IR 05000424/1998002

Insp Repts 50-424/98-02 & 50-425/98-02 on 980125-0307. Violations Noted.Major Areas Inspected:Operations,Maint & Engineering

ML20216J675
Person / Time
Site:	Vogtle
Issue date:	04/02/1998
From:	Skinner P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20216J640	List: IR 05000424/1998002 ML20216J635 ML20216J661
References
50-424-98-02, 50-424-98-2, 50-425-98-02, 50-425-98-2, NUDOCS 9804210453
Download: ML20216J675 (16)

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U. S. NUCLEAR REGULATORY COMMISSION (NRC)

REGION II

Docket No and 50-425 License No NPF-68 and NPF-81 Report No: 50-424/98-02. 50-425/98-02 Licensee: Southern Nuclear Operating Company. In Facility: Vogtle Electric Generating Plant (VEGP) Units 1 and 2 Location: 7821 River Road Waynesboro. GA 30830 Dates: January 25, 1998 through March 7. 1998 i

Inspectors: J. Zeiler. Senior Resident Inspector K. O'Donohue. Resident Inspector M. Widmann. Resident Inspector l Approved by: P. Skinner. Chief l Reactor Projects Branch 2 Division of Reactor Projects l

Enclosure 2 9004210453 900402 PDR ADOCK 05000424 .

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EXECUTIVE SUMMARY Vogtle Electric Generating Plant Units 1 and 2 NRC Inspection Report 50-424/98-02. 50-425/98-02 This integrated inspection included aspects of licensee operation engineering. maintenance, arid plant support. The report covers a 6-week period of resident inspectio Doerations

. A Violation was identified for the failure to enter a Limiting Condition for Operation (LCO) for the Control Room Emergency Filtration System (CREFS) which was rendered inoperable by scheduled heater maintenanc Operations personnel failed to fully understand the CREFS design and the impact that the maintenance activity had on system operability prior to authorizing the work (Section 02.1).

. The operators properly responded to a voltage transient on Channel 1 125 Volt AC vital instrument panel. Abnormal operating procedures were entered and properly followed. The inspectors noted that abnormal operating procedures did not contain restoration steps to control equipment re-configuration following entry and exit from these procedures; however, the licensee was already in the process of addressing this issue (Section 04.1).

. A review of the interim World Association of Nuclear Operators annual assessment of site activities conducted in November 1997 indicated that the issues identi'ied were consistent with NRC perceptions of licensee performance (Sect an 08.1).

Maintenance e Maintenance and surveillance activities were generally completed by ,

personnel that were knowledgeable of the assigned task, Procedures were l present at the work location and being followed. Procedures provided '

sufficient detail and guidance for the intended activities (Section M and M1.2).

. A Non-Cited Violation (NCV) with two examples, was identified for the failure to properly test the turbine trip and Feedwater Isolation signal from the Solid State Protection System circuits. as well as the core exit temperature indication signals to the remote shutdown Janel The licensee's identification of the failure to properly test t1e core exit temperature signal was an example of good attention to detail and questioning attitude on the part of Instrument and Control Technicians (Section M8.1 and M8.2).  !

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. A system engineer demonstrated effective review of a work activity involving his area of responsibility by identifying a case where a Deficiency Card (DC) was not initiated for a breaker failure. A DC was subsequently initiated, but did not initially address several issues associated with the breaker failure (Section E3.1).

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Reoort Details

!; ' Summary of Plant Status Unit-1 The unit operated at full power throughout the inspection perio Unit 2

, The unit operated at full power until February 13.-1998, at which time the licensee commenced a coast down for the sixth refueling outage (2R6). At 5:00 a.m., on March 7. 1998, a shutdr e to begin 2R6 was commenced from 82 3ercent power. The unit completed 500 uays of continuous operation prior to t1e planned shutdown. At the end of the inspection period. the licensee was in the process of entering Mode 2 on the unit, i r Operations l

Ol' Conduct of Operations u

01.1 General Comments (71707)

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L The inspectors conducted frequent reviews of ongoing plant operations.

