IR 05000424/1987001
| ML20209E044 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 04/11/1987 |
| From: | Shymlock M, Linda Watson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20209E018 | List: |
| References | |
| TASK-1.C.2, TASK-TM 50-424-87-01, 50-424-87-1, IEIN-86-061, IEIN-86-61, NUDOCS 8704290419 | |
| Preceding documents: |
|
| Download: ML20209E044 (39) | |
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p2 Ric UNITED STATES oq'o
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NUCLEAR REGULATORY COMMISSION
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101 M ARIETTA STREET N.W., SUITE 2900
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Report No.:
50-424/87-01 Licensee: Georgia Power Company P. O. Box 4545 Atlanta, GA 30302 Docket No.: 50-424 License No.: NPF-61 Facility Name: Vogtle 1 Inspection Conducted: January 5 - 9 and January 12 - 16, 1987 Inspector:
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'/!87 L. J./ Watson, Team Leader Dath Signed Team Members:
B. R. Bonser M. S. Lesser A. R. Long P. B. Moore G. Nejfelt l
T. J. O'Connor W. K. Poertner
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M. B. Shymlock C. L. Vanderneit Approved By:
WO M8,887 M. B. ShymlocY, Chief Date Signed Operational Programs Section Division of Reactor Safety SUMMARY Scope:
This routine, announced inspection was conducted 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 procedures.
Corrective action for findings described in NRC Inspection Reports 424/85-36, 424/86-60 and 424/86-117 were reviewed.
Results:
One violation was identified involving four examples of failure to follow procedures. No deviations were identified.
8704290419 870417 PDR ADOCK 05000424 O
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- P. D. Rice, Vice President, Project Engineering
- G. B. Bockhold, Jr., General Manager, Nuclear Operations
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- T. Greene, Plant Manager
- E. M. Dannemiller II, Technical Assistant to General Manager, Nuclear Operations
- 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
- C. E. Felton, Vogtle Coordinator, Nuclear Operations
- L. 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
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- J. A. Edwards, Senior Regulatory Specialist
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- W. F. Kitchens, Manager, Operations
- L. Russell, Operations Procedure Coordinator d*C. F. Meyer, Superintendent, Operations fA. Caudill, Superintendent, Operations
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- H. Varnadoe, Plant Engineering Supervisor i
Other licensee employees contacted included engineers, technicians,
operators, mechanics, and of fice personnel.
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NRC Resident Inspectors
- J. F. Rogge
- R. J. Schepens
+*H. Livermore
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- Attended exit interview on January 9, 1987
- Attended exit interview on January 16, 1987 i
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2.
Exit Interview The inspection scope and findings were summarized on January 9 and 16, 1987 with those persons indicated in paragraph 1 above.
The inspectors described the areas inspected and discussed in detail the inspection findings listed below.
No dissenting comments were received from the licensee.
IFI Number Status Description / Reference Paragraph 424/87-01-01 Open VIOLATION - Failure to follow procedure for 1) confirmation of test results for vital battery surveillance (paragraph 7.a.1), 2) QA hold point review and Shift Supervisor approval to work MWO (paragraph 7.b.1), 3) verification by maintenance technicians that drawings and vendor manuals were current revisions (paragraph 8.a), 4) review and initialing operations logs (paragraph 10.b)
424/87-01-02 Open IFI - Review of provisions for determining that acceptance criteria are met (paragraphs 7.a.8 and 12.11)
424/87-01-03 Closed IFI - Followup on adequacy of functional tests and work instructions for maintenance (paragraphs 8.c and 12.jj)
424/87-01-04 Open IFI - Completion of QA review of DR on mounting of radiation monitors (paragraphs 7.b.1 and 12.kk)
424/87-01-05 Closed IFI - Determination if temporary modifications negated surveillance tests completed after preoperational tests (paragraphs 9 and 12.11)
424/87-01-06 Open IFI - Miscellaneous Findings on Surveillance and Maintenance Program Review (paragraphs 7.b.3 and 12.mm)
424/87-01-07 Closed IFI - Use of Master Setpoint Document (paragraphs 12.nand12.nn)
424/86-117-01 Closed IFI - 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 12.c)
424/86-117-02 Closed IFI - Venting followup items including high point vents on AFW and procedure revisions for system venting (paragraph 12.d)
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424/86-117-03 Closed IFI - Procedure revisions to include adequate subcooling margin requirements (paragraph 12.e)
424/86-117-04 Closed IFI - Correction of valve identification and
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i system lineup discrepancies (paragraph 12.f)
424/86-117-05 Closed IFI - Correction of technical concerns in Unit Operating Procedures (paragraph 12.g)
424/86-117-07 Open IFI - Correction of discrepancies on labeling of valves and equipment (paragraph 12.h)
424/86-117-09 Open IFI - Correction of discrepancies in RVLIS surveillance procedure and followup on vendor recommendations (paragraph 12.1)
424/86-117-10 Closed IFI - Procedure revision to include check of i
equipment actuation on Control Room ventilation start (paragraph 12.j)
424/86-117-11 Closed IFI - Procedure prerequisites are general and not well understood by operators (paragraph 12.k)
Clarification of cleanliness levels 424/86-117-12 Closed IFI
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(paragraph 12.1)
424/86-117-13 Closed IFI - Review of events covered by Abnormal Operating Procedures (paragraph 12.m)
424/86-117-14 Closed IFI - Licensee to review annunciator response j
procedures for technical adequacy, walkdown ARPs and revise ARPs involving annunciators on the main control board, as appropriate,
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prior to fuel load.
Remaining ARPs to be reviewed within 90 days (paragraph 12.n)
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424/86-117-15 Closed IFI - Resolution of ISI test data for CCW pump (paragraph 12.0)
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424/86-117-16 Closed IFI - Resolution of acceptance criteria for RHR differential pressure on recirc flow (paragraph 12.p)
424/86-117-17 Closed IFI - Resolution of water hammer in NSCW ESF chillers (paragraph 12.q)
424/86-117-18 Closed IFI - Review of implementation of the surveil-lance program administrative controls and tracking system (paragraph 12.r)
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4 424/86-117-19 Closed IFI - Review of test control and configura-tion control for surveillances performed prior to release to the Operations Department (paragraph 12.s)
424/86-117-20 Closed IFI - Revise procedures to clarify use of Staggered Test Basis for determining frequency of test (paragraph 12.t)
424/86-117-21 Closed IFI - Review of the justification for the use of pre-operational tests to meet surveillance test requirements (paragraph 12.u)
424/86-117-22 Closed IFI - Corrective action to assure control of twelve hour surveillances (paragraph 12.v)
424/86-117-23 Open IFI - Resolution of various technical issues in regard to surveillance procedure adequacy (paragraph 12.w)
424/86-117-24 Closed IFI - Licensee to implement operational phase corrective and preventive maintenance program (paragraph 12.x)
424/86-117-25 Closed IFI - Resolution of Technical Specification 3/4.7.5 wording in reg (ard to availability of the Ultimate Heat Sink paragraph 12.y)
424/86-117-26 Closed IFI - Corrective action for locking or system lineup verification of boron injection flowpath valves (paragraph 12.z)
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424/86-117-27 Open IFI - Followup on surveillance procedures which have not been identified as complete on the Technical Specification / procedure
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i cross reference tracking list and review of completed cross reference tracking list
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(paragraph 12.aa)
424/86-117-28 Closed IFI - Procedure revision for consistent defini-tion of surveillance test completion date and time (paragraph 12.cc)
424/86-117-29 Closed IFI - Review of implementation of special triggering mechanisms to assure completion of special condition surveillances (paragraph 12.dd)
l 424/86-117-30 Closed IFI - Controls on location of BOP operator (paragraph 12.ee)
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424/86-117-31 Open IFI - Verification of key control and access to plant equipment by operations staff (para-graph 12.ff)
424/86-117-32 Closed IFI - Revise TS and procedure for 18 month check of reactor trip breaker UV and shunt coil trip (paragraph 12 99)
424/86-117-33 Open IFI - Resolution of miscellaneous technical concerns on operating procedures (paragraph 12.hh)
424/86-60-10 Closed IFI - Adequacy of shift turnover procedures (paragraphs 10.b and 12.00)
424/86-96-05 Closed IFI - Review of completed surveillance procedures (paragraph 12.bb)
TMI It e T.C.2 Closed Shift Relief and Turnover (paragraphs 6 and 10.b)
Although proprietary material was reviewed during the inspection, no proprietary material is contained in this report.
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Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspection.
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Unresolved Items
No unresolved items were identified during the inspection.
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List of Abbreviations i
ACCW(S)
Auxiliary Component Cooling Water System AFW Auxiliary Feedwater System A0P Abnormal Operating Procedure ARP Annunciator Response Procedure BIT Boron Injection Tank B0P Balance of Plant 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 DR Deficiency Report i'
ECCS Emergency Core Cooling System (s)
EDG Emergency Diesel Generators E0P Emergency Operating Procedure EQ Environmental Qualification EQDP Environmental Qualification Data Package ESF Engineered Safety Feature i
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F Degrees Fahrenheit FSAR Final Safety Analysis Report HFAS High Flux at Shutdown HVAC Heating, Ventilation and Air Conditioning HX Heat Exchanger IEN NRC Office of Inspection and Enforcement Notice IFI Inspector Followup Item IST Inservice Test LP Lineup Procedure MDAFW(P) Motor Driven Auxiliary Feedwater (Pump)
MLB Monitor Light Board M0V Motor Operated Valve MSIV Main Steam Isolation Valve MWO Maintenance Work Order MWPG Maintenance Work Planning Group NLO Non-Licensed Operator NPMIS Nuclear Plant Maintenance Information System NRC Nuclear Regulatory Commission NSAC Nuclear Safety and Compliance Section 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 RER Request for Engineering Evaluation RHR Residual Heat Removal System R0 Reactor Operator RVLIS Reactor Vessel Level Indication System RWST Refueling Water Storage Tank SI Safety Injection SIS Safety Injection System SG Steam Generator S0P System Operating Procedure SS Shift Supervisor SSMP System Status Monitoring Panel STS Standard Technical. Specifications TCP Temporary Change to Procedure TDAFW(P) Turbine Driven Auxiliary Feedwater (Pump)
TS Technical Specification UOP Unit Operating Procedure VCT Volume Control Tank 6.
