IR 05000445/1989057
| ML20246H521 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/25/1989 |
| From: | Burris S, Joel Wiebe Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20246H509 | List: |
| References | |
| 50-445-89-57, 50-446-89-57, NUDOCS 8909010276 | |
| Download: ML20246H521 (57) | |
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I APPENDIX B U. S. NUCLEAR REGULATORY COMMISSION l
l OFFICE OF NUCLEAR REACTOR REGULATION l
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NRC Inspection Report: 50-445/89-57 Permits: CPPR-126 50-446/89-57 CPPR-127 l Dockets: 50-445 Construction Permit 50-446 Expiration Date:
Unit 1: August 1,.1991 Unit 2: August 1, 1992 Applicant: TU Electric Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name: Comanche Peak Steam Electric Station (CPSES),
Units 1 and 2 Inspection At: Comanche Peak Site, Glen Rose, Texas Inspection Conducted: July 17 through July 28, 1989 Team Leader: $. TvA 1. P. SWMIT Bj2.5-lB9 P. Burris, Team Leader Date Team Members: S. D. Bitter R. J. Evans D. T. Nelson R. B. Vickery Reviewed by: A Ii
/ Dale
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. T. Wiebe, Senior Project Inspector 8?O9010276 890828 FDR ADOCK 05000445 O FDC
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Inspection Summary Inspection Conducted: July 17 through July 28, 1989 (Report 50-445/89-57; 50-446/89-57)
Areas Inspected: An announced inspection of the controls and implementation of operations and maintenance procedures for Unit Results: Within the areas inspected, the team noted that a significant number of procedures, both administrative and technical, contained large numbers of errors. During the inspection, one violation involving the applicant's failure to control in-process documents (paragraph 8), and one unresolved item involving the discrepancies between Station Administration Manual and other administrative procedures (paragraph 9), were identifie i
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l-DETAILS (.
l Persons Contacted
- M. Blevins, Nuclear. Operations, TU Electric
- H. Bruner, Senior Vice President, TU Electric
, *W. Cahill, Jr., Vice President, TU Electric l
- J. Donahue, Manager, Operations, TU Electric
- D. Ehat, Bentham Corporation
- R. Flores, Operations, TU Electric
- W. Guldemond, Licensing, TU Electric
- J. Hicks, Licensing, TU Electric
- J. Kelley, Plant Manager, TU Electric
- D. Kross, Operations, TU Electric
- J. Laughlin, Instrumentation & Control (I&C)
- A. Scott, Vice President, Nuclear Operations, TU Electric
- W. Sly, Assistant-IC Manager, TU Electric
- J. Smith, Plant Operations Staff, TU Electric
- M. Steelman, Licensing, TU Electric
- N. Terrel, Operations, TU Electric
- M. Thero, CASE
- 0. Thero, CASE
- B. Wieland, Maintenance Manager, TU Electric The NRC inspectors also interviewed other applicant employees during this inspection perio * Denotes personnel present at the July 27, 1989, exit intervie . Introduction and Summary (42400, 42450, 42451)
Background During the relicensing phase of a near term operating plant (NTOL), the NRC conducts operational readiness inspections to determine the applicant's readiness for safe operation of the power plant. One of these inspections is the review of the applicant's established administrative program for generation, implementation, and control of plant operating procedures. In preparation for this inspection, the inspectors obtained from the applicant a list of all approved procedures currently in use by the Operations departments on site. The applicant provided the current Master Procedure Index, effective date of June 1, 1989, which contained a listing of all currently approved procedures. During the course of the inspection, the team noted two approved procedures which were not on the
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Master Procedure Index. The inspectors identified this discrepancy to the applican !
HThe applicant's commitments as outlined in their ~
Administrative Procedures program are broken down into a tiered document control format which incorporates the applicabltr Regulatory Requirements and Industry Codes and Standards in the following documents (ranked in their order of authority).
. Final Safety Analysis Report (FSAR) and other Commitment . Nuclear Engineering and Operations Policies and Procedure . Station Administrative Manua . Operations Department Manua . Departmental Instructions and Procedure Methodology The Procedure Review Team (PRT) based its inspection on che criteria outlined in NRC Manual Chapters 42400 (Plant Procedures Inspection), 42450 (Operating Procedures Inspection), and 42451-(Maintenance Procedure Inspection).
Each area was inspected using the following guidanc . Inspection Objective To confirm that the scope of the plant procedures system is adequate to control safety-related operations within applicable regulatory requirement To determine the adequacy of management controls in implementing and maintaining a viable procedure syste . Inspection Method The inspectors verified that administrative controls have been established for the review, approval, and periodic updating of the following categories of procedures:
Administrativ General Plant Operatio Startup, Operation, and Shutdown of Safety-Related System Correcting Abnormal, Off-normal or Alarm Conditions.
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Combating Emergencies and other Significant Event Control of Measuring and Test Equipment Maintenanc Refuelin Technical Suppor .
Maintenanc The inspectors verified that responsibilities have been assigned in writing to assure that the procedures will be reviewed, updated, and approved as required (including 10 CFR 50.59 considerations).
The inspectors verified that controls have been established in writing for the following:
. Preparation of procedures including the desired format and conten . Issuing new and revised procedure . Control / disposal of outdated procedure . Controlling temporary changes to procedure . Assuring that changes to procedures will be approved by the same organization that approved the original document unless another qualified organization has been designated.
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. Assuring that the training organization is apprised of changes to procedure The inspectors verified that administrative controls provide for the preparation and correction of operating logs, shift turnover activities, and log review The inspectors selected recently issu'ad plant procedures and verified that:
. Review, approval, and updating have been accomplished in accordance with administrative control . Issue of new procedures and control of superseded procedures has been in accordance with administrative control _ _ . _ _ - - _ - - - _ - _ _ _ _ _ _ _ _ .
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-. Working copy'(control room,' shop, etc., as l
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appropriate) is the same as the current-approved l
" 1 revision in' master fil The inspectors' verified:by: interviewing several shift supervisors, that they are aware of and understand the r systems established for controlling: temporary changes to-procedures.-
The inspectors also verified that temporary or standin orders are not being used in place of procedures which j should undergo appropriate reviews and approvals., l
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Results
The'PRT selected approximately 8% (160) of the total procedure population. This percentage was based on selecting at least 10% (or minimum recommended) in each area (i.e., ABNs,' ALMS, .)
ETPs, etc.) for review. Each area inspected will be discussed )
in detail under separate paragraphs which are divided into )
subsections, and formatted as follow l
. Procedures which were reviewed - procedure number, revision number, and titl . Descriptive subsection paragrap ,
. NRC specific observations and comment Results of the inspection were discussed in detail with
' applicant management personnel in working meetings during th inspection in which a large number of specific questions were i provided to the applicant (Attachment C).- As discussed, each .]
of these questions needs to be specifically addressed.by the 4 applicant and a method developed to identify and correct: .
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similar deficiencies in procedures that were not' reviewed by .l
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the NRC. In addition to identifying these~ items, the PRT identified one violation (paragraph 8) and one unresolved item (paragraph 9).. ' Station Administrative Manual procedures and-Operations Department Administrative-Manual Procedures (42400, 42451)
The inspector reviewed selected administrative procedures to det. ermine if they were written, approved, and revised in
- accordance with regulatory requirement Procedures reviewed were as follows:
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. ODA-102, Revision 10, " Shift Conduct Responsibilities and Authorities."
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ODA-108, Revision 0, " Post Trip Review Evaluation."
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. ODA 202,. Revision 5, " Preparation of System Operating l Procedures."
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. ODA 207, Revision 2, " Guidelines for the Preparation and l
' Review of Operations Procedures."
. ODA-308, Revision 0, "LCO Tracking Log."
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. ODA-407, Revision 2, " Guidelines on Use of Procedures."
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. STA 202, Revision 17, " Administrative Control of Nuclear Operations Procedures."
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. STA 203, Revision 13, " Control of Nuclear Operations Procedure Manuals."
. STA 205, Revision 11, " Changes to Procedures."
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. STA 302, Revision 13, " Station Records."
l . STA-503, Revision 2, " Plant Incident Report."
. STA 606, Revision 9, " Work Requests and Work Orders."
. STA 707, Revision 4, " Safety Evaluations."
The following procedures were referred to in the review of Station Administrative Procedures:
. NEO-2.13, Revision 3, " Management of Nuclear Power Plant Records."
L . NEO-2.23, Revision 3, " Turnover of Nuclear Power Plant Records."
. NEO Policy Statement No. 38, " Records Management."
. RMP 1.2.1, Revision 5, " control of Intermediate Storage Areas."
. RMP 1.2.2, Revision 4, " Corrections, Changes, Enhancements, Re-Creations and Supplements to Documents / Records."
. RMP 1.3.1, Revision 8, " Record Turnover Specifications and Turnover of Records."
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These administrative procedures describe how the plant operating procedures should be written and revised. They also define those personnel responsible for ensuring the revisions are reviewed and approved as applicabl Examples of inspector observations / concerns included in Appendix C are discussed below: STA 202, Revision 7, Procedure Change Notice (PCN)
STA-202-R17-21 changes the qualification of the reviewer as defined in 4.8 of the procedure. This change removes the qualifications as, stated by ANSI 18.1. It appears that the qualifications of the reviewer have been lowered by this chang STA 205, Revision 11, PCN STA-205-R11-07 changes the definition in Part 4.13 of this procedure to read: "A review to assess the impact of a procedure change on a specific area by a knowledgeable individual who meets the requirement.of STA 202." The reason for this change as stated on the PCN was to meet Revision E of the plants Technical Specifications. However, in the administrative portion of the Technical Specifications, Revision E, Section 6.5.3.la, states, in part, that changes to procedures which do not change the intent of approved procedures may be approved for implementation by two members of the Nuclear Operations staff, at least one of ;
whom holds a Senior Operator License. From this i statement, it appears that the changes made to both STA 202 and STA 205 are not in compliance with the plant's Technical Specificatio STA 707, Revision 4, " Safety Evaluation Screening,"
PCN-707-R4-04 adds the statement to include non-Nuclear Operation department However, it was found in various changes in the procedure to read for Nuclear Operations activities only. Examples of this are found in Sections 6.2.1, 6.2.5, and 6.2. The inspector is concerned that this statement can be misinterpreted so that a safety evaluation is not performed on a revision to a procedure and, therefore have an impact on the safe operation of the plan The procedure change policy is of concern because the applicant does not have specific guidance and/or instructions that control the number of procedure changes that can be issued before the procedure is required to be revised. For example, STA-202, Revision 17 (7/21/88) had 19 changes outstanding as of June 29, 198 STA-606 has numerous changes outside the margin; furthermore, some l I
changes required the user to skip around and follow
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arrows to indicate the place where the change was entere The inspectors were informed that the applicant leaves the decision as to when to revise procedures up to 4 the individual department l In summary, the plant administrative procedures appear to be adequate. However, they contain numerous problems in change control, consistency with Technical Specifications, and consistency with applicable standards, such as ANSI 1 . Abnormal Operating Procedures (42450)
The inspector reviewed a number of randomly selected abnormal operating procedures to verify that the procedures followed the format as described in administrative procedures and that each procedure was technically adequate to accomplish its stated purpos Procedures reviewed were as follows:
. ABN 104A, Revision 2, " Residual Heat Removal System Malfunction."