L In general, the reviews indicated that the conduct of operations was 3 l .

professional and.. safety-consciou Operational Status of Facilities and Equipment 02-.1 Missed Entry Into Aoolicable Limitina Condition for Ooeration (LCO) for

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-[ontrol Room Emeraency Filtration System (CREFS)-

l l- Insoection Scone (71707)

The inspectors reviewed the licensee's identification that maintenance had been performed on the Unit 2 CREFS train B heater control panel without operations entering the applicable LC Observations and Findinas On February 19. 1998, at approximately 2:00 p.m. the Unit 2 Shift Supervisor (USS) authorized Maintenance Work Order (MWO) 29703253 to  !

replace the Silicon-Controlled Rectifier (SCR) number 6 on the heater j control panel of the train B CREFS. This work re '

de-energized, rendering train B CREFS inoperable-, quired requiring entrythe heater to be

~into LC0 3.7.10." Control Room Filtration System - Both Units Operating."

However, operations personnel did not recognize that an LCO entry was missed until February 20. after completion of surveillance procedure j 54054-2. " Control Room Emergency Ventilation System Performance Test 2- ;

1531-N7-001-Train A. 2-1531-N7-002 Train B." Revision (Rev.) 7, which i functionally tested the heaters. The on-shift USS then documented the applicable LCO entry and exit and generated a Deficiency Card (DC). A Enclosure 2 i

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review of the.USS. control room log by the licensee concluded that no loss of safety. function existed during the time the CREFS train B unit was inoperabl The inspectors review of this issue identified several factors that contributed to the cause of the missed LCO entry. In discussions with the USS on shift February 19. 1998, the inspectors learned that the USS was not aware'of the heater KW output requirements listed in Technical S7ecification (TS) 5.5.11. " Ventilation Filter Testing Program," and that removal of one SCR would make the entire CREFS unit inoperabl Another factor was the use of the risk assessment summary sheet that was issued daily..'As aart of their normal duties. the USS reviewed the summary sheet whic1 included a list of work items and other special attention items that hed associated LCO entries. There was no LCO entry indicated for the CREFS unit. The inspectors learned that not all LCO entries were listed or the summary sheet unless the system was considered to be a risk significant . system. In accordance.with the-Maintenance Rule Scoping Manual, the CREFS unit was not considered to be risk significant. However, the USS relied on the risk assessment summary sheet to help determine if an LC0 entry was necessar The inspectors interviewed the individual that planned the work schedule and concluded that he had not recognized that replacement of one SCR would render the CREFS unit inoperable'. Additional items which contributed to the missed LC0 included the following: 1) a default "No" in the MWO 3ackage for the necessity of a clearance or an LCO entry indicated.tlat a review had been performed and the CREFS would not be inoperable: 2) although the work activity was discussed in the Plan of the Day (P0D). meeting, it was not recognized by operations or maintenance representatives that an LCO was required; and. 3) the work-activity description contained in the MWO package indicated that a "SCR v Card" was to be replaced. The SCR was a module and the use of a more detailed description of the activity may have resulted in further review for the need of a clearance. Another contributor identified by the

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inspectors was that no engineering representative attended the POD L meeting or reviewed the MWO 3rior to it being authorized, although the system engineer understood tlat the work would make the system i inoperable.

o l TS 5.4.1.a requires that written procedures be implemented for the activities identified in Appendix A of RG 1.33. Rev. 2. including procedures for making TS LCO log entries. The inspectors concluded that the failure of the USS to enter TS LC0 3.7.10 and complete the LCO log sheet for a condition that extended beyond one shift was contrary to the requirements of procedure 10008-C. " Recording Limiting Conditions For Operation." Rev. 20. This is identified as Violation (VIO) 50-425/98-02-01. " Failure to Follow Procedure for Documenting LCO Entry on Unit 2 CREFS."

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l' Conclusions-The inspectors concluded that the USS did not fully understand the CREFS-p system design, nor the impact that the maintenance activity had with respect to system operability, prior to work authorizatio The failure to properly document entry into TS LC0 3.7.10 for maintenance that rendered CREFS train B inoperable was contrary to procedural requirements and was . identified' as a violatio ' Operations Procedures and Documentation 03.1 : Failure to Provide Annunciator Resoonse Procedures-for Heat Trace Panels Inspection Scooe (71707)

The inspectors reviewed annunciator response procedures for heat trace annunciator panels in the control room and DC 119980055 which addressed a pulled annunciator card from control room Heat Trace Annunciator Panel 2-1817-U3-007 ' Observations and Findinas On February 8.- 1998, operations personnel were investigating an alarm on control room Heat Trace Annunciator Panel 2-1817-U3-0078. When operations personnel reviewed the Unit 1 heat trace annunciator panel for comparison, it was discovered that an annunciator card was pulled for annunciator window 1-1817-U3-009/010. This annunciator window was

