ML18152B172
| ML18152B172 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 05/24/1988 |
| From: | Belisle G, Mellen L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152B170 | List: |
| References | |
| 50-280-88-11, 50-281-88-11, NUDOCS 8806200440 | |
| Download: ML18152B172 (13) | |
See also: IR 05000280/1988011
Text
,,~1>-R REG,11
UNITED STATES
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NUCLE:AR REGULATORY COMMISSION
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REGION II
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101 MARIETTA STREET, N.W.
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ATLANTA, GEORGIA 30323
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Report Nos.:
50-280/88-11 and 50-281/88-11
Licensee:
Virginia Electric and Power Company
Richmond, VA
23261
Docket Nos.:
50-280 and 50-281
Faci 1 ity Name:
Surry 1 and 2
License Nos.: DPR-32 and DPR-37
Inspection Conducted:
March 29 - April 1 and April 11-15, 1988
. .
-'
/
Inspector:
r£ '(//)-f_-z_ L /Cc'" _4,.-
L. Mellen
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Accompanying Personnel:
T. Cooper
K. Jury
~. Lea
.
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Approved by:
/i,;f/,~i:L /Lc."f-*
G. A. Be 1 is 1 e
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Quality Assurance Programs Section
Operations Branch
Division of Reactor Safety
SUMMARY
sh
Date
Scope:
This routine, announced inspection was in the area of quality assurance
effectiveness.
Results:
Two violations were identified:
Terminating an Unusual Event (UE)
and Limiting Condition of Operation (LCD) prior to completing appropriate
corrective actions; and
Failure to follow Technical Specification (TS) 3-12.C.
requirements .
8806200440 880607
ADOCK 05000280
Q
REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- 0. Benson, Station Manager
- H. Collar, Quality Auditing Supervisor
- E. Grecheck, Assistant Station Manager
S. McKay, Plant Engineering Supervisor
- G. Miller, Licensing Coordinator
- H. Miller, Assistant Station Manager
- 0. Ogren, Superintendent of Maintenance
- G. Pannell, Director Safety Evaluation and Control
- J. Price, Quality Assurance Manager
- R. Saunders, Manager of Nuclear Programs
Other licensee employees contacted included engineers, technicians,
operators, mechanics, security force members, and office personnel.
NRC Resident Inspectors
B. Holland
- L. Nicholson
- Attended exit interview
2.
Exit Interview
3.
The inspection scope and findings were summarized on April 15, 1988, with
those persons indicated in paragraph 1 above.
The inspector described the
areas inspected and discussed in detail the inspection findings.
No
dissenting comments were received from the licensee.
Item Number
280, 281/88-11-01
280, 281/88-11-02
Status
Open
Open
Decription/ Reference Paragraph
Violation - Terminating an UE and
LCO prior to completing appropriate
corrective action (paragraph 9.d).
Violation - Failure to follow TS 3.12.C
requirements
(paragraph
9. d).
The licensee did not identify as proprietary any of the materials provided
to or reviewed by the inspectors during this inspection .
Licensee Action on Previous Enforcement Matters
(
2
This subject was not addressed in the inspection.
4.
Unresolved Items
Unresolved items were not identified during this inspection.
5.
Quality Verification (TI2515/78)
The objective of this inspection was to assess quality assurance effectivess.
For this report, quality assurance effectiveness is defined as the ability
of the licensee to identify, correct, and prevent problems.
The term
quality assurance effectiveness is used in this a~plication, but it is not
meant to be limited to the licensee's Quality Assurance Department.
It
is the total sum of all efforts to achieve quality results.
This was a performance-based inspection.
The principal effort was to
determine whether the results that the Qua 1 i ty Assurance program was
designed to accomplish were actually achieved.
However, when problems
were identified, appropriate regulatory requirements were enforced.
The inspection effort was divided into the following areas:
1.
Quality Assurance
2.
Design Control
3.
Maintenance
4.
Operations
Each area is addressed separately in this report.
6.
Quality Assurance (35701, 40702, 40704)
The effectiveness of the licensee's Quality Assurance (QA) organization
was assessed by examining and evaluating audit adequacy, corrective
action effectiveness and timeliness, trend analysis, personnel qualifica-
tions, and procedures and practices.
The licensee's QA organization
consists of six supervisors (one administrative) reporting to the QA
Manager.
Two supervisors oversee auditing and surveillance functions,
two oversee Quality Control (QC) inspection activities, and one oversees
(NOE)
inspections.
