectors reviewed surveillance procedures for the RHR, NSCW, SI, CVCS, CS, CC, Electrical Power, and AFW systems. In addition, the inspectors reviewed surveillance tests to assure operability of reactor trip and engineered safety feature An inspection was also conducted of surveillance test procedures associated with reactivity control TS The inspectors determined that the licensee had not yet implemented the surveillance program administrative controls except on a small number of systems which had been accepted by the Operations Departmen Followup on the implementation of the operational surveillance program administrative controls and tracking system is identified as IFI 424/85-117-1 During the review of the surveillance program administrative controls, the inspector determined that procedure 00404-C, Surveillance Test Program, defined the completion date and time differently in section 2.5, Definitions, and in Figure 1, the surveillance task sheet cover page. The definition in section 2.5 indicated that the test was completed at the end of the review of test result Figure 1 indicated that the test was completed at the end of the performance of the test. This discrepancy was brought to the attention of the licensee. Resolution of this item will be tracked as IFI 424/86-117-2 During the review of surveillance procedures, the inspectors noted the absence of several special triggering mechanism These examples are discussed in paragraph 6.a.6. Special triggering mechanisms are designed to identify and ensure the adequate completion of surveillance items required in the event of special plant -condition Programs should exist in all departments that procedurally control tracking the completion of special condition triggered surveillances including the time triggered, completion time /date, and notification of Operations of completion to ensure that operators maintain the status of LCO Followup on the licensee's actions to develop and implement such programs and to confirm that all special condition surveillances are triggered appropriately is identified as IFI 424/86-117-2 During the surveillance test reviews, the inspectors evaluated the applica-bility of the final draft TSs to the as-built systems by reviewing the final draft TSs against the procedures and conducting plant walkdowns and system reviews to assure that the TSs reflected the as-built plant features for those systems reviewed. Two TSs were identified that did not clearly reflect the plant design. These TSs were 3/4.6.1.7, Containment Ventilation Systems, and 3/4.7.5, Ultimate Heat Sink. The discrepancies identified are
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discussed in paragraphs 7.g and 7.b, respectively. The licensee initiated action to resolve these concerns and completion of these actions will be verified in a subsequent inspection. Additional differences were noted between the procedures and final draft TSs. These differences involved changes between the previous drafts and the final draft which had not yet been entered into procedures by the licensee, or TS ch nges which were still under review by the NRC. The inspectors determined that these items were being adequately tracked by the license One significant difference involved the testing of the reactor trip breaker undervoltage and shunt trip coils. This difference is discussed in paragraph Some procedures referenced in the TS / surveillance procedure cross reference list had not been written and/or had not been identified in the cross reference list. Verification that procedures are completed and the cross reference list is updated is identified as IFI 424/86-117-2 The licensee stated that some of the surveillances would be performed using a pre-operational test procedure. The inspectors identified the review of the justification for use of preoperational tests to meet TS surveillance requirements as IFI 424/86-117-21. The inspectors stated that the emphasis of the review would be to determine that adequate justification had been provided and properly documented in accordance with procedure 00404-C when a preoperational test was used to satisfy a portion or all of a surveillance requiremen The inspectors determined that in some surveillances performed during the preoperational testing, the prerequisites were not always satisfied prior to beginning the test. It was not clear in the cases reviewed whether or not credit would be taken for the tes In cases where surveillances are conducted prior to the turnover of the system to operations and prior to establishment of configuration control, the inspectors emphasized that provisions must be in place to assure that the system is tested in the proper configuratio In addition, subsequent evolutions or modifications must be carefully evaluated and controlled to assure that the system is not altered in a way to negate the test. Review of these test controls and implementation of configuration control for surveillances is identified as IFI 424/86-117-1 Surveillance procedures and TS applicability for the following systems were reviewed during this inspection: Residual Heat Removal System The inspectors reviewed surveillance procedures for the RHR syste The review covered applicable Technical Specifications, operations logs, surveillance procedures, and other documents related to the surveillance of the equipment in the system.
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The following is a list of surveillance procedures that were reviewed:
14001-1 Rev. 2 Operations Shift And Daily Surveillance Logs 14805-1 Rev. 1 Residual Heat Removal Pump And Check Valve Inservice Test 14721-1- Rev. 0 ECCS Subsystem Flow Balance Test The procedures were found to be adequate for demonstrating the operability of the specified components in accordance with the Technical Specification Each procedure made reference to the applicable TS. Precautions and limitations in conjunction with prerequisites or initial conditions appeared to be sufficient to ensure that unsafe conditions would be precluded from occurrin Independent verification was required for several important steps and appeared adequat Procedure 14001-1 was reviewed to ensure that the more frequent control room surveillances that are required by TSs for the RHR system would be performed. The inspector found no problems with this procedur Technical Specification surveillance sections 4.0.5, 4.4.9.3.2, 4.5.2, 4.7.5, 4.9.8.1 and 4.9.8.2 were reviewe These TSs were found to agree with the as-built plant equipmen No violations or deviations were identifie b. Nuclear Service Cooling Water System Inspectors reviewed surveillance procedures for the NSCW system. The review covered applicable Technical Specifications, operations logs, procedures, and other documents related to the surveillance of the equipment in this syste The following is a list of surveillance procedures that were reviewed:
14001-1 Re v. 2 Operations Shift And Daily Surveillance Logs 14801-1 Rev. O NSCW Transfer Pump Inservice Test 14430-1 Rev. 0 NSCW Cooling Tower Fans Monthly Test 14721-1 Rev. 0 ECCS Subsystem Flow Balance Test The procedures were found to be adequate for demonstrating the operability of the specified components in accordance with the Technical Specification Each procedure made reference to the applicable T Precautions and limitations in conjunction with prerequisites or initial conditions appeared to be sufficient to ensure that unsafe conditions would be precluded from occurrin Independent verification was required as appropriate. There was a concern over the generation and usage of the In-Service Test (IST) baseline data. This is addressed in paragraph 6.e of this repor .
