ML18044A498
| ML18044A498 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/18/1979 |
| From: | Baker K, Little W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18044A496 | List: |
| References | |
| 50-255-79-20, NUDOCS 8002070381 | |
| Download: ML18044A498 (13) | |
See also: IR 05000255/1979020
Text
U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-255/79-20
Docket No. 50-255
Licensee:
Consumers Power Company
212 West Michigan Avenue
Jackson, MI
49201
Facility Name:
Palisades Nuclear Generating Plant
Inspection At:
Palisades Site, Covert, MI
Inspection Conducted:
October 22-26, 29 and 30, 1979
Inspector: ~~~
v}Y~"'-
Approved By: -42-~~-:~:ting Chief
Nuclear Support Section 1
Inspection Summary
License No. DPR-20
Inspection on October 22-26, 29 and 30, 1979 (Report No. 50-255/79-20
Areas Inspected:
Routine, unannounced inspection of surveillance of
safety related components and equipment; implementation of ASME Code
Section XI for pumps and valves.
The inspection involved a total of 56
inspector-hours on site by one NRC inspector.
Results:
Of the areas inspected, six items of noncompliance were identi-
fied (Infractions - Control of Test Equipment, 10 CFR SO, Appendix B,
Criterion XII, Paragraph 5; Failure to report as required by Technical
Specifications 6.9.2.a(6), Paragraph 4; Failure to test as required by
Technical Specifications 4.5.3.a, Paragraph 3; Failure to make a tem-
porary change as required by Technical Specification 6.8.3, Paragraph 4;
Failure to conduct surveillance tests at the interval specified by Tech-
nical Specification 4.13.c, Paragraph 8; Failure to implement ASME
Section XI test requirements for valves, Paragraph 9.
8002070 3g'
1.
DETAILS
Persons Contacted
- R. DeWitt, Vice President Nuclear Opeations
- J. Lewis, General Manager - Palisades
- F. Butler, I&C Engineer
- B. Schaner, Operations Supervisor
- R. Vincent, Senior Engineer
- G. Gilbody, QA Engineer
- D. Kennedy, Associate Engineer
- J. Meineke, Reactor Engineer
- D. Powers, QA Engineer
- G. Petitjean, Technical Engineer
H. Palmer, Technical Superintendent
S. Ghidotti, Shift Supervisor
T. Konicki, Shift Supervisor
The inspector also contacted several other licensee employees.
- Denotes those attending the exit interview.
2.
Surveillance of Safety Related Components or Equipment
a.
Purpose of Record Review
The inspector reviewed plant surveillance records to verify:
(1)
Test procedures are approved in accordance with the Tech-
nical Specifications.
(2)
Test procedures include appropriate (a) prerequirsites and
preparations, (b) acceptance criteria, and (c) instructions
to ensure tested item is restored to operation following
the test.
(3)
Technical content of procedures assures compliance with
the Technical Sp~cifications and/or Inservice Inspection
Program.
(4)
Tests were performed within the time frequencies specified
in the Technical Specifications and Inservice Inspection
Program.
(5)
Tests were performed by qualified individuals.
(6)
Test results were reviewed as required by facility
administrative requirements .
- 2 -
(7)
Test results were in conformance with Technical Specifica-
tions and Inservice Inspection Program.
(8)
Appropriate action was taken for test results not meeting
the acceptance criteria.
b.
Administrative Documents and Test Records Reviewed
(1) . Test Records
(a)
D-W-1, Daily, Weekly Operations
Surveillance, Rev. 9
(b)
M0-20 Inservice test procedure,
Charging Pumps, Rev. 11
(c)
MT-15 Reactor Internals Noise
Monitor Test, Rev. 8
(d)
Q0-5 Valve Test Procedure, Rev. 11
(e)
QE-9 Diesel Fire Pump Battery
Surveillance, Rev. 2
(f)
A0-3 Shutdown Cooling System Test,
Rev. 4
(g)
AE-5 DC Lighting Test, Rev. 3
(h)
R0-22 Control Rods Drop Time,
Rev. 5
(i) Fuel Oil Samples T-10
(2)
Personnel Qualification Records
Date of Test
10/22-25/79
1/16/79, 2/19/79,
3/15/79, 4/16/79,
5/23/79, 6/18/79
5/30/79, 6/8/79,
6/15/79, 6/18/79,
6/22/79, 7/2/79,
7 /11/79, 7/20/79,
7/31/79, 8/16/79,
8/17/79, 8/31/79,
9/7 /79
10/8/78, 1/17/79,
4/17/79, 7 /15/79
9/7/78, 12/5/78,
3/2/79, 6/6/79
7/5/78, 7/29/79
5/30/78, 5/17 /79,
4/9/78
Monthly results
August 1978 through
October 1979
The qualification for two individuals involved in the tests
identified in 2b.a and 2b.h above were reviewed to determine
if the individuals were qualiffed in accordance with the
Technical Specifications and ANSI N18.1
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3.