Review of TMI Items (TI 2515/65)
(Closed) TMI Item I.C.2.
Shift Relief and Turnover.
The inspector
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reviewed the implementation of the requirements of TMI Item I.C.2 and i
determined that the licensee had completed the actions necessary to meet these requirements.
This review is documented fi paragraph 10.b of this i
report. TMI Item I.C.2 is closed.
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7.
Surveillance Program and Procedure Review (42450B)
During the inspection ending December 12, 1986, the inspectors had determined that the licensee had not yet fully implemented the surveil-lance program administrative controls except on a small number of systems which had been accepted by the Operations Department. This item had been identified as IFI 424/86-117-18.
During this inspection, the inspectors reviewed the implementation of the surveillance program and a number of additional surveillance test packages.
Although several concerns and one example of a failure to follow procedure were identified; in general, the results of this review indicated that the surveillance program was adequately implemented.
The review conducted is documented below.
IFI 424/86-117-18 is closed, a.
Review of Completed Surveillance Packages The inspectors reviewed completed active surveillance packages.
The surveillance reviews were performed to verify that specific controls were established and the surveillance system was working in accord-ance with procedure 00404-C, Surveillance Test Program.
The inspectors reviewed the following:
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System was readied by Operations before performance of the surveillance.
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Prerequisites were completed and if not completed, adequate justification was provided for prerequisites which were marked not applicable.
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All procedural steps were completed or marked appropriately.
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Acceptance criteria were met and completed surveillances were included in the surveillance tracking system.
Data packages supported the acceptance criteria.
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Task sheets were attached and completed in accordance with
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procedure 00404-C, Surveillance Test Program.
Appropriate reviews were completed as required.
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The surveillance packages reviewed were:
SURV. TASK TITLE COMPLETED DATE 14225-101 Operations Weekly Surveillance Logs 1/14/87 14235-102 On Site Power Distribution Operability 1/10/87 Verification 14420-101 Solid State Protection System Train A 1/01/87 (B) Operability Test
14420-102 Solid State Protection System Train A 1/10/87 (B) Operability Test 14423-106 Source Range NIS Analog Channel 1/14/87 Operational Test 14805-101 Residual Heat Removal Pump and Check 1/09/87 Valve Inservice Test 14811-101 Boric Acid Trant.fer Pumps and Discharge 1/08/87 Check Valves Ir. service Test 14850-102 Cold Shutdown Valve Inservice Test 1/08/87 14890-1 Diesel Generctor Operability Test Not recorded 14895-101 ECCS Check Valve Refueling Inservice 9/27/86 14896-101 ECCS Check Valve Cold Shutdown Inservice 9/22/86 14980-111 Diesel Generator Operability Test 1/09/87 14980-1 Diesel Generator Test Not recorded (Fuel Oil Sampling for Water)
24342-1 Pressurizer Level Control F-121 Not recorded Channel Calibration 24519-101 R. C. Pressure (Wide Range) Protection I 10/21/86 P-405 ACOT and Channel Calibration 24519-103 R. C. Pressure (Wide Range) Protection I 1/07/87 P-405 ACOT and Channel Calibration 24597-1 Containment Cooling Units 5, 6, Not recorded 7 & 8 - Condensate Detection L-17094 24626-101 Containment Vent Effluent Air Particulate 1/08/87 Monitor 1RE-2565A 24681-101 Meteorological Station 10M Wind Direction 10/30/86 Channel Calibration 24684-C Meteorological Station 60M Wind Speed Not recorded Channel Calibration 24688-101 Meteorological Station 10M Ambient and 9/12/86 and 10-60M Delta Temperature Channel Calibration 24737-101 Time History Accelerograph AXT-19903 12/04/86 24737-102 Time History Accelerograph AXT-19903 12/04/86 24739-101 Peak Acceleration AXR-19910 1/02/87 24806-101 Refueling Water Storage Tank Level L-990 1/15/86 ACOT and Channel Calibration 24840-101 Containment Pressure High Transmitters 1/02/87 RTT Sensors PT-934 28210-101 Main Steam Line Safety Valve Test 4/86 thru 120 28211-101 RHR Suction Relief Valve Test 2/20/86 28211-102 RHR Suction Relief Valve Test 1/09/86 28215-101 Safety Relief Valve IST 1 PSV-8010A 3/04/86 28215-102 Safety Relief Valve IST 1 PSV-80108 2/27/86 28215-103 Safety Relief Valve IST 1 PSV-8010C 3/05/86 28290-101 Containment Spray Nozzle Flow Test N/A 28711-101 Diesel Fuel Oil Storage Tank Cleaning 9/08/85 28711-102 Diesel Fuel Oil Storage Tank Cleaning 9/09/85 28712-101 Diesel Fuel Oil Piping Pressure Test 3/23/84 28820-C Battery Charger Load Test Not recorded l
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l 28905-C Motor Operated Valve Thermal Overload Not recorded and Bypass 18 Month Test 28910-102 Class 1E 18 Mo. Battery Inspection 12/08/86 and Maintenance 28912-102 Class IE Quarterly Battery Inspection 1/02/87 and Maintenance 54708-101 Containment Isolation and Containment 10/14/86 Ventilation Isolation - Manual Initiation 54820-101 Train "A" SI Pump Response Time Test 9/28/86 54822-101 Train "B" SI Pump Response Time Test 9/28/86 54825-101 Train "B" CCWP Response Time Test 9/25/86 The following items were identified during the inspection:
(1) On procedures 28910-101,102,103, and 104, Class 1E 18-Month Battery Inspection and Maintenance, the inspector noted that the recorded data indicated that intercell resistance on rack to rack and tier to tier jumpers exceeded the Technical Specification requirement of 50 X 10-6 ohms.
The Surveillance Task Sheets (STS), which listed the TS requirement as part of the acceptance criteria, had in each case been signed off as meeting acceptance criteria.
The licensee was questioned about the signoffs.
The licensee stated that the engineer had signed off the step because the excess resistance was attributed to the cable length between the rack to rack and tier to tier jumpers.
The inspector requested the evaluation of the cable resistance value.
The licensee stated that an evaluation had not been performed.
Since the cable resistance had not been determined and subtracted from the total resistance, the value of the cell to cell resistance was not known.
Procedure 00404-C, Surveillance Test Program, Step 4.5.4.1, requires an independent reviewer to confirm that test results satisfy acceptance criteria.
The reviewer signed the STS indicating that the acceptance criteria were met.
10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality be accomplished in accordance with documented instructions, procedures, or drawings.
This requirement is implemented by Section 17.2, Operations Quality Assurance Program, of the FSAR.
The failure to follow procedure 00404-C to confirm that test results met the acceptance criteria for the rack to rack and tier to tier jumpers on the vital batteries is identified as an example of violation 424/87-01-01.
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(2) On data sheet 2 of procedure 14423-106, Source Range NIS Analog Channel Operational Test, performed on January 14, 1987, the normal reading taken from the Neutron Level Drawer Meter exceeded the upper limit values given on the data sheet.
A note on the data sheet directs the test performer to add the pre-test indication on meter NI-101 to the upper limit values for specific switch positions given on the data sheet.
This would raise the upper limit.
Nowhere on the-data sheet, however, is the reading on NI-101 documented.
This makes the true upper limit unclear and makes it appear the procedure is unsatisfactory when in fact it is satisfactory.
The licensee agreed to change the procedure to include the reading on NI-101 on the data sheets.
No violations or deviations were identified.
(3) On procedure 14423-106, the High Flux at Shutdown (HFAS) set-point was not checked.
A note on the proceddre stated that the i
HFAS setpoint would be set after two fuel bundles were loaded t
in the reactor vessel.
The inspector questioned the licensee on the triggering mechanism for establishirg the HFAS setpoint.
The licensee stated it was part of startup test procedure
- 1-500-01, Initial Fuel Load Test Sequence.
The inspector verified this and had no further comments.
No violations or deviations were identified.
(4) On procedure 14895, ECCS Check Valve Refueling Inservice Test, completed September 17, 1986, required flow rates which were marked "LATER" had been changed to specific values without a proper procedure revision.
This item had also been identified by the licensee's QA audits and was being followed by QA.
No violations or deviations were identified.
(5) Procedure 14811, Boric Acid Transfer Pumps and Discharge Check Valves Inservice Test, had been identified as not acceptable by the IST group but NSAC was showing the surveillance to be acceptable.
This item was also identified in a QA audit and was being followed by QA.
No violations or deviations were identified.
(6) The inspector questioned the absence of dates on a number of
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Task Sheets attached to active surveillances.
The licensee provided verification that the problem was corrected and the
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surveillance tracking system was working as delineated in procedure 00404-C, Surveillance Test Program.
The inspector had no further questions.
No violations or deviations were identified.
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(7) Surveillance procedure 14896-101, Revision 0, which was completed and reviewed by the licensee on January 12, 1987, was not revised in accordance with the outstanding TCP, No.
14896-187-1.
The flow rate criterion on Data Sheet 1, for the emergency core cooling system (ECCS) check valve cold shutdown inservice test, was not changed from 3,000 gpm to 3,788 gpm, as required by this TCP nor was another TCP written to change the flow rate criterion.
No violations or deviations were identified.
(8) The inspectors noted that items 1, 4, 5, and 7 raised questions about the reviews required to assure that acceptance criteria were met.
The review of the licensee's procedures to assure that adequate administrative controls exist for review of acceptance criteria and determination that the acceptance criteria are met is identified as inspector followup item 424/87-01-02.
No violations or deviations were identified.
b.
Field Review of Surveillance Instructions The inspectors performed a field review of surveillance procedures by observation of surveillances in progress or by walkdown of procedures in the field. The following concerns were identified:
(1) The inspector observed chemistry technicians dismantling a radiation monitor identified as 1RE-12444C.