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Procedure 14001-1 was reviewed to ensure that the more frequent control room surveillances that are required by TSs for the NSCW system would be performed. The inspector identified no concern Technical Specification surveillance sections 4.0.5, 4.4.9.3.2, 4.5.2, 4.7.5, 4.9.8.1 and 4.9.8.2 were reviewed. All but one of these TSs were found to be satisfactory. TS 3/4.7.5 had confusing wording and some unacceptable action statement exemption The following changes to the final draft version of TS 3.7.5.a.1 and 2 are under review. The instruments referenced here will be identified by train so as not to suggest that each basin contains more instruments than it really doe ACTION b will have the first sentence reworded to correct a miswordin Also, the statement, "The provisions of Specification 3.0.4 are not applicable" will be deleted. This statement could have allowed the licensee to change modes without any of the tower fans or sprays operable. In TS 4.7.5.a, the word " average" is to be deleted for water level. The water temperature surveillance is to be changed to be consistent with accident analyses. Followup on the revision of the TS to adequately address the above concerns is identified as IFI 424/86-117-2 No violations or deviations were identifie c. Safety Injection System The inspector reviewed applicable portions of the following procedures for technical adequacy to ensure that TSs would be met:
14805-1 Rev. 1 Safety Injection Pump Test 14228-1 Rev. 1 Monthly Operations Surveillance Log Procedure 14000-1 Rev. 2 Shift and Daily Operations Surveillance Log Procedure 14460-1 Rev. 1 ECCS Subsystem Flowpath Verification 14935-1 Rev. 0 ECCS Needle Valve Position Stop Verification 14721-1 Rev. 1 ECCS Subsystem Flow Balance Test 54821-1 Rev. O Train B SI Pump Response Time Test 55016-1 SI System Leakage Assessment Procedure 14721-1 required SI pumps to be operated during the test, however, there was no provision to open and rack out the motor supply
- breakers upon test completion. TS 4.5.3.2 requires the motor supply breakers to be open while in Mode 4, 5 and 6. The inspector was shown a draf t revision to the procedure which included adequate steps. The procedure additionally specified that maximum allowed flow was 650 gpm although TS 4.5.2.h.2.b allows up to 660 gpm. Although the requirement was conservative, it was inconsistent with other requirements in the procedure. The same draft revision also corrected the allowable flow to 660 gp m
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Procedure 14460-1 did not require venting through valve 1-1204-X4-827, SI Pump Miniflow Vent Valve. TS 4.5.2.b.1 requires the venting of ECCS pump discharge piping high points at least once per 31' days. The licensee stated that a TCP would be initiated. The procedure addi-tionally referred to the A SI pump as Procedure 14000-1 did not specify that the surveillances on page 17 were to be performed in modes 1 or 2 only. Procedure 54821-1 incorrectly referenced TS Table 3.3-5 for required response times. This table does not exist and response times are listed in Section 16 of the FSA Procedure 55016-1 incorrectly references TS 6.8.4.a instead of 6.7.4.a for reduction of system leakage requirement Followup on these discrepancies is included in IFI 424/86-117-2 No violations or deviations were identifie d. Engineered Safety Features The following procedures were reviewed for technical adequacy and to ensure that TSs would be met:
24525-1 Rev. 2 Pressurizer Pressure Protection Channel I IP-455 Analog Channel Operational Test and Channel Calibration 24589-1 Rev. 1 Containment Pressure Channel IV Analog Channel Operational Test and Channel Calibration 24795-1 Rev. 1 Steam Pressure Loop 3 Prntection Channel I Analog Channel Operational Test and Channel Calibration 54801-1 Rev. 0 ESF Actuation Response Time Summation for 3 Channel System 54803-1 Rev. 0 ESF Actuation Response Time Summation for 1 Channel System TS 4. 3. 2.1. 5. c , Feedwater Isolation on Low RCS Tave Coincident with Reactor Trip, did not specify which surveillances are to be performe This TS was recently adde The applicant has not yet prepared procedures for performing the intended surveillance Procedure 54803-1 had an overall response time criteria of 15 seconds for containment ventilation isolation on high radiation. The required response time is 5 seconds, not including valve closure time. The applicant stated that this procedure was being deleted and the surveillances would be included in procedure 54802- The correct response time was to be included in the revisio The inspector observed the performance of the analog channel opera-tional test on Pressurizer Pressure Protection Channel I, using procedure 24525-1. During the surveillance the technicians discovered that the optical pickup test equipment was not functioning properly and
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had to delay the test to obtain another one. Two of the technicians were not familiar with how to operate the optical pickup in conjunction with the ramp / step generator, however, a third technician was knowl-edgeable and provided guidance. While testing the Low Pressurizer Pressure Reactor Trip bistable,1PB-455C, it was discovered that the bistable had been jumpered out to reverse its logic for ESFAS testin The technicians were able to deduce this only after numerous attempts to cycle the bistable with test signals. There was no method to inform technicians of jumpered components prior to conducting the surveil-lance. This, however, should not be a problem once ESFAS testing is complet Later the technicians observed the bistable for the PORV block valve interlock 1-PB-455H to be out of specificatio Upon further troubleshooting, the technicians discovered the acceptance criteria voltages on data sheet 1 of procedure 24525-1 to be incorrec Even with the correct data the bistable was still out of specificatio Steps were then taken to initiate a procedure revision to complete the surveillance. This surveillance apparently had been done previously and the inspector was concerned why the error on the data sheet had not been uncovered. The inspector reviewed work order MWO 24525-101-185 completed on October 30, 1986. This work order performed the 18 month channel calibration and did not include the analog channel calibration check. Thus data sheet 1, which records data for the analog channel calibration check, had never been validate The inspector was satisfied that the procedure adequately tested the instrumen No violations or deviations were identifie e. Chemical and Volume Control System The inspector examined the following procedures which implemented the respective TS surveillance requirement Rev. 0 Operations Shift and Daily Logs 14405-1 Rev. 2 Boron Injection Flow Path Verification During Operation 14460-1 Rev. 1 ECCS Flow Path Verification 14721-1 Rev. 0 ECCS Subsystem Flow Balance Test 14935-1 Rev. 1 ECCS Throttle Valve Position Stop Verification 24806-1 Refueling Water Storage Tank Level L-990 Analog Channel Operational Test (ACOT) and Channel Calibration 24807-1 Refueling Water Storage Tank Level L-991 ACOT and Channel Calibration The inspector identified the following items:
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Procedure 14460-1 and 14405-1 did not perform a surveillance on BIT isolation valves 1-HV-8803A and B. This did not conform to the requirements of TS 4.5.2.b.2 which stated that the licensee shall
" verify that each valve (manual, power-operated or automatic) in the ECCS flow path that is not locked, sealed or otherwise secured in position, is in its correct position," at least once per 31 days. This is identified as IFI 424/86-117-2 In reviewing procedure 14935-1, Rev. 1 draft, the inspector noted that the revision would delete the need to verify the correct position of each electrical and/or mechanical position stop for the ECCS throttle valves, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> following completion of each valve stroking operation. The justification for deleting this requirement stated that the valves must be repositioned per a flow balance which is performed under procedure 14721-1. Followup on the revisions to the surveillance task cross reference index and the master surveillance index to include the revision to procedure 14935-1 is included in IFI 424/86-117-2 Procedure 14721-1, Rev. O, is referenced to TS 4.5.2 and 4.5.3.1 which have applicability to Modes 1, 2, 3 and Procedure 14721-1, Rev. O, under paragraph 2.0, states that the procedure is applicable to Modes 1, 2, and 3 with Tave greater than or equal to 350 degrees F. Correc-tion of this inconsistency will be tracked as part of IFI 424/86-117-2 No violations or deviations were identifie f. Containment Spray System The inspector reviewed the following surveillance procedures:
14806-1 Rev. O Containment Spray and Check Valves Inservice and draft copy Test of Rev. 1 14485-1 Rev. 1 Containment Spray System Flow Path Verification 54071-1 Rev. 1 Train B Containment Spray System Automatic Actuation Test
! The inspector also confirmed final draf t TS Sections 3/4.6.2.1 and 3/4.6.2.2, Depressurization and Cooling Systems, and Spray Additive System, respectively, are appropriate for the as-built system. The inspector identified the following items:
Section 6.0, Acceptance Criteria, in both revisions of procedure 14806-1 did not include observation of proper lubricant level as specified in the Inservice Test Quantities table IWP-3100-1 of ASME B&PV Code,Section XI, when the equipment was known to be operating acceptably, i
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The inspector noted in procedure 14806-1 that test instrumentation used during the test had been properly identified but calibration due dates were not checked. The inspector recommended the inclusion of calibra-t' ion due dates to avoid mistakes and confirm traceability of instrumen-tatio Section 8.0, References, of procedure 14806-1, draft Rev. 1, does not include the date of the applicable edition of ASME B&PV Code,Section X The inspector recommended that the licensee check the containment spray lines for sodium hydroxide prior to recirculating to the RWST to prevent NaOH contamination of the RWS Procedure 54701-1 included removal and reinstallation of the thermal overload bypass jumpers from two MCCs (52-1BB048 and 52-1BB039) for two motor operated valves,1HV-9001B, containment spray isolation . valve, and 1HV-8994B, spray additive tank outlet valve. Following reinstalla-tion of the thermal overload bypass jumpers, the procedure does not include the requirement to verify the operability of the bypass devices as specified in TS 4.8.4. Procedure 28905-C, MOV Overload and Bypass 18 Month Test, fulfills the TS 4.8.4.2.b requirement. Procedure 54071-1, step 5.2.4, directs the test performer to unlock and close valve 1-1206-U6-029, spray additive tank outlet isolation. There is not a step in the procedure to open and lock in position this normally-locked open valve following completion of the test. Step 5.3.12 of this procedure directs the opening and locking in position of valve 1-1204-U6-018, Train B spray header isolation. There is not a step earlier in the procedure to unlock and close this normally locked open
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, valve. Also, valve 1-1204-U6-018 is not included in the Independent Verification of Restoration section of the procedur Followup on the discrepancies identified above is included in IFI 424/86-117-2 No violations or deviations were identified.
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i The inspector reviewed surveillance procedure 14490-1, Rev. 1, Containment Cooling System Operability Test, and also confirmed final draft TS 3/4.6.2.3, Containment Cooling System, was appropriate for the as-built system. The inspector had no comments. The inspector did, however, note that the TS was restrictive when compared to Westinghouse standard TSs. The licensee stated that this was intentiona The inspector reviewed surveillance procedure 14982-1, Rev. O, Contain-ment Ventilation Isolation - Refueling, and also reviewed final draft l
TS 3/4.6.1.7, Containment Ventilation Syste The inspector had no j comments on the procedur The inspector identified the following items on the Technical Specification:
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The valve numbers in the LCO appear to be incorrect. HV-2624 A and B are 4 inch isolation valves in the Containment Building Post LOCA Exhaust System. Valves HV-2627 A and B and HV-2629 A and B, which are containment purge and exhaust isolation valves, are not included in the statement of the LCO. The valve numbers in surveillance requirement 4.6.1.7.1 are not all 21-inch containment purge and exhaust isolation valves as indicated. HV-2624 A and B are 4 inch Containment Building Post LOCA Exhaust isolation valves. HV-2626B and HV-26-288 are 14-inch Containment Building mini purge supply and exhaust isolation valve Followup on the correction of the TS is included in IFI 424/86-117-2 No violations or deviations were identifie (h) Reactor Trip Portion of procedures implementing TSs 4.2.5.2; 4.2.5.3; 4.2.5.4; and, tables 2.2-1, 3.3-1, and 4. 3-1, Items 2, 3, 4, 12, 13, 14, 15, 16. a ,
16.b,18,18.f,19 and 21 were reviewed to determine that representa-tive procedures were established to implement the items with the required accuracy and frequency. Also, certain of the frequencies and setpoints of the above surveillances were verified to be in agreement with WCAP-10271-P-A and WCAP-11269 respectively. (It should be noted that the licensee is requesting deletion of TS requirement 4.2.5.2.).