(3)
The following facility administrative documents were used
during the review;
(a)
EM-09-04, fnservice Testing of Selected Safety Related
Pumps, Rev. 2
(b)
QAPP 11-51, Test Control for Nuclear Plant Operations,
Rev. 0
(c)
EM-09-01, Technical Specification Testing, Rev. 19
(d)
EM-09-02, Inservice testing of Plant Valves, Rev. 4
(e) Administrative Procedure Number 6 Technical Admini-
stration, Rev. 4
(f)
QAPP 6-51 Distribution and Control of Quality Related
Document
(g)
Administrative Procedure 10-3, Document Distribution
and Control
(h)
Administrative Procedure 10-3-1, Temporary Procedure
Change
(i) Administrative Proceudre 17.0, Control of Measuring
and and Test Equipment
(j)
QAPP 12-51 Control of Portable and Laboratory Measuring
and Test Equipment
(k)
QAPP 15-51, Contr~l of Nonconforming Items
c.
Findings
Unless discussed in the following sections of the report, the
surveillance activities were found to be in compliance with
regulatory requirements.
Shutdown Cooling System Test A0-3
The inspector reviewed the content of the test to determine if it
fulfilled the surveillance requirements of Technical Specification 4.5.3.a(l) "The portion of the shutdown cooling system that is
outside the containment shall be tested either by use in normal
operation or hydrostatically tested at 255 psig at the interval
specified in 4.5.3.d," 4.5.3(2) "Piping from valves CV-3029 ...
to discharge of safety injection pumps and containment spray
pumps ... 100 psig ... ," 4.5.3a(3) "Visual inspection made for ex-
- cessive leakage ... ," and the acceptance criterion of 4.5.3.b of
"less than 0.2 gpm under the normal head from the SIRV tank .
- 4 -
l
Test A0-3, Rev. 4, dated November 17, 1977, was performed July 5,
1978 and July 29, 1979, which fulfills the frequency requirement,
but the procedure does not fulfill the requirement of 4.5.3.a(l) in
that (1) Section 6.2 specifies a minimum test pressure of 255 psig.
The test pressure on July 5, 1978, was 225 psig and 227 psig on
July 29, 1979.
(2) The Section of piping between MOV3016 and valves
3199 and 3190, which contains a portion of the shutdown cooling
system that is outside the containment is not tested by the proce-
dures.
These two items appear to be in noncompliance with Technical Speci-
fication 4.5.3.a(l).
The test pressure as specified in Section 6.1 of the test procedure
is 100 to 150 psig in the suction piping of shutdown cooling system.
This appears to be in conflict with Technical Specification 4.5.3a(l),
but the basis contained on page 4-35 of the Technical Specification
states, "The test pressure (270 psig) achieved either by normal
system operation or by hydrostatically testing gives an adequate
margin over the highest pressure within the system after a DBA.
Similarly, the hydrostatic test pressure for the return lines from
the containment to the shutdown cooling system (100 psig) gives an
adequate margin over the highest pressure within the lines after a
DBA."
It was also noted the Specification requires testing at a minimum of
250 psig while the basis used 270 psig.
It was also noted that the acceptance criteria is given as 0.2 gpm
leakage.
The values recorded in the test are in milliliters per
minute.
It would seem logical to give the acceptance criteria in
the same units as the measurement is made to reduce errors.
Add-
itionally, Section 7 .1. 3 of the procedure requires that if the
leakage equals or exceeds one-half gallon per minute, a deviation
report will also be initiated. It would seem that one should be
initiated when the leakage exceeds the Technical Specification
acceptance criteria.
The above was discussed with the licensee and the licensee stated
the items would be resolved.
4.
Iodine Removal System Valved Out
During a review of completed. "Shutdown Cooling System Test" A0-3,
the inspector noted indications that for the test performed on
July 29, 1979, that valves 3364ES and 3363ES, NAOH to SI, had been
left in the closed position upon completion of the test, then at
some later time returned to the open position.