The majority of the
in specter I s effort was concentrated in the auditing and survei 11 ance
functions. Some QC functions were also evaluated.
The inspector evaluated the QA department size and experience level as
well as seven auditors* qualifications.
The organization appeared to be
sufficiently structured to encompass the QA functions necessary in evalua-
ting the adequacy of plant activities.
Responsibilities and personnel
reporting hierarchy were well delineated. The QA Audit group consisted of
a Supervisor, a Staff Specialist, two Senior Quality Specialists, and four
Quality Specialists, all of whom were certified as lead auditors.
Most
auditor's technical qualifications had been obtained through industry
experience.
The inspector noted a lack of degreed auditing personnel in
the QA department.
Six people in the department; however, are currently
working toward degrees.
Despite the lack of formal higher education, the
3
auditor 1 s qualifications appeared to be adequate.
An observation [in this
area] was identified in th!lt the audit participation requirement for
newly certified lead auditors was met by having the auditors participate
in short duration, procedure compliance oriented audits.
The auditors
were certified after participating in the minimum number of audits.
This
practice could possibly lend itself to certifying lead auditors that may
need more audit participation experience before leading audits or perform-
ing audits on their own.
The inspector reviewed the following audits in
the areas of corrective action, maintenance, design control, in-service
inspection, and operations.
Audit Number
S 86-15
S 86-09
S 87-08
S-87-22
S 87-01
S 87-07
S 87-09
S 88-20
Title
Design Control Program
Corrective Actions
Corrective Action
Mechanical Maintenance
and Welding
Operations Administration
Inservice Inspection
Corrective Action
Instrumentation Maintenance
Report Date
February 12, 1987
May 28, 1987
August 5, 1987
October 8, 1987
December 8, 1987
January 13, 1988
February 23, 1988
March 17, 1988
Two weakness were identified in the licensee 1s auditing program, one of
which the licensee had also identified. After reviewing the above audits,
it appears that the licensee 1s audit program utilized procedural compliance
veri fi cation as the key i ndi ca tor in assessing department performance
during an audit. The licensee acknowledged this concern and in fact, had
identified this as a programmatic weakness prior to the inspection. The
QA department is in a transitional period in this audit philosophy;
however, the more recent audits and findings reviewed were still oriented
toward procedural compliance.
The inspector reviewed QA 1 s corrective action verification methodology,
which included evaluating corrective action adequacy on audit findings.
The inspector identified a weakness in this area, in that audit finding
closure is often times based on procedure revisions or, in some cases
where procedures are not followed, a reaffirmation by management that
procedures will be followed.
This practice in itself is not a problem;
however, as part of the corrective action process, corrective action
implementation must be verified.
The inspector identified that there
were at least two instances where audit findings were closed without
verifying corrective action implementation where the condition identified
in the finding still existed after finding closure.
Audit finding
S87-08-02 dealt with required QA notifications (i.e., audit finding
responses, completion dates) not being sent to QA in a timely manner.
The station manager issued a memo to cognizant station management stressing
the need to meet procedural time frames in response to audit findings .
This memo was cited as the basis for closing finding S87-08-02, without
verifying effective implementation of this memorandum.
This deficiency
was not re-evaluated during the next Corrective Action Audit, S87-09.
4
Additionally, a memo on February 17, 1988, was issued from an auditor to
the Auditing Supervisor that states in part:
11 *** We should track the time
it takes for QA to receive each response so that this information could be
gathered to show Station Management that there is a serious problem with
late responses.
11
During audit S87-09, a finding (02) was written concern-
ing performing work on safety-related systems without the use of approved
written procedures.
As a result, SUADM-M-16, Operation of the Maintenance
Department, was revised and stated that only work determined to be
11minor
ma i ntenance
11 could be performed without written procedures, and the audit
finding was closed (on April 4, 1988) without verifying implementation.
Upon review of QC records on work packages reviewed from March 3, 1987
(date of SUADM-M-16 revision), until April 13, 1987, there were 83 safety-
related WOs (Mechanical and Electrical Maintenance) reviewed by QC that had
no procedures.
The large majority of these WOs were probably completed
before the effective date of the procedure revision; however, this was not
evaluated by QA prior to closing the audit finding.
This weakness is offset, somewhat, by the fact that QA has in the past
formally re-evaluated findings where correctiv~ action implementation was
not verified before finding closure.