. ABN 502A, Revision 0, " Component Cooling Water System Malfunction."
. ABN 703A, Revision 2, " Power Range Instrumentation Malfunction."
. ABN 710A, Revision 2, " Steam Generator Level
. instrumentation Malfunction."
. ABN 803A, Revision 0, " Response to a Fire in the Control Room or Cable Spreading Room."
. ABN 907A, Revision 1, " Acts of Nature."
The procedures describe the symptoms, automatic actions, and subsequent operator actions required to return the plant to normal operating conditions. The selected procedures followed the admird strative procedures and appear to be more than technically adequate. However, the inspectors have some concerns which are summarized below; All of the procedures reviewed had errors associated with references to the Technical Specifications of the plan In some cases the procedure refers the operator to the wrong specifications or to nonexistent Limiting Conditions for Operation (LCO). Also the reference section of these procedures refer the operators to specifications that are not applicable or do not contain the specifications as addressed in the body of the
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, ' procedure.- In some instances, the procedures do not give the~ operator;enough guidance as.to what specifications.
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apply, and the operator must rely on memory. The format 1 .for' listing'.the LCOs is'not consistent throughout the procedures. .One format should be chosen and followe ,
Examples'of the concerns in Attachment C are listed-below:
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. ABN 703A. Revision 2, " Power Range Instrumentation Malfunction," references Technical Specifications L (T.S.s) 3/4 10.3 anc 3/4 10.4 which do not seem to
, apply to this procedur LCO 3/4 2.4 is referred to.in the body of the procedure and is not listed in the Reference
Sectio . ABN.104A, Revision 2, " Residual Heat Removal System Malfunction," Step 2.4, e.7, caution statement m refers.to T.S. Figure'3.4-4, when it should apparently refer to Figure 3.4- Page 16 of 64 refers to T.S 3/4 9.3 which does not seem' applicabl . ABN 710A, Revision 2, " Steam Generator Level Instrumentation Malfunction," Step e. (page 5 of 25)
in part, reads 3/4 3.3.5 (Table 3.3-8). This should read 3/4.3.3.3 (Table 3.3-6). . ABN 907A, Revision 1, " Acts of Nature" Refers to
T.S. 3/4 3.3.3, this T.S. which does not address seismic monitorin b. . Some-procedures were very difficult to follow due to the letter designation of the specific steps in the procedure. Some procedures had so many hand-written revisions that an operator could misread a procedure.or could have difficulty in finding the-proper step to implement. This concern is exemplified by the following:
. ABN 104A, Revision 2,." Residual-Heat Removal System Malfunction," Step i.5, (page 26 of 64) states,
" proceed to Step n." . It would appear that, with this format, a page number (such as proceed to Step n, page 30 of 64) would assist the operator in finding the proper step especially when the next step is actually several pages further on in the procedure.
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Step i.6.f directs the user to go to Step j (page 27 of 64). However, it is not clear where this step is- 1
~1ocate . ABN 803A, Revision 0, " Response to a Fire in the Control Room or Cable Spreading Room." There is very poor layout / organization of the procedure on pages 14, 14.1, and 15. The large number,of changes implemented into these pages have altered the format of the procedure to such an extent that the operator is forced to jump around the procedure to perform the required steps. It appears that it would have been better to revise the procedure to incorporate these change It appears that altering a procedure to such a. great extent could constitute an intent chang The inspectors noticed that some of the procedures were incomplete. This is evidenced in those procedures that contain steps which use the term "later".in lieu of naming a-specific value or reference, etc. Specific examples of this are listed belo . ABN 104A, Revision 2, " Residual Heat Removal System Malfunction," 5.3.a, states, in part, " level is less than (later)", and Attachments 2, 3, 4, 5, and 14 (later) are not yet identifie Attachmeng 7 (page 7 of 8) Caution states, in part,
"RCS >140 F use Attachment 14 which is (later)." The inspectors noted that in one procedure, the setpoint for the reactor trip did not agree with the limiting safety system settings as specified in the Technical Specification . ABN 710A, Revision 2, " Steam Generator Level Instrumentation Malfunction," Step 2.2a. states, in part, "(Turbine Trip / Auxiliary Feedwater Actuation at 43.4% S/G 1evel)." This value (43.4%) does not agree with the setpoint (28%) of the limiting safety system setting In summary, the team determined that the applicant needs to resolve these problems in the abnormal procedures before the operators can rely on them for proper guidanc _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ - _ - _ _ - _ _ - _ _ - _ _ _ _ _ _ _ _ _ - _ - _ _ . _ - - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ - _ _ _ - _ _ - _ _ _ - _ - _
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5. System Operating Procedures f42450)
Selected system operating procedures.(SOPS).were reviewed to confirm that the procedures were prepared to adequately control safety 1 elated operations within the applicable L regulatory requirements. Each SOP was reviewed to verify they were in the appropriate format as specified in the j administrative control procedures and were technically 1 adequate to accomplish their stated purposes. The procedures j were also compared to the. general guidance of ANSI-N18.7-1976/ANS-3.2, " Administrative Controls and Quality
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Assurance for the Operational Phase of Nuclear Power Plants."
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! systems was walked down and compared to their SOPS. The walkdown was performed to ensure the procedures were capable of being performed by operators and to observe the as found system lineup and condition at the time of the inspectio The procedures reviewed included:
. SOP-201A, Revision 3, " Safety Injection System."
. SOP-204A, Revision 3, " Containment Spray System."
. SOP-304A, Revision 5, " Auxiliary Feedwater System."
. SOP-610A, Revision 2, " Diesel Generator Fuel Oil and Transfer System."
. SOP-809A, Revision 2, " Diesel Generator Rooms Ventilation Systems."
. SOP-815A, Revision 4, " Safety Chilled Water System."
A review of the administrative controls procedures for SOPS was performed. No problems or discrepancies between ANSI N18.7 requirements and the administrative control procedures were identified. However, the administrative procedures were incorrectly implemented in several SOPS as discussed below:
. Format errors were observed in several SOP SOP-201A and SOP-204A had several "When-Then" logic statements that did not meet ODA-207 requirements. SOP-204A had two steps with lL action statements, which is not allowed by ODA-20 . Lack of PCN control was noted. PCN R3-1 was not fitlly incorporated into SOP-204A. Only two of eight changes made by PCN R3-1 were actually implemented into SOP-204 A PCN to ODA-202 revised a step to allow the une of bullets in procedures. The bullets allow steps in procedures to be performed out of sequence. The actual change implemented into ODA-202 did not mention bullet The bullets being used in SOPS were not allowed by the
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wording of ODA-202, because the PCN was not correctly
. implemented into ODA-20 Guidelines on how many PCNs were allowed to be outstanding on a SOP before a revision was required did not exist. The SOPS reviewed did not have unusually high numbers of outstanding PCNs against the . Inconsistencies between administrative procedures were identified in STA-202, ODA-202, and ODA-207. ODA-202
' required the GOP-title pages to include the' site operations. review committee (SORC) meeting number and date, but that requirement was deleted from ODA-207. The title pages of SOPS reviewed did not have the SORC meeting numbers and dates. Additionally, STA-202 required SORC meeting number and dates to be added to administrative procedures, but the sample title page shown in STA-202 did not show the SORC meeting number and date blank . Lack of reference. control was observed in the control room. A licensed operator was noted to be using a draft copy of alarm response procedures when responding to inspector questions. The use of unreviewed and unapproved procedures was contrary to ANSI N18.7 and STA-202 requirements. The applicant stated that approved alarm response procedures were i'i the control room and the draft procedures were for information onl i l . Several items related to cross reference control were note For example, the performance of STA-707 (Safety Evaluations) should be more integrated into the procedure review and change process. Attachment 8.B of STA-202,
" Procedure / Form Technical Review Guidelines," should have included STA-707. Additionally, the form presents yes/no questions to the reviewer. The form should have been revised to add yes/no checkoff blanks for the reviewer as he answers the question ?. technical review of selected Unit 1 SOPS was performed. The procedures were compared to the administrative controls procedures, piping and instrument diagrams (P& ids) and Unit 1 Technical Specifications. Generally speaking, the procedures were technically correct and useable.
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had not been implemented at the time of the inspectio Additionally, numerous differences were noted to exist between P&ID representation of locked valves and the valves required to be locked per the SOP valve lineups. SOP-610A had 6 differences between the P&ID and procedure, SOP-302A had 11 differences, SOP-201A had 24, and SOP-204A (Containment Spray System) had 50 differences. The applicant stated the
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locked valve program procedure was in the process of revision, and the locked valve program was to be implemented by September 1, 198 Items noted during the technical review of the SOPS included:
. Changes made to Revision E of Technical Specifications were not incorporated into three procedures. The procedures were SOP-610A (incorrect fuel oil storage tank level), SOP-304A (incorrect condensate storage tank level), and SOP-204A'(incorrect spray additive tank volume).
. Two day tank drain valves, 1D0-410 and 411, were shown on the applicable P&ID, were located in the field, but were not listed in the SOP-610A valve lineup. Valve 1AF-236,
. secondary sample system isolation, was shown on the P&ID, was located in the field, but was not in the SOP-304A lineup. Four level gauge root valves 1CH-321, 328, 309 and 319, were shown as shut on the P&ID, but were open in the SOP-815A lineup. In SOP-304A, the identification number of the 1-PT-2476 and'2475 root valves are different in the procedure from the numbers given on the P&ID (field labelling agrees with the procedure).
. Instrument root valves shown on P&ID MI-302 were not labelled on the P&ID and were not specifically listed in Procedure SOP-809A lineup. Instrument root valves were labelled and included in valve lineups in other SOP SOP-610A had vendor supplied valves in the valve lineup, but did not have identification numbers for the valve Observations made during SOP walkdowns and plant tours included:
. Labelling of components in the precedure were compared to the as found labelling in the field. Names of components in the SOPS generally agreed with labels in the plan Labelling discrepancies observed included inconsistent use of "Hi Head" versus "CCP" and use of " Hot Shutdown Panel" versus " Remote Shutdown Panel," both in the procedure and on label .
Two conflicting alarms were energized simultaneousl The"AnyDGRMTempLow"alarmfsetpoint40 ) and "DG 1 RM Temp Hi" alarm (setpoint 122 F) were noted to both be engrgize The Train A room temperature was noted to be 96 The high temperature alarm was set at the Technical Specifications (Table 3.7-3) limit of 122 F and was energized. The alarms were pointed cut to a licensed operator for corrective action.