The valve line up
sheets to restore the system after testing (Appendix 5 and 7 of the
- 5 -
test) required these valves to be closed.
The pages containing the
signoffs for these valves were photocopies, which had then been
marked over in ink to show the valves had been opened.
The mark
over had been done by a shift supervisor who was on duty subsequent
to the completion of the test.
A temporary change was initiated on
August 1, 1979, to change the valve position on the checklist from
closed to open.
Piping Instrument Diagram M-204, Rev. 15 requires these valves to be
locked open.
The valves are manual valves located in the Engineered
Safeguards Rooms.
The function of the system is to add sodium
hydroxide to the recirculation water after a LOCA to establish a
neutral pH.
This addition requires operator action to operate
valves from the Control Room.
Location of the valves 3364ES and
3363ES would make them difficult to impossible to open after a LOCA
due to radiation levels in the Engineered Safeguards Rooms.
Tech-
nical Specification 3.19.1 requires the Iodine Removal System to be
operable during power operation.
System inoperability for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />
is allowed by the Technical Specifications.
A review of test records, logs and discussions reveal the following:
a.
July 29, 1979, sometime during A shift (00-08) - valves 3363ES
and 3364ES were closed in preparation for surveillance test
A0-3.
Basis - Initials on valve check off sheet and list of personnel
on A shift.
b.
July 29, 1979, sometime during B shift (08-16) - valves 3363ES
and 3364ES checked in closed position following test.
Basis - Initials and signatures on valve check off sheets and
list of personnel assigned to B shift on July 29, 1979.
c.
July 29, 1979, sometime during C shift (16-24) - a second check
of valve line up in accordance with check off sheets of A0-3
was conducted.
The valves were in the closed position.
Basis - Shift supervisors written notes in procedure, signature
on completed valve sheets and discussion with shift supervisor.
d.
July 30, 1979, sometime during A shift, the valves were opened.
The shift was following up on a question of valve numbering
they had had on the 29th but had not had time to resolve.
The
shift supervisor in attempting to resolved the matter sent an
operator to look at the valve labels.
The operator reported
their labeling and said they were closed.
The shift supervisor
questioned this and compared the present position to that
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required by startup valve check lists CL3.l and 3.2.
He then
ordered the valves open.
The shift supervisor then marked up
the completed copy of A0-3 to show the positions he had placed
them in.
A memo was sent to the Technical Superintendent re-
questing the A0-3 procedure be corrected.
This resulted in a
temporary change being initiated on August 1, 1979.
Basis - Initials on valve lineup sheet, July 30, 1979, memo
from shift supervisor, temporary change T-79-036, and discus-
sion with shift supervisors.
A review of the completed test procedure for the test ran
July 5, 1978, revealed that the valves had been left open upon
completion of the test.
The valve list had been modified to
indicate the valves should be left open with the shift super-
visor's initials. It appears that this was a change to the
procedure which was not made in compliance with the require-
ments of Technical Specification 6.8 and Administrative
Procedure 10-3-1, "Temporary Procedure Change."
This item is
considered to be in noncompliance with Technical Specification 6.8. If the procedure had been changed properly the problem
would not have occurred in 1979.
Technical Specification 6.9.2.a(6) requires a written report be
submitted to the NRC within 14 days of procedural inadequacies
which prevent or could prevent, by itself, the fulfillment of
function required of systems required to cope with an accident
analyzed in the FSAR.
The error in the A0-3 test procedure
could have prevented the sodium hydroxide system from fulfilling
its function and should have been reported as required by
Technical Specifications 6.9.2.a(6) when the error was detected
in the procedure.
This appears to. be an item of noncompliance.
5.
Control of Measuring and Test Equipment
During reviews of completed "Shutdown Cooling System Test" A0-3
procedures for traceability of test equipment used and proper
calibration of test equipment, the inspector noted the following:
a.
July 5, 1978 test.
No serial number was recorded on the data
sheet (Appendix 3) for the pressure gauge used during the test.
A calibration sheet was attached to the completed procedure
which indicated a gauge serial number 6-20-78-1, "new test
gauge" had been calibrated for A0-3 test on June 20, 1978.
The
calibration sheet recorded that dead weight tester serial
number 8428-100018 was used to calibrate the gauge on June 20,
1978.
The dead weight tester had last been calibrated on
June 13, 1977, and had a calibration due date of June 13, 1978.
The calibration sheet contained a reference to Deviation Report
-
7- -
(DR)78-220.