When the inspector asked to review the MWO under which the technicians were performing the work, they replied that they were dismantling the monitor via surveillance procedure 34223-C, Rev. 1, Channel Calibration of the Gaseous Effluent Monitors.
The inspector reviewed the procedure and associated attachments to determine if the procedure was being followed properly.
The inspector determined that the technicians had not obtained the signature of the shift supervisor prior to performing work or the signature for review of QC holdpoints.
The inspector noted that, step 5.1 of procedure 34223-C, Prerequisites, states, " Ensure a Quality Control (QC) represent-ative has signed the checklist indicating a QC review of the procedure for hold points.
If hold points are indicated, notify QC prior to starting." Additionally, step 5.2 states, " Notify the Operations Shift Supervisor, or his designee, of the work to be performed and obtain his signature authorization."
Neither of these signatures had been obtained.
When the lead technician was questioned on these steps, the technician stated that verbal approval had been obtained from the Shift Supervisor to perform the work.
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10 CFR 50, Appendix B, Criterion V, requires, in part, that activities affecting quality be accomplished in accordance with documented procedures.
VEGP FSAR, section 17.2, Operations Quality Assurance Program, also requires that activities affecting quality be accomplished in accordance with documented procedures.
The activities described above were not accom-plished in accordance with procedure 34223-C in that the signature of a QC representative had not been obtained for the hold point review, indicating that the review was not accom-plished, and the signature of the Shift Supervisor had not been obtained to authorize performance of the work.
The inspector later verified that the Shift Supervisor had provided verbal approval.
The failure to follow procedure 34223-C is identified as an example of violation 424/87-01-01.
During the review, the inspector questioned whether or not the radiation monitor was seismically and/or environmentally quali-fied equipment and if provisions existed in the procedure to maintain these qualifications.
The inspector determined that Vogtle administrative procedure 00350-C, required that work performed on seismically or environmentally qualified equipment be done under the control of an MWO.
The inspector questioned the use of surveillance procedures to control removal and restoration of seismic and/or environmentally qualified equipment.
Resolution of this issue was identified as IFI 424/87-01-04.
During subsequent inspections, the inspector was informed by the licensee that radiation monitor 1RE-12444C was seismically qualified and the technicians were not taking any special precautions to maintain the equipment qualification.
The licensee generated Deficiency Reports (DRs) 1-87-0203, on the disassembly of monitor RE-12444-C; and,1-82-0204, on detector removal and reinstallation for monitors RE-0020A and RE-00208.
A Request for Engineering Review (RER) was written for problem resolution and MW0s were written to cover the remaining work.
Regarding the concern of whether or not the EQ of the monitors was compromised by the routine disassembly and reassembly, the inspector reviewed the system description 9002-DRMS-002 to ascertain what is required to maintain EQ. The system descrip-tion indicates that no specific removal or replacement proce-dures are required.
Nomal safety precautions and general shop techniques were adequate for this task.
The portion of the monitor that could degrade the EQ of the monitor is never opened for these routine calibrations.
Since these calibration activitics do not directly affect the seismically sensitive areas of the equipment, the original procedure was not clearly in violation of administrative procedure 00350-C, which requires MW0s to be written for work performed on seismic or environ-mentally qualified instrumentation.
However, the licensee i
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stated that all procedures that affect radiation monitors that have seismic and/or environmental concerns are being reviewed and revised as deemed appropriate.
Procedure 39350-C, Initial Calibration of Gaseous Process Monitors, was written to require an MWO for the removal or reinstallation of any components on radiation monitor RE-2562.
This system is seismically qualified per FSAR Table 11.5.2-1.
Other calibration procedures will be revised similarly in the near future to cover all of the monitors in this table.
The inspector was concerned that simply placing this caution in the calibration procedure would not guarantee that a technician would not start with the procedure for the removal of the detector; then use the procedure for the calibration and find out that an MWO was required to implement precautions so as not to jeopardize the EQ of the equipment.
The inspector then reviewed the licensees EQ program in order to determine whether or not it provided adequate assurance that EQ is maintained.
The inspector interviewed personnel from the Maintenance and Engineering departments as well as the Work Planning Group.
The EQ program is implemented under procedure 20009-C, Rev.
1.
The inspector found the procedure to be satisfactory.
Any equipment that must be EQ had an associated package of information called the Environmental Qualification Data Package (EQDP).
These EQDP's were numbered and controlled documents. Each package was divided into nine parts. The parts
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are:
(a) EQDP equipment identification list (b) Environmental summary sheet (c) NUREG 0588 Checklist (d) Master listing - seismic (e) Seismic qualification and recorder data sheets (f) Calculations (g) Maintenance / replacement information (h) EQ design change signoff form (1) Miscellaneous information The inspector reviewed four EQDP's: Relief Valves; Radiation Monitors; Limitorque Valves; and Rosemount Transmitters.
The inspector determined that the packages were comprehensive and found the information easily accessible.
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The inspector reviewed three procedures to determine if the EQDP information had been implemented into these procedures.
These procedures were: 22402-C, Rosemount Transmitter Removal and Reinstallation; 28211-C, Relief Valve Test Procedure; and
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25240-C, General Bolted Flange Torquing Procedure.
All of these procedures compared favorably with their respective EQDP.
The inspector reviewed the licensee's Nuclear Plant Maintenance Information System (NPMIS) to observe how EQ equipment was flagged to prevent compromise of the EQ requirements.
All equipment had a safety classification that was reviewed whenever an MWO was written against the equipment.
In accordance with Regulatory Guide 1.60, Design Response Spectra for Seismic Design of Nuclear Power Plants, the licensee uses a project classification matrix (Table C13-1 from the VEGP Project Reference Manual) that delineates what safety classification code is used to designate safety related equipment and whether the equipment is EQ or not. All of the equipment with a safety classification that indicates either seismic or environmental qualification must be reviewed by QC.
In addition, the Work Planning Group engineer and the Environmental Qualification Group engineer must both sign off on any EQ equipment that all proper reviews have been performed, the EQDP had been referenced, and the installation / replacement documents are accepta,ble.
Finally, the inspector reviewed constructica documents to determine if the equipment had been installed correctly.
The most important aspect of the seismic qualification of the radiation monitors is the e, led upon which they are mounted during normal operation.
All seismic modeling of the equipment was performed assuming that the sled was instaited the way that it was designed. The inspu, tor found that probNms had occurred with the installation of the sled.
These are detailed in Readiness Review finding M-13.
Correspondence from F. B. Marsh of Bechtel Western Power Division to J. A. Bailey of Southern Company Services discussed the specifics and stated that the deficiency was not reportable under the rules of 10CFR 50.55(e).
A Deviation Report (DR) CD-9158 was generated on December 19, 1987 to address and disposition the discrepant condition.
The DR, which details the evaluation that determined the condition was ratisfactory, appeared adequate to the inspector.
The DR had not been sent to QC for approval.
Overall, the inspector found the licensee's EQ program to be satisfactory and in some aspects, exemplary.
IFI 424/87-01-03 will remain open pending review of the revisions of all radia-tion monitor procedures that affect those monitors listed in FSAR Table 11.5.2-1, and the closing out of CD-9158.
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(2) Sections of procedure 24519-1, Rev. 2, Reactor Coolant Pressure (Wide Range) Protection I 1P-405 Analog Channel Operational Test and Channel Calibration, which apply to the analog channel operational test using the manual system, were observed.
The operational test failed.
As-found readings fell outside the expected band.
Section 4.20, Summing Amplifier Card Field Calibration, of procedure 23300-C, Rev.1, Field Calibration Procedure, was performed and the appropriate sections of procedure 24519-1 were repeated.
No violations or deviations were identified.
(3) An inspection of portions of the field performance of procedure 24634-1, CR Air Intake Process Radio Gas Monitor Analog Channel Operational Test & Channel Calibration, and procedure 24623-1, Containment Low Range Area Monitor Analog Channel Operation Test and Channel Calibration, was performed.
The inspector had no comments.
The inspector reviewed procedure 24183-1, Rev.1 Fuel Handling Building Effluent Radiogas Monitor, ARX-2533.
The inspector noted an inconsistency betwcen the procedure and panel in that labeling for a connector was IAJ3 versus J3 on the panel.
An LED which was unmarked on the remote / control box, did not light as indicated by the procedure.
No LED was provided on unit IRT-1005 as indicated in step 4.1.3.6.b.
The inspector reviewed procedure 24756-1, Rev.
2, Steam Generator Level (Narrow Range) Protection Channel II, IL-553.
The inspector noted that the location of equipment was determined using an out of date drawing due to the time required to pull new drawings.
After this walkdown, the inspector encouraged the licensee to evaluate the distribution of drawings from Document Control.
Requests for drawings by the inspector to the technicians, who were performing work in the plant, typically resulted in a 50-minute wait in Document Control. The inspector was concerned that the opportunity to use obsolete information would be more likely if the people who needed the information consistently found obtaining new drawings difficult. Prompt distribution can greatly enhance compliance with drawing and document control requirements. During two surveillances, which were witnessed by
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the inspector, technicians spent approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> to find I
equipment that was either erroneously listed in the procedure (e.g., local indication for radiation area monitor) or moved in a modification (e.g., a steam generator level transmitter). The inspector asked the technicians in both instances, after a
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twenty-minute search, if it would be more expedient to check the drawings.
In both cases, the technicians thought the equipment would be located any moment and the time spent to obtain a drawing was unnecessar.
i The inspector reviewed procedure 24634-1, Rer.1, Control Room
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i Air Intake (1RE-12116) Process Radio Gas Monitor.
During the surveillance, remote control test box was removed.
This item was identified to the licensee as part of IFI 424/87-01-06.
The equipment was later determined to be used only for testing
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perform calibrations on other monitors without any tracking, i.e., no MWO was issued. Deficiency Report 1-87-161 was written to document this occurrence and engineering report 87-0036 was generated to perform an evaluation of the incident.
The engineering report determined that the RCB is interchangeable on the monitors and there is no problem with using them in this manner.
Still, the removal of the RCB does require a MW0 and the licensee showed the inspector a procedure that cautioned personnel performing this action with a RCB to generate a MW0.