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. The containment spray heat exchanger aX1 drain line was noted to.haveLa moderate flow of water draining out of the drain lin Either the drain valves were leaking by or the pressure relief valve was lifting. This was pointed out to a licensed operator for corrective actio . The. Auxiliary Feedwater System (AFW) was noted not to be aligned correctly per SOP-304A. The condensate storage tank discharge valve HV-2485 power supply was of Four controllers were in auto, but were required to be in
. manual per the control switch lineup. Four other controllers were in the Auto positions. One controller-had no energized status lights, possibly' indicating a loss of power to the controller. The four AFW isolation valves were shut,-but should have been open. The AFW turbine trip and throttle valve power supply should have been off per the electrical lineup, but was found o In conclusion, the SOPS reviewed were noted to be technically correct and useable by operations personnel. The number and type of observations appear to be related to lack of attention to detail by procedure reviewers. Additionally, changes being ,
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made in the plant were not being incorporated into P& ids and SOPS in a timely manner. All observations made were presented to the applicant for resolutio No specific violations or deviations were identified in this area of the inspectio . Instrumentation and Control (I&C) Procedures (42451)
The NRC inspector reviewed a number of randomly selected I&C procedures to verify technical adequacy and to verify that they were written and approved in accordance with STA-202, Revision 17, " Administrative Control of Nuclear Operations Procedures," and ICA-114, Revision 0, " Instrument and control Section Procedures." The following procedures were reviewed:
. INC-109, Revision 2, "I & C Preventative Maintenance Program."
. INC-205, Revision 2, " Instrument & Control Equipment Channel Calibration."
. INC-2007, Revision 1, " Venting and Filling Pressurizer and Steam Generator Level Transmitters."
. INC-2050, Revision 1, " Calibration Temperature Switches."
. INC-2083, Revision 0, " Air Sampler Flow Indicator Calibration."
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. INC-4050A, Revision'1, " Channel Calibration Component Cooling Water Surge Tank Level Channel 4500."
. ICI-4204A, Revision 1, " Channel Calibration Steam Generator Level Control Loop 2 Channel LX-0529."
._ ICI-4249A, Revision 2, " Channel Calibration Feedwater Pump 1-B Suction Pressure Channel 2297."
. INC-4252A, Revision 1, " Channel Calibration Pressurizer Level Control Channel LX-0459."
. INC-4339A,. Revision 1, " Channel Calibration Power Relief Valve Control ~ Steam Generator 1 Channel 2325."
. INC-4425A, Revision 1, " Channel Calibration Turbine Driven Auxiliary Feedwater. Pump Discharge Flow Channel 2458."
. INC-4630A, Revision 1, " Channel Calibration Containment Spray Pump 02 Pressure Channel 4775-1."
. ICI-4664A, Revision 2, " Channel Calibration Emergency Boration Flow Channel 0183."-
. TCI-4729A, Revision 1, " Channel Calibration Pressurizer Safety Discharge Temperature Channel 0466."
. INC-4943X, Revision 2, "LRAM Calibration - Fuel Building Entrance CH XRE6288."
. INC-6448, Revision 0, " Calibration of Hewlett Packard Model 3490A Digital Multimeter."
. INC-7306A, Revision 3, " Analog Channel Operational Test and Channel Calibration Steam Pressure, Loop 3, Protection Set III Channel 0536."
. INC-7550A, Revision 3, " Sensor Response Tbme Test, RWST Level, Channel 932."
. INC-7764A, Revision 2, " Analog Channel Operational Test and Channel Calibration Reactor Coolant Flow, Loop 2, Protection I Channel 0424."
. INC-7917A, Revision 1, " Trip Actuating Device Operational Test Solid State Safeguards Sequencer Train A."
These procedures appeared to be technically adequat However, many of them displayed format discrepancies, inconsistencies, and ambiguous or awkward phraseolog Examples of these follow:
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17 Format Discrepancies
. The APPLICABILITY section (Section 2.0) is used inconsistently among numerous procedures. Both ICA-ll4,-Revision 0, " Instrument and Control Section Procedures,"~and STA-202, Revision-17,
" Administrative Control of Nuclear Operations Procedures" state that the subject matter to be addressed in this section should be the applicable unit (s) and the applicable system (s) and/or component (s). Furthermore, rules are give Basically,'if the procedure applies to only one of the units, that unit number should be specified. On the other hand, if the procedure applies to both units, no statement needs to be mad In the following procedures, applicable to Unit 1 only, no statement is made to that effect:
INC-4050A ICI-4664A ICI-4249A ICI-4729A INC-4339A INC-7306A INC-4425A INC-7917A
. In Procedure INC-2007, a note following Step 11.1.22 states that "The following steps that are marked with double asterisk (**) require an independent verification signature." None of the other procedures reviewed use this symbolism for the independent verification signatur . Procedure ICA-205 does not use the same section numbering as other procedures that were reviewe ICA-114 does state that the 4000, 5000, 6000, and 7000 series procedures are to be written in accordance with STA-202. The question arises: Are all the remaining I&C procedures required to be written in accordance with ICA-ll47 In general, the use of two different procedures to control the generation of I&C procedures is confusin Inconsistencies - One example of this is that INC-2007 refers to ". . . . problem report in accordance with STA-504." This report is now termed a " condition I report." Awkward / Ambiguous Phraseology
. Many of the procedures direct the technicians to perform certain steps if a card " adjustment" is performed. It is not clear what is meant by the term " adjustment." Is it a generic term? Or, is it
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'i a term that has a specific meaning, as is the case ,
with the term " calibration"? l
. Step 12.1 in INC-2007 appears to combine an action I step with general information. This is confusin ,
In reality, there are two actions to be' performed in j this ste .)
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. Step 9.2 of the Precautions and Limitations section i
- in INC-2007 states
- " Isolate channel before , !
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proceeding with Section 11.0 of this procedure." It :
is unclear as'to the meaning of the word " isolate." 1 Section 11.0 does contain explicit instructions for .
' isolating'the channel's transmitte !
. The word " spurious" is improperly used in ICI-4249 The' alarm that will be rece.i~ed is not " spurious." l Its cause'and occurrence a'.e predictable and' ;
understandabl ,
. Step 4.7.6 in INC-2083 contains' directions for i reading'a flow indicator. .These directions would be more properly placed as a NOTE that just precedes Step 4. .
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. Step 4.7.7 in INC-2083 is poorly written. It is t unclear as to whether there is one or several dial readings per inpu . In general, the data sheets are crowded. References to the data sheets should be more explicit as to which column of input data is to be used as input dat Review Cycle - It is not evident that the procedures have been reviewed every two years as required by ANSI-N18.7-1976, to which the applicant is committe In summary, the I&C procedures appear to be technically ,
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adequate. However the large number of discrepancies
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collectively degrades their overall qualit !
7. Maintenance Procedures (42451)
The inspector reviewed a number of randomly selected i maintenance procedures to verify that the procedures are l written in accordance with the proper format and o verify !
that the procedures are technically adequate to accomplish their stated purpose. The following procedures were reviewed:
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. Electrical Maintenanc MSE-CO-1000, Revision 1, "Namco Series EA-180 Limit Switch Rework."
MSE-CO-5903, Revision 0, PCN 1, " Battery Maintenance."
MSE-GO-1201, Revision 0, PCN 1, "Megger Testing of Busses, MCCs and Resistive Loads." MSE-GO-1209, Revision 0, "Hi-Pot Testing."
MSE-GO-1210, Revision 0, " Troubleshooting Guidelines."
MSE-GO-4001, Revision 0, PCN 1, " Generic Motor Disconnection and Connection."
MSE-PO-4310, Revision 0, "RCP Motor Major Inspection and Maintenanc MSE-PO-4318, -ion 0, " Service Water Pump Motor Inspectio MSE-SO-5701, Revision 1, " Surveillance of Safety Related Station Batteries."
MSE-SO-5702, Revision 1, " Battery Service Test." H MSE-SO-5706, Revision 0, PCN 1, " Battery Inter-cell Connector Resistance Test."
MSE-SO-5713, Revision 0, PCN 5, " Battery Charger Load Test." ,
MSE-S1-0673B, Revision 0, " Unit 1, Train B Sequencer Undervoltage Relay Surveillance."
MDA 311, Revision-0, " Meter and Relay Calibration Program."
MRP 601, Revision 2, PCN 1, " Metering Device l Calibration."
MRP fJ2, Revision 2, PCN 9, " Relay Calibration."
I MRP 701, Revision 0, PCN 2, "Undervoltage Relay i Surveillance." ;
MRP 702, Revision 0, PCN 1, " Monthly RCP Undervoltage and Underfrequency Relay Surveillance."
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. Engineering and Mechanical Maintenanc MEI-007, Revision 1, " MODS Input Data Review."
I MEI-015, Revision 1, " Deficiency Report Processing."
MEI-017, Revision 0, " Preventive Maintenance Implementation into MODS."
MEI-018, Revision 0, " Protective Coating Surveillance to Detect Damage or Deterioration."
MMI-830, Revision 3, PCN2, " Emergency Diesel Engine Disassembly and Reassembly."
In general, the procedures were adequate in that they:
. Stated a purpos . Identified acceptance criteri . Contained precautions and limitation . Listed reference . Contained prerequisites with required verificatio . Contained detailed instruction . Used caution and note statement . Identified hold point . Provided for system restoratio . Contained adequate attachments for special tools; measuring and test equipment; verification sheets; drawings, charts, graphs, etc., as require The inspectors noted several items of concern in the procedures. Several examples of these concerns are explaine belo Format Discrepancies
. The acceptance criteria (Sectica 2.0) stated in both procedure MSE-CO-5903 and MSE-PO-4310 leaves the i
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procedure user in doubt as to which value to use and when to use the manufacturer's minimum valu ,
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. The methods that are to be used to monitor temperatures and to ensure minimum required ventilation are not clearly explained to the users of Procedures MSE-PO-4310 and MSE-SO-570 _ -.
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. Bicarbonate of soda _is the only recognized agent for acid spills in all battery procedures reviewed,
-except MSE-CO-5903. This procedure allows other approved agents.