A review of the DR showed it had been initiated
on June 20, 1978, and an evaluation due date had been assigned
of July 21, 1978.
The tester was calibrated on September 18,
1978, and found to be in calibration.
The evaluation and dis-
position of the DR was completed on November 28, 1978.
Dis-
cussions with personnal and review of* the DR show that at the
time of use it was known the tester was past due for calibration
and DR was initiated to document this.
The decision to use the
tester had been.made by the I&C Engineer as no other tester was
available at the time and that the tester appeared to be in
fine working condition.
b.
July 29, 1979 test.
Three different serial numbers had been
recorded on the data sheet (Appendix 3) for the gauge used
(only one gauge used in the test).
Two of the serial numbers
had corresponding calibration dates recorded.
Calibration
data sheets attached to the procedure showed gauge serial
number 8-676-1 had been calibrated on July 17, 1979.
This
gauge serial number corresponded to one of the serial numbers
recorded on the data sheet.
During the inspection on October 23,
1979, a licensee's representative placed a note on this sheet
that the gauge was broken on A shift July 29, 1979.
The inspector
observed a gauge with this serial number that had been broken.
The second calibration data sheet attached did not record a serial
number for the gauge being calibrated.
The date of this calibra-
tion was July 29, 1979.
The review section of this calibration
data sheet had not been signed off.
Under the calibration equipment
used in calibrating this gauge a test gauge serial number 8428-00392
was recorded.
This serial number also appeared on the A0-3 data
sheet.
The licensee showed the inspector a gauge in a plastic
bag (for contamination control) that had a tag attached which was
annotated as A0-3 test gauge and had a calibration sticker dated
July 29, 1979.
A manufacturer's QC type sticker on the back of
this gauge contained the number 8620 which was also one of the
numbers recorded on the A0-3 data sheet.
A review of the licensee QA program and administrative proce-
dures to implement the requirent of 10 CFR SO, Appendix B,
Criteria XII, Control of Measuring and Test Equipment, revealed
the following:
(1)
Administrative Procedure 17.0, Rev. 0 dated November 2,
1977, states the equipment will be traceable and will be
labelled to indicate status.
(2)
QAPP for Operations 12-51, Rev. 1, dated October 31, 1977,
Control of Portable and Laboratory Measuring and Test
Equipment in Section 5.11, states that test equipment not
recalibrated within the calibration interval are to be
considered nonconforming per QAPP 15-51 until corrective
measures have been taken per QAPP 16-51, which is basically
- 8 -
taped, marked or segregated to prevent use until released
for use after disposition of the DR is completed per QAPP
16-51.
The control of test equipment used in performing A0-3 on
July 5, 1978, and July 19, 1979, does not appear to be in
noncompliance with 10 CFR SO, Appendix B, Criterion XII
requirements and the licensee's QA Program Procedures
12-51.
6.
Overpressure Protection System Surveillance Testing
A review of procedures and test records was conducted to determine
the licensee's compliance with Technical Specification 4.1.la and b ..
This specification was issued on September 10,1979.
The facility
was in refueling at that time.
At the time of this inspection the
reactor vessel head was being installed, the CRD tool access flanges
were removed and the pressurizer safety valves were also removed.
Therefore, the only portion of the surveillance which was required
was verification of PCS vent path.
D-W-1 and SH-1 which are daily,
weekly and shift checks by the operators fulfill the requirements of
Technical Specifications 4.1.1.a3 and 4.1.1.b.
Shift records for
the period October 22-25, 1979, were reviewed to verify implementation
by the licensee.
The licensee presently has no approved procedures for the surveillance
requirements of Technical Specifications .4.1.la.1, 2 and 4.
These
are channel functional tests of the PORV, channel calibration, and
valve testing per ASME Section XI, Section IWV Category C valves.
The inspector discussed with the licensee that his surveillance in
accordance with these sections of the Technical Specifications must
be current prior to placing the PORV portion of the system in service.
That either he must be able to show testing of the PORV's per Section
IWV of the code within the last five years or test them prior to
placing them in service.
An acceptable alternative would be to ob-
tain a change to the Technical Specification.
This was also discussed
at the exit interview.
This item is considered an unresolved item pending actions by the
licensee. (255/79-20-1)
7.
Charging Pump Capacity
During a review of data and acceptance criteria for procedure M0-20
Inservice Test Procedure Charging Pumps the inspector noted that
acceptance criteria and data indicated flows below 40 gpm.
These
acceptance criteria are based upon reference values obtained in
accordance with ASME Section XI.