The following procedures were reviewed during this inspection:
24790-1 Rev. 2 Reactor Coolant Flow Loop 1, Protection Channel III, F-416, Surveillance Test, Loop Functional Test and Calibration 14000-1 Rev. 2 Operations Shift and Daily Logs 14030-1 Rev. 1 Power Range Calorimetric Channel Calibration 14424-1 Rev. 1 Intermediate Range NIS Analog Channel Operability Test 14701-1 Rev. 2 Reactor Trip Breakers UV and Shunt Trip Test 14702-1 Rev. 1 Reactor Trip Breakers Test from SSPS 14901-1 Rev. O Turbine Trip - Reactor Trip Actuating Device Operational Test 24553-1 Rev. 2 Turbine Trip - Reactor Trip Hydraulic Pressure P-6161 ACOT and Channel Calibration 24583-1 Rev. 2 RCP 3 Train B, Reactor Trip Underfrequency (281-B) and Undervoltage (227-B) Relays Trip Actuating Device Operability Test and Channel Calibration 24617-1 Rev. 1 Turbine Impulse Chamber Pressure Protection II P-506 Loop Functional Test and Calibration 24700-1 Rev. O Nuclear Instrumentation System Power Range Channel Calibration 24762-1 Rev. 2 Steam Generator Level (Narrow Range)
Protection Channel III loop L-518 Functional Test and Calibration
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'45 . Rev. 2 Reactor Coolint Flow Loop 1, Protection Channel III, Loop F-416, Surveillance Test, Loop Functional Test and Calibration On December 11, 1986, during the walk through of reactor coolant pump loop 1F-416, ; procedure 24790-1, the inspector observed" that the technician needed to go to the shift clerk's office thre'e times to
.obtain the keys needed to open the reactor solid statb protection system (SSPS) cabinets to perform the surveillance prp& dure. The verification of key control and access to equipment ts identified as
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The inspector noted that the automatic di gnostic referenced ,in .
procedure 24790-1 and other SSPS test procedures, Automatic SurVeli-lance Technician (/,STEC), had not been implemented nor had the control of its software been establishe ASTEC when implemented should provide an indication of which equipment requires manual cal (bratio The final TS draft, reviewed did not specify testing of the' reactor trip breaker undervoltage (UV) and shunt coil Generic letter 83-28 required this testing to be performed with an 18 month frequency, as a minimum. The reactor trip breaker UV and shunt coils surveillance was established by procedure 14702- However, no procedure had been '
established to test the reactor trip bypass breakers UV -and ' shunt -
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coils. The modification to TS T*ble 4.3-1, Item 19, to reflect the 18 month surveillance of the UV and shunt coils and the establishment of a
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procedure to test the reactor tr1p bypass breaker UV and shunt coils ,
are identified as IFI 424/86-117-3 ; -
During the review of the reactor coolant pump UV procedure, 24583-1, it was noted that TCP 3 was in effect. The inspector obtained TCPs 1 and 2 for this procedure and f6und that one change was not incorport.ted from TCP 1 on the procedure with TCP 3; and that two items on TCPs 2 and 3 wers identical. The resolution of this administrative discrep-ancy was left to the license The inspeciAr reviewed and walked through with an I&C technician specific sections of procedure 24700-1. The walk down consisted of the technician pointing out the actual instrumentation and explaining to the inspector how the steps of ,the procedure would be performed. The inspector identified that sections 4.4.17 and 4.4.18 of procedure 24700-1 were char.ged and are now written in longhand. These hand-written changes should be incorporated into the procedur Step 4.4.17.10 referred to a Figure 1 for correct bistable trip setpotnt for negative rate trip bistable calibration. This figure was not incorpo-rated into the procedur St.en 4.4.16.2 was incorrect ir that it referred to a drawer B to conne n a digital multimeter to h o terminal points OUTPUT TP3H(+) and GND TP1H(-). The drawer number should be drawer A. The licensee stated that these changes would he mad .
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The1 inspector reviewed and walked through with a qualified Senior Reactor Operator procedures 14030-1 and 14424-1. The inspector noted that Section 4.0 of procedure 14030-1 and data sheet 2 of procedure 14424-1 contained the entry "LATER" for several setpoint values. The licensee was in the process of reviewing the procedures against the final draft TSs to assure that all values were appropriately included.
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s 1. Auxiliary Feedwater and Condensate Storage Tank The following procedures were reviewed, checked against P& ids, and discussed with the licensee. A portion of a surveillance conducted on a motor driven AFW pump was observe The inspector reviewed 14545-1, Motor Driven Auxiliary Feedwater Pump Monthly Operability Test, which implements TS 4.7.1.2.a.1. The inspector determined that the procedure as written indicates that the two motor driven auxiliary feedwater pumps are tested at the same time rather than on a staggered test basis as required by the T The inspector reviewed the surveillance scheduling program and determined
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that the test would have been scheduled at the appropriate interval since the schedule is controlled by a separate administrative procedure. The inspector reviewed 14546-1, Turbine Driven Auxiliary Feedwater Pump Operability Test, which implements TS 4.7.1.2.1.a.2 and
. noted that the surveillance frequency for this surveillance was also not clear. Interviews with procedure writers indicated that the definition of staggered test basis, which was provided in TS 1.34, was not understood. In addition, the administrative procedure, 00404-C, which defined test frequency definitions, did not clearly indicate the meaning of staggered test basi Followup on corrective actions to
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assure surveillances conducted on a staggered test basis are correctly i' scheduled is identified as IFI 424/86-117-2 , -
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The inspector noted that the acceptance criteria of procedure 14546-1 required a discharge pressure of greater than or equal to 1645 psig, which was more conservative than the TS requirement of 1605 psig. At the request of the inspector, the licensee verified that the TS value was correc The licensee plans to revise the acceptance criteria to be consistent with T The inspector observed a portion of the performance of MDAFWP surveil-lance using procedure 14807-1 and was told by the licensee that the prerequisite to align the AFW for normal operation cculd not be followed due to ESFAS testing. The licensee was aligning only the portions of the AFWS necessary for the test, i.e. , the recirculation path. The inspector noticed that the test coordinators had, however, obtained a xeroxed list from an unknown source to use as a checklist
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for aligning the needed portions of the system. These practices are not adequate for establishing system configuration for a TS surveil-lance test. The inspector questioned the adequacy of the test based on this finding, but could not determine if the test would be used as the final TS surveillance test. The review of system configuration for surveillance testing is included as part of IFI 424/86-117-1 While witnessing the MDAFWP testing, the inspector scanned procedure 14807-1 and noticed that there was no step in the system restoration to place handswitch HS-5131A back into automatic. Followup on this item is included in IFI 424/86-117-2 The inspector reviewed procedure 14495-1, Auxiliary Feedwater System Flow Path Verification, which implements the surveillance requirements of TS 4.7.1.2.1.a.3 and 4.7.1.2.1.a.4. No concerns were identifie The inspector reviewed portions of procedure 14000-1, which implemented TSs 4.7.1.3.1 and 4.7.1.3.2. The licensee identified the flow path and operable level indication as additional requirements for the CST to be operable. The inspector reviewed procedure 11610-1, Auxiliary Feed-water System Alignment for Startup and Normal Operation, and verified that the procedure addressed the flow path verification. The inspector reviewed;the control room instrumentation and verified readability and