!! . Most procedures provided attachments for' measuring and test equipment. MSE-CO-5903 did not provide one for the torque wrenches that were require ' Reference Discrepancies
. Several procedures did not make specific reference to some of the references listed in'the reference section of the procedur . Several procedures did not list NEO 2.13 and 2.23 in the reference section. But, these NEO procedures
..were referred to in the records section of the procedure Technical Inadequacies
. Several procedures listed torque wrench ranges that varied from the torque values of the reor edure by more than ten percen . In Procedure MSE-GO-4001, a phase rotation meter was listed in the special tool list. However, a Bittle meter should have been listed instea . Records Control (42400, 42450, 42451)
During the I&C procedures review, the inspectors also reviewed the method of control for completed I&C procedures. From this review it appears that the applicant has not maintained control of these completed procedures in accordance with the administrative control procedures; for example, numerous procedures were being stored on open book shelves and personal desks in an administrative office are The applicant's administrative program outlines specific receipt, and maintenance and storage requirements for those documents which are ir. process. Nuclear Engineering and Operations (NEO) Procedure 2.23, " Turnover of Nuclear Power Plant Records," section 5.5, states, in part, that each organization wi!.1 identify an individual who will be
- responsible for collecting records; responsible for processing, rece.?pt, and storage of documents prior to turnover; respons.'ble for legibility and accountability verification; and for interfacing with the Project manager, Records, when implementing this procedure. NEO Procedure 2.13, " Management of Nuclear Power Plant Records," )
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i Section 5.5 specifies, in part, that the Records Coordinators
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of releasing organizations be " Responsible for the processing, i receipt, and storage of documents prior to transfer to TU Electric Records Management." In addition NEO-2.13, Section 6.3, subsection 6.3.1 clearly states that
" Organizations who-process and store documents prior '.o turnover and acceptance by TU Electric Records Management shall provide for the control, preservation, and safekeeping of documents as defined in the RMPM." The Records Manageeent l
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Program Manual (RMPM) RMP-1.2.1, Revision 5, discusses the applicable, storage requirements for Intermediate Storage Aress as defined in Section 4.0.- In addition, this procedure outlines guidance requirements for the (1) receipt; (2) withdrawal procedures; (3) preservation, safekeeping and storage controls; and (4) transmittal controls. RMP-1.2.1, Section 6.2 specifies, in part; that prior to receipt of
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documents, Records Coordinators shall provide for the preservation, safekeeping, and storage of documents utilizing the following guidelines:
(a) Methods should be established to guard against larceny, vandalism, and unauthorized acces (b) Documents should be stored in such a manner to provide
. protection from damage due to condensation and wate (c) Documents should not be stored loosely, but should be firmly attached to binders or stored in folders or envelopes in containers on shelving or in file cabinet (d) Special processed documents, i.e., radiographs, photographs, negatives, microfilm, and computer media should be stored to prevent damage from excessive light, excessive pressure, electromagnetic fields, temperature, and humidit (e) No food, beverages, tobacco, matches, or lighters should be allowed within the immediate area surrounding document (f) Fire protection controls should be established and maintaine (At a minimum, a fire extinguisher should be accessible for use in the area.)
(g) A filing system indicating storage location of documents should be maintained in each storage area. The filing system should identify documents required to be stored in the area and their location within the are (h) An access list of personnel authorized accces to documents should be posted at the entrance to the are The access list should reflect the date of issue of the
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list, id"entify all personnel allowed to enter the storage area without an: escort, and should be approved by the manager / supervisor or records coordinator procedurally responsible for the storage are Contrary..to the above requirements,'a review of the I&C document control program found that the applicant's current receipt, storage and control of in-process documents was not as outlined above in that:
. The individual identified by the I&C organization in accordance with NEO 2.23, Section 5.5 and NEO 2.13, '
'Section 5.5 was not aware of the detailed requirements of RMP-1.2.1, Revision 5, regarding storage and handling of in-process document . The IGC organization did not provide for the control, preservation, and safekeeping of documents as discussed in RMP-1.2.1, Section 6.2, prior to turnover and acceptance by TU Electric Records Management in that numerous (hundreds) in-process documents were being stored on open bookcases and desk tops for long periods of time (up to two years).
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This failure to properly incorporate all of the applicable administrative controls for the in-process documents is considered to be a violation of 10 CFR 50, Appendix B, Criterion XVII (445/8957-V-01). Summary of Inspection Activities During this review, the team identified 197 concerns dealing with five different areas of the procedure review. These l areas are format, procedure changes, consistency, procedure references, and technical adequacy. The majority of these items are individually minor in nature; however, due to the large number of items identified, the team feels that the applicant should not only correct the individual concerns, but should take a closer look at the generic implications of these concern 'Due to the large number of items identified, some of which appear to be violations of the applicant's administrative program, the team feels that it would be best to let the i applicant track and resolve each issue with a follow up i inspection to be conducted by the NRC staff at a future date; therefore, all of the items will be tracked as an unresolved item (445/8957-U-02), " Procedural Problems Found during PRT Inspection."
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10. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. One unresolved item disclosed during the inspection is discussed in paragraph . Exit Meeting (30703)
An exit meeting was conducted on July 27, 1989, with the applicant's representatives identified in paragraph 1 of this repor The Appendix C, List of NRC Questions, was provided verbally to the applicant by the inspectors during this reporting period. The applicant'did'not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection. During this meeting, the NRC inspectors summarized the scope and findings of the inspectio .
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L APPENDIX C List of NRC Questions PROCEDURE ITEM DATE NUMBER QUESTION
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4 /26/89 GENERAL A) 1&C PROCEDURES APPEAR AWKhNtD IN PLACES. B) REVIEW CYCLE DOES NOT APPEAR 70 NAPPEN EVERY TWO YEAR $. C)
FORMAT PROBLEn D)! INCONSISTENCIE I
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Cape W PROCEDURE ITEM DATE NWBER QUESTION
..... ........ ......... .............................. /21/89 00A 407 WHO NAS THE ULTIMATE RESPONS!8!LITY FOR ENSURING TNAT CPERATORS NAVE PROCEDURES
"AVAILABLE AND REFERENCED" AS OUTLINED IN SECTION .2 07/21/89 CDA 407 WHAT CRITERIA DOES THE UNIT SUPERVISOR USE TO MAKE A DETERMINATION IF A LINEUP CAN BE PERFORMED OUT OF SEQUENC .3 07/21/89 ODA-407 STEP 6.1.13 GIVES DIRECTION ON THE USE OF ALM's. N0 WEVER, STA 205 IS NOT REFERENCE DOES TN!S PROCEDURE SUPERCEDE STA 205 OR NOTT /21/89 CDA 407 STEP 6.2.4.9 ALLOWS VALVE LINEUPS 10 8E ACCEPTABLE FOR UP TO CNE YEAR FROM THE DitCRETION OF THE UNIT SIM RVISOR. NOWEVER, IF MAJOR MAINTENANCE (NOT WELL DEFINED)
I$ DONE, IT BNOULD BE CONSIDERED TO DE REPERFORME I /21/89 ODA 306 DEFINE "INIT!ATION TIME" AS .
REFERENCED IN SECTION .1 07/21/89 CDA 106 WAT DOES THE $0RC USE AS CRITERIA DURING A FOLLOWUP REVIEW 7 /21,39 ODA 108 WHAT VERIFIES THE THREE SORC QUESTIONS ARE ANSVERED IN STEP 4.11.1, 4.11.2, 4.1 I i
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..... ........ ......... .............................. /21/89 ODA 106 WHAT VERIFIES THE NE0 8.02 SECTION 6.3.5 REQUIREMENT IS METT /21/89 ODA 108 THE NUMBERING LOGIC IS NOT CONSISTEN .E.,1,2,3 V I,II,11I WHEN REFERENCING VARIOUS SECTION .1 07/21/89 ALM 0031A DOTN STA 202 AND ODA 205 REFERENCE USING SORC APPROVAL FOR PROCEDURE REVISION OR GENERATION. N0 WEVER, THIS PROCEDURE DOES NOT HAVE SORC APPROVAL OR DOCUMENTATIO .1 07/21/89 GENERAL OPT's REVIEWED WILL NEED TO BE CORRECTED AS TO THE REFERENCES TO THE TECnWICAL SPECIFICATION .1 07/21/89 00A 102 STEP 6.2.2.28 IMPLIES TNAT ALL PIR's ARE INITIALLY REPORTED AS A POTENTIALLY REPORTABLE ITEN, TMUS DOWNGRADED AS WECESSARY. IF SO, WHAT CRITERIA IS USED TO REVIEW DOTH THE INITIAL AND FINAL ,
CONSIDERATIONS /21/89 IPo 001A WHAT PROCEDURE IDENTIFIES WHO MAS AUTHORITY TO APPROVE OPERATIONS EVOLUTION .2 07/21/89 IPO 001A SECTION 2, STEP 2.1 REFERENCES
"0PERATIONS TECHNICAL MANAGER". HOWEVER, THERE IS NO DESCR!Pfl0N IN ODA 102 FOR THl3 JOB TITL l
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I 1 /21/89 GENERAL VARIOUS PROCEDURES REFERENCE AN "0PERATIONS TECHNICAL MANAGER". NOWEVER, THERE IS No DEFINITION FOR TNil TITL .
1 /21/89 ALM 0071 TNis PROCEDURE 8RJSI HAVE BORC APPROVA .2 07/21/89 ALM 0092A Tuts PROCEDURE st)ST HAVE SORC APPROVA .3 07/21/89 ALM 1701A TNIS PROCEDURE MUST HAVE $0RC APPROVA .4 07/21/89 ALM 3102A TNis PROCEDURE MUST HAVE SORC APPROVA .1 07/21/89 ABN 104 Tul$ PROCEDURE 18 EXTREMELY CONFUSING TO US .1 07/21/89 STA 702 STEP 6.2.1 WORDING IS EXTREMELY CONFUSIN "$ HALL INCLLDE THE FOLLOWING EXCEPT -
TNE FOLLOWING PROCEDURE TYPES:".
1 /21/89 OPT 108A !$ TECM SPEC 3/4.3.3.5 THE CORRECT TECN SPEC REFERENCE?
j 1 /21/89 OPT 1DBA USE OF "LATER" $HOULD DE REVISE .1 07/21/89 ODA 207 THE SORC MEETING IDENTIFIED FROM THE TITLE PAGE WAS DROPPED ON 11 14 88 (CHANGE l' #3). ODA 207 STILL REFERENCES l ODA 207 FORM WHICM SHOWS SORC BLOCK ON TITLE SHEE (PROCEDURE BECAME EFFECTIVE ;
7 28 87) ABN 502A, ABN 803A AND ABN 907A NO SORC BLOCK.
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1 /21/89 ODA 207 TMERE IS NO REFERENCE TO ABN PROCEDURE DEVELOPMENT UNTIL CNANGE 84 (5 30 89).
1 /21/89 OPT 201A TNIS TEST REFERENCES TECHNICAL SPECIFICATIONS WICM 00 NOT EXIST (4.5.2.81 AND 4.5.2.52)
3 C7/25/89 STA 202 PAGE 13.1 (a) DEFINITION OF-TYPOGRAPHICAL ERROR $ IS LOOS I.E., "0MITED STMBOLS, CHANGE BARS, AND PAGES" . PAGES COULD BE ADDED ARBITRARIL SAFE AS STA 205, REV 11, PAGE 5 STEP 6.1.5. (b) PAGE 13 STEP 6.3.2.3, DEFINE " EQUIVALENT".