. associated with heat tracing-for-the train B Nuclear Service Cooling

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' Water (NSCW) system cooling tower piping. A work request sticker, dated

' January 30. 1998, was attached to the annunciator window indicating that the alarm was intermittent: however, the annunciator card was not'

documented as pulled as required by procedure 10018-C. " Annunciator Control." Rev. 14. The annunciator card was reinserted and the alarm was returned to servic The inspectors determined that the annunciator card had been pulled when the January 30. 1998, work request was written. At that time, operations personnel had 3erformed an initial investigation into the annunciator alarming at t1e local heat trace control 3anels 1-1817-U3- ,

009 and 1-1817-U3-010. but were unable to determine t1e cause of the !

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alarm. The operators left the annunciator card pulled and did not !

. initiate any compensatory actions because there was no annunciator i response procedure. Development of annunciator response procedures for Unit 1 and Unit 2 control room heat trace annunciator panels had been

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Engineering evaluations indicated that the NSCW piping could freeze over l an eight hour period with the-temperature.below 40 degrees Fahrenheit-(F). The system engineer verified temperatures at the B train NSCW f~ Enclosure 2

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cooling tower remained greater than 40 degrees F during the Jeriod that the annunciator was inoperable. Because the conditions for leat trace protected systems to freeze were not present, the safety significance of the issue was minima Technical Specifications 5.4.1.a requires that written procedures be implemented for the activities identified in Appendix A of Regulatory Guide (RG) 1.33. Rev. 2. RG 1.33 requires that control room alarm response procedures be implemente No alarm response procedure was developed for Unit 1 or Unit 2 control room heat tracing annunciator panels. Lack of annunciator alarm response procedures is a violation of TS 5.4.1.a. This failure constitutes a violation of minor significance and, consistent with Section IV of the NRC Enforcement Policy is identified as Non-Cited Violation (NCV) 50-424/98-02-02. " Failure To Provide Annunciator Alarm Response Procedures for Control Room Heat Trace Panels." Conclusions The heat trace annunciator panels were not equipped with annunciator response procedures to provide the required guidance. The inspectors concluded that the lack of an annunciator response procedure contributed to inadequate control of the annunciator panel conditio Operator Knowledge and Performance 04.1 Unit 1 Vital Instrument Channel Voltaae Transient Insoection Scone (71707)

The inspectors reviewed the operator response to a voltage transient on the Channel 1 120 Volt AC vital instrument pane !

i Observations and Findinas On February 4.1998, at approximately 3:23 a.m.. the Unit 1 control room operators received several alarms indicating trouble with Channel 1 120 l Volt AC vital instrument power panel 1AY1A. Voltage dropped several l times on the power panel and then stabilized. The voltage fluctuation l caused the pressurizer Power-Operated Relief Valve (PORV) to cycle.

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reducing reactor coolant system pressure about 50 pounds per square inch (psig). The control rods inserted 12 steps before the operators transferred the rod control system to manual. The operators entered Abnormal Operating Procedure (AOP) 18032-1. " Loss of 120V AC Instrument Power." Rev. 1 While investigating the source of the transient. the licensee discovered the 26 Volt AC primary power supply to the Channel 1. 7300 process protection cabinet had experienced a fault and the backup 7300 process power supply automatically picked up. The licensee replaced the primary Enclosure 2

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power supply automatically Jicked up. The licensee replaced the primary 7300 process power supply t1e following day. The licensee was continuing to evaluate the breaker and fuse coordination of the 7300 process equipment and Channel 1 vital instrument pane During review of this incident, the inspectors noted that AOP 18032-1 did not provide restoration steps for realigning equipment following A0P exit nor were control room operator log entries made to document equipment re-configuration. The inspectors verified that equipment and switches manipulated per A0P 18032-1 were properly re-configured once the operators exited the AOP. The inspectors were informed that the licensee was in the process of enhancing all A0Ps to add appropriate restoration step Conclusions The inspectors determined that the operators properly responded to a j voltage transient on Channel 1 125 Volt AC vital instrument pane i Abnormal operating procedures were entered and properly followed. The inspectors noted that abnormal operating procedures did not contain restoration ste)s to control equipment re-configuration following entry and exit from t1ese procedure Miscellaneous Operations Issues (71707)