A review of section 14.14 of the
FSAR for the steam line break analysis shows two of the three 40 gpm
- 9 -
charging pumps are used to deliver concentrated boric acid.
Section
14.17 for the LOCA analysis also mentions charging pumps of 40 gpm
capacity.
The acceptance criteria used in M0-23 (Temporary Change
T-79-023 to M0-20, Rev. 11) allows flows as low as 34 gpm.
It is
not clear if the values given in the FSAR are nominal or minimum
valves.
If they are nominal, what is the lowest acceptable flow
rate?
The inspector discussed this with the licensee.
The inspector
stated that the acceptance criteria used must be consistent with the
values used in any safety analysis, even though they may be in com-
pliance with Section XI requirements.
That the licensee should not
enter a mode where the charging pumps are required, until he can de-
monstrate that flow rates below 40 gpm are acceptable.
The licensee
acknowledged the inspector's comments.
This item is considered to be an unresolved item pending actions by
the licensee. (255/79-20-2).
During the review of M0-20 the inspector noted that on April 12, 1979
the acceptance criteria (refernce value) for the B pump was changed
to 39.1-34 gpm.
The inspector questioned the reason.
The licensee
suggested it might have been because of maintenance.
A comprehensive
search of maintenance records failed to show any maintenance on the
pump at that time. It was later found that it had been changed due
to a Deviation Report initiated as the result of a QA audit which had
found the value should have been changed in January 1979.
The desir-
ability of prompt changes and the need to maintain the basis for re-
ference values in an easily retrievable location was discussed.
The
licensee acknowledged the inspectors comments.
8.
Reactor Internals Vibration Monitoring
The inspector reviewed completed tests MT-15 conducted. through the
period of May 30, 1979, to September 7, 1979, to determine compliance
with the surveillance requirement of Technical Specifications 4.13.
The following was noted:
a.
Data sheets used in the performance of the test were labelled
Rev. 7, instead of the current revision, Rev. 8.
A review of
the data sheets showed they were a Rev. 7 which had been altered
to contain the same requirements as Rev. 8.
This was brought
to the licensee's attention and the supply of the Rev. 7 sheets
was removed.
The potential for problems associated with the
control of data sheets was discussed with the licensee.
b.
Some graphs of data were not well labelled in that they required
explaination as to range, scale and various values.
This was
discussed with the licensee and the licensee agreed to improve
the labelling .
- 10 -
c.
A review of the frequency of the Phase I measurements for July
1979 revealed that they were taken on July 2, 11, 20, 31, 1979.
The facility operated at power for the entire month with no
trips.
Power reductions occured for short periods on July 11
and 25, 1979 due to equipment problems.
Technical Specification 4.13.c states that "as a minimum during normal plant operation,
Phase I measurements shall be recorded and analyzed once per
seven days.
The licensee's procedure does not define normal
operation.
The type of data taken would not be meaningful dur-
ing power changes or during large xenon changes.
Based upon
this, it would have been meaningless to take the measurement on
the 25th and possibly for a period on the 26th.
Data was taken
on the 11th prior to the power reduction.
Technical Specification 4.0.2 allows an extension of interval not to exceed 25% or about
nine days in this case.
Also, the total maximum combined interval
for any three consecutive intervals shall not exceed 3.25 times
the interval or about 23 days in this case.
The interval from
July 20 to 31, 1979, exceeds the 25% and the period from July 2
to 31, 1979, for three intervals exceeds the 3.25 times allowance.
Therefore, the above appears to be in noncompliance with Technical
Specification 4.13.c.
9.
ASME Section XI Valve Test
The inspector reviewed completed valve test procedure Q0-5 for the
licensee's implementation of inservice testing of valves in accordance
with ASME Section XI; 1974 Edition with Addenda through Summer 1975
as required by 10 CFR 50.SSa(g).
The licensee has applied for exemption
from some of this timing requirement of Section 1WV-3410c (3) and his
procedure reflects his exemption request.
Valve CV-0522B, Steam B to
turbine driven auxillary feedwater pump, stroke time was measured as
42.2 seconds on January 17,1979, and 57.0 seconds on May 17, 1979.
Even considering the licensee's exemption. request, the frequency of the
testing should be increased to once per month per the code.
This was
not done in this case and appears to be in noncompliance with 10 CFR
50.SSa(g) and ASME Code Section XI.
It was also noted that time for
MOV-2140 Boric Acid Injection valve increased from 2 seconds to seven
seconds between October 8, 1978 and January 17, 1979.
