ML19323B813
| ML19323B813 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/04/1980 |
| From: | Baker K, Boyd D, Heishman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18044A874 | List: |
| References | |
| 50-255-80-02, 50-255-80-2, NUDOCS 8005140298 | |
| Download: ML19323B813 (16) | |
See also: IR 05000255/1980002
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U.S. NUCLEAR REGULATORY COMMISSION
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OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-255/30-02
Docl.et No. 50-255
License No. DPR-20
Licensee:
Consumers Power Company
212 West Michigan Avenue
Jackson, MI 41201
Facility Name:
Palisades Nuclear Generating Plant
Inspection At:
Palisades site, Covert, MI
Inspection Conducted: December 3-7, 10-14, 17-21, 1979; January 7-11, 14-18,
21-25 and 29-31, 1980.
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Inspectors:
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. Jorgensen
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Approved By:',' R!}F. Lay
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eishman, Chief
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Reactor Operations and
Nuclear Support Branch
Inspection Summary
Inspection during December 1979, and January 1980 (Report No. 050-255/80-02)
Areas Inspected: Routine resident inspection program activities includ-
ing operations, reportable occurrences, action on IE Bulletins and follow-
up to previously identified items.
Special inspection of licensee activ-
itie; pursuant to NRC Order Modifying License DPR-20 dated November 9,
1979. The inspection involved 379 inspector-hours on site by three NRC
inspectors.
A meeting was held with local officials on January 14, 1980, to brief
them on the NRC Resident Inspection Program and to introduce to them the
Resident Inspector assigned at the Palisades Plant.
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~Results: Of the four areas examined, no items of noncompliance were
identified in three areas. One item of noncompliance (infraction-failure
to leak-test on restoration of primary containment boundary) was identi-
fied in the remaining area of inspection.
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DETAILS
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1.
Persons Contacted
Palisades Plant
- J. Lewis, General Manager, Palisades
- H. Keiser, Operations and Maintenance Superintendent
- H. Palmer, Technical Superintendent
T. Kanicki, Shift Supervisor
S. Martin, Electrical Maintenance Supervisor
B. Harshe, Senior Engineer
C. Thomas, Mechanical Maintenance Supervisor
D. Kozin, Plant Chemist
F. Butler, Instrument and Control Engineer
G. Petitjean, Technical Engineer
D. Langschwager, Shift Supervisor
D. Kaupa, Shift Supervisor
J. Richter, Control Operator
Quality Assurance
- R. McCaleb, Quality Assurance Superintendent
- G. Gilbody, Quality Assurance Senior Engineer
J. Palancher, Quality Engineer, Gilbert / Commonwealth Associates
M. Fox, Project Quality Coordinator, Gilbert / Commonwealth Associates
Corporate Office
- F. Buckman, Director, Nuclear Activities Department
K. Berry, Screening Team Leader (Task Force)
- R. Rosenfeld, Reliability and Performance Administrator
- J. Schepers, Action Team Supervisor (Task Force)
- K. Brienzo, Action Team Walkdown Supervisor (Task Force)
Midland Task Force Members
J. Flynn, Operations Superintendent (Review Group Leader)
- M.
King, Shif t Supervisor
C. Kramer, Shift Supervisor
Numerous other members of the Palisades Plant operations, maintenance
and technical staffs and of the various special work groups establish-
ed to complete activities for compliance with an NRC Order for Modifi-
cation of License were also contacted.
- Denotes those procent at the final management interview for this
inspection period on February 1, 1980.
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General - Operations
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During the period covered by this inspection (December 3, 1979
'through January 31, 1980) the facility remained in the cold shutdown
condition. Among the numerous activities underway were corrective
and preventive maintenance.; testing; facility modifications (parti-
cularly due to requirements of NUREG-0578, 'Three Mile Island -
Lessons Learned"); and actions on selected IE Bulletins and on an
NRC Order for Modification of License.
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General operations and maintenance activities were reviewed during
several facility tours conducted during the inspection.
Compliance to selected applicable limiting cond':. ions for operation,
considering plant shutdown status, was verified
Specifically ex-
amined were continuous availability of a boric acid injection flow-
pata and primary coolant system overpressure protection. The over-
pressure protection requirements included a shiftwise verification
by the licensee that all high pressure injection pumps (unless one
was required for the injection flowpath) were disabled.
No items of noncompliance or deviations were identified.
3.
Reportable Events
The inspector reviewed the licensee's actions concerning the follow-
ing event reports to verify proper review and evaluation; corrective
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action; and compliance with license requirements. Records and per-
sonnel interviews were used in the review.