However, in the case of audit
finding S87-08-02, corrective action implementation was not initially
verified, implementation was not verified on the subsequent audit (S87-09),
and based on the internal QA memorandum discussed above, the situation
still exists. This situation was discussed with the Station Manager, and
the inspector was told that unless QA keeps the audit finding open to
verify implementation or reverifies and writes a new finding, the station 1 s
responsibility for corrective actio~ adequacy is complete upon initial
finding.
This combination of station philosophy and QA methodology on
closing audit findings based on procedure revisions or reaffirmation of
following procedures without verifying implementation, could allow a
deficient condition to exist until possible reverification, if reverifica-
tion occurs. This allows a situation to exist where the adequacy of steps
to prevent recurrence of deficiencies may not be evaluated, in that QA has
no formal mechanism by which to ensure this evaluation for all findings.
This situation is exacerbated by the fact that revision to NODS-QA-01,
Corrective Action, removed stringent requirements for escalation of
corrective action response and resolution delays.
The QA department does not have a formalized trending program for correct-
ive action documents; however, there are several seemingly effective
informal methods used by QA to evaluate recurring deficient areas.
A
strength exists in the fact that if a known deficient area is to be
audited, QA sometimes utilizes matrices to identify potential weak areas
that enables an auditor to concentrate in those areas. The matrices were
utilized in Audits S87-07 and S87-09 concerning weakness in the inservice
inspection program and in the processing of Nonconformance Report (NCRs).
It is a strength of the auditing group that these matrices are utilized,
yet a formal trending program would encapture more recurring deficient
area.
The QA department has realized this and is in the process of
implementing a
11 How To
11 program for audits as well as trending improvements.
5
This "How To
11 program consists of making a reference file for all QA
audits which will include, but is not limited to, the following;
past
audit findings,
NRC violations and concerns,
surveillance findings,
pertinent procedure revisions, and relevant documentation.
This should
be beneficial to the QA organization not only in implementing a more
performance oriented audit program, but wi 11 al so help identify adverse
and positive trends in certain areas and be a helpful indication of
performance history for a certain group or department.
It appears that
one other benefit will be the continued reduction in the excessive time it
takes in conducting an audit. The time span has already been reduced from
107 man-days per audit in 1986 to 33 man-days for the four audits conducted
in 1988.
Another strength evident in the QA department is the cross training of
personnel within the department.
Surveillance personnel are certified as
auditors and many auditors have also had QC certifications in the past
This allows QA department needed flexibility in allocating
manpower as needed.
This enabled the QA department to remain stable with
minimum use of contract personnel.
Additionally, the department has
implemented using system guidelines to familiarize surveillance and
inspection personnel with system descriptions, transients associated with
the systems, a review of component history, scope of work to be performed
during outages, lessons learned, and surveillance scope and activities .
These guidelines should be advantageous to any QA personnel monitoring
plant activities.
The licensee's QA department appeared to be well organized and implementing
improvements in deficient aspects.
Considering the direction of this
department and its current performance, with the exception of the weakness
noted, the effectiveness of the QA department is adequate.
7.
Design Control (37702)
The effectiveness of the licensee's QA program in the area of design
control was assessed by reviewing design change packages (DCPs),
engineering work requests (EWRs), QA audits, and by interviewing cognizant
personnel.
Eight DCPs were reviewed to determine the adequacies of documents within
the design package.
The work requested on each DCP was completed and the
design change package closed.
A 11 documents required by procedure
SUADM-ENG-03, Design Change, were contained in each package reviewed.
The
technical review and safety analysis (10 CFR 50.59 and CFR 72.35) were
provided when required.
Each technical review and safety analysis reviewed
were adequate.
Each design package reviewed required field changes in order to complete
implementation.
Several DCPs required greater then 20 field change
rev1s1ons.
DCP-84-53, *ory Cask Independent Spent Fuel Storage Installa-
tion, required 49 field changes to complete implementing the DCP.
Each
6
field change was detailed and encompassed changes that resulted from
implementing the DCP.
The inspector also reviewed EWRs and temporary modifications to determine
the adequacy of the design control program and documentation.
The
following temporary modifications and EWRs were reviewed:
2-87-81
2-88-2
2-88-3
2-88-10
2-88-17
86-162 87-337
87-400
The documentation reviewed was
completed as per plant procedures,
SUADM-0-11 (AMO 29.5), Function Bypass and Temporary Modification Controls,
and SUADM-ENG-01 (AMD-9), Engineering Work Request. A significant increase
in the quality of the technical reviews and safety analysis provided with
each temporary modification and EWR was noted for evaluations written
after 1986.