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consistency' of labeling agair.st the procedure The inspector also verified that the annunciator response procedure covered the CST level alarm No violations or deviations were identifie J. Moderator Temperature Coefficient Procedure 53002-C was shown in the cross reference list for BOL moderator temperature coefficient surveillance (TS 4.1.1.3.a) but will not be used for the initial startup test and has not been writte This procedure will be an integrated low power physics testing procedure to be used for reload For the initial test program, MTC will be measured using startup test procedure 1-600-03. This procedure has previously been reviewed by NRC with ro comments identifie The TS cross reference list did not show which startup tests are used to satisfy surveillance requirement Followup on surveillance procedures which have not been written and review of the cross reference list against TSs is included in IFI 424/86-117-2 The inspector reviewed procedure 54009-C which implements TS 3/4.1.1.3.b. The inspector identified a missing step in the calcula-tion but was shown a draft revision of the procedure to which the step had been added. Xenon worth appears in the procedure as an input to
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the moderator coefficient calculation, but the source of the xenon worth value is not documented. The inspector considers that the source of the xenon worth should be documented in this procedure, and that other physics procedures should be reviewed to ensure that the source of such calculations is traceabl The inspector reviewed procedure 54061-C and discussed the procedure with the licensee. No discrepancies were identified. The inspector
'did note that the physics curve book had not been completed. Verifica-tion of completion of the physics curve book is included in IFI 424/86-117-2 No violations or deviations were identifie Axial Flux Difference The inspector reviewed 54005-C, which implements TS 4.2.1.3 and 4.2.1.4. The inspector's comments on Revision 0, including a question on the adequacy of test prerequisites, all appeared to be satisfac-torily addressed in the draft of Revision No violations or deviations were identifie . Heat Flux Hot Channel Factor - FQ(Z)
The inspector reviewed 54004-C which implements TS 3/4.2.2 and 3/4. No violations or deviations were identifie Electrical Power Systems The inspector reviewed the final draft of TS Section 3/4.8, Electrical Power Systems, and compared the section with the as-built plant drawings to determine their applicability to the design features of Vogtle Unit 1. Surveillance procedures were also reviewed to verify that the procedures adequately addressed TS requirements, were workable, and adequately addressed vendor requirements. The inspector interviewed personnel and reviewed procedures and drawings in concert with walkdowns of the as-built electrical systems. TSs 3/4.8.1 through 3/4.8.3.2 were addressed in the revie The electrical TSs that were reviewed were found to be acceptable when compared to the as-built plant. Discrepancies identified between the final draft TSs and the as-built plant had been documented by the applicant on licensing document change requests TS86-005 and TS86-052. In particular, these items concerned TSs 4.8.1.1.2.g.3 and 4.8.1.1.2.g.8.
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TS 4.8.1.1.2.g.3 addressed the diesel generators capability to reject a load of 7000 KW without trippin The TS stated that the voltage cannot exceed 4760 volts during and following the load rejection. The licensee had proposed to change this value to 5000 volts due to results obtained during pre-op testing which indicated a 0.3 second peak voltage of 4900 volts. This item is under NRC review for a T5 chang The licensee had been requested to provide NRC with an analysis to show that the loads on the shutdown buses would not be affected by a 5000 volt peak and that all instrumentation circuits which remain connected to the diesel generator were designed to withstand these peak voltage TS 4.8.1.1.2.g.8 referred to the 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> rating of the diesel generator. It identified this rating as 6100 KW in the final draft of the TS's. however, the FSAR and the diesel vendor manual (AX4AK01-509)
indicated that the continuous rating of the diesel is 7000 K The applicant proposes to revise this TS to indicate a continuous rating of 7000 K The inspector examined the following surveillance procedures for acceptability to ANSI N18.7-1976, Sections 5.3.2, Procedure Content, and 5.2.10, Test and Inspection Procedure Rev. 1 AC Source Verification 14235-1 Rev. 2 On-Site Power Distribution Operability Verification 14980-1 Rev. 2 Diesel Generator Operability Test 28714-C Rev. 0 E0C Diesel Generator Checkout 28810-C Rev. 4 Class IE Battery Service Check 28815-C Rev. 4 Class 1E Battery Performance Check 28820-C Rev. 3 Control Building Battery Charger Load Test 28911-C Rev. 4 Class IE Seven-day Battery Inspection and Maintenance Check 28912-C Rev. 8 Class IE 92-Day Battery Inspection and Maintenance Check 30080-C Rev. 6 Diesel Fuel Chemistry Control 54055-1 Rev. O Train A Diesel Generator and ESF System Actuation Test The inspector informed the licensee of the following comment The inspector recommended that the applicant consider adding words to step 5.2.9 of procedure 14980-1 to address the increased 7-day surveillance test interval specified by TS table 4.8- Procedure 28714-C did not reference the specific TS surveillance item that the procedure implemented (TS 4.8.1.1.2.g.1). The licensee agreed to add the reference. Figure 2 in the procedure could not be deciphered due to poor reproduction. The licensee was aware of the
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problen, and stated that a better copy of figure 2 would be provide Review of Transamerica Delaval, Inc. Owners Group Maintenance Matrix indicated that surveillance procedure 28714-C included appropriate vendor recommended maintenanc Chapter 8 of the FSAR contained the following statement, " Test procedures will specifically state that the diesel generator unit is to be reset at the conclusion of the test to allow an automatic start when required." This statement had not been included in procedure 54055- The inspector informed the licensee of this item and they committed to add this statement to the procedur TS 4.8.1.1.2.b required that if a diesel generator had been operated for a period of one hour or greater, the diesel fuel oil day tank shall
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be checked for water. This requirement could not be found in procedure 54055-1 after the completion of the 24-hour run test. The licensee committed to add this requirement to the procedure. The licensee did indicate that this action would have been performed through procedure 13145-1, Diesel Generator The inspector performed an initial review on Rev. 5 to 30080-C. Two comments were identified. Rev. 6, which was approved on December 5, 1986, resolved these issue Step 4.8.1 of procedure 28911-C referenced the wrong TS surveillance number, 4.8.2.1.6. The correct TS is 4.8.2. This discrepancy appeared to be a typographical error. The licensee was informed of this error and agreed to correct the erro Step 5.1 of both procedure 28911-C and procedure 28912-C stated that the electrolyte level of the batteries was acceptable if the level was above the low (minimum) level indication mark and less than or equal to 1/4 inch above the high (maximum) level indication mark. In addition to the requirement for level to be above the low mark, TS table 4.8-2 stated that only less than 1/4 inch above the high level indication mark was the acceptance criteria. The TS did not include the criteria of equal to 1/4 inch above the high level indication mar The licensee was informed of this concern-via telecon on December 9, 198 They indicated that the procedure had been initially developed using the proof and review copy of the TSs which contained this requiremen The final copy of the TSs is now being compared to all existing surveillance procedures. The licensee committed to correct this item in all related procedure TS 4.8.2.1.b.3 requires that the average electrolyte temperature of twelve connected cells be greater than 55 degrees F. Procedure 28912-C calculates the average temperature using all 59 cells (step 4.5.8). It exceeds the requirements of the TSs and is considered acceptabl ..