The procedure was a draft copy. Until the procedure is revised, this part of IFI 424/87-01-06 will remain open.
The inspector also noted during plant walkdowns that an ambient temperature difference of 8 to 10 existed between the Control Building normal air conditioning room temperature gauge and the ESF air conditioning room temperature gauge,1-1539-TIC-13150 and 1-TSH-13151.
The inspector requested the licensee to investigate if the instruments were operable.
In a letter dated January 12, 1987, the licensee stated that an investigation had revealed that the instruments served separate functions, i.e.,
monitored different rooms.
However, as a result of this finding, the inspector later determined that the licensee had written maintenance work order (MW0) 18700997 to correct the discrepancy between these instruments, since both instruments measured the same ambient room temperature. This is considered acceptable; however, the action did not correspond to the January 12, 1987 response.
No followup is considered necessary for this item.
Other concerns involving emergency lighting which was out in a stairwell, the failure of personnel to close fire doors and a question on the wire bend radius of cable at location A-1813-M3-027 were promptly answered or corrected by the licensee.
The wire bend radius was determined to be within specification.
These concerns had also been identified as part of IFI 424/87-01-06. These concerns are considered closed.
No violaticns or deviations were identified.
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8.
Maintenance Program and Procedure Review (42451B, 357438)
During previous inspections, reviews had been conducted of the administra-tive controls for plant maintenance, the technical adequacy of maintenance procedures and the implementation of the maintenance program. The review included an assessment of the corrective maintenance program; an assess-ment of the preventative 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 program.
The program had not been fully implemented under the operational quality assurance program at that time.
Followup on the implementation of the program was identified as IFI 424/86-117-24.
During this inspection, the inspectors reviewed procedure 00350-C, Maintenance Program, Rev. 5, dated December 3,1986.
This procedure was the administrative procedure which governed maintenance activities during operation.
Additionally, the inspectors witnessed several maintenance activities in progress including the processing of mainte-nance work orders (MWO) in accordance with the requirements of 00350-C.
The inspectors also reviewed completed work packages that were accom-plished under the operational QA program.
The inspectors verified that the licensee had implemented its planned maintenance program.
Based on the review, IFI 424/86-117-24 is closed.
The field review consisted of observing 14 MW0s which addressed various aspects of plant maintenance.
The inspector noted that MW0's, with one exception, were appropriately filled out and all MW0s reviewed addressed such areas as QC hold points and proper initial review by other depart-ments.
The inspector noted a number of cross outs which detracted from legibility. The inspector identified the following items:
a.
The inspector determined that maintenance personnel had not verified that approved drawings, procedures and vendor manuals included in MW0s in use in the field were the current revision.
Procedures 00103-C, Document Distribution and Control, and 00101-C, Drawing Control, required that drawings, procedures and vendor manuals be verified as current every seven days. These procedures also required that any documents which affected the revision to be noted on the affected working copy.
In addition, procedure 20050-C, MWPG Work Order Processing, requires that working copy documents be verified current prior to their issuance to the field; and, procedure 20407-C, Maintenance Conduct of Operations, states that it is the responsi-bility of the user to ensure that only current, approved working copy documents are used.
The maintenance personnel observed by the inspector had failed to perform the seven day review for drawings on MW0s 18700429,18700453 and 18624440 and for vendor manuals on MW0 18624165.
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10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality be accomplished in accordance with documented instructions, procedures or drawings.
The failure to follow procedures 00101-C, 00103-C and 20407-C is identified as an example of violation 424/87-01-01.
During the week of January 12, 1987, the inspector determined that the drawings and vendor manuals included in the MW0s reviewed were the latest revisions. The Maintenance Department issued a memorandum to all maintenance department supervisors and foremen requiring them to review all work packages in their possession to assure that all working copy documents are the latest revision.
Deficiency Report (DR) 1-87-0185 was written by the licensee to document the finding. The licensee stated that the Quality Assurance Department will perform random audits of the maintenance program.
Additionally, the licensee will consider incorporating into the appropriate Maintenance Department procedure the requirement that
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foremen and supervisors verify weekly that working copy documents are the latest revision.
b.
Paragraphs 4.1.2.c through e of 00350-C, stated that MW0s were not required for certain activities which do not involve safety-related, seismic or environmentally qualified equipment.
The inspector interviewed members of the Maintenance Work Planning Group concerning the process used in making this determination and documentation of the review.
The MWPG stated that equipment addressed by paragraphs c, d, and e of 00350-C was contained in the Nuclear Plant Management Information System (NPMIS) which delineates all of the pertinent information on the safety-related, seismic and environmental qualifi-cation classifications of equipment.
If the foreman is in doubt, an MWO is submitted which will be reviewed for procedural applicability.
Additionally, paragraph d, which addresses labeling, was being performed under operations procedure 10016-C, Equipment Labeling Guidelines.
No violations or deviations were identified.
c.
The inspector noted that MW0 18624097 did not have a functional test assigned in block 32 as required by procedure 00350-C.
During review of other maintenance work orders the inspectors noted that MW0s appeared weak in the area of functional testing.
This item is of particular concern in light of the number of findings identified by the Quality Assurance Department related to the failure to assign functional testing to MW0s.
These findings are documented in audit reports No. OP15/TP02-86/20, #045-II, July 12 thru August 5,1986; No. OP15-86/45, November 17 thru December 5, 1986; and No. OP15-87/03, January 6 thru 11,1987.
The inspectors identified this item as IFI 424/87-01-03.
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The inspector reviewed the corrective action for this item during the week of January 12, 1987.
In response to the item, the licensee had issued procedure 20051-C, Maintenance Work Order Functional Tests, to provide guidelines for proper functional test assignments.
The licensee also plans to revise the MWO processing procedure to assign the functional testing requirements after the work has been accomplished.
In addition, the licensee established a review team assigned the task of assessing the quality of the MW0s being issued by the Maintenance Work Planning Group and returning to the MWPG those MW0s lacking sufficient direction or adequate functional testing.
The work conducted under MWO 18624097 was complete and awaiting the assignment of the appropriate functional testing.
The inspector determined that the licensee had implemented procedures which provided adequate direction and review to ensure that MWO instructions are sufficiently detailed and are assigned the appropri-ate functional testing.
IFI 424/87-01-03 is closed. The IFI number will remain assigned to the item to allow tracking of the finding.
No violations or deviations were identified.
9.
Review of Aaministrative Controls for Temporary Modifications (424518)
During the inspection, the inspector noted that there were numerous temporary modifications installed in the plant. The inspectors determined that the licensee had a mechanism to review temporary modifications and their effect on system operability once the system was formally turned over to operations. However, the licensee was performing surveillances on systems that had temporary modifications installed.
Therefore, the validity of the surveillance could be affected for surveillance tests completed after preoperational testing and prior to establishing configu-ration control by Operations.
This concern was identified as Inspector Followup Item 424/87-01-05.
During the week of January 12, 1987, the inspection team conducted a review of the licensee's procedures.
Procedure 00350-C, Maintenance Program, addressed the removal of temporary modifications to ensure that proper documentation was provided and that the functional testing, including assessment of its impact on surveillances, was performed.
Procedure 00307-C, Temporary Modifications, addressed the methods utilized to ensure that temporary modifications are properly identified, docu-mented, controlled and evaluated.
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While under the jurisdiction of the Start Up Manual, Procedures SUM-10, Temporary Modification Control, and SUM-22, Maintenance Work Orders, adequately addressed the subject of temporary modifications including the
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assessment of its impact on surveillance tests.
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The aforementioned maintenance and temporary modification procedures ensure that work / temporary modifications performed on a system will verify that surveillances are active and document that components / systems are functioning properly and capable of performing their intended safety function.
Temporary modifications which were in place during pre-operational testing which was utilized to satisfy surveillance require-ments were adequately addressed by the constraints imposed by Section 4.4 of procedure 00404-C, Surveillance Test Program.
Under the pre-operational test program, the test supervisor was responsible for reviewing the temporary modification log for items which may preclude completion of the test or invalidate the test results upon completion.
Specifically, paragraph 4.4.6.1 required that " documentation for the completed procedure or work activity shall be carefully reviewed to ensure that satisfaction of the surveillance requirements is clearly documented and that the conditions during the period of the test are the same as would be experienced during the operational phase surveillance test procedure.
Discrepancies shall be noted in the comments section of the documentation check list."
As a further area of discussion, it should be noted that test / surveil-lance procedures contain steps which require the introduction of modifications which place the system / component into a configuration such that the test / surveillance procedure attains the required objective. The introduction of such modifications is reviewed with the development of the procedure.
The inspector feels that all concerns regarding temporary modifications have been addressed and therefore inspector followup item 424/87-01-05 is closed.
The inspector followup item number will remain assigned to the item to allow tracking of the item.
No violations or deviations were identified.
10. Control Room Activities Review (424508)
a.
The inspector reviewed control room administrative procedures and verified documentation maintained in the control room to assure the documentation was being maintained in accordance with procedures.
Documents reviewed were:
Reactor Operator & Shift Supervisor Logs LC0 Log i
Standing Orders Jumper & Lifted Wire Clearance Log Operations Reading Book Disabled Aanunciator Log The inspector also checked 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Technical Specification valve position verification requirements applicable to the ECCS subsystems.
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These verifications were being performed properly. The inspector had no comment _ _
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It was noted previously that numerous administrative controls established for the management of those plant and control room activities conducted under the direction of licensed operatcrs were not implemented.
These findings were documented in NRC Inspection Report 424/86-117.
However, during this inspection the inspectors noted a marked improvement in this area.
The administrative controls were implemented and review of record, logs and checklists indicated thorough input and current status.
The inspector had no further comments in this area.
No violations or deviations were identified.
b.
(Closed)
Inspector Followup Item 424/86-60-10 (TMI Action Item I.C.2).
Shift Relief and Turnover. The inspector reviewed procedure 10004-C, Shift Relief, Rev. 3, and the shift turnover process to ensure adequate controls were in place to provide for a complete shift turncver and the meeting of TMI action item I.C.2 requirements.
The inspector's review included observation of control room activity, review of logkeeping and log review, and a review of all procedures governing shift turnover.