08.1 World Association of Nuclear Ooerators (WANO) Assessment The inspectors reviewed the interim report of the WANO annual assessment of site activities conducted in November 199 The inspectors found that issues identified were consistent with the NRC perceptions of licensee performance. No safety significant issues that required immediate attention were identifie .2 (Closed) Licensee Event Report (LER) 50-424/97-011: " Procedure Discrepancy Results in Doeration Outside of Technical SDecification Conditions." The details of this incident were previously reviewed and documented in NRC Inspection Reoort 50-424. 425/97-10. The inspectors reviewed procedure 12002-C. Unit icatup to Normal Operating Temperature and Pressure (Mode 4 to Mode 3). Rev. 35- The procedure had been revised to require closure of the subject hot ies isolation valves prior to reaching 375 degrees F in Mode In addition. during recualification training. licensed operators were briefed on the event anc need to properly reference TS and bases document Enclosure i

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I Maintenance M1 Conduct of Maintenance M1.1 Maintenance Work Order Observations Insoection-Scooe (62707)

The inspectors observed portions of maintenance activitiies involving the following MW0s:

19701743 Preventative Maintenance on Component Cooling Water Pump #6 19702551 Lubricate Shuttle Valve on loop 4 Bypass _ Feedwater Isolation Valve 1-HV-15196 19800403 Isophase Bus Duct Cooling Fan Belt Replacement on 1-1802-E4-M01 19800414 Change Out Pressure Gauge and Tubing Motor Driven Auxiliary feedwater Train B 29703336 Solid State Protection System (SSPS) and Integrated Plant Computer Demultiplexer Power Sup)ly Measurements-29800614 . Troubleshoot Loop 4 Atmospheric Relief Valve 2-PSV-3030 Observations and Findinas

' Maintenance personnel were knowledgeable of their assigned task procedures were present at the work location and being followed. The-procedures provided sufficient detail and guidance for the intended maintenance activities.

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l The inspectors concluded that routine and corrective maintenance L activities were performed satisfactorily.

l: M1.2 Surveillance Observation Insoection Scone (61726)

The inspectors observed the performance or reviewed the following surveillance and plant procedures:

14421-2 Solid State _ Protection System (SSPS) and Reactor Trip Breaker Train B 0)erability Test. Rev. 8 14629-1- SSPS Slave Relay (623 Train B Test Containment Isolatio Rev. 7 14659-1 SSPS Slave. Relay K740 and K741 Train B Test Semi-Automatic Switch-Over to Containment Sum). Rev. 6 14980-2 Diesel Generator Train B Opera)ility Test. Rev. 29 14644-2 SSPS Slave Relay K 643 Train A Test Containment Spray, Re Enclosure 2 J

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28210-C Main Steamline Code Safety Valve Setpoint Maintenance. Re C Flow Testing of Safety Related NSCW System Coolers. Rev.14 84201-2 Containment Spray System Leakage Assessment. Rev. 5 Observations and Findinas On February 9, 1998, the inspectors observed the performance of Unit 2 Containment Spray (CS) System surveillance 14644-2. 84201-2. and 83308-C. These activities were planned to be performed in 3arallel. This planning allowed for portions of one surveillance to 3e performed with a transition point identified for the performer to transfer to another surveillance then back to the first until all applicable steps were completed. During the performance of the surveillance. Unit 2 Train A CS pump failed to start due to a test circuit interlock that was not identified during the planning of the scheduled activities. Although shift personnel reviewed the surveillance to establish the sequence of procedure step performance, not all of the required sup) ort documentation was available to the shift personnel at tlat time. Prior to starting the activities, due to a scheduling conflict with maintenance personnel, an additional review resulted in a new sequence for the procedure steps. As a result of the sequence changes, the Train 3 A CS pump failed to start. The step sequence was redefined and the l surveillances were completed successfully. This issue will be i identified as Inspector Followup Item (IFI) 50-424.425/98-02-03. " Review I of Surveillance Procedure Sequencing." Conclusions The observed surveillance activities were generally comaleted by personnel that were knowledgeable of their assigned tascs. Procedures j present at the work location provided sufficient detail and guidance for i the intended surveillance activitie i l

M8 Miscellaneous Maintenance Issues (62707)'(92700) (92902) (92903) l M (Closed) LER 50-424. 425/98-002: " Solid State Protection System Testina Inadeauate." On November 14. 1997, the licensee determined that surveillance procedures 14420-1/2 and 14421-1/2 did not adequately test the turbine trip and feedwater isolation (FWI) signals generated from a safety injection. P-14 steam generator high-high level, and P-10 source '

range automatic block. As such, the surveillance requirements of TS 3.3.2. " Engineered Safety feature Actuation System Instrumentation."