The inspector concluded that there has been an increasing trend in the
quality of DCPs and the design control program is adequate based on the
material reviewed.
8.
Maintenance (62700, 62702)
The inspector reviewed the maintenance area to make an overall assessment
of the performance of the Operations group.
The assessment resulted from
direct observation of work activities, personne 1 interviews, and a
reviewing records of past activities.
a.
Quality Maintenance Team Program
The inspector examined the use of the Quality Maintenance Team (QMT)
program during the 1987 and 1988 time period. Training requirements
for the program, as outlined by 1 icensee procedure SUADM-SP-02,
ADM-113,
11Quality Maintenance Team (QMT)
11 , approved August 27, 1987,
were reviewed.
The licensee procedure does not state to what extent
the program will be implemented; however, the maintenance supervisors
interviewed stated that the goal is to have all electricians and
mechanics, along with the foremen, qualified to a QMT.
At present,
all but the newer people have completed training as (QC) inspectors,
per ANSI N45.2.6, Qualifications of Inspection, Examination, and
Testing Personnel for Nuclear Power Plants. The majority of the
personnel have completed training as advanced radiation workers.
This training has enhanced the normal training and experience
received by maintenance personnel, making them more aware of the
requirements and bases for maintenance practices.
7
Per the licensee procedure, maintenance personnel utilized as QC
in specters mu st be approved by a QC supervisor and, during the
duration of the task, report to the QC supervisor.
The inspector
interviewed numerous personnel that completed the training and were
certified as Level 2 QC inspectors.
The inspector concluded that the
personnel interviewed had a thorough knowledge of the requirements
for reducing problems which arise when both the workers and the
inspector report to the same supervisor.
The inspector observed work in process and examined completed work and
found that the work was completed in an adequate manner by maintenance
department personnel.
The QMT program has effectively increased the knowledge and quality of
the maintenance department and is considered a strength.
b.
Equipment Tagging
Licensee procedure SUADM-0-13, ADM-29-7, "Operations Department -
Operations, Maintenance and Tagging", approved November 23, 1987,
outlines the process used to remove equipment from service to protect
personne 1 and p 1 ant equipment during maintenance.
Fo 11 owing the
independent verification conducted by Operations Department personnel,
the person directly in charge of the work must perform an in-field
verification of the adequacy of the tagout prior to beginning work.
The inspector interviewed personnel in both the Operations and the
Maintenance Departments and determined that the personne 1 were
familiar with the purpose and requirements of the equipment tagging
program.
The maintenance personne 1 indicated that the maintenance
verification does not consist of checking the compliance with the
tagging order; it determines and verifies the safety of the condition
of the equipment required for the maintenance task.
The inspector reviewed the Deviation Reports (DRs) for the 1987 and
1988 time period and did not identify any evidence of a history of
tagging related problems.
The equipment tagging program at Surry and
its effective implementation is considered a strength in both opera-
tions and maintenance.
c.
Predictive Maintenance Program
The inspector reviewed predictive maintenance utilization. Predictive
maintenance has been incorporated int6 routinely scheduled equipment
survei 11 ances. A notation was present in the Contra 1 Room Survei 11-
ance Schedule indicating that predictive maintenance was scheduled
to be performed concurrently with surveillances.
The Maintenance Engineering Supervisor was interviewed concerning the
predictive maintenance program.
Predictive maintenance has been
included in daily activities on site.
The program has sucessfully
increased maintenance activity efficiency.
There have been several
8
instances where predictive maintenance determined that the cause of
high pump vibration was coupling misalignment, which prevented the
need for pump disassembly for troubleshooting.
This effective
utilization of the predictive maintenance program is viewed as a
strength.
d.
Station Nuclear Safety and Operating Committee (SNSOC) Reviews of
Procedure Deviations
Licensee Technical
Specification 6.4.E requires that temporary
changes to procedures receive an approval from the SNSOC within 14
days of the change.
A review of station DRs determined that since
January 1987 there have been approximately 60 DRs written on late
SNSOC reviews of temporary changes to procedures.
The inspector reviewed 35 DRs and determined that each DR contained
an average of three procedures which had received a late SNSOC review.