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The inspector reviewed procedure 28820-C and noted that TS 4.8.2.1 only required the chargers to be loaded at rated output amperes for eight hour However, the surveillance procedure acceptance criteria required that the chargers provide rated current for twelve hour This is consistent with the twelve hours specified in the FSAR. The licensee indicated that the twelve hour requirement in the surveillance procedure will be revised after the FSAR is amended to indicate 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> In procedure step 3.2, the word " charge" was misspelle Step 4.15 of procedure 28815-C references Table 6. Table 6 was not included in the procedure. The correct reference appeared to be Table 5 which was included in procedure 28815- No violations or deviations were identifie . Maintenance Program and Procedure Review (35743B, 424518)
An inspection was conducted of the administrative controls for plant maintenance, the technical adequacy of maintenance procedures and the implementation of the maintenance program. The review included an assess-ment of the corrective maintenance program; an assessment of the preventa-tive maintenance program; a review of equipment control including the removal and restoration of equipment, equipment status tracking and functional testing requirements; verification of control of special processes, housekeeping and system cleanliness; and, document review and field verification of the implementation of the maintenance progra The inspectors reviewed portions of the following procedures:
SUM-22 Rev. 13 Maintenance Work Orders (MWO)
SUM-24 Rev. 8 Initial Test Program Personnel Certification 00051-C Rev. 5 Procedures Review and Approval 00201-C Rev. 4 Quality Control Inspection Program 00304-C Rev. 8 Equipment Clearance and Tagging 00306-C Rev. 3 Temporary Jumper and Lifted Wire Control 00350-C Rev. 4 Maintenance Program 00350-C Rev. 5 Maintenance Program 20008-C Rev. O Mechanical and Electrical Procedure Validation 20011-C Rev. 5 Electrical Maintenance Personnel Training And Qualifications 20012-C Rev. 4 Mechanical Maintenance Personnel Training And Qualifications 20013-C Rev. 4 Instrument and Control Maintenance Personnel Training and Qualification 20015-C Rev. 4 Planned Maintenance 20016-C Rev. 1 Predictive Maintenance 20050-C Rev. 1 Maintenance Work Planning Group Work Order Processing
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20405-C Rev. 6 Control of Maintenance Shop Measuring and Test Equipment 20409-C Rev. 2 Maintenance Procedure Review Guidelines 20411 Rev. O Control of Lubricants 25006-C Rev. 1 RHR Motor Disassembly Inspection and Reassembly 25230-C Rev. 3 Relief And Safety Valve Setpoint Check 25235-C Rev. 0 In Line Testing of Relief and Safety Valves With Dresser Model 1566 Hydroset Testing Device 26501 Rev. O Rockwell Hermavalve Maintenance 26830 Rev. 3 Limitorque Type SMB/BB/SBD 000 and 00 Valve Maintenance 26832 Rev. O Limitorgea Type SMB/SB/SBD 0 through 4 Valve Operator Maintenance 26836 Rev. 2 Limitorque Type SMB, SB, and SBD Valve Operator Electrical Checkout and Adjustment 26837 Rev. 2 Limitorque Type SMB/SB/SBD Valve Operator Functional Test 26859 Rev. 1 MOV Testing Using MOVATS 2150 Analysis and Test System 27012-C Rev. 3 Bingham-Williamette Type VCM Pump Maintenance 28211-C Rev. O RHR Suction Relief Valve Test Preventive Maintenance The inspector reviewed the licensee's program for equipment control, preventive maintenance, and predictive maintenance. The inspector reviewed numerous completed work requests for adequacy and monitored maintenance activities conducted in the plan The inspector also reviewed selected maintenance procedures for adequacy and conformance to administrative guidelines for writing procedures. Within the areas reviewed the inspector had the following observations:
Only two 1E systems had been released to operations. These systems are the 4160V and 480V IE electrical systems. Maintenance activities were being controlled using the startup manual. The licensee had not fully implemented the operational preventive (planned) maintenance progra The procedures established by the licensee to control maintenance activities during the operational phase appeared adequate, however, the inspectors were not able to verify the implementation of the progra As of this inspection, 108 of 122 systems had been loaded into the planned maintenance tracking system. Of the 108 loaded, approximately 50 percent of the planned maintenance activities were being scheduled for performance. The program established to control the planned maintenance program appears adequate, however, the implementation of the program will have to be inspected in the futur This is identified as a part of IFI 424/86-117-2 ..