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a.
LER 79-13: Coincident low level in two safety injection tanks.
While draining the "D" tank, the "C" tank level also went low
due to a leaking control valve. The resident inspector witness-
ed this occurrance and the immediate corrective action. The
respective control valves on all four safety injection tanks
were overhauled and tested during the current outage. This' item
is closed.
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b.
LER 79-17: Two station battery cells damaged by hydrogen ex-
plosion inside cells during testing. The affected cells were
jumpered when an analysis showed selected capacities remained
adequate. New cells have since been installed and all cells
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on both batteries have been provided with explosion proof caps.
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The method and procedure for the testing have also been revised.
This-item is closed.
c.
LER 79-23: CVCS degraded by regenerative heat exchanger leak.
The leaking, high porosity. weld was ground out, repaired, and
tested (dye penetrant) and the system returned to service.
This item is' closed.
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d.
LER 79-29:
Low safety injection tank level. The pre-limit
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annunciation protection failed to alert the operators due to
misoperation from loss of liquid in the instrument reference
leg. Electrical adjustments were made to restore instrument
accuracy and both upper and lower setpoints were tested. An
examination of the system did not reveal how reference leg
liquid (estimated at 100cc) was lost. This item is closed.
e.
LER 79-25: Engineering evaluation of CCW heat exchanger tube
fouling determined heat transfer coefficients during part of
1977 were lower than assumed in safety analyses. The licensee
has implemented a program for cleaning the tubes each refueling
(based on a study of fouling rate) and has established new
limits as a result of analysis of the effect of tube fouling on
heat transfer. This item is closed.
f.
LER's 79-26 through 79-30:
Secondary system chemistry limits
exceeded during transient chemistry evolution involving conden-
ser tube leakage and use of the condensate polishing system.
As licensee personnel acquired experience with the interactions
of tube leakage, condensate polisher use and power level changes,
the existing procedures were fine-tuned.
Items addressed in-
cluded pre-inspection of polisher septums, resin-form ratios,
and guidance for polisher operations under various conditions.
These items are closed.
g.
LER 79-34:
Low Channel "B" Thermal Margin / Low Pressure cutput
limiter setpoint. The low limiter potentiometer was mistakenly
removed. All Instrument and Control technicians attended re-
view sessions for discussion of the event. This item is
closed.
h.
LER's 79-32 and 79-39:
Secondary system chemistry limits
exceeded. Licensee actians as described in f. above. These
items are closed.
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LER 79-36: Emergency diesel-generator failed to start during
testing. Dirty governor oil in the booster servo-motor was
drained, the system was flushed and refilled with clean oil,
and the generator satisfacorily start-tested. The existing
procedure for annual governor oil change was revised to spec-
ifically include changing oil in the servo-motor section of
the system. This item is closed.
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LER 79-37 and LER 79-43:
See Paragraph 5 below. These items
are closed.
No items of noncompliance or deviations were identified.
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4.
IE Bulletin
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The inspector reviewed the licensee's actions with respect to the
following IE Bulletins.
a.
IEB 79-15:
Deep Draft Pump Deficiencies. The deep draft pumps
at Palisades include only the service water and firewater pumps.
The service water pumps have good reliability histories under
lengthy or continuous service conditions, ranging up to 7 to 15
months without maintenance. Their maintenance histories were
reviewed by the inspector. They showed fairly routine seal
repacking (2 to 5 times per year) and quite infrequent (once in
several years) bearing replacement as the only required mainten-
ance. The firewater pumps are typically operated only intermit-
tantly for testing. No instances were found over the past sev-
eral years when maintenance was required on these pumps, though
maintenance records before about 1976 are not so comprehensive
and detailed as provided by current practice. This item is
closed.
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b.
IEB 79-23: Potential Failure vf Emergency Diesel Generator
Field Exciter Transformer. The generator wiring deficiencies
identified in the Bulletin do not exist in the Palisades design.
Sustained full-load operations tests (24 hrs. minimum) of both
diesel generators were conducted successfully. The inspector
witnessed portions of the load test of EDG 1-2 on January 21,
1980. This item is closed,
c.
IEB 79-24:
Frozen Lines. As reported in the licensee's letter
dated October 31, 1979, no frozen instrument or sampling lines
have been experienced at Palisades, despite several seasons of
severe weather. This item is closed.
d.