Table 3.3.2-1. Function 5. for a turbine trip and FWI were not fully met. The licensee revised the surveillance procedures and successfully completed tests of the SSPS logic circuits without inciden ;

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The licensee determined that the root cause was an inadequate test design and deficient test procedures written prior to initial startup of the plant. Based on a review of the root cause determination, the inspectors * agreed with the. licensee's conclusion During the ins)ector's review. a minor concern was raised with respect to the reporta]ility timelines The inadequate testing of the SSPS circuits was originally identified on November 14, 1997, but the licensee did not determine until January 26, 1998, that this issue was reportable. The licensee attributed the delay to insufficient information available from Westinghouse on the details of the circuit and its impact on the surveillance test )

q The inspectors concluded that the failure to properly test the turbine trip ~and FWI signal from the SSPS circuits re] resented an inadequately )

Jerformed surveillance tests. Consistent witl Section VII of the Enforcement Policy, this licensee-identified and corrected violation was identified as an example of NCV 50-424. 425/98-02-04. " Failure to Properly Perform Surveillance Testing - Two Examples." J

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M8.2 (Closed) LER 50-424. 425/98-003: " Core Exit Temoerature Indicator l Surveillance Testina Inadeauate." On January 28, 1998, during performance of calibration procedure 24520-2. the licensee determined that the circuit board that provides signals for both neutron flux monitoring and core exit temperature indicators did not respond as expected. Further investigation determined that the surveillance l procedure did not test the core exit temperature 4-20 milliamp signal i from a Database Processing Unit (DPU) to the indicator located at the shutdown panel. TS Surveillance Requirement 3.3.4.3. " Remote Shutdown System - Channel Calibration." requires.that the entire circuit be tested every 18 months. As a result, the licensee revised the channel I

calibration procedures and successfully completed testing of the Unit 1 and Unit 2 temperature indicator circuit The licensee attributed the cause of the inadequate surveillance testing i to an improperly scoped test that resulted in an inadequate test i procedure. These procedures were written prior to initial plar>t

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startup. The licensee's corrective action which included revision of l the channel calibration procedures, addressed this issu l

The inspectors concluded that the failure to properly test the signal from the DPU to the temperature indicators located at the remte  !

shutdown panels represented an inadequate surveillance test. Consistent .

with Section VII of the Enforcement Policy, this licensee-identified )

and corrected violation was identified as an example of NCV 50-42 /98-02-04. " Failure to Properly Perform Surveillance Testing - Two Examples . " The inspectors also concluded that the identification of this missed surveillance was a good example of attention to detail and a questioning attitude by Instrument and Control Technician Enclosure 2

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M8.3 (Closed) LER 50-424/97-010: " Manual Reactor Trio Durina Rod Droo Startuo Testina." This LER was of minimal safety significance and is close II Enaineerina E3 Engineering Procedures and Documentation E3.1 Weaknesses in Breaker Failure Evaluation and Documentation Insoection Scooe (375511 The inspectors reviewed DC 1-97-753 involving the failure of Unit 1 breaker 1BA0304 (feeder breaker to Train B safety-related 480V switchgear 1BB07) to close properly. Additionally the inspectors reviewed the breaker repair documentation, discussed the breaker failure and root cause with engineering and maintenance personnel, and reviewed breaker electrical drawing Observations and Findinas- I The DC indicated that breaker 1BA0304 had failed to close properly during Engineered Safety Features Actuation System (ESFAS) testing conducted October 9. 1997. Troubleshooting performed under MWO 19703138 identified binding in the breaker control device. The control device was replaced and the breaker was successfully tested and then returned to service. A DC was initiated on November 18. 1997, after the system engineer reviewed the MWO package and recognized that a DC had not been written to address the_ equipment failure. As part of the evaluation for the DC. a root cause evaluation was performed. The root cause was ]

attributed to binding of the limit switch. crank lever on the control device due to worn and dirty springs. This prevented the breaker from closing on demand. The licensee determined that the failure was a .

functional failure, but did not meet the maintenance rule classification l of a maintenance' preventable functional failure (MPFF). This was based i on the breaker overhaul conducted every 10 years by the breaker vendor l which includes disassembly of the breaker control device and spring i replacement as determined necessary. The licensee revised preventative i-maintenance procedures for breaker inspections to include a check of the '

limit switch crank lever freedom of movemen The inspectors identified several issues associated with the breaker i failure that were not addressed by the DC. The inspectors discussed ;

these issues with the licensee engineering and management aersonne . Subsequently. the licensee contacted the vendor about the areaker failure. The vendor agreed with the licensee's root cause result !