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The licensee is implementing a predictive maintenance program. The predictive maintenance program will consist of vibration analysis, lube oil analysis, M0 VATS testing, infrared and trendin Presently the programs are in the developmental phase, however, once implemented the predictive maintenance program will be used in conjunction with the planned maintenance program to ensure the operability of equipmen The licensee's maintenance procedures reviewed appeared adequate for unit operation. Review of completed work requests showed no discrep-ancies, however, the work requests reviewed were controlled using the startup manual and not the licensee's operational QA maintenance progra No violations or deviations were identifie b. Corrective Maintenance The licensee's corrective maintenance program was inspected by reviewing the documents and procedures that establish the program, interviewing personnel, reviewing completed maintenance work orders, observing maintenance activities, reviewing personnel certifications, and walking through the control procedures for measuring and test equipmen Administrative procedures for controlling maintenance activities were reviewed. Pr icedure 20008-C was used for the field verification of mechanical and electrical maintenance procedures. Procedure 20409-C set forth the level of qualifications of personnel reviewing maintenance procedures and provided guidance in the form of administrative and technical review requirements checklists. Procedure 00051-C set forth the administrative requirements for the approval of procedures whether they were new, revised, or eliminated procedures. The inspector found these procedural controls to be sufficient to perform the function of assuring that proper caution is exercised and appropriate reviews are performed on any revisions to procedures which control maintenanc The inspectors reviewed the implementation of the operational maintenance program which is described in procedure 00350-C. The inspectors found that the operational maintenance program had not been completely implemente The maintenance program was being conducted primarily under the startup maintenance program that is governed by SUM-22. The inspectors assessed the generation and evolution of MWO's performed under the SUM-22 program. The main thrust of this review was directed towards completed MWO's. The inspectors reviewed 22 completed MWO packages that had been performed on the AFW system, RHR system, SI system, and NSCW system. These packages were reviewed to ensure that they had met the following criteria: proper approvals and sign-offs;
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identification of pe-sonnel performing the work; the use of appropriate
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procedures; Measuring and Test Equipment (M&TE) used; QC hold points properly obtained and performed; control of special processes when required; determination of the probable cause of the malfunction; corrective action description; identification of post maintenance functional testing performed; identification of replacement parts or materials used; and, proper equipment control exercised as evidenced by operations staff notification where appropriate. All of the reviewed work orders were satisfactory and complete with the exception of one minor error made in the recording of a required calibration date. The inspectors did not identify any significant concerns in regard to the implementation of the maintenance program via startup procedure SUM-2 SUM-22, the startup maintenance control procedure, and 00350-C, the operational QA maintenance control procedure, accomplish similar objectives of establishing administrative controls for maintenance activities, however, the generation and review cycle for the opera-tional maintenance program assures implementation of appropriate operational requirements. Both procedures included instructions on initiating MWO's, criteria and responsibility for the review and approval of MWO's, the designation of safety and non-safety related work, inspection of maintenance and Quality Control hold points. Both procedures assigned the responsibility for the assembly, review and transmittal to Document Control of the MWO's to the Maintenance Work Planning Group (MWPG).
Procedare 20050-C establishes the administrative controls for the processing of MWO's within the MWPG. The MWPG is also responsible for assuring that special processes such as welding or other activities requiring a fire watch or special supervision were given the proper ati.entio Maintenance procedures were reviewed for the RHR system and the NSCW system. These included procedures 25006-C, 25230-C, 25235-C, 27012-C, and 28211-C. The maintenance procedures reviewed were easy to under-stand and used clear instructions with numbered steps that corresponded to the attached data shnt QC hold points were indicated and provisions were made for in kpendent verification on these data sheet There were signoffs on the data sheets to verify that QC had reviewed the maintenance item for hold point Vendor manuals were referenced in the procedures where applicable. The following vendor manuals were reviewed:
Crosby Nozzle Type Relief Valve Instruction Manual Instruction Manual For Bingham-Williamette Type VCM Pumps (NSCW pumps)
Instruction Manual For Bingham-Williamette Type VCM Pumps (NSCW Transfer Pumps)
Ingersoll-Rand RHR Centrifugal Pump Manual
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These vendor manuals were easy to retrieve from document control and were clear and legible. No discrepancies were identified between the vendor manuals and the respective maintenance procedures with one exception. The inspector was concerned that procedure 27082-C did not clearly specify how and when maintenance would be performed on the mechanica! seals of the NSCW pumps. There were no references in any of the reviewed procedures towards the maintenance of these mechanical seals. The vendor manuals recommended that preventive maintenance be performed on these seals and the licensee should consider adding this to their pump maintenance procedure Personnel interviews were conducted to assess the plant staff's familiarity with the maintenance program and also to aid the inspectors in understanding the characteristics of the organizatio The
, applicant was implementing a computer system called Nuclear Plant Maintenance Information System (NPMIS) to assist in the generation and control of MW0's. This system was expected to be fully operational by the startup of the plant. NPMIS was being used as a tracking system but it will eventually be used to initiate and close out MW0's. The NPMIS will generate hard copy MWO's from a request and will provide information such as the exact location of the system, whether or not it is a safety or non-safety related system, possible TS conflicts (for example electrical train work), functional test requirements, and tag number Each MWO will still require review and signatures from responsible personnel. The system will provide ample opportunity for feedback from those performing the work in the fiel Appropriate
, plans have been made to protect against system failure and personnel will have the ability to return to the manual method of generating MWO' M&TE control was reviewed including inspection of the M&TE shop. An MWO that had a recording error on the calibration date of M&TE equipment was used as a starting poin The piece of equipment was a 0"-1" I micrometer. The inspector asked the shop attendant to demonstrate the l traceability in determining that the micrometer used was in calibration j and how, if it was not, any work performed with out-of-calibration j equipment could be traced. The inspector also reviewed several pieces i of M&TE equipment chosen at random to review calibration record Overall the control of M&TE equipment wss adequate and provided the traceability necessary to assure that accurate equipment would be available and work being performed would be within tolerance.
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Procedure 00201-C established the policies and minimum requirements for the QC inspection and work monitoring programs. The inspector found the procedure to be adequate and implementation, as evidenced by the j reviewed work orders, to be consistent.