3 /25/89 STA 205 PCN F3 REVISED PROCEDURE CHANGE FORM. WAS TNIS AN INTENT CHANGE OR WO .3 07/25/89 GENERAL (e) PROCEDURE FORMAT lt NOT C3NS!$ TENT FOR PROCEDURE REVIEWED. (b) NO REFERENCE TO WN!CN PROCEDURE WRITERS QUIDE USED. (c) SOME PROCEDURES ARE SORC APPROVED, SOME ARE NO .4 07/25/89 ODA 108 (s) STEP 4.14.2 & A.15 CONTAIN PROCEDURE CHANGES WHICN 00 NOT HAVE THE ASSOCIATED PCN (DATE CHANGES DON'T AGREE WITN CURRENT PCN). (b) CHANGE JUSTIFICATION WAS EXTREMELY WE R. (c) CHANGE TO STEP 4.15 DOES NOT APPEAR TO BE ASSOCIATED WITH WE0 8.01 REQ'MENT !
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3 /25/89 STA 503 (a) DEFINE "lWCIDENT". (b)
CNANGE STEP 6.6.1 "SNALL" TO
"$NQULD.,
3 /25/89 ODA 207 PAGE 17, SECTitri " ADDITIONAL INFORMAfl0N, OTHER THAN A CAllTION". ONE SENTENCE SAYS THAT A NOTE WILL NOT CONTAIN INSTRUCTIONS. tNE NEXT SENTENCE SAYS IF'A NOTE CONTAINS INSTRUCTIONS ENSURE
'THAT TN0$E INS 1 RUCTIONS ARE QUTLINED IN THE PROCEDURE STEP .7 07/25/89 ODA 207 SECTION 5.2 CHANGE To TITLE
"QPERATIONS TECHNICAL MANAGER" ON 11 14 88. A REVIEW 0F CDA 108 REV. O SECT!DN 4.14 &
4.15 REFERENCE A CHANGE IN TITLE WHICH APPEARS 70 NAVE BEEN CHANGED WITNOUT A PC SECTION 4.12 & 4.13 REFERENCE TNIS SAME CHANGE W/0 PC .1 07/26/89 GENERAL WHAT PROGRAM, IF ANY, CROSS REFERENCFS THE LCO'S AND PROCEDURES SUCN AS THE SURVEILLANCE PROGRAM l REQUIREMENTS AND THE PROCEDURES IN THE MASTER g SURVE!LLANCE TEST LIST (MSTL).
THIS MSTL APPEAR $ 70 SE INADEOUATE IN CERTAIN CASES REVIEWE i 4 /26/89 OWI 103 PCN CHANGES WERE NOT SEQUENTIALLY WlMBERED. PCN #3 I TO PCW f5. NO PCN f l l,
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42.1- 07/M/SP ' OPT 1084 A) TECN. SPEC. REFERENCE-IRONG, B) "LATEks" SNOULD B AEVISE ,
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2 .07/21/89 STA 707 PAGE 37 THE PERFORMANCE OF STA 707(50.59) SHOULD BE MORE
.l INTEGRATED INTO THE PROCEDURE REVIEW /CNANGE PROCES SPECIFICALLY, ADD STA 707 TO ATTACHMENT 8.8 0F STA 20 " PROCURE / FORM TECHNICAL REVIEW 9UIDELINES".
2 /21/89 STA 202 PAGE 10, STEP 6.2.3.1.3 ADD WORDS "AND REVISIDE $" TO STEP. THl$ l$ REQUIRED DUE TO SAMPLE PROCEDURE TITLE PAGE (FIGURE 7.3, PAGE 20).
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2 /21/89 GENERAL (a) NO OUIDELINES FOR # OF PCNe ALL0 BED AGAINST A PROCEDUR .2 07/21/89 GENERAL REVISION d's AND NAMES NOT ROUTINELY PROVIDED WITH REFERENCES IN SOP .3 07/21/89 GENERAL CANNOT DETERMINE WHICK RE REVISION WAS USED IN EACM PROCEDURE REVISION. T OR FT 2 /21/89 ODA 207 PAGE 3 STEP 6.2.1: CHANGE #3 FAILED TO CKANGE STEP 6. (TITLE OF OPS. TECH. MGR.)
2 /21/89 GENERAL DRAFT PROCEDURES USED IN CONTROL RCOM RESPONSES TO ALARMS. (e) ANSI N18.7 STEP 5.2.15 "EACH PROCEDURE SHALL j
BE REVIEWED AND APPROVED PRIOR TO INITIAL USE." (b) STA 202, 6.1 " PROCEDURES SHALL DE REVIEWED AND APPROVED PRIOR To THE!R USE..."
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2 /21/89 ODA 202 TITLE PAGE REQUIREMENTS PER CDA 202, 6.2.1.4 SORC MEETING f AND DATE, 6.2.1.5 EFFECTIVE DATE NOT FOUND ON SOPS. REVISE CDA 20 .1 07/21/89 STA 202 .PAGE 10 STEP 6.2.3.1.4 SORC MEETING # AND DATE NOT SHOWN ON PAGE 20 SAMPLE PAGE 2 /21/89 CDA 202 PAGE 10, TYPD (a) UNDERLINE 1.0 * CONTROL ROOM * AND " LOCAL" TO AGREE WITH PROCEDURE REQUIREMENTS. (b)
STEP 6.2 DOES NOT CLEARLY BENTION BULLETS ADDED BY PCN CDA 202 R5 1. (c) DULLETS BEING USED IN SOPS NOT ALLOWED BY CURRENT WORDING OF 09A 20 .1 07/21/89 SOP 809A SETP0!NTS (ATTACHMENT 3) Pts 5693A SHOULD SE .4 PLUS OR MINUS .12 AS FOUND 2.0 ps i
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ASSLME QUTPUT IS CORREC WHAT IS THE INSTRUMENT TOLERANCET VS SETPOINT TOLERANCE OF PLUS OR MINUS
.1 .2 07/21/89 EP 809A SETPOINT (ATTACHMENT 3)
PIS 56930 SHOULD SE .6 PLUS OR MINUS .12 AS FOUND 1.5 ps ASSME DUTPUT IS CORRECT. WHAT
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IS TNE INSTRUMENT TOLERANCE 7 VS SETPOINT TOLERANCE OF PLUS OR MINUS .12.
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l 2 /21/89 30P 809A SETPOINTS (ATTACHMENT 3)
PIS 5693E SHOULD DE .6 PLUS OR M!NUS .12 ** AS FOUND 2.1 pe ASSUME QUTPUT IS CORRECT. VMAT IS THE INSTRt24ENT TOLERANCET VS BETPo!NT TOLERANCE OF PLUS OR MINUS .1 .4 07/21/89 50P 809A TWO ALARMS ENERG!2ED, *ANY DG RM TEMP LOW" (SOURCE TIS
$690A/B AND 5694A/s). "DG 1 RM TEMP NI" (SOURCE TIS 5692).
TEMPERATURE CANNOT BE LOW AND NIGN $18ULTANE0VSLY. ROOM TEMP WAS NOTED TO SE 96 DEGREES .5 07/21/89 30P 809A ATTACNMENT 3 * WHAT IS DIFFERENCE BETWEEN NS 5690A(s)
AND TIS 56CCA(B), MS 5690A(t)
MlbtASEL IN FIELD AND ON P&lD OR NOT OH LINEUP OF ATTACMMENT 3. DOES Tis-5690A(I) COWTROL NEAftE ON/0FF AND NS 5690A(B)
CONTROL LOLO TEMP ALARNT 2 /21/89 $0P 809A TIS 5692 COULD NOT BE LOCATED 2 /21/89 50P 809A ALARM "DG 1 RM TEMP Ml" REQUIRED TO BE ENERG12ED AT 122 DEGREES ALARM F0JND ENERG12ED AND LATER FOUNC DE ENERGIZED. WHAT IS THE AS FOUND SETPOINTT (SEE COMMENT 29.8 SELOW)
2 /21/89 $0P 809A T.S. TABLE 3.7 3 SETPolNT 90R MAX TEMP LIMIT is 122 DEGREES F. NOT TO EXCEED 8 HR UNIT 1 VIOLATING TS SETPOIONTST
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PRotEDURE ITEN CATE NUMBER QUESTION seese ........ ......... messessenessenessenessessemens 2 /21/89 30P 809A P&lD MI 302 Inst. Root VALVES $NOWN ON P810. N0 3D 8s ON P&!D AND NOT LISTED IN PROCEDURE LINEUP. ASSUME IT IS PART OF THE INST. LINEUP VERIFICATION (ATTACMMENT 3).
INET ROOT VALVES LABELLED ON OTNER PE!D .10 07/21/89 30P 809A ITEP 5.3.1, 5.3.2 * LASEL D!$CREPANCIES (REFERENCE 00A 207 4.6.2) (a) 5. CURRENTLT "DG 1 01 VENT FN 4" $N00LD DE " DIESEL OIL DAY TAaN: ARIA FAN 04*, (b) 5. CLatENT * " VENT FAu 25" $NOULD M " DIE $EL GENERATOR ROOM FAN 25*.
29.11 07/21/89 80P 809A STEP 1.0, 4.0 (3 PLACEf)
SPELLING Of TITLE DOE 5 NOT AGREE WITN 00A 207, $TEP 4. (CAPITALIZE FIRST LETTER)
3 /21/89 30P 610A (ATTACNMENT 4) SET PolWT DISCREPANCIES Pls 3383 AS FOUND e 7.1 RE00! RED e PLUS OR MINUS .15 psie 3 /21/89 SOP-610A (ATTACHMENT 4) SETPO!NT DISCREPANCIES PIS 3384 A$ FOUND e 6.1 REQUIRED e PLos OR MINUS .1 .3 07/21/89 SOP 610A STEP 5.3. LI 3379, INST. NOT LABELED WITN 108 LOCALL I
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3 /21/89 $0P 610A STEP 5.2.D.1, STEP INSTRUCTS OPERATOR TO DE ENERGl2E EQUIPMENT BT OPEN!NG MCC BREAKERS STEP DID NOT MEWil0N COMPARTMEN! # .5 07/21/89 $0P 610A STEP 5.2.C, CHANGE FO XFR PUMP SWITCH Po$1110H FROM OFF 70
$ TOP TO AGREE WITH A$ FOUND LABEL $.