IEB 79-25: Failure of Westinghouse BFD Relays in Safety-Belated
Systems. A review showed none of the subject relays in use or
planned for use in safety systems at Palisades. This item is
closed.
e.
IEB 79-28: Possible Malfunction of Namco Model EA 180 Limit
Switches at Elevated Temperatures. A review showed none of the
sabject switches in use or planned for use in safety systems at
Palisades. This item is closed.
No items of aoncompliance or deviations were identified.
5.
Licensee Action on Previously Identified Items
(Closed) Noncompliance Item (50-255/79-15): Violation of containment
integrity during operations. This item is the same as reported by
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LER 79-37.
Theinspector'sreviewofshort-termlicenseeactiog
on this matter is documented in a previous inspection report. -
Further review during this inspection inc2uded procedure revision
for improved locked-valve control and verification of maintained
compliance to containment integrity requirements as a function of
plant condition. The inspector is satisfied the licensee's actions
for this specific item have been appropriate. Actions to address
the broader issues reflected in an NRC Order Modifying License,
which relates to this item, continue under review and are discussed
in Paragraph 6 below.
(Closed) Noncompliance Item (50-255/79-15): Failure to verify con-
tainment integrity after refueling via check of every locked-closed
containment isolation valve. The inspector's review of tg licens-
ee's initial actions is described in an earlier report. - This
inspection included a selective verification that proper followup
actions to correct additional minor discrepancies was completed.
(Closed) Noncompliance Item (50-255/79-15): Failure to adhere to
a procedure for surveillance and testing of a safety-related system.
This inspection included verification of procedure revision, and re-
view of the event and the revised procedure with applicable plant
personnel.
(Closed) Noncompliance Item (50-255/79-17): Failure to perform
required shiftwise primary coolant system analysis for bor.n con-
centration during refueling. This item is the same as reported by
LER 79-43. This inspection included verification of licensee ac-
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tions as described in his letter dated December 22, 1979.
(Closed) tMncompliance Item (50-255/79-17): Failure to maintain
required reactor cavity / spent fuel pool level during refueling.
This inspection included verification of corrective actions as
stated in the licensee's letter of December 22, 1979.
No items of noncompliance or deviations were identified.
6.
Order Modifying Licensee
This inspection included a review of licensee activities responsive
to the NRC Order Modifying License dated November 9, 1979.
This
Order has three basic requirements. The first item requires the
licensee to conduct, prior to startup, a comprehensive review of
checklists and procedures to assure they identify and control pro-
per positioning of valves and other controls for engineered safety
1_/ IE Inspection Report No. 050-255/79-22.
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features. A previous inspection report $!
documents some earlier
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examination of this matter, and considerable additional review dur-
ing this inspection is discussed below. The second item requires
monthly inspection and reporting (following the return to operation)
concerning compliance of engineered safety systems to the Limiting
Conditions for Operations requirements of the Technical Specifica-
tions. During this inspection, the licensee's procedure (in draft
form) to accomplish this requirement was examined. The scope and
content of this procedure were considered adequate to provide for
compliance to this requirement of the Order, if the program is
properly implemented. The inspectors had no further questions
concerning this procedure. Proper implementatiion, however, will
be subject to further inspection as the program is commenced. The
final requirement of the Order directed the licensee to meet with
the Director, Office of Inspection and Enforcement, to explain how
the first two requirements would be implemented. This meeting was
held on November 30, 1979, in Washington, D.C., and was also attend-
ed by senior staff of the Region III Office of Inspection and En-
forcement.
It was concluded that the licensee's program, as des-
cribed, was adequate to satisfy the Order pending verification by
Region III that the program was properly implemented. The require-
ment which is a prerequisite to startup, therefore, is verification
of proper review and correction, where necessary, of checklists and
procedures. This is addressed immediately below.
a.
Licensee Activities
The description below is intended only as a summary.
It does
not address in detail all of the licensee's actions, some of
which were based on considerations and developed into a scope
well outside that of the Order. Further, selected licensee
actions to be responsive to concerns raised in his own or in
the NRC review, are discussed in subsequent sections.
The licensee's overall approach was to identify and define the
scope of the work to be performed; to develop methods and con-
trols for performing the review work; to implement those methods
and controls in the review process; to specifically identify
needed changes or improvements; to evaluate and implement the
changes or improvements; and to verify proper implementation.
A variety of task force or teams were formed to accomplish
these activities. These included the commitment of substantial
manpower resources, including program management expertise,
beyound the plant staff. Corporate office personnel and Mid-
land Nuclear Plant staff were particualrly involved.