The inspector noted that adequate controls appeared to be in place to maintain access to the control room in an orderly manner.
The operators also appeared to display a professional manner and surveil-lance of the control boards appeared to be adequate.
The Reactor Operator (RO), Balance Of Plant (80P), and Non-Licensed Operators (NLO) utilize rounds sheets to log and record plant parameters. The inspector reviewed the rounds sheets of the R0, B0P, and the NL0s.
These sheets appeared to be properly completed and to adequately meet the part of TMI action item I.C.2 which requires that the licensee provide assurance that plant parameters were within allowable limits.
The rounds sheets of the NL0s are reviewed by the R0, B0P, and Shift Supervisor (SS) to ensure knowledge of plant parameters not indicated in the control room.
The rounds sheets of the R0 and the B0P are also reviewed by the SS.
The inspector determined that these reviews appeared to be taking place and that the operators in the control room were cognizant of the status of the plant.
While reviewing the narrative logs, the inspector noted on January 15, 1987, that the SS log had no initialed review by the day shift SS for the previous night's log entries.
When questioned as to the apparent lack of a review, the SS told the inspector that he did not review the previous night's logs and that he was not required to review his own logs by procedure because the verbal turnover from the off-going SS was adequate.
The inspector showed the SS where procedure 10004-C, Revision 3, Shift Relief, required the on-coming operator to review and initial the
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narrative logs completed since the last shift worked by that operator or for the preceding 5 days, whichever is less.
The SS stated that he was referring to direction received from procedure 10001-C, Revision 3, Logkeeping, however, when he showed the procedure to the inspector he noted that he was incorrect and that he was also required to review his narrative logs by this procedure.
The failure to review and initial the Shif t Supervisor narrative logs is a failure to follow approved plant procedures in accordance with 10 CFR 50, Appendix B, Criterion V.
This item is identified as an example of violation 424/87-01-01.
During the review of procedure 10004-C the inspector identified a discrepancy between the procedure and the On Shift Operations Supervisor (0505), R0, and B0P checklists.
These checklists are provided in procedures 11870-C,11872-C, and 11869-C, respectively.
The procedures require each on-coming OSOS, R0, and 80P to review the following logs in addition to the rounds sheets and narrative logs:
Special Conditions Surveillance Log, Clearance Log, Lif ted Wire Log, and Temporary Modifications Log.
The OSOS, R0, and 80P checklists were missing the appropriate check blocks for each of the above logs.
This was brought to the attention of the licensee and the checkshetts were modified to reflect the intent of the procedure.
The TMI action item also required implementation of a system to evaluate the effectiveness of the shift relief turnover procedure.
Step 3.12 of procedure 10004-C states that the 050S shall make an evaluation of shift relief and turnover at least semiannually.
The results of this evaluation were to be forwarded to the Operations Manager for disposition.
Although the statement contained in the licensee's procedure directed the Operations Superintendent to perform an evaluation, the procedure provided no instructions on how the evaluation was to be performed.
The inspector discussed this item with the licensee and the licensee issued a revision to the Non-Technical Specification Activities sheet.
Prior to the revision the sheet merely restated the step in the procedure and provided no further direction.
The revision provides direction to the OSOS by listing several specific items to be addressed during the evaluation.
This revision appeared to satisfy the final requirement of the TMI action item. TMI Action Item I.C.2 and IFI 424/86-60-10 are closed.
11.
Inspection and Enforcement Notice Review (92701)
The inspector reviewed the licensee's response to IE Notice 86-61, Failure of Auxiliary Feedwater Manual Isolation Valve.
The inspector l
discussed the notice with the licensee and determined that the preventive maintenance requirements for manual isolation valves were determined on a case-by-case basis during the formulation of the PM program.
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12.
Inspector Followup Items (92701)
a.
(Closed) Inspector Followup Item 424/85-36-02.
Evaluation of Operational Event Reports.
The IFI involved a concern that the licensee tended to address items programmatically rather than technically. The applicant had committed to reopen and reevaluate IE Information Notice 85-23 and reevaluate preoperational testing associated with differential pressure transmitters.
The inspector reviewed a March 14, 1986 memorandum from Ron Bone, GPC to Bob Lide, GPC which provided the technical evaluation of the preoperational and startup testing of the differential pressure transmitters and an evaluation of IE Information Notice 85-23.
The inspector did not identify any concerns with the licensee's disposition of the evalua-tion findings.
In addition, the inspector reviewed five additional IE Information Notice evaluations and identified no concerns.
This item is considered closed.
b.
(Closed) Inspector Followup Item 424/85-36-03.
Performance of Safety Evaluations and Duties and Responsibilities of Plant Review Board.
The IFI concerned the lack of procedural requirements to submit safety evaluations for unreviewed safety questions and Technical Specification changec to the Plant Review Board for review.
The inspector reviewed a revised copy of 00051-C, Review and Approval of Procedures, which added this requirement. This item is closed.
c.
(Closed) Inspector Followup Item 424/86-117-01.
Independent Verification.
The inspector reviewed procedure 00308-C and deter-mined that the licensee had met the NRC g'aidance in regard to independent verification.
The inspector verified that independent verification was being performed in accordance with procedure 00308-6, Independent Verification Policy. The inspector observed the performance of a Boric Acid Transfer Pump tag-out and checked a co.'pleted RHR system lineup. This item is considered closed.
d.
(Closed) Inspector Followup Item 424/86-117-02.
Lack of Vents on AFW Piping at Apparent System High Points. The inspectors had noted in a 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 stecm generators 1 and 4.
The inspectors were concerned that any back-leakage and 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. There were no provisions within the procedure, 13610-1, to monitor these highpoints for 1eakage and steam formation, nor to take action, upon detection of
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steam formation, to resolve water hanner concerns.
The inspector reviewed the analysis performed by the licensee for backleakage into the AFW system and determined that the present design and monitoring procedures provide adequate assurance that backleakage will not occur or result in waterhammer in the AFW system. This item is closed.
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e.
(Closed) Inspector Followup Item 424/86-117-03.
Precautions on Maintaining Subcooling Margin.
Item a was closed in Inspection Report 424/86-117.
In regard to Item b, which concerned A0P 18009-1, Steam Generator Tube Leak, the inspector had determined that Step 5,
" Response Not Obtained", required the reduction of RCS temperature from 557 F to 500 F prior to isolation of the faulted SG if the faulted S/G was not immediately identified.
The procedure then required the subsequent identification and isolation of the faulted S/G and RCS depressurization to 25-50 psig greater than the faulted S/G pressure. Under these conditions, RCS subcooling margin would be approximately 5 F, which is substantially less than the 28 F sub-cooling 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.
In addition, no instructions were given to isolate the cold leg accumulators at 950 psig.
The inspector reviewed the revision of the procedure that had been reviewed and approved by the Plant Review Board.
(The revision was handwritten at the time of the review.)
Prior to the steps that depressurized the RCS to 25-50 psig of the faulted S/G, the licensee i
had inserted the following steps: "If pressurizer pressure lowers to less than 1000 psi, accumulators should be isolated." and, "During cooldown, maintain at least 50 F RCS subcooling."
These changes adequately addressed the problems described above and Item b of IFI 424/86-117-03 is closed.
f.
(Closed) Inspector Followup Item 424/86-117-04. Correction of Valve Identification and Lineup Discrepancies. Each item identified in IFI 424/86-117-04 is addressed separately below.
Item a.
NSCW valve 1-1202-X4-205, shown to be on the return line l
of the train "A" reactor cavity cooling coil, was listed on the alignment checklist of procedure 11150-1, Rev.1, but was not on the P&ID, nor was it found in the system during a system walkdown.
The licensee provided the inspector a Temporary Change to Procedure (TCP) form number 11150-1-87-2, generated and approved on January 8, 1987, which corrected the checklist. The TCP required final approval by the Plant Review Board by January 22, 1987.
Item a of IFI 424/86-117-04 is closed.
Item b.
A vent valve on the NSCW system on the outlet from the lube oil cooler for the centrifugal charging pumps on train A was not on the valve lineup verification list of procedure 11150-1, Rev. O.
This discrepancy had been corrected on Rev.1 of this procedure.
Item b of IFI 424/86-117-04 is closed.
ltem c.
This item was closed in Inspection Report 424/86-117.
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Item d.
This item was closed in Inspection Report 424/86-117.
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Item e.
The CS system alignment procedure, 11115-1, and the CS system P&ID, drawing 1X4DB131, did not agree.
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 closed.
Also, in the same flushing connection, the CS alignment procedure showed valve U4-012 closed.
The CS P&ID showed the valve locked open. The inspector reviewed procedure 11115-1 and determined that the licensee had corrected the discrepancies.
Item e of IFI 424/86-117-04 is closed.
Iten f.
The IFI concerned the removal of a reference to a obsolete controller from a procedure.
No followup review was considered necessary.
Item g.
The inspector noted that CTB Cooling Unit Outlet Dampers were required to be locked open per Containment Heat Removal System drawing 1X4DB212.
Procedure 13120-1 did not include the locking requirement and the locking method.
The inspector determined that the licensee had corrected the discrepancy.
Item g of 424/86-117-04 is closed.
g.
(Closed) Inspector Followup Item 424/86-117-05.
Discrepancies in Unit Operating Procedures.
Each item identified in IFI 424/86-117-05 is addressed separately below.
Item a.
Item a was closed in Inspection Report 424/86-117.
Item b.
Item b was closed in Inspection Report 424/86-117.
Item c.
Procedure 12006-1, step 2.2.5, paraphrased a Technical Specification requirement.
The paraphrase was incorrect.
The step should have read "... and at least one loop in operation with the reactor trip breakers open."
The inspectors verified that 12006-1 had been corrected.
Item c of IFI 424/86-117-05 is closed.
Item d.
Procedure 12006-1, Section C4.1, Preparation for Continuing Unit Cooldown, required action be taken to accivate protection against cold overpressurization.
Only one method of cold over-pressure protection was addressed, the use of PORVs.
The procedure also should have addressed the two other mear of cold overpressure protection and a mechanism to declare which method was providing protection.