Greater than 85 percent of these deviated procedures with late reviews
were the responsibility of the maintenance department.
The SNSOC
identified this problem in meeting 87-335 on December 18, 1987;
11 E.
Discussion was led by the SNSOC Chairman concerning station
deviations as a result of procedure deviations that had a
late SNSOC review.
This violates Technical Specification 6.4.E.
The importance of timeliness in the 14-day review
requirement temporary changes to procedures was emphasized.
Each member agreed to ensure that this issue would receive
additional attention in the upcoming year.
11
The inspector examined the rate at which the procedures were
reviewed late since the problem was identified by the SNSOC and
- observed that it had not significantly changed.
Site management
is aware of this problem, and has made appropriate changes which
have the potential of correcting the problem.
Late procedure
reviews are identified as a weakness.
Observations
Interviews conducted with personnel in both the maintenance and the
operations departments, revealed that there exists a difference of
opinion between the management and the line employees in several areas:
1)
Second level managers and above consider the communications
between themselves and their employees to be one of the main
strengths at the site.
Conversely, first line management and
personnel below these position expressed the consensus opinion
that poor communications between line employees and top level
management was a major weakness at the site.
9
2)
The training department considers the training given on modifica-
tions to licensed personnel to be a strength in the training area.
The licensed personnel interviewed, both ROs and SROs, consider
training received on modifications to be weak, lacking timeliness
and accuracy.
These two items are offered as observations which resulted from the
opinions received from various personnel interviewed on site.
e.
Work Orders
f.
The inspector noted several discrepancies in work order documentation
for a small (five) sample of work orders reviewed for installing a
vent rig on the charging system.
Although the work performed in each
of the five cases was essentially identical, the work orders were all
documented differently.
The following table indicates some of the
differences noted:
WO #56144 EQ-yes, Nuclear Safety-no, Class lE-yes, Tech Spec-3.2,
Tagging Required-28 items, tools required - NIA, Drawing Require -
22448FM-888.
WO #55695 EQ-no, Nuclear Safety-no, Class lE-no, Tech Spec-NIA,
Tagging Required-23 items, tools required-NIA, Drawing Required-
WO #59597 EQ-yes, Nuclear Safety-yes, Class lE-yes, Tech Spec-NIA,
Tagging Required-NIA (OPS Standby), tools requi red-2, Drawing
Required-NIA
WO #56845 EQ-yes, Nuclear Safety-yes, Class lE-yes, Tech Spec-3.3,
Tagging Required-23 items, tools required-3, Drawing Required-
11448FM-888.
WO #57778 EQ-yes, Nuclear Safety-no, Class lE-yes, Tech Spec-3.2,
Tagging Required-2 items, tools required-2, Drawing Required-
11448FM-88B.
The inspector interviewed the appropriate Maintenance and Operations
personnel and concluded the work had been consistently and correctly
performed.
Due to the fact the actual work was performed correctly,
these are identified as a weakness in the inconsistency and inatten-
tion to detail in documenting of work orders.
Maintenance Documentation
The inspector reviewed three examples of completed Mechanical Correc-
tive Maintenance procedure, NMP-C-G-227, Horizontal Rotating Equipment
Alignment.
Each of the completed procedures had errors in the final
approved documents.
The following are examples of the errors:
Mark Number 1-CH-P-2C dated January 15, 1988, step 3.3 required
the entry of the name of the Maintenance Engineer or to NIA the
step.
Instead, the entry was a procedure number.
Steps 5.5.2
g .
10
through 5.6.2 require an entry of N/A for the opposite shaft but
they were left blank.
Step 6.2 required the entry of a work
request number but it was left blank.
Mark
Number
l-CH-P-2A dated November 30, 1987, step 5. 7. 5
required an entry for #2 Bar sag; this was left blank.
Mark Number l-CH-P-2C dated November 13, 1987, attachment 1,
page 1 of 2, the acceptance criteria given should have been .002.
The method of inspection was listed as visual but was actually
by dial indication.
The final alignment of l-CH-P-2C was *left
outside of the correct acceptance criteria.
The above examples are not all inclusive but represent a general lack
of attention to detail in the completion of maintenance documentation.
Upon discussions with the QC Supervisor, it was noted that several of
these discrepancies should have been identified during the QA review
and the documents should not have received QA approval.
This inatten-
tion to detail in maintenance documentation is identified as a
weakness.
Material Storage
The inspector noted several examples of category 1 materials which
required level A and B storage that were left in the laydown area
behind the maintenance shop.