3/ IE Inspection Report No. 050-255/79-22
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Procedures were prepared to define the scope of the required
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review effort. These were basically to provide a screening
process wherein all checklists and procedures were examined to
determine which might interact with engineered safety features.
Where such interaction might occur, the procedure or checklist
was identified for detailed review.
Procedures were also prepared to control the detailed review.
The accuracy and comprehensiveness of checklists was reviewed
by detailed system walkdowns. These walkdowns utilized teams
of two members each, and included a concurrent review of plant
piping and instrument diagrams (P & ID's) for the subject
systems. Thus, a three-way verification, (as-built to diagram
to checklist) was obtained. Each apparent discrepancy identi-
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fied was categorized and uniquely numbered.
The accuracy and comprehensiveness of procedures was examined
in a separate detailed review process; again under procedural
controls. As with checklists and P & ID's, apparent discre-
pancies identified during the procedure review process were
uniquely identified and a recommendation for corrective action
made.
All items identified in the review processes as apparent dis-
crepancies were independently reviewed and evaluated and a
determination was made concerning corrective action.
Some
discrepancies required several actions to resolve. After
specific corrective actions were assigned, implemented and
reviewed for checklist /P&ID items, a seperate verification
of proper completion was made by the Quality Assurance staff.
Final verification of completion on procedure items was pro-
vided by the Plant Review Committee review, required for chang-
es to safety-related procedures. Records were maintained ade-
quate to track each item through identification, evaluation,
assignment, correction and verification.
b.
NRC Review
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The review of licensee actions on the Order Modifying License
was conducted as a special inspection by the Resident Inspector
and by Messrs. Boyd and Baker of the Region III Office of In-
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spection and Enforcement. Messrs. Boyd and Baker were onsite
for this review on December 17-21, 1979, and January 8-11 and
January 30 through February 1,1980.
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The first purpose of this review was to verify the licensee's
review of checklists and procedures was sufficiently comprehen-
sive'in scope. This included a determination that all check-
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to screen checklists and procedures were reviewed by examina-
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tion of the controlling procedures prepared by the licensee
for that purpose:
" Engineered Safety Features Determination Procedure"
T-117, " Safety Related Boundaries Procedure"
" Sorting Review Procedure"
Finally, an independent screening of a number of checklists and
procedures (including some not designated for detailed review
by the licensee) was coverage was found to be adequate.
The second purpose of the NRC review activities was to verify
the licensee's in-depth review of checklists and procedures was
sufficiently detailed. This included review of the procedures
prepared by the licensee for performing his detailed reviews:
T-116, " Checklist Review"
T-118, " Procedure Review"
Further, licensee personnel were accompanied and observed in per-
formance of the system walkdowns used to review checklists and
P&ID's for significant portions of the following checklists:
CL 2.1, "CVC System"
CL 3.3 " Containment Integrity"
CL 12.1 "Feedwater System"
Licensee personnel observed during these walkdowns were found
adhering to the controlling procedure.
Finally, the licensees discrepancy list developed from review
of checklists and diagrams was cross checked against a similar
list of discrepancies developed
downsatapreviousinspection,gyringearlierNRCsystemwalk-
addressing IE Bulletin 79-06B.
This cross-check verified the detail of the licensee's review
was sufficient to re-identify independently, all the NRC-identi-
fied items for which corrective action had not yet been completed.
The detail of the licensee's methods for review was found to be
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adequate if properly implemented.
4/ IE Inspection Report No. 050-255/79-07.
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The third purpose of the NRC review was to examine the licens-
ee's system for corrective action on identified discrepancies.
This included a review of mechanisms for deciding what correc-
tive action to take; assigning responsibility for implementing;
tracking status; and verifying adequacy of completed corrective
actions. These matters are covered in procedures T-116 (for
checklists) and T-118 (for procedures) identified above, and
were part of the NRC review of these procedures. The correc-
tive action processes developed for this program were found
being properly implemented during a selective review of cor-
rective action on about fifty individual items, including
representative direct verification out in the plant.
The final purpose of the NRC review was to evaluate the effec-
tiveness of the licensee's overall program by independent re-
view of the finished product;
i.e.,
corrected checklists and
procedures.