The procedure should have addressed the implementation of the TS :urveillance requirement on the RHR relief valves which must be completed prior to taking credit for the RHR reliefs.
The inspector verified that procedure 12006-1 had been changed.
Item d of IFI 424/86-117-05 is closed.
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Item e.
Procedure 12005-1 did not include a requirement in the Limitations section to refer to TS 3.4.1.2.
The inspector verified i
that procedure 12005-1 had been changed.
Item e of IFI 424/86-117-05 is closed.
Item 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 time.
The inspector verified that 12006-1 had been changed.
Item f of IFI 424/86-117-05 is closed.
j h.
(0 pen) Inspector Followup Item 424/86-117-07.
Discrepancies in Equipment Labeling.
Each item identified in IFI 424/86-117-07 is
addressed separately below.
i Item a.
Name tags were missing from RHR valves HV-8701B and 1205-027.
The licensee stated that one of these tags had been replaced and the other had been ordered.
These valves will be examined during a subsequent inspection to assure that these actions l
are taken.
Item a of IFI 424/86-117-07 is open.
l Item b.
The inspector determined that the B train controller at the remote shutdown panel was still labeled as 4.
Item b of IFI 424/86-117-07 remains open.
Item c.
The TDAFW panel SG level gauge was not labeled wide range or narrow range.
The procedure did not indicate the range. An AFW to SG bypass flow gauge was not labeled with engineering units.
The inspector verified that the SG level gauge had been labeled.
The bypass flow gauge had not been labeled.
Item c of IFI 424/86-117-07 remains open.
Item d.
Item d was closed in Inspection Report 424/86-117.
Item e.
Item e was closed in Inspection Report 424/86-117.
Item f.
The inspector had noted that engineering units were not displayed on strip chart recorder scales for main steam temperature and other recorders.
The inspector subsequently reviewed labeling of main control board strip chart recorders for engineering units.
Although the main steam temperature had been correctly labeled by
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the licensee, other recorders still had no units.
Item f of IFI
424/86-117-07 remains open.
Item g.
The inspector noted that remote handwheels in the CVCS system including BIT valves and charging crossover were not labeled.
The applicant stated that handwheels had been installed recently and labeling was planned but had not been completed.
The inspector conducted a tour of the auxiliary building levels containing the CVCS
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system and noted a greatly improved level of labeling for the remote
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manual valve operators, however, the inspector noted several remote i
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manual valve operators in the waste gas disposal area which lacked tags. The licensee stated that final efforts were being completed in assuring the adequacy of valve labeling.
No additional followup is considered necessary.
Item g of IFI 424/86-117-07 is closed.
Item h.
The CS alignment procedure, 11115-1, lists two sets of 120V AC CS MOV space heater breakers. A check of the 120V AC breaker panels (IAYD1 and 18YD1) identified the breakers as being labeled
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" spares."
The applicant is determining if these breakers are utilized for the M0V space breakers.
Item h of IFI 424/86-117-07 remains open.
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(0 pen) Inspector Followup Item 424/86-117-09.
Review of Reactor Vessel Level Indication System.
Four concerns were identified during the review of RVLIS involving procedure nomenclature, instrumentation references in procedure 14228-1, a vendor recommendation for a control room annunciator that had not been provided, and a vendor recommendation for periodic checks of locally indicating null meters.
The inspector was provided a Daily Schedule Control Sheet which indicated that the null meters would be checked by Operations quarterly.
It is noted that the RVLIS will be tested when the reactor coolant system is at system operating pressure during startup testing.
The inspector will review the reuining items and the results of the RVLIS testing after startup.
IFI 424/86-117-09 remains open.
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(Closed) Inspector Followup Item 424/86-117-10.
Procedure Revision to Include Check of Equipment Actuation on Control Room Ventilation Start.
The inspector reviewed procedure 13301-1, which had been revised in Rev.1 to include steps that verify that the outside air supply dampers close on manual actuation of Control Room Toxic Gas Isolation.
IFI 424/86-117-10 is closed.
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(Closed) Inspector Followup Item 424/86-117-11.
Adequacy of Procedure Prerequisites.
The inspectors had identified that scme of the prerequisites in S0Ps 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 prerequisites.
By letter dated January 14, 1987, the licensee committed to implement additional controls of prerequisites until the procedures were reviewed and modified to clarify prerequi-sites.
The licensee stated that standing order 1-87-04 had been issued to Operations to require that prior to initial use of any procedure being used in the control room the Shift Supervisor and operator will review the prerequisites / initial conditions section to ensure clarity and understanding of the required conditions. The order contains provisions to upgrade prerequisites by submitting comments / changes via an attachment to the letter.
Based on this commitment, IFI 424/86-117-11 is close.
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(Closed) Inspector Followup Item 424/86-117-12.
Clarification of Cleanliness Levels.
The IFI involved clarification of the cleanli-ness zone designations in Section 4.1.d of procedure 00254-C, Plant
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Housekeeping and Cleanliness Control, to ensure that all open RCS
components, as well as the refueling cavity, would be classified as Level II. The licensee revised the Level II cleanliness requirements in 00254-C, Section 5.4, to specifically include any system that could allow contaminates to reach the RCS.
This revision meets the intent of the IFI and IFI 424/86-117-12 is closed, i
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(Closed) Inspector Followup Item 424/86-117-13.
General Review i
of Abnormal Operating Procedures.
Topics from Regulatory Guide 1.33, Revision 2, February 1978, were verified to have procedures established.
The following contingencies were implemented by the procedures listed below:
l Procedure Revision Event Number Number Loss of Condenser Vacuum
- 18011-1
18023-1
Loss of Containment Integrity
- 17005-1
Loss of Feedwater
- 17009-1
18016-1
Conditions Requiring Emerg. Boration
- 17010-1
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18007-1
Fuel Cladding Failure
- 17005-1
18006-1
High Activity in Coolant or Offgas
- 17100-1
17213-1
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18009-1
Pressure Control Malfunction
- 18011-1
Plant Fires
- 17103-C
18038-1
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i Abnormal Releases of Radioactivity
- 18009-1
j Based on this review, procedural implementation of Regulatory
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Guide 1.33 is adequate and IFI 424/86-117-13 is closed.
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(Closed) Inspector Followup Item 424/86-117-14. Annunciator Response Procedure (ARP) Discrepancies. The inspector reviewed the licensee's commitment to conduct a review of ARP's to determine the adequacy of initial operator actions, the accuracy of window labelling, and the overall adequacy of each procedure.
The inspector reviewed Main Control Board (MCB) ARP's (panels 1 through 20) and concluded that a thorough review had been performed on these procedures and the procedures accurately reflected the annunciator windows and provided sufficient initial operator action.
The inspector also reviewed several of the review packagos for the annunciator panels, particu-
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larly those on the MCB. All of the reviews appeared to be comprehen-sive and competent. Although the ARP's for the annunciators that are (
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not on the MCB have not all been revised as yet; the reviews that were completed were adequate and the licensee program for completion of the reviews was determined to be adequate.
Therefore, IFI 424/86-117-14 is closed.
During the review of the corrective action for IFI 424/86-117-14, the inspector detennined that the ARPs referenced a Master Setpoint Document in lieu of giving an actual setpoint for certain annunciator alarms.
Interviews with several operators indicated that they did not know where to find this document.
In addition, personnel in the Operations Department were not sure as to the exact form or location of this document.
Followup on the licensee's actions to establish the document or to replace the references to the document in the ARP's with the actual setpoint was identified as IFI 424/87-01-07.
This IFI was subsequently reviewed during this inspection and the inspector determined that the licensee had taken corrective action for the IFI. This review is documented under paragraph 12.nn for IFI 424/87-01-07 in this report.
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(Closed) Inspector Followup Item 424/86-117-15.
Acceptability of Baseline IST Data for Section XI ASME Pump Testing.
This item concerned baseline data obtained on four of six Component Cooling Water (CCW) pumps which was below the data obtained during preopera-tional testing.
The inspector requested engineering justification for the operability of these pumps prior to fuel load. The inspector discussed with the licensee the ASME Section XI code, the licensee's ISI program, the inherent error in the measuring equipment, and the configuration of the preoperational test versus that of the ISI test.
Pump curves from the manufacturer were compared with the preopera-tional data and the baseline data.
The licensee provided adequate justification as to the operability of the CCW pumps in question.
IFI 424/86-117-15 is closed.
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(Closed) Inspector Followup Item 424/86-117-16. Technical Specifica-tion on the Discharge Flow of the RHR Pump.
The inspector had determined that the discharge pressure on the recirculation flow of RHR pump B was equal to 180 psid. TS 4.2.5.f required the discharge pressure to be 1180 psid. The licensee had stated that a TS revision
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had been requested to change the value to be 1165 psid. The inspec-tor subsequently reviewed the TS revision whIch incorporated the change.
IFI 424/86-117-16 is closed,
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(Closed) Inspector Followup Item 424/86-117-17.
Resolution of Water Hanner in NSCW. The item concerned the waterhammer that had occurred on the NSCW system during the Loss of Offsite Power test.
The licensee's analysis, which concluded that the waterhammer did not impair the operability of the system, was reviewed and found to be acceptable.
IFI 424/86-117-17 is closed.
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(Closed) Inspector Followup Item 424/86-117-18.
Implementation of Surveillance Program.
During the inspection ending December 12, 1986, the inspectors had determined that the licensee had not yet fully implemented the surveillance program administrative controls except on a small number of systems which had been accepted by the Operations Department.
During this inspection, the inspectors reviewed the implementation of the surveillance program and a number of additional surveillance test packages. Although several concerns were identified and one example of a failure to follow procedure was identified; in general, the results of this review indicated that the surveillance program was adequately implemented.
The review is documented in paragraph 7 of this report.
IFI 424/86-117-18 is closed.
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(Closed) Inspector Followup Item 424/86-117-19.
Review of Test Control and Implementation of Configuration Control during Performance of Surveillance Testing.
The inspectors had 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 test. The inspectors reviewed a number of completed surveillance packages and observed additional performances of surveillance testing.
No additional instances of failure to satisfy prerequisites or establish system configuration were noted.
