ML20059J235
| ML20059J235 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 11/04/1993 |
| From: | Nerses V Office of Nuclear Reactor Regulation |
| To: | Mcmeekin T DUKE POWER CO. |
| References | |
| TAC-M86012, NUDOCS 9311120107 | |
| Download: ML20059J235 (14) | |
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UNITED STATES f)
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November 4, 1993 Docket Hos. 50-369 and 50-370 Mr. T. C. McMeekin Vice President, McGuire Site Duke Power Company 12700 Hagers Ferry Road Huntersville, North Carolina 28078 i
Dear Mr. McNeekin:
1
SUBJECT:
SPECIAL AUDIT OF CONTROL PROCESSES FOR COW 11TMENTS AND CURRENT LICENSING BASIS, MCGUIRE NUCLEAR STATION (TAC NO. M06012)
The purpose of this letter is to provide you with the results of the commit-i i
ment management audit conducted by the Office of Nuclear Reactor Regulation at the McGuire Nuclear Station from June 7 through 11, 1993. As you are aware, the staff conducted audits of several reactor plants to assess the processes used by licensees for controlling commitments that affect the plant's current licensing basis. The information gathered during the audits will be used by the staff to evaluate the regulatory process in this area.
McGuire was the i
i seventh site visited by the staff. Our audit report is enclosed.
The team focused on three principal areas:
(1) management of commitments made to the U.S. Nuclear Regulatory Commission (NRC), (2) reporting changes to comitments made to NRC, and (3) maintaining and updating the Final Safety Analysis Report (FSAR).
In addition to reviewing the governing programs for l
these areas, the team reviewed the status of commitments made to the NRC in I
response to specific issues (in selected generic letters, bulletins, licensee event reports, and notices of violation) in order to examine the programs in actual practice.
Overall, the team found that commitments affecting the plant's current licensing basis were being implemented. However, the team found that there was no systematic process for ensuring that implemented comitments would not be subsequently modified or deleted.
Plant management relied greatly on the experience and corporate memory of its staff to ensure that commitments were not deleted or altered after they were implemented. Although the team did not find examples of conuiltments that were subsequently changed, the team notes that both McGuire units are relatively young plants and that the commitments made today remain part of the plant's current licensing basis throughout its lifetime.
In addition, maintenance of a plant's current licensing basis is very important for license renewal considerations.
i The team also found that changes to comitments were evaluated on a case-by-case basis by the compliance group to determine if NRC notification was necessary. Here again, the compliance group relied on the knowledge and experience of the plant staff to identify commitments that had