Independent system walkdowns using corrected checklists were
conducted during the week of December 17, 1979. These walk-
downs covered all or parts of the following checklists:
CL 2.1, "CVC System"
CL 3.1, " Engineered Safegur ds-Shutdown Cooling in Service"
CL 3.2, " Engineered Safeguards-To Secure Shutdown Cooling"
CL 16, " Component Cooling"
CL 22.1, " Diesel Generators"
CL 22.2, " Fuel Oil System"
As a result of these walkdowns, a number of discrepancies were
identified which were of the same type as the licensee's walk-
downs had identified; i.e., valves without tags, disagreement
between checklist and valve tag, missing locks and, in two
instances, valves not on a checklist. As with most of the
licensee's findings, these items were predominantly in small
lines such as instrument, test, flush or drain connections to
the subject systems. By convention, many such items, particu-
larly instrument root and isolation valves, were not included
on the original P&ID's, from which the checklists may have
been derived in part. Similarly, such items had not normally
been tagged and, in fact, many were not even numbered. Thus,
the licensee's effort, as required by the Order, to identify
all valves in engineered safety systems, required a change in
convention and resulted in the identification of hundreds of
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small valves not numbered, not tagged, not on the P&ID or
not on the checklist. The inspectors' additional findings
were discussed with licensee personnel during a meeting on
December 21, 1979. The inspectors expressed their concern
these findings might indicate inadequacies in performance of
the initial walkdowns by licensee personnel.
It was noted
this initial system walkdown had been the only portion of
that program not originally provided independent verification.
The licensee subsequently developed an additional procedure
(T-129, " Action Team System Walkdown") for a second system
walkdown which was performed during January 1980. Procedure
T-129 and the results of the second walkdown were reviewed by
the inspectors. One of the purposes of the second walkdwon
(there were several
primarily production of completely ac-
curate "as-built" P&ID's) was verification of the first. Some
additional items missed in tle first effort were identified.
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These were small in number compared to the first walkdowns
findings, indicating the quality of the initial effort was,
in fact, relatively high.
It was concluded the second effort
did contribute a small but needed improvement and that, taken
together, the two efforts provide confidence that plant check
lists now satisfy the requirements of the Order for comprehen-
siveness and accuracy.
The special inspection efforts during the weeks of January 7
and January 28, 1980, focused on review of corrected proce-
dures, including the following:
T-FC-344A-1, " Electrical Canister Test Procedure"
T-FC-449-1, " Test Procedure, Containment Building Purge Interlock"
HP 6.8, " Stack Gas Particulate and Iodine Sampling"
BAGO 3 MO 18, " Auxiliary Feed Pump Room Floor Drain Inoperation"
F 3.10, " Component Cooling System Sampling"
F 3.16, " Lubricating Oil System"
S0P 2A, " Chemical and Volume Control System Charging and Letdown;
Concentrated Boric Acid"
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ESS-E-2, " Replacement of Torque Switches and Setting of Geared
Limit Switches and Torque Switches"
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VAS-M-5, " Visual Inspection of Containment Isolation Valves
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CV1805, CV1806, CV1807 and CV1808 Rubber Seats."
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VAS-M-6, " Installation of a 48" Blank Flange on Containment
Purge Lines for Isolation."
EPS-N-2, " Corrective Electrical and Mechanical Maintenance
Procedure for Diesel."
MSM-M-17, " Miscellaneous Relief Valve Setpoint Testing."
VAS-M-4, "T-Ring Replacement of CV1805, CV1806, CV1807 and
CV1808."
VAS-1-2, " Refueling Surveillance Procedure Containment Pressure
Channels Calibration."
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M-MSI-I, " Basic Pressure Transmitter Indicator Calibration
Procedure."
SOP-3, " Safety Injection and Shutdown Cooling."
SOP-4, " Containment Spray and Iodine Removal System."
SOP-5, " Containment Air Cooling and Hydrogen Recombining System."
S0P 16, " Component Cooling Water System."
S0P 30, " Station Power."
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D4.1, " Reactor Trip."
D4.4, " Partial Loss of Primary Coolant Flow."
D4.5, " Loss of Feedwater."
D4.11, " Containment Isolation."
D4.20, " Fuel Cladding Failure."
As a result of these reviews, the inspectors identified several
inaccuracies pertaining to valve or switch numbering, in system
operating procedures (SOP's). These were discussed with the
licensee during the meeting on February 1, 1980. The licensee
has committed to a repeat review of SOP's and emergency procedures
specifically to verify accuracy of valve and controls numbering.
The results of this review will be examined during a future in-
spection.
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The inspectors also noted instances wherein " initial conditions"
had been deleted from system operating procedures.