3 /21/89 30P 610A STEP 5. CKANGE F0 XFR PLDP 480V BREAKER POSITION FROM OPEN TO 0FF TO AGREE WITH Al FOUND LABEL .7 07/21/89 SOF 610A STEP 5. t!T 3395, DG 1 F0 STORAGE TK LEVEL (a) NOT LABELED IN FIELD, (b)
ELECTRONIC METER READ $ CUT IN UNITS OF GALLONS / FEET /17 (c)
TS IN CALLout/PAOCEDURE REQUIRES 1. (d) OME $1GN OFF 700 MANT, REVISE PROCEDURE, 3 /21/09 90P 610A STEP 2.1, FOST LEVEL OF 88,175 C INCORRECT, SHOULD BE 100,000 G MINisAm PER .9 07/21/89 50P 610A ATTACHMENT 1 NUMEROUS VALVES DID NOT HAVE TAG #s. A NOTE AT BOTTOM 0F ATTACHMENT 1 STATES TAG is REQUEtlE.D VIA DCA 76441, $0P 61CA APPROVED
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9/26/88. CORRECTIVE ACTIONS 70
$0P WOT PROMP l
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30.10 07/21/89 50P 610A TYP0 IN ATTACH 1, AT VALVE 100-022 DESCRIPTION, CHANGE PI 3390 TO PI 138 .11 07/21/89 50P 610A TYP0 IN ATTACN 1, AT VALVE 1D0-023 DESCRIPTION, CHANGE PI 3389 TO PI 339 .12 07/21/89 50P 610A TYPO IN ATTACM M * CHANGE 1 PS 2409 4A TO 1 PS 3409A 30.13 07/21/89 50P-6104 ATTACHMENT #1 * VENDOR SKID SUPPLIED VALVES NOT SHOWN ON TU ELECTRIC'S P& ids MI 0215, 0215 A. VALVES NOT LABELED IN Fl[L .14 07/21/89 $0P 610A IN ATTACHMENT 1, WRONG YALVE POSITlots FOR (a) 100 002 -
OPEN TO L.O. (b) 1D0 006 TO OPE .15 07/21/89 50P 610A ATTACHMENT 1 LABELLING DISCREPANCY AT VALVE 1D0 029 -
PROCEDUR[ STATES *F0 DAY TK 01 TO CNGN SPLY8 AS F(UND + "DG 01 fuel CIL SUPPLT".
30.16 07/21/89 SOP 610A 100 0410 DAY TANK OKAIN 1
!@ 0411 (a) NOT IN VALVE LINEUP (b) ENOWN ON P8lD (c)
LOCATED IN FIEL .17 07/21/89 50P 610A PSID MI 0215 VALVES ON P&lD NOT SHOWN AS L.D. - 100 0002, 0003, 00014, 0015, 0029, 003 . _ _ _ . .. - - - - - - - - - -
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3 /21/89 SOP 304A TWD TRAINS SW FEED TW TRAINE OF AFW THRU ONE PIPE 15 EEPERATION CRITIERA METT 3 /21/89 . BOP 304A STEP 2.1, ADD INSTRUCTIONS TO WRIFY CST LEWL ABWE TS REQUIREMENTS. (CET OPERABLE PER T.S. 3.7.1.3)
3 /21/09 SOP 304A STEP 2.1, ADD N2 SUPPLY TO CST IN SERVICE AND ALIGNED TO CS .4 07/21/89 SOP-304A STEP CST LEWL IS 53X noi SSE, PER REV E OF T .5 07/21/89 30P 304A STEP 5.1.1.F, 5.2. CHANGE 5 ADDED REQUIREMENT 70 $ TART NP CNEN FEED PUNPS REFERENCE THE PROCEDURE THAT PERFORMS THE STEP (R ADD TME INSTRUCTION .6 07/21/89 scP 304A 5.3 WNTING VALES ARE REPostfl0NED AND ARE NOT
- RESTORED TO STANDBY MODE POSITION .7 07/21/89 $0P 304A STEP 5.3.1.E, .G + ADD INSTRUCTIONS To OPEN/CLOSE AF 062 WHEN PERFORMING STE .8 07/21/89 SOP 304A STEP 5.3.2.E. .G ADD INSTRUC110NS To OPEN/CLOSE 1Af050 3 /21/89 10P 334A STEP 5.3.3.E, G ADD INSTRUC110NS TO OPEN/CLOSE 1AF-034
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31.10 07/21/89 $0P 304A STEP 5.5. CHANGE SEC .1 70 .11 07/21/89 $0P 304A .tTEP 5.5.1.9 - ADD *AND LOCK *.
31.12 07/21/89 $0P 304A STEP 6. TS 3/4.7.13 SHOULD SE 7.1 .13 07/21/89 $0P 304A STEP 6. TS 3/4.6.13 SNOULD BE .14 07/21/89 $0P 304A b!SCREPANCIES BETWEEN STEPS IN 800 TOR AMPS (a) 5.1.1.D -
(40 50 AMPS) (b) 5.5.1.N -
(30 35 AMPS) (c) 5.5.3.3.5 -
(30 35 AMPS).
31.15 07/21/89 ScP 304A PAGE 36, 38 AND 50 - 1 PT 2476 ROOT VALVE DISCREPANCY 1 AF 026 CR 0247 EITNER P810 OR PROCEDURE INCORRECT. ALSO 1 PT 2475 ROOT VALVE DISCREPANCY, EITNER AF 016 OR 244? FIELD LABELLING AGREES WITH PROCEDUR .16 07/21/89 $0P 304A MANY INSTRUMENTS LISTED IN ATTACH $4 WOT ON P810, VENDOR SKID SUPPLIED EQUIP?
31.17 07/21/89 SOP 304A DISCREPANCIES DETWEEN LOCKED VALVES PER PROCEDURE AND P81D REQUIREMENTS 1 AF 042, 07/,
122, -055, 091, 067, 09 , 164, 163, 16 l
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'31.19 07/21/89 80Pe304A VALVE 1AF 236 ON P&ID, mot IN LINEUP AND WOT LA8ELED IN FLEL .1 07/21/89 scP 815A REVER$E TITLC* OF 1CH 408, 4D9 ON PAGE 3 .2 07/21/89. 30P 8154 1CN 321, 1CN-328, 1CH 309, 1CM 319 * OPEN IN LINEUP, $ HUT ON P&lD 3 /21/89 80P 815A ON PAGE 27, CHANGE XCH 313 FRON VENT TO DRAIN, PER P&l .4 ' 07/21/89 SOP 815A PAGE 31, ICM 202 DRN IN PRO VENT ON P&l .5 07/21/89 30P 815A PAGE 34, XCH 316 DRN IN PRO VENT ON P&l .1 07/21/89 SOP 204A PAGE 12, CT 039, TC IN PROC, TC IN FIELD DRAIN ON P&li. 18 THERE A DCN ON P&lD?
3 /21/89 $0P 204A 1CT*246, 247, 249 $NOWN ON P&lD, PCN 1 DELETED VALVES FROK PROCEDURE, OUT$TANDING CHANGE REQUEST ON P&lDT 3 /21/89 SOP 204A PAGE 31, $fEP 1 CT 141, REQ'O TO BE L.C. FOUND $ NUT IN FIEL .4 07/21/89 SOP 2044 PAGC 22 THRU 3?. DISCREPANCIES 4 BETWEEN P&lD AND PROCEDURE ON I LOCKED VALVES (TOTAL D1$CREPANCIES: 50).
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3 /21/89 30P 204A PAGE 18, STEP 5.2.3 S. -
ENSURE T.S. LIMITS FOR TAK ARE E t 3 /21/89 SOP 204A PAGE 14, STEP 5.2.1.V. PAGE 17 STEP 5.2.2.V - ADD *THEN" TO AGREE WITH CDA 207, STEP 4. REQUIREMENT .7 07/21/89 SOP 204A PAGE 12 STEP 5.2. T00 MAN) ACTIONS (15) IN ONE STEP CDA 207, STEP 4.1.3, PAGE 15. O! SALLOWS (NIS. ALSO APPLIES TO STEP 5.2.2.C ON PAGE 1 .8 07/21/89 SOP 204A PAGE 10, 11 ADD FLOW RATE LIMITATIONS As h0TE BEFORE STEP 5.1. .9 07/21/89 SOP 204A PAGE 8 STEP ' 1.1.H, CHANGE
- SPRAT" TD "CHEN" TD AGREE WITN f! ELD LABEL .10 07/21/09 SOP 204A PAGE 9 CHANGE "NOT CLOSE" TO
"0 PEN" (2 f; ACES) TO AGREE WITH FIELD LABEL .11 07/21/89 $0P 204A PAGE 6 STEP CHANGE $167 To $314 TO AGREE WITH REY. E NUMBER, ADD 4.6 RWST i T/S (ADD TS RE0'D LE'KL TO VERIFT RWST OPERABLE).
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3 /21/09 30P 201A 1.3 ADD "100L VLV". (TYP0)
3 /21/09 30P 201A 1.19 ADD als0L". (TTP0)
3 /21/89 30P 201A 1.20 CHANGE 2 T0 "1". (TTP0)
3 /21/99 50P 201A PAGE 37, CHANGE HI NEAD St INJ ISO VLV TO "CCP $1 ISOL YLV" lu TWO PLACES (10 AGREE WITN FIELD LASELS).
I 3 /21/89 $0P 201A 2.13, 3.1, 4.1 CHANGE NI NEAD B1 INJ. ISOL VLV 10 "CCP $1 ISOL VLV" TO AGREE WITN FIELD LASEL .6 07/21/89 SOP 201A DISCREPANCIES BETWEEN P$lt AND PROCEDURES FOR LOCKED VALVES (24 DISCREPANCIES).
3 /21/89 $0P 201A PAGE 5, STEP 5.1.2 ADD ANNUNCIATOR LOCAfl0N .8 07/21/89 s0P 201A 5.5.1.E, PAGE 11 ADD *FOR PLMP 70 SE STARTED"
$1P 1
$1P 2 ".
3 /21/89 SOP 201A PAGE 12, 5.5.1.N, 5.5.2.1.r, 5.5.2.2.L, 5.5.2. .5.2.4.L INCORRECT WHEN, THEN LOGIC STATEMENT $
(00A 207, STEP 4.2.4, PAGE 16).
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34.10 07/21/89 SOP 201A PAGE 8, 5. TERM " CLEAR AND TAG" WOT CLEA .11 07/21/89 SOP 201A PAGE 7, 3 STATUS LIGHTS ENERG12ED WITH VALVES CLOFID (VALVES 8821A, 8821B AND 8835). WERE THE VALVES DLIT-OF POSITION?