The review of
the test by the Project Engineer which is supposed to identify the
need for increased frequency of testing when there are changes in
stroke time does not appear to have been done for January 17, 1979
and April 17, 1979 test, based upon a discussion with the Engineer
and the lack of sign offs on the completed tests. It was also noted
that on the October 8, 1978, steam generator blowdown isolation valve
CV-0770 was not cycled, and no note was made as to why the valve was
not cycled.
- 11 -
10.
Diesel Fire Pumps Battery Surveillance
Technical Specification 4.17.2.2.b(2) requires the licensee, at an
interval of every three months, to verify that the specific gravity
of the starting battery bank is appropriate for continued service of
the battery.
The inspector reviewed completed QE-9 Diesel Fire Pump
Battery Surveillance Procedures from 9/7/78, 12/5/78, 3/2/79, 6/6/79.
The following was noted:
a.
The 9/7/78 test had an acceptance criteria for specific gravity
of 1.200 - 1.265 as established in temporary change T-78-051.
Cells 5 and 9 in lower bank P-41 had specific gravity readings
of 1.270. It appears no actions were taken on these readings
which exceeded the acceptance criteria.
b.
By the test on 3/2/79 T-78-051 had been incorporated as a
permanent change in Rev. 2.
The acceptance criteria was
1.200-1.265.
Data taken on 3/2/79 revealed a number of cells
at a specific gravity of greater than 1.265.
A temporary
change was written on 3/19/79 which raised the upper limit to
1.270 and the test results were approved on 3/20/79.
c.
Test data on 6/6/79 revealed a number of cells exceed the 1.270
limit.
Another temporary change was initiated and approved on
6/25/79 to raise the upper limit to 1.280.
The test results
were approved on 6/25/79 based upon the raised acceptance
criteria.
P41 upper bank had two cells with low specific
gravity.
A maintenance order was initaited on 6/8/79 and work
completed on 6/22/79 to raise the specific gravity.
d.
The inspector attempted to review the September 1979 results
and they were not in the file.
The test was found in the
electrical maintenance department.
Review had not been com-
pleted.
Data taken on 9/6/79 showed a number of cells exceeded
the 1.280 limit. A Deviation Report was initiated on 9/20/79.
As of 10/30/79, neither the DR or results of the test procedure
had been signed off as acceptable by the licensee.
The DR had
an evaluation due date of 10/21/79 assigned.
The time interval between observing a reading outside an accep-
tance criteria, slow corrective actions and continual adjustment
of acceptance criteria was discussed with the licensee. It is
not clear how the licensee can take credit for operable equipment
when the surveillance test results exceed acceptance criteria.
This is considered an unresolved item pending review by the
licensee and Region III.
(255/79-20-3)
- 12 -
11.
Surveillance Test Procedures
The inspector noted that a number of surveillance test procedures do
not specify the qualification of test personnel.
QAPP 11-51 requires
the qualification of personnel to be included in surveillance test
procedures.
This was discussed with the licensee.
The licensee
stated that presently procedures were in the process of receiving
periodic review and that this review would be correcting items such
as this.
The licensee's use of acceptance criteria in procedures is at times
questionable.
Examples are discussed in Section 3, 7, 9 and 10 of
this report.
These deal with incorrect, misleading, or not meeting
acceptance criteria.
Another example was observed in the review of
R0-22, Rev. S, Control Rod Drop Times.
As an acceptance Criterion
in this test, Section 3.2 states "Turbine runback will automatically
decrease the maximum power to less than or equal to 70% rated power."
The test procedure does not test the runback feature.
The runback
feature has been deleted from the facility. It only tests the rod
drop alarm.
The test results were reviewed and approved by the
licensee, which leads to questions as to the quality of review and
the comparison of results to acceptance criteria. In many of the
procedures the acceptance criteria are only listed in Section 3 and
not restated where the measurement or comparison is made.
The in-
spector believes some improvement can be achieved by restating the
acceptance criteria where the measurement is made.
This was discussed
with the licensee.
12.
Unresolved Items
- Unresolved Items are matters about which more information is required
in order to ascertain whether they are acceptable items, Items of
Noncompliance, or Deviations.
Unresolved Items are disclosed during
the inspection as discussed in Paragraphs 6, 7 and 10.
13.
Exit Interview
The inspectors met with licensee representatives (denoted in
Paragraph 1) at the conclusion of the inspection on October 30,
1979.
The inspectors summarized the purpose and the scope of the
inspection and the findings.
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