Some of these
cases were accompanied by statements at the conclusions of procedure
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segments to "rcturn lineup to normal." This lack of specificity
in valve position control was quertioned, and specific examples
of potential problems were discussed. The licensee indicated a
need for flexibility on the part of the operating staff which could
be compromised by specifying " normal" conditions in detail when, in
fact, a variety of conditions might be both permissible and " normal."
To verify the noted lack of specificity does not occur in instances
where specificity would be needed to assure compliance to required
or permitted conditions, the licensee committed to review a cross-
section of cases and make such a determination. The results of this
review will be examined during a future inspection.
The inspectors questioned how proper interfacing between cross-re-
ferencing procedures would be assured after the significant review
and revision process is completed.
In some cases this process could
change procedure names, numbers and/or format.
Some new procedures
were also written.
The licensee had recognized this potential
problem and developed a list of all cross-references by procedure
number. Additional reviews are planned, including procedure number.
Additional reviews are planned, including procedures outside the
scope of the Order, to integrate procedures together and possibly
improve general workability. This is a longer-term activity for
which methods and a detailed schedule are still being developed.
It is not considered an Order requirement by the inspector.
No Technical Specification surveillance testing procedures had been
completely processed and corrected as needed at the time of this
inspection. The inspectors intend to review a sampling of these
procedures during a future inspection.
During the review of VAS-1-2 (identified above) it was noted a pipe
cap or test plug must be removed from the containment pressure
transmitter and switch instrument line to perform instrument testing
and calibration. This cap is part of the containment boundary dur-
ing operation. The licensee's procedure did not provide for leak
testing the capped connection when the cap is replaced, as stipulat-
ed in 10 CFR 50, Appendix J.
Review of completed tests done June 5
and July 2, 1979, showed a leak rate test had not been conducted
after removal and replacement of this component. This appears to
in noncompliance with 10 CFR 50, Appendix J. requirements.
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Subsequent to the initial NRC reviews of selected maintenance pro-
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cedures, several such procedures were conceled by the licensee.
This cancelling of procedures was discussed with the licensee.
In
general, the licensee expressed a preference for use of the existing
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Equipment Outage Request (EOR) system for proper control of return-
to-service for equipment undergoing maintenance. The inspectors
noted this would increase the burden on the operations staff in
making more frequent, unreviewed decisions on correct system test-
ing and verification. The licensee acknowledged the inspectors
comments.
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6.
Meeting With Local Officals
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On January 14, 1980, the Resident Inspector and Messrs. D. C. Boyd
and J. R. Strasma of the Region III Office of Inspection and En-
forcement met with local municipal, township and county officials.
This meeting, requested by NRC, was to introduce the Resident In-
spector to the local officials and to prvide general information
concerning the NRC Resident Inspection Program and Program imple-
mentation in inspection of activities at the Palisades Nuclear
Plant.
7.
Management Exit Meeting
A management exit meeting, attended as indicated in Paragraph 1,
was held at the conclusion of the inspection on February 1, 1980.
,
]
Status meetings had previously been conducted as indicated in these
details to keep licensee personnel informed of pertinent findings.
Items discussed at the February 1 meeting, including licensee re-
sponses (some of which were provided in a February 6 meeting), were
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as follows:
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a.
The inspectors stated the licensee'r. actions in review and
upgrading of checklists was considered to satisfy the require-
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ments of the NRC Order (the Order) Modifying License dated
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November 9, 1979.
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b.
The inspectors summarized their review of the licensee's draft
'
procedure for monthly verification of engineered safety systems
after return of the plant to operations. The program to satis-
fy this part of the Order is considered adequate pending veri-
fication of propu implementation at a later inspection.
c.
The inspectors stated their review of System Operating Proce-
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dures (S0P's) had identified inaccuracies in certain valve or
switch numbering.
Examples were provided. The licensee com-
mitted to an additional specific review of SOP's and emergency
procedures to correct numbering errors.
d.
The inspectors noted a lack of specificity in certain SOP's
concerning initial and final position requirements for valves.
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Specific examples of potential problems were discussed. The
licensee indicated excessive specificity could be a problem
in itself; unnecessarily restricting needed operational flex-
ibility beyound Technical Specification requirements. The
,
licensee committed to a selective review of SOP's to assure
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identified instances of non-specific controls do not occur
where specific controls are required to assure compliance to
the. Technical Specification.
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The impact of the current extensive review and revision pro-
e.
cess on procedure interfacing was discussed. The licensee
plans a longer-term effort to assure proper cross-referencing
among procedures and to maximize general workability. The
inspectors concurred in the need for such an effort, but stated
it is not considered a requirement of the Order.
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