34.12 07/21/89 80P 201A PAGE 5, 5. ADD "10F 3" TO ANN. ?tTL .13 07/21/89 $0P 201A 5.1.6 (a) ADD "1" TO VALVE 8923A. (b) ADD "HI NEAD" AND CNANGE CCP TO NI NEAD IN PROCEDURE (3 PLACES). (c)
REVISE TITLES "2 & 3" AND "1 AND 4" FOR 8802A AND 8802 .1 07/21/89 SOP 204A PCM R31 * WOT FULLY INCORPORATED INTO SO .1 07/21/89 SM 204A PAGE 26, 9.1 = 1CT 127 NAS A BLIND FLANGE NOT A CA .2 07/21/89 50P 204A PAGE 26, CS NX1 DRAIN LINE (a)
WATER FOUND DRAINING OUT OF DRAIN LINE (MODERATE FLOW) (b)
EITH[A DRAIN VALVES LEAKING SY OR PRESS. RELIEF VALVE 3 /21/89 $0P 304A PAGE 42, 4.7 * AFWPT TRIP / THROTTLE VALVE COMP 2KL (a) FOUND ON (b) SHOULD BE Off PER LINEUP (c) is PROCEDURE CORREC17
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3 /21/89 30P 304A' PAGE 45,1.17 CHANGE "TP" TO
"TD".
3 /21/89 30P 306A PAGE 46, 3.2 CHANGE "MS" TO
"usL4".
3 C7/21/89 90P 304A PAE 42, .6 WRONG TITLES EM: PROC "AFW1V 1 TRW A", IN FIELD: "TD AFWlV 1".
3 /21/89 30P 304A PAGE 45 1.18 1.21 AFW1Vs 1 4 F0lMD $ NUT, $NOULD BE OPE .24, 1.25 2 CONTROLLERS FOUND IN MANUAL, EHOULD BE AUT .6 07/21/09 30P 304A PAGE 47, 3.11, 3.12 CONTROLLERS FOUND IN MANUAL, NOT AUTO.
I 3 /21/89 SOP 304A PAGE 43, 6.1 - CCT D!$CH VAL' E l MCC 1 Eta 1, COMPT 9C POWE8 FOUND OFF, NO C.k. LIGHTS ENERGl2E .8 07/21/89 SOP 304A PAGE 44, CNDS XFER PUMP DOES NOT HAVE A PTL Pos! TIO .9 07/21/89 $0P 304A PAGE 47, 3.13 - 1 FK 2/61B NO INDICAfl0N LIGHTS IN C.R. NO POWER (OBSERVATION). EITNEt LIGNT SULB !$ BURNED OUT OR CONTROL ROOM l$ DE ENERG12E .10 07/21/89 SOP 304A PAGE 46 NOT SHUTDOWN PANEL (NSP) 15 OLD TERMINOLOGY FOR THE REMOTE 5/D PANEL, SWITCHES ON $/D XFER PANEL ARE LABELED
"HSP/CR".
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ITE DATE IRMBER 'GUESTION-
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37211' '07/21/W - 80P 304A -STEP 3.0,' CNANGE TITLE FROM NSP TO REMOTE S/D PANE .12 07/21/M - 80P 204A LASEL DISCREPANCIES DETWEEN
>
PROCEDURE, FIFLD LABELS, STEPS 1.1, 1.2, 3.2.
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3 /25/89 STA 202 PCW STA 202 R17 21 CHANGES THE QUALIFICATION OF THE REVIEWER AS DEFINED IN 4.8 0F TNil PROCEDURE. THIS CHANGE #EMOVES THE GU dIFICATICes AS STATED BY ANSI 18.1. IT APPEARS THAT TNE QUALIFICATIONS OF THE REVIEWER NAVE SEEN LOWERED BY THIS CMAWG .2 07/25/89 STA 205 1 PCN STA 205 R1107 CNANGES DEFINITION OF PART 4.13 TO READ *A REVIEW TO ASSESS THE IMPACT OF A PROCEDURE CNANGE ON A SPECIFIC AREA BY A KNOWLEDGEA8LE INDIVIDUAL WHO 81EETS THE REQUIREMENT OF STA 202". THE REASON FOR CHANGE WAS TO MEET REV E OF THE PLANT 3 /25/89 STA 205 . TWO MEMBERS OF THE NUCLEAR OPERifl0NS STAFF, AT LEAST ONE i (F WHOM HOLDS A SENIOR OPERATOR LICENSE. FROM TNlt STATEMENT 17 APPEARS THAT THE CHANGES MADE TO DDTH STA 202 Alm STA 205 ARE WOT IN COMPLIANCE WITN THE PLANT'S TECH SPEC .4 07/25/89 STA 707 PCN 707 R4 04 ADDS THE STATEMENT TO INCLUDE NON NUCLEAR OPERAfl0st$
DEPARTMENTS. NOWEVER, IT WAS FOUND IN VARIOUS CHANGES IN
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THE PROCEDURE TO READ *(FOR NUCLEAR OPERATIONS ACTIVITIES ONLT)". A FEW EXAMPLES ARE AS FOLLOWS: 6.2.1, 6.2.5, 6.2. _ - - - _ _ _-
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4 /26/89 Asu 803A PCN Atu 803A RO 03 APPEAR $ TO BE MORE THAN A *NON lWTENT*
CHANGE. STEP ($EE THE ADDED REQUIREMENTS IN STEP m.)
3 /26/09 GENERAL ALL PROCEDURES REVIEWED HAD ERROR $ ASSOCIATED WITH REFERENCES TO THE PLANT'S TECW SPEC 5. IN SOME CASES, THE PROCEDURE HA$ THE OPERATOR REFER TO THE WRONG SPECIFICATIONS, OR TO NON EXISTENT LCOs. t.LSO, THE REFERENCE SECTION OF THESE PROCEDURES (cont'd)
3 /26/09 GENERAL AS TO WHAT SPECIFICAtl0NS APPLY AND THE OPERATOR MUST BELY ON HIS MEMORY. THE FORMAT FOR LISTING THE LCOs IS NOT CONS!$ TENT THROLiGHOUT THE PROCEDURES. ONE FORMAT $NOULD BE CMOSEN AS FOLLOWE *
3 /26/09 ABN 703A (e) REFERENCE 3/4.10.3 AND 3/4.10.4 DO NOT SEEM TO APPLY TO THIS PROCEDURE. (b) LCO 3/4.2.4 15 REFERRED TO IN THE 80DT OF THE PROCEDURE AND !$
NOT IN THE REFERENCE SECTIO .1 07/26/89 ABN iO4A STEP 2.4.e.7 CAUTION STATEMENT REFERS TO T.S. FIGURE 3.4 4, WHEN IT $HOULD REFER TO FIGURE 3.4 .2 07/26/89 ABN 104A PAGE 16 0F 64 REFERS 70 3/4.9.3 WHICH DOES NOT SEEM APPLICABLE.
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3 /26/09 ABN 104A PAGE 6 0F 64 TTPO, y 3.4.4.1.4.1 SHOULD DE
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3.4.1. .4 07/26/09 ABN 104A 9.1 REFERENCE SECTION (a) .4.9.3, WHY REFER TO TN18 SPECIFICAfl0NT (b) FIGURE
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3.4 4 SHOULD BE 3.4*2. (c)
T.S. 3.5.3.4 WOT LISTED EVEN THOUGH IT lt USED Det PAGES 24 0F 64 AND 25 0F 64 i 3 /26/89 Ams 502A STEP 5.3.7 MAS THE OPERATOR -
REFER TO THE T.S.10 ENSURE LCOs ARE NOT VIOLATED. DOES THE Sto CR R0 DETERMINE
{
WETNER AN LCD ACTION
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STATEMENT lt APPLICABLE OR IF I THE PLANT IS IN VIOLATION OF THE T. .1 07/26/89 ABN 71DA .
STEP e. PAGE 5 0F 25 READS, IN PART, "...AND 3/4.3.3.5 (TABLE 3.3 8)". IT EN0ULD READ
,
3/4.3.3.3 (TABLE 3.3 6).
3 /26/89 ABN 907A REFERS TO T.S. 3/4.3.3.3 WICN DOES WOT ADDRESS SEISMIC MONITORIN .1 07/26/09 GENERAL t SONE PROCEDURES WERE VERY l
DIFFICULT TO FOLLOW DUE TO THE LETTER DESIGNAfl0N OF THE SPECIFIC STEPS IN THE PROCEDURE, AND SOME PROCEDURES MAD SD MANY MAND WRITTEN REV1$10NS IT WOULD BE VERY I EAST FOR AN OPERATOR TO MISREAD A PROCEDURE OR (CONT'D)
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4 /26/89 ASN 104A PAGE 26 0F 64 STATES, PROCEED TO STEP n. WHERE 15 n? IT WOULD APPEAR IN THIS FORMAT THAT A PAGE NLMBER (SUCH AS PROCEED TO STEP n PAGE 30 of 64) WOULD ASS!$T THE OPERATOR IN FINDING THE PROPER STEP ESPECIALLY WHEN THE NEXT STEP (cont'd)
4 /26/89 ABN 803A VERY POOR LAYOUT / ORGANIZATION OF THE PROCEDURE AS SHOWN ON PAGES 14, 14.1, AND 1 .1 07/26/89 A8N 104A SEVERAL PROCEDURES CONTAIN (LATER) AND DO NOT APPEAR TO BE FULLY COMPLETED. EXAMPLE -
5.3e AS STATED IN PART ARE NOTED OR LEVEL IS LESS THAN (LATER). ALSO ATTACHMENTS 2, 3, 4, 5 AND 14 (LATEP).
4 /26/09 sM 104A ATTACNMEN1 7, PAGE 7 0F 8 CAUTION STATES IN PART "...RCS
> 140F USE ATTACHMENT 14" WHICH !$ (LATER). NOW WILL THE OPERATOR KNOW WHAT THE LEVEL IS IN THE REAC10R VESSEL 7 4 /26/89 ABN 710A THE SETPOINT OF THE REACTOR TRIP DID NOT AGREE WITH THE LIMIT!NG SAFETT SYSTEM SETTINGS AS SPECIFIED IN THE PLANT'S TECH SPECS. STEP 2.2a ETATES IN PART "...(TURBINE TRIP / AUXILIARY FEEDWATER l= ACTUATION AT 43.4% S/G LEVEL)
l WHICH DOES NOT AGPEE WITH t
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v 1 I 31.18- 07/21/89 . EVANS 3 VALVES ON P&ID DELETED fROM-PROCEDUREI CHANGE REQUES CUTSTAICING ON P&lD?
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1 /21/89 STA 202 THE LICENSEE DOES NOT HAVE GUIDANCE / SPECIFIC INSTRUCTIONS THAT CONTROL THE NUMBER OF PROCEDURE CHANGES THAT CAN BE ISSUED BEFORE THE PROCEDURE is REQ'D 70 SE REVISED. STA 202, REV.17 (7 2188) HAD 19 CHANGES THROUGH (6 29 89).