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The procedures that define the personnel training and qualification process are SUM-24, 20011-C. 20012-C, and 20013-C. They were satisfac-tory in that they met the requirements of ANSI /N18-1971. No review of personnel records was performed at this tim ,
Overall the program appeared to provide appropriate administrative controls and accountability to assure the performance of quality wor However, as' stated above, the inspectors found that the program was not fully implemented under the operational QA program and could not assess the effectiveness of the program. Review of the implemented corrective maintenance program is identified as part of IFI 424/86-117-2 No violations or deviations were-identifie c. Housekeeping, Cleanliness and Control of Special Processes The inspector reviewed the following procedures against the recommenda-tions of ANSI 18.7-1976, ANSI N45.2.6, ANSI N45.2.1, ANSI N45.2.3 and RG 1.33.
00350-C Rev. 5 Maintenance Program 20427-C Rev. 2 Maintenance Cleanliness and Housekeeping Control 00254-C Rev 3 Plant Housekeeping and Cleanliness Control The review yielded the following observations:
The Operations representative to the maintenance work planning group (MWPG) was the individual responsible for assigning functional tests to systems / components to prove operability following maintenanc Procedure 20427-C, Rev. 2, adequately addressed the subject of cleanliness controls by delineating cleaning procedures for the cleaning of safety related components and systems, maintaining the cleanliness of previously cleaned systems, establishment of cleanliness classifications of plant systems and the assignment of the responsi-bilities for implementing the control Procedure 00254-C, Rev. 3, and 20427-C, Rev. 2, also adequately addressed the subject of housekeeping control by establishing house-keeping zones and the control of such zones during maintenance activities, including the requirement to perform monthly housekeeping :
inspection Discrepancies were identified in the specification of cleanliness levels as discussed in paragraph 6.c of this repor The inspector reviewed procedure 00204-C, Control of Special Processes, against the recommendations of ANSI 18.7. The review of the procedure yielded the following observations:
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Procedure 00204-C. identifies the following as special processes:
welding, heat tracing, NDT, flushing, cleaning, brazing, protective coatings, freeze sealings, and injection sealin Procedures for flushing are controlled in procedure _00254-C, under section 3.13, which assigns the responsibility to the Engineering Support Superintendent (ESS) to manage flushing operations and perform the operations in accordance with 'the requirements of ANSI N45. There are no specific procedures for flushing or for the writing of flushing procedures in accordance with ANSI N45.2.1. Procedures which governed all aspects of the welding program appear to be adequate, however, at the time of the inspection weld technique sheets had not been approved and subsequently a review of their implementation was not conducte The use of mockups or other special training was only addressed by procedure 00910-C, VEGP ALARA Program, which governs _ activities to be performed in radiation environments. The licensee stated that mockups for various pieces of equipment were being ordered for training purpose No violations or deviations were identifie . IE Notices The inspector reviewed the licensee's response to IE Notice 86-80 which delineates an event where a unit startup involved improper interpretation of the terms " operable" and " operability" in the TSs. The licensee's response states that SR0 licensed operators have been trained appropriately in the use of TSs and that the IE Notice has been placed in the licensed operators'
required reading book. The inspector feels that the Notice was adequately responded to by the license This item is close . Review of Control Room Activities The inspector reviewed various control room logs, binders and checklists and their associated plant procedures for shift activitie The following procedures and/or documents (listed under the associated procedure) were reviewed:
00003-C Rev. O Shift Relief Checklist 00304-C Rev. 8 Equipment Clearance and Tagging 00306-C Rev. 3 Temporary Jumper and Lifted Wire Control
- Clearance Book and Unit Clearance Log 00307-C Rev. 1- Temporary Modifications
- Temporary Modification Request Log
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10000-C Rev. 2 Conduct of Operations
! 10001-C Rev. 3 Logkeeping l - Shift Supervisor Log l - Unit Control Log
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10002-C Rev. 3 Plant Operating Orders
- Standing Orders and Night Orders 10004-C Rev. 2 Shift Relief 10008-C Rev. 2 Limiting Conditions for Operation and Cumulative Downtime
- LCO Status Log 10009-C Rev. 2 Operator Aids
- Information Tag Log 10017-C Rev. 0 Operations Reading Book
- Operations - Required Reading Book 10018-C Rev. 1 Annunciator Status Control
- Disabled Annunciator Log 11871-C Rev. 2 Shift Supervisor Relief Checklist 11872-C Rev. 2 Reactor Operator Relief Checklist 14000-1 Rev. 2 Operations and Daily Surveillance Logs Standing Order No. 1-86-51, System Readiness for Fuel Load The inspector reviewed the implementation of administrative controls established for the management of those plant and control room activities conducted under the direction of licensed operator The inspector determined that many of the administrative controls for control room activities were not implemented as yet. Examples of the failure to fully implement these administrative controls were provided to the licensee for resolution. The inspector informed the licensee that additional inspection would be conducted in these areas after full implementation of the administra-tive controls. In addition, the inspector identified the following concerns in regard to procedural adequac During the review, the inspector noted that procedure 10000-C did not specify the area of the control room or plant in which the balance of plant (BOP) operator was to remain in order to perform his dutie The shift operating staff had been trained on the use of the Emergency Operating Procedures using three licensed staff members. Revision of this procedure to include the specific location of the B0P operator is identified as IFI 424/86-117-3 The inspectors also determined that twelve hour surveillances performed in
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the control room walkdown procedures were not adequately controlled in that the walkdown could be performed at the beginning of one shift and end of another, resulting in an interval longer than twelve hours. The licensee confirmed that the appropriate walkdown procedure would be revised to require the walkdown to be performed within the first two hours of the shift. This item is identified as IFI 424/86-117-2 The inspector reviewed procedure 00003-C, Rev 0, which addressed shift relie The inspector noted that the resident inspectors had identified that the operator turnover checklists did not ensure a complete transfer of I _
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information between shifts and did not include all the appropriate safety related equipment. During that review, the inspector determined that the procedure did not appear to satisfy the requirements of TMI Item I.C.2 for shift turnover. One finding was that no program had been established to evaluate the effectiveness of shift turnover procedures, as is required to meet Item I.C.2. This finding was previously identified as IFI 424/86-60-10. Resolution of this item is needed to close TMI Item I.C.2. Further
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inspection is required to resolve this item, therefore, IFI 424/86-60-10 is considered to be ope No violations er deviations were identified.
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