The inspector rereviewed the performance of the MDAFW surveillance procedure,14807, and determined that the system had been retested.
Additional information on the review of the surveil-lance program is provided in paragraph 7.
IFI 424/86-117-19 is closed, t.
(Closed) Inspector Followup Item 424/86-117-20.
Revise Procedures to Clarify Use of Staggered Test Basis for Determining Frequency of Test.
The inspector had determined that although the Surveillance Test Coordinator was correctly tracking surveillances required on a staggered test basis, the test frequencies specified in certain surveillance procedures did not mention the requirement for stagger-ing the tests.
The inspector determined that procedure 00404-C, Surveillance Test Program, has been revised to include the TS definition of staggered test basis.
The inspector reviewed the deficient procedures identified and determined that the surveillance procedures had been revised to specify that the tests are to be performed on a staggered test basis where appropriate.
IFI 424/86-117-20 is closed.
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(Closed) Inspector Followup Item 424/86-117-21.
Review of Justifications for Use of Preoperational Tests to Meet TS Surveillance Requirements.
The inspectors reviewed the preoperational test data used to take credit for the 18 month surveillance tests of the emergency diesel generators (EDG) and the battery chargers.
The inspectors reviewed the pre-op tests with the engineers responsible for the EDGs and the battery
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chargers.
The review included a step by step table-top walkthrough uf the effected surveillances with a comparison of the pre-op data used to take credit for required data in the surveillances.
In both cases the inspectors determined that the pre-op data appeared to be a valid substitute for the data required for the surveillance and that the licensee did an adequate job in the justification of the use of the pre-op data.
The inspector discussed the controls with the licensee which will be utilized for assuring that startup tests are appropriately evaluated if the tests are to be used in lieu of surveillance tests.
The inspector determined that the licensee made significant improvements in the evaluation of the use of other tests in lieu of surveillance tests and took steps to assure that surveil-lance tests were performed in those cases where other tests did not satisfy the surveillance test requirements.
The inspector had no additional questions.
IFI 424/86-117-21 is closed.
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(Closed) Inspector Followup Item 424/86-117-22. Corrective Action to Assure Control of Twelve Hour Surveillances. The inspector reviewed procedure 14000-1, Rev. 3, Operations Shift and Daily Surveillance Logs, which now specify that surveillances be performed within two hours of each shift.
Procedure 10000-C, Rev. 3, Conduct of Operations, had been revised to require that the On Shift Operations Supervisor or the Shift Supervi::or ensure that procedure 14000-1 be performed within the first two hours of each shift.
IFI 424/86-117-22 is closed.
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(0 pen) Inspector Followup Item 424/86-117-23.
Miscellaneous Technical Issues Identified in Review of Surveillance Program.
This IFI included examples of various technical concerns identified during the review of surveillance procedures and/or surveillance program implementation.
Each concern is identified separately below by the paragraph number in Inspection Report 424/86-117.
Paragraph 7.c.
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 Modes 4, 5 and 6.
The inspector was shown a draft 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 flew to 660 gpm.
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 applicant stated that a Temporary Change Procedure (TCP) would be initiated.
The procedure additionally referred to the A SI pump as 1.
The inspector verified that the procedure was corrected.
Procedure 14000-1 did not specify that the surveillances on page 17 were to be performed in modes 1 or 2 only.
The inspector verified that the procedure was v
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corrected.
The correction of minor comments on procedures 54821-1, which referenced a deleted TS table, and 55016-1, which contained a typographical error in a TS reference, was verified. The comments on the surveillance procedures for the safety injection system in IFI 424/86-117-23 are considered closed.
Paragraph 7.e.
A review of procedure 00404-C, Surveillance Test Program, Rev.
2, dated December 3, 1986; 00405-C, Commitment Identification, Tracking, and Implementation, Rev.
3, dated October 22, 1986; and 00051-C, Procedures Review and Approval, Rev. 5, dated December 1,1986 indicated that the mechanisms to govern changes to procedures which implement technical specification commitments and changes to technical specification commitments which are implemented in procedures were in place.
The aforementioned procedures will ensure that if changes occur, the changes will be reflected in the surveillance task cross reference report and the master surveillance report.
It should be noted that procedure 14935-1, Rev. I draft, which prompted this concern, was approved. A review of the associated paper work revealed that the individual responsible for the commitment review failed to identify the deletion of a commitment.
The appropriate corrections were made when the error was identified to the reviewer. This part of IFI 424/85-117-23 is closed.
A review of procedure 14721-1, ECCS Subsystem Flow Balance Test, Rev.1, dated January 2,1987, discloses a revision which changes the applicability of the procedure to modes 1, 2, 3 and 4.
This is consistent with TS 4.5.2 and 4.5.3.1.
This part of IFI 424/86-117-23 is closed.
Paragraph 7.f.
Section 6.0, Acceptance Criteria, in both revisions of procedure 14806-1 did not include observation of proper lubricant level or check of calibration due dates. Section 8.0 of draft Rev.1 did not include the date of the applicable edition of ASME B&PV code,Section XI.
The inspector verified that these items had been corrected. These comments are considered closed. Procedure 54701-1:
(1) did not meet the requirements of TS 4.8.4.2.b, (2) failed to require the opening and locking of valve 1-1206-U6-029 after comple-tion of the test, (3) did not include a step to unlock and close valve 1-1204-U6-018, and (4) did not include independent verification of the position of 1-1206-U6-018.
The inspector verified that the licensee had corrected these items.
This portion of IFI 424/86-117-23 is closed.
Paragraph 7.g.
The valve numbers in TS 3/4.6.1.7 were incorrect.
Valves HV-2624 A and B, 4 inch isolation valves in the Containment Building Post LOCA Exhaust system; and, HV-2627 A and B and HV-2629 A and B, containment purge and exhaust isolation valves, were not included in the statement of the LCO. The valve numbers in surveil-lance requirement 4.6.1.7.1 were not all 24-inch containment purge
and exhaust isolation valves as indicated.
HV-2624 A and 8 were 4 inch Containment Building Post LOCA Exhaust isolation valves.
HV-26268 and HV-26-288 were 14-inch Containment Building mini-purge supply and exhaust isolation valves. The inspector verified that the numbers in the TS were corrected.
This portion of IFI 424/86-117-23 is closed.
Paragraph 7.h.
The reference to paragraph 7.h in Inspection Report 424/86-117 was a typographical error.
Coments in this section were evaluated and no followup was considered necessary.
Paragraph 7.i.
While witnessing the MDAFWP testing, the inspector noted in procedure 14807 that no step was included in the system restoration to place handswitch HS5131A back into automatic.
The system restoration section of procedure 14807, Rev.1, now includes a step to place handswitch HS5131A back into automatic at the conclu-sion of the MDAFW surveillance test, and to independently verify this step. This portion of IFI 424/86-117-23 is closed.
Paragraph 7.J.
The inspector noted that the physics curve book had not been completed.
During a subsequent inspection, the inspector determined that the physics curve book was near completion.
The majority of the reactivity data, which had been extracted from WCAP-11338 and reformatted, had been provided to Reactor Engineering for review. This portion of IFI 424/86-117-23 will remain open until completion of the curve book is reviewed.
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(Closed) Inspector Followup Item 424/86-117-24.
Implementation of the Operational Phase Corrective and Preventive Maintenance Program.
This item is closed as discussed in paragraph 8 of this report, y.
(Closed) Inspector Followup Item 424/86-117-25.
Ultimate Heat Sink Technical Specification Clarification.
A revision was to be made to the ultimate heat sink TS to clarify the wording, remove ambiguities, and modify a surveillance so that it could be realistically met. The inspector determined that the changes had been approved and would be included in the TS.
IFI 424/86-117-25 is closed.
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(Closed) Inspector Followup Item 424/86-117-26.
Verification of Position of BIT Isolation Valves.
A review of procedure 11006-1, Chemical and Volume Control System Alignment for Start-up and Normal Operation, Rev. 3, dated December 29, 1986, contains a revision which calls for the verification of BIT isolation valves 1-HV 9803 A & B in the open position with the Limitorque handwheel lon ed.
This revision satisfies TS requirement 4.5.2.b.2 by designating these valves, which are in the ECCS flow path, as locked valves, thereby excluding them from the 31 day correct position verification.
The inspector field verified that the appropriate locks were installed.
IFI 424/86-117-26 is close aa.
(0 pen) Inspector Followup Items 424/86-117-27.
TS / Surveillance Procedure Cross Reference List and Surveillance Procedure Completion.
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.
Procedure 53002-C was shown in the cross reference list for BOL moderator temperature coefficient surveillance (TS 4.1.1.3.a) but the licensee did not plan to use the procedure for the initial startup test and it had not been written. This procedure will be an integrated low power physics testing procedure to be used for reloads.
The inspectors confirmed that the procedure to be used was adequate to meet the surveillance requirements.
The TS cross reference list did not show which startup tests are used to satisfy surveillance requirements.
Startup testing will be observed in future inspections.
The inspectors reviewed a portion of the cross reference list to confirm that procedures required for Mode 6 had been identified and completed.
The inspectors provided several minor comments to the licensee for resolution, but determined that the cross reference list was adequate for startup.
IFI 424/86-117-27 will remain open pending further review of the status of procedures required for power operation.
IFI 424/86-96-05, which involved the review of the completion of procedures required to meet TS surveillances, is closely related to IFI 424/86-117-27.
Based on the review of the surveillance program documented in paragraph 7 and the followup to be conducted to close IFI 424/86-117-27, IFI 424/86-96-05 is closed.
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(Closed) Inspector Followup Item 424/86-96-05.
Review of Surveil-lance Procedure Completion.
This item is closed as documented in paragraph 12.aa.
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(Closed) Inspector Followup Item 424/86-117-28.
Procedure Revision for Consistent Definition of Surveillance Test Completion Date and Time.
Administrative surveillance tracking procedure 00404-C, was revised by Revision 4 to correct a discrepancy between Section 2.5 and its surveillance task sheet completion instructions, note 20, concerning the surveillance official completion date and time.
A surveillance test is now consistently considered complete only after the test results have been reviewed. Therefore, IFI 424/86-117-28 is closed.
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(Closed) Inspector Followup Item 424/86-117-29.
Review of Special Condition Surveillance Test Triggering Mechanisms.
The inspector reviewed documentation to determine whether or not the applicant has adequate triggering mechanisms to ensure certain special condition surveillances are performed. A computer printout listing all special condition surveillances for mode 6 and all modes was reviewed.
The list contained approximately 112 surveillance requirements, the department responsible for triggering, the department responsible for
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completion, and the applicable procedures. The inspector audited 20 surveillance requirements to determine that adequate steps or precautions had been inserted into the appropriate procedure to
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trigger the required surveillance test.
In all but one case either an adequate procedure existed, a Temporary Change Procedure (TCP) had been generated, or a revision was in the approval process which the inspector reviewed.
The inspector noted one case where inadequate triggering mechanisms existed.
Procedure 17034-1 did not contain a requirement to verify 125V battery opera-bility after battery discharge or overcharge within 7 days as required by TS 4.8.2.2.
Although procedure 17034-1 had been desig-nated to have the triggering mechanisms for the maintenance department to perform the surveillance, the revision had not been done.
This was pointed out to the licensee.
A TCP was immediately processed.
The inspector reviewed the TCP and found that the change incorporated the appropriate triggering mechanisms.
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The inspector reviewed methods and procedures for departments to
keep track of special condition surveillances.
Draft procedure 50045-C, Engineering Special Condition Surveillances, was reviewed.
The procedure included a log for keeping track of active surveil-lances.
Discussions with responsible personnel indicated that the
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draft copy reviewed by the inspector was not finalized for approval and that additional EFPD sensitive surveillances, which were not requirements for fuel load, were to be incorporated into the procedure.
The inspector reviewed chemistry procedures 31045-C, Rev.
4, Chemistry Logkeeping, Filing, and Record Storage; and, 30040-C,
Rev. 1, Reporting Chemistry Data to Operations Department.
The procedures were adequate to track surveillances in the Laboratory Logbook. Special condition surveillances for the Instrumentation and i
Control Section were primarily associated with instrument calibra-tions after a seismic event and one associated with RCS pressure calibration after refueling. The following procedures were reviewed:
18036-C, Rev.0, Seismic Event; 50022-C, Rev. 3, Seismic Event Plan; 55039-C, Rev. O, Seismic Monitoring Instrument System; 12000-1, Rev.1, Refueling Recovery.
Items will be tracked through Operations as equipment is placed inoperable.
The Maintenance Department triggered all of their special condition surveillances through the planning and work order programs and did not have a log to keep
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track of active surveillances; however, procedure 20051-C, Rev. O, Maintenance Work Order Functional Tests, itemized surveillances to be triggered after certain maintenance items.
This was deemed adequate.
IFI 424/86-117-29 is closed.
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(Closed) Inspector Followup Item 424/86-117-30.
Control on the Location of the B0P Operator.
The inspector reviewed procedure 10000-C, Rev. 3, which had been revised to state that the balance of plant operator normally remains in the control room.
IFI 424/86-117-30 is closed.
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ff. (0 pen) Inspector Followup Item 424/86-117-31.
Key Control.
On December 11, 1986, during the walk through of the reactor coolant pump loop 1F-416 procedure, 24790-1, the inspector had observed that the technician needed to go to the shif t clerk's office three times to obtain the keys needed to open the reactor solid state protection system (SSPS) cabinets to perform the surveillance procedure.
In a letter dated January 13, 1987, which referenced a memorandum dated January 8, 1987, the licensee stated that the control of keys to all panels and cabinets which require operator
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access would be reviewed and validated. The memorandum stated that a
new key control cabinet had been added, that an up-to-date list of keys had been completed and that the cabinet keys would be validated by February 6, 1987. By memorandum dated January 15, 1987, a copy of which was provided to the inspectors, the licensee stated that the cabinet key controls would be in place by February 21, 1987.
The inspectors agreed that this date was acceptable. The memorandum also
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stated in regard to locked doors inside the power block, that these
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doors would routinely be left unlocked, except vital area doors, remote shutdown panel doors, essential 4160V AC switchgear room doors and high radiation area doors.
Due to the types of locks on some of the interior doors, the licensee stated that certain locks would have to replaced to allow the doors to be left unlocked.
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The licensee stated that the locks would be replaced by April 1, l
1987.
IFI 424/86-117-31 will remain open until these actions are verified.
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(Closed) Inspector Followup Item 424/86-117-32. Technical Specifica-tion Change to Reflect 18 Month Surveillance of Under Voltage and Shunt Trip Coils on Reactor Trip Breaker. The final TS draft did not specify testing of the reactor trip breaker undervoltage (UV) and shunt coils.
Generic letter 83-28 required this testing to be performed with an 18 month frequency, as a minimum.
The inspector verified that procedure 14701-1, Rev. 3, had been changed tn incorporate these items to test the reactor trip breakers unde -
voltage and shunt trip.
IFI 424/86-117-32 is closed.
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(0 pen) Inspector Followup Item 424/86-117-33.
Miscellaneous Technical Issues Identified in Review of Operations Procedures.
This IFI included examples of various technical concerns identified during the review of operations procedures. Each concern is identi-
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fied separately below by the paragraph number in Inspection Report 424/86-117.
Paragraph 6.b.6.
Two alarm panels were not displayed above the i
CCW operating switches in the control room as required by 18020-1 and ARP 17002-1.
The inspector verified that the licensee had taken action to correct these discrepancies.
This portion of IFI 424/86-117-33 is closed.
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Paragraph 6.b.7.
In procedure 18003-1 the following coments 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 2.2.11.3.
The seal injection flow shown on Figure 1 showed six to eight 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 block.
The inspector verified that procedure 18004-1, Rev. 2, corrected the:e items. This portion of IFI 424/86-117-33 is closed.
Paragraph 6.b.9.
The inspector had identified concerns in that procedure 13610-1 did not contain provisions for monitoring and responding to adverse bearing oil temperatures for all three AFW pumps and did not implement provisions for positioning and aligning the turbine driven AFW pump overspeed test switch (HS-15130) and speed control potentiometer.
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 the concern.
Procedure 11882-1, Outside Areas Round Sheets, did 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 reservoir.
The inspector verified that all of the issues had been satisfactorily addressed by the licensee except one.
Gland seal leakage from the turbine driven AFW purrp has not been dispositioned yet.
IFI 424/86-117-33 remains open to follow the corrective action on the gland seal leakage.
Paragraph 6.b.10.
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.
The inspector verified that the procedure had been revised.
This portion of IFI 424/86-117-33 is closed.
Paragraph 6.b.11.
Steps 2.2.1 and 2.2.2 in procedure 13120-1 did not list the applicable TS modes.
The inspector verified that the procedure was revised. This portion of IFI 424/86-117-33 is closed.
Paragraph 6.c.
The concern involved limiting excessive overtime for personnel performing safety related functions.
Limiting exces-sive overtime is addressed by TMI Action Item I.A.1.3.
Procedure l
00005-C, Rev. 2, Overtime Authorization, now includes the requirement I
of TS 6.2.2.e that overtime should not be routinely scheduled for l
personnel responsible for performing safety-related functions.
Procedure 10000-C, which applies to Operations personnel, also had been revised to state that overtime should not be routinely scheduled.
This portion of IFI 424/86-117-33 is closed.
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(0 pen) Inspector Followup Item 424/87-01-02.
Acceptance Criteria Reviews.
The IFI involved the review of the licensee's procedures to assure that adequate administrative controls exist for review of acceptance criteria and determination that the acceptance criteria are met. This item is discussed in paragraph 7.a.8 of this report.
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(Closed) Inspector Followup Item 424/87-01-03.
Implementation of Controls to Assure Adequate MW0s and Assignment of Appropriate Functional Testing.
The inspector had determined that a MWO did not designate the functional testing to be performed.
In addition, the inspector noted that QA audits indicated recurring problems in the adequacy of MWO instructions and designation of functional tests.
The inspector reviewed the corrective action taken by the licensee.
This review is described in paragraph 8.c. of this report.
IFI 424/87-01-03 is closed.
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(0 pen) Inspector Followup Item 424/87-01-04.
Resolution of Concerns on the Seismic and Environmental Qualification (EQ) of Radiation Monitors. This IFI is discussed in paragraph 7.b.1 of this report.
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(Closed) Inspector Followup Item 424/87-01-05.
Review of Temporary Modifications.
This IFI is closed as discussed in paragraph 9.
The IFI number will remain assigned to allow tracking of the item.
mm.
(0 pen) Inspector Followup Item 424/87-01-06.
Miscellaneous Findings on Surveillance and Maintenance Procedure Implementation.
The concerns, which are discussed in paragraph 7.b.3 of this report included equipment mislabeling and an inadequate lighting safety concern.
The items were determined to be isolated cases and have been corrected by the licensee. After obtaining additional informa-tion from the licensee, the fire doors and a wire radius bend concern were determined not to be issues.
Therefore, with the exception of one item, discussed in paragraph 7.b.3, IFI 424/87-01-06 is closed, nn.
(Closed) Inspector Followup Item 424/87-01-07.
Reference of Nonexistent Setpoint Document in Control Room ARP's.
Control Room ARP's were found to reference a Master Setpoint Document that was used in lieu of giving the actual setpoint.
No one in either the Control Room or the operations department could produce or describe the document.
The licensee provided revised procedures for the following ARPs that had previously been noted as deficient.
The procedures no longer referenced the Master Setpoint Document.
The procedures reviewed were 17001-1, Rev. 5; 17013-1, Rev. 3; 17014-1, Rev. 3; 17015-1, Rev. 2; 17016-1, Rev. 2; 17017-1, Rev.1; and, 17020-1, Rev. 3.
The inspector found that the revised procedures were incorporated into the control room copies.
The inspector determined that the ARP's in the control room no longer referenced the document.
IFI 424/87-01-07 is considered closed.
oo.
(Closed) Inspector Followup Item 424/86-60-10.
Shift Relief and Turnover. The item is discussed in paragraph 10.b.