1 /21/89 NLO 2.13 PARAGRAPN 5.5.2 & 3 REQUIRE COORDINATORS OF RELEASING ORGANIZATIONS 70 BE RESPONSIBLE FOR STORAGE &
INTERFACING WITN THE RECORDS PROJECT MGR. PARA: 6. REQUIRES ORGANIZATIONS WHO STORE DOCLMENTS TO PROVIDE CONTROL, PRESERVATION &
SAFEKEEPING PER RMP .2 07/21/89 RMP 1. PARAGRAPM 5.3 REQUIRES RELEASING ORGANIZAfl0NS TO NAVE A RECORDS COORDINATOR FOR INDETERMINATE STORAG PARAGRAPN 6.3 SETS REQUIREMENTS FOR COORDINATOR TO PROVIDE STORAGE PER THE GUIDELINES LISTE .3 07/21/89 RMP 1. RMP 1.3.1 DEFINES THE RELEASING ORGANIZATIONS AS THE HOLDER OR KEEPER OF THE DOCUMENT UPON COMPLETION OF PROCESSING OR REQUIRED WOR .4 07/21/89 ANS! ANSI N45.2.9 SETS REQUIREMENTS N45. FOR THE IN1ERMEDIATE STORAGE OF RECORDS AND IS REFERENCED IN kEO .- _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _
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semes==ssass==assan=== .ssasse 2 /21/09 GENERAL ' MSEs (1415) (a) SEVERAL MINOR DISCREPANCIES (b) SEVERAL PROCEDURES WITH "NONE" NOTED (c) OVERALL WELL WRITTEN WITH EXCELLENT DETAILED INSTRUCTIONS AND INFORMAfl0 .1 07/26/09 CENERAL SELECTION OF STAi10N BATTERY PILOT Celt ($). PROCEDURES REQUIRE A SELECTION To BE MADE EVERY QUARTER. THE SELECTION PROCESS JUST MOVES TO THE NEXT ADJACENT CELL. NRC FEELS THIS SELECTION DOES NOT MEET THE INTENT OF REPRESENTING ALL CELL .1 07/26/89 MSE 5903 MSE CO 5903 RO 1 SECTION 2. ACCEPTANCE CRITERIA FOR INTER CELL CONNECTION RESISTANCE 15 NOT LISTED OR AVAILABLE. TMis VALUE IS STILL UNDETERMINED ALTHOUGH THE PROCEDURE DOES NOT INDICATE THA .2 07/26/89 MSE 5903 MSE CD 5903 RO 1 SECTION BICARBONATE OF SODA OR OTHER APPROVED AGENT FOR ACID SPILLS. OTHER PROCEDURES Do i
NOT RECOGNIZE OTHER APPROVED AGENT i
4 /26/89 MSE 5903 MSE CD 5903 R01 ATTACNMENT *
j NO ATTACHMENT TO LIST METE EQUIPMENT SUCH AS REQUIRED TORQUE WRENCHE !
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4 /26/99 MSE 1201 MSE 001201 R01 SECTION 2.0 -
NOW IS IT KNOWN IF THE MANUFACHAtER'S MIN!IRM IS DIFFERENT FROM THE STANDARD VALUE USED?
4 /26/89 MSE 1201 MSE 001201 Ro 1 ATTACMMENT 10.3 18 A GRAPH FROM IEEE 43 1974 WICH IS NOT LISTED AS REFERENC .1 07/26/89 MSE Go 12 SECTION 6.3 PROPER GROUNDlWG 09 15 ADDRESSED BUT No GUIDANCE
!$ GIVEN AS TO GROUNDING DEVICE MINIMUM OR MAXIMUM SIZ .2 07/26/89 MSE GO 12 SECTl0N 6.5 RUBBER GLOVES ARE 09 NOT ADDRESFED AS TO WHETHER THEY SHOULD BE LOW VOLTAGE OR HIGN VOLTAGE GLOVE .3 07/26/89 MSE Go 12 ATTACHMENT 10.2 LISTS "TOROUE 09 WRENCH (5 TO 60 FOOT POUNDS),
AS APPLICABLE" FOR TORQUE VALUES ON THE TORQUE CHART FROM 3.5 TO 60 FT LB WITH A PLUS OR MINUS 101 TOLERANC .1 07/26/89 MSE G0 40 MSE GO 4001 FO 1 ATTACHMENT 01 10.1 PHASE ROTATION METER LISTED ON SPECIAL TOOL List WHEN A BITTER METER SHOULD HAVE BEEN LISTED. NOALUX AS USED IN STEP 8.3.2 WAS NOT LISTE j l
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j 4 /26/89 MSE P0 43 MSE P0 4310 RO SECTION
8.4.10.1 TME METN00 0F MONIROTING TEMPERATURES AND THE FREQUENCT AND FORMAT OF DATA IS NOT CLEA ~4 /26/89 MSE PO 43 MSE P0 4310 R0 ATT 1 SPECIAL fool LIST, LOCS AND TACS ARE REQUIRED IN STLPS 8.2.50 AND 8.2.52. TEXACO R&D 46 OIL USED IN STEPS 8.3.36 AND 8.3.63 NOT LISTE .3 07/26/89 MSE PO 43 MSE PD 4310 RO ATT 10.2 TORQUE
WRENCH TOR 3190 fT LS$ WNEN TORQUE VALUE I$ 3000 TO 2300 IN STEPS 8.3.13.1 A S 8.3.13. .1 07/26/89 MSE PO 43 MSE PO 4318 R0 ATT 10.1 (a)
TTP3 TEKACO RELAL h&O 220 Olt
. Ys 320 FOR STEP 8.4.13. (b)
DIL QUANTITY IS NOT SPECIFIE (c) CONTAINERS FOR DRAINING O!L INTO NOT LISTED IN STEP 8.2.11. (d) RAYCHEM KIT NOT SPECIf!ED FOR STEP 8.6.1 $ /26/89 MSE PD 43 MSE P0 4318 R0 ATT 10.2 TORQUE 18 WRENCN, 0 300 FT LBS (a) STEP
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f 8.5.1 REQUIRES TORQUE FROM 258 274 FT LBS. (b) STEP f 8.6.11.4 NAS LOW RANGE TORQUE REQUIREMENT i
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5 /27/89 MSE $0 57 NF SO 5701 R1 1 TABLE 1 REF
TEMPERATURE OF 77 DECREES NOT INCLUDED IN THE TEMPERATURE CORRECTIO _ - _ - _ _ _ _ _ _ - - - -
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5 /27/89 ' MSE 50-57 MSE 50 5701 R1 1 SECTION METHOD OF ENSURING VENTILATION IS OPERABLE IS NOT SPECl?IED WOR l$ ANY MIN! MUM REQUIREMENTS ADDRESSED IF NECESSAR .3 07/27/89 MSE 80 57 MSE 50 5701 R1 1 SECTION 01 8.4.10 METHOD OF SELECTION OF PILOT CELL l$ UNUSUAL AND MAT WOT BE PROVIDING A REALISTIC GENERAL CONDITION OF ALL CELLS 70 SEVE AS AN INDICATION OF THE 8ATTERY CONDITION SETWEEN SCHEDULED DVERALL INDIVIDUAL CELL READING .1 07/27/89 MSE $0 57 MSE 50 5702 R1 SECT 10N 8.3.13 02 NETHOD AND EQUIPMENT FOR TEMPERATURE MONITORING OF THE INTERCELL CONNECTOR $ IS NOT CLEAR. PTROMETER I. 32 .!STED IN EQUIPMENT OR T ATTACHMENT .1 07/27/89 MSE 50 57 MSE $0 5706 RO 1 SECTION TORQUE VALUE OF 24 TO 26 INCH LBS M&TE ATTACHMENT 1 LISTS TOROVE WRENCH (40 200 INCH LBS).
5 /27/89 MEl 038 MEl 038 RO SECTION 1 THls PROCEDURE IS DlFFICULT TO USE IN COORDINATION BETWEEN PROCEDURE STEPS AND DATA SHEETS. THE ACCEPTANCE CRITERIA IS NOT SPECIFICALLY FLAGGED AS SUCH. THE PROCEDURE APPEARS TO BE A STAND A'.ONE PROCEDUR . _ - _ _ - - _ _ - - _ - . _ . _ - - - - - - - -
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5 /27/89 El 038 El 038 RO SECTION 7. ADDRESSES TORQUE OF BOLTS FOLLOWING THE APPROPRIATE PROCEDURE AND INDICATES THAT ATTACHMENT 5 PROVIDES THIS INFO ATTACHMENT 5 ADDRESSES THE FINAL TOROVE VALUES SUT DOES NOT FOLLOW (CONT'D)
5 /27/89 MEl 038 NEl 038 RO SECTION REFERENCES - MEl 38 DOES NOT REFERENCE m l 830 5 /27/89 MEl 038 NEl 038 R0 SECTION 2. IF THESE PROCEDURES ARE WORKED IN CONJUNCTION THEY ARE NOT COORDINATED WELL AND TORQUE INSTRUCTIONS SHOULD BE CLEAR AND EXPRESSED WITHOUT CONFLICT OR CONFUSIO .1 07/27/89 MSE SI 06 - MSE SI 0662 ko SECTION ACCEPTANCE CRITERIA IS NOT IDENTIFIED AS A/C IN PROCEDURE l
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STEPS WHEN THIS DATA IS RECORDE {
i 5 /27/89 MSE St 06 MSE SI 0664 R0 SECTION REFERENCES 4.2, 4.3, 4.5, 4.6,
& 4.10 ARE NOT SPECIFICALLY USED IN THE PROCEDURE. NEO 2.13 & 2.23 REFERENCED IN PARA. 11.0 ARE NOT LISTE .3 07/27/89 MSE St 06 MSE SI-0664 R0 SECTION 8.1. IS TNis DONE IN ACCORDANCE WITH STA 606T
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..... ........ ......... essessasse... ..easesseemanase 5 /27/89 MSE SI 06 MSE SI 0664 RO ATTACH 1 VARIABLE DREQUENCT 58 62 HZ o4-FALLS OUTSIDE THE ACCEPTANCE CRITERIA 0F > 57.1 N .1 07/27/89 MSE 51 06 MSE St 0603A RO SECTION A REFERENCES 4.1, 4.2, 4.8 &
4.10 NOT SPECIFICALLY USED IN PROCEDURE. WE0 2.13 & 2.23 0F PARA, 11.0 MIS $ LN .2 07/27/89 MSE SI 06- MSE.SI 0603A R0 SECTION 8.1.5
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03A TMl$ IS NOT CONSISTENT WITN CINER STATEMENTS SUCH AS IN MSE SI 0669 PARA. 8.1.5 IN ACCORDANCE WITH 2 A 11 .1 07/27/89 MRP 701 & THESE WEat LISTED ON THE 702 MASTER FREQUENCT INDEX AND NAD ALREADY BEEN SUPERSEDED BY TNE A80VE TWO PROCEtuRE .2 07/27/89 MPR 602 MPR 602 R2 9 PAGES 104.1, 104.2, 104.3, 104.4, 106.5 &
104.6 CONTAIN TWO DifFERENT PAGES OF EACN PAGE IN THE PROCEDUR _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ ______ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. ._ _______________________________.______________________a