The licensee reviewed this practice
and immediately corrected the deficiencies during the inspection.
This is identified as a weakness in the storage of some category 1
materials.
9.
Operations
The inspector reviewed the operations area to make an overall assessment
of the performance of the operations group.
The assessment resulted from
direct observations of work activities, personnel interviews, and reviewing
records of past activities.
a.
Shift Turnover
The inspectors witnessed several shift turnovers.
The turnovers were
conducted in accordance with appropriate procedures.
The thorough,
we 11 organized, and professionally conducted shift turnovers were
considered a strength in the operational area and contributed to the
overall effectiveness of the operations group.
b.
Contra 1 Room Demeanor
During the direct observation of control room activities, the inspector
determined that the professional attitude demonstrated during shift
turnover represented the general daily control room demeanor.
As in
the case of shift turnover, the professional control room demeanor has
contributed to the overall effectiveness of the operations group.
11
c.
Post Trip Reviews
The inspector reviewed several post trip reviews.
There has been an
overall improvement in the review quality, with the most recent
reviews delineating appropriate corrective actions and thorough defini-
tive root cause analysis.
The improvemenl in post trips reviews is
considered a strength.
d.
Inoperable Control Rods Due to Failed Phase Control Cards
At 0102 on March 5, 1988, while operating at 100 percent power, Unit 2
received a control rod urgent failure alarm.
The control rod urgent
failure resulted from a phase control card failure in the 1BD power
cabinet.
This failure prevented the normal movement of the Band D
control rod banks.
At 0302, the licensee began ramping down in power
at 60 MWE/HR.
At 0307 a Notification of Unusual Event (NDUE), as
required by the Surry Power Station Emergency Plan which implements
the requirements of 10 CFR 50 Appendix E, was declared due to a reduc-
tion in power required by a TS LCD.
At 0409, the failed phase control
card was replaced and the urgent failure alarm was cleared.
The
licensee stopped the power reduction ramp.
At 0412, the licensee
exercised the D control bank.
At 0432, the NDUE was terminated.
At
0437, the licensee attempted to perform surveillance testing (PT-06)
on 1B control bank and received a second control rod urgent failure
alarm.
At 0445, the second failed phase control card was replaced.
At 0530, the D contra l bank was realigned.
At 0548, PT-06 was
satisfactory completed on the B control bank.
The licensee terminated the NDUE prior to completing all testing for
the circuitry affected by replacing the phase control card.
After
performing the appropriate tests on the affected circuitry, the B
control bank was still inoperable.
The card was replaced for a
second time, and all subsequent testing performed was satisfactory.
In a similar manner the LCD was terminated prior to completing the
appropriate corrective action.
This is identified as violation 280, 281/88-11-01, Terminating an UE
and LCD when, in fact, the condition still existed.
Additionally, Technical Specification 3.12.C.3 states that if more
than one rod assembly in a given bank is out of service because of
a single failure external to the individual rod drive mechanism
(i.e., programming circuitry), the provisions of Specifications
3.12.C.1 and 3.12.C.2 shall not apply and the reactor may remain
critical for a period not to exceed two hours provided immediate
attention is directed toward making the necessary repairs.
In the
event the affected assemblies cannot be returned to service within
this specified period, the reactor will be brought to hot shutdown
conditions.
The unit remained critical for the entire duration of
this event (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 46 minutes).
The licensee did not comply with
the requirements of Technical Specification 3.12.C in that the unit
remained critical in excess of the time period.
This is identified as
violation 280, 281/88-11-02, Failure to Follow Technical Specification 3.12.C Requirements.
' *
12
e.
Logs and Records
The inspector noted a genera 1 disregard for the requirements of
Administrative Procedure SUADM-0-09, Operations Department -
Logs
and Records, as it pertained to the required entries in the Control
Room Log and the Shift Supervisors Log (Team Supervisors Log).
Dupli-
cate 1 og entries were required in both 1 ogs; however, 1 og entries
frequently appeared in one log but rarely in_ both as required by
SUADM-0-09.
Si nee the events reviewed by the inspector could be
reconstructed by using combinations of the existing log entries, the
disregard of SUADM-0-09 is identified as a weakness.
f.
Conclusions
The documentation of work activities does not reflect the professiona-
lism or quality of the work the inspector observed in the Operations
department. - With the exception of those items noted above, the
Operations department appears adequate.