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Additionally, the vendor confirmed that the 10 year overhauls would identify potential control device binding. :The inspectors concluded that these issues did not change the root cause results and effectiveness of the licensee's corrective action Conclusions A system engineer demonstrated effective review of a work activity involving his area of responsibility by identifying a case where a DC was not initiated for a breaker failure. A DC was subsequently initiated. but.did not initially address several issues associated with the breaker failur I Plant Support 1 R1: Radiological Protection and Chemistry (RP&C) Controls R1'.1 General Comments (71750)

The inspectors periodically toured the Radiological Control Area (RCA)

during the inspection period. The inspectors concluded that radiation control practices were prope S1 Conduct of Security and Safeguards Activities S1.1 General Comments-(71750)

During the inspection period, the inspectors toured the protected area j-and noted that the perimeter fence was intact and not compromised by erosion nor disrepair. Isolation zones were maintained on both sides of the barrier and were free of objects which could shield or conceal an -

l individual. The inspectors periodically observed personnel. packages, and vehicles entering the protected area and verified that necessary searches, visitor escorting..and special Jurpose detectors were used as applicable prior to entr Lighting of t1e perimeter and of the protected area was acceptabl Manaaement Meetinas and Other Areas X- Review of Updated Final Safety Analysis Report A recent discovery of a licensee o)erating its facility in a manner contrary to the UFSAR description lighlighted the need for a special focused review that compares plant practices. procedures and/or parameters to the UFSAR descriptions. While performing the inspections Enclosure 2

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11 l discussed in this resort, the inspectors reviewed the applicable portions of the UFSAR that related to the areas inspected. The inspectors verified that the UFSAR wording was consistent with the observed plant practices, procedures and/or parameter X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at tie conclusion of the inspection on March 13. 1998. The licensee acknowledged the findings presente PARTIAL LIST OF PERSONS CONTACTED Licensee J. Beasley, Nuclear Plant General Manager S, Chestnut. Manager, Operations G. Fredrick, Plant Support Assistant General Manager J. Gasser, Plant Operations Assistant General Manager K. Holmes, Manager, Maintenance M. Sheibani Nuclear Safety and Compliance Supervisor C. Tippins. Jr., Nuclear Specialist I INSPECTION PROCEDURES USED IP 37551: Onsite Engineering IP 61726: Surveillance Observation IP 62707: Maintenance Observation IP 71707: Plant Operations IP 71750: Plant Support Activities IP 92700: Onsite Followup of Written Reports of Nonroutine Events at Power Reactor Facilities IP 92901: Followup - Operations

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IP 92903: Followup - Engineering ITEMS OPENED AND CLOSED Opened Tvoe Item Number Descriotion and Reference VIO 50-425/98-02-01 Failure to Follow Procedure for Documenting LCO Entry on Unit 2 CREFS (Section 02.1)

IFI 50-424. 425/98-02-03 Review of Surveillance Procedure Sequencing (Section M1.2)

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l Closed lyng item Number Descriotion and Reference i

l NCV 50-425/98-02-02 Failure To Provide Annunciator Alarm Response l Procedures and Failure to Follow Annunciator

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Disabling Procedure (Section 03.1)

LER 50-424/97-011 Procedure Discrepancy Results in Operation l Outside of Technical Specification Conditions (Section 08.2)

NCV 50-424, 425/98-02-04 Failure to Properly Perform Surveillance Testing

- Two Examples (Sections M8.1 and M8.2)

LER 50-424, 425/98-002 Solid State Protection System Testing Inadequate (Section M8.1)

LER 50-424.-425/98-003 Core Exit Temperature Indicator Surveillance Testing Inadequate (Section M8.2)

LER 50-424/97-010 Manual Reactor Trip During Rod Drop Startup Testing (Section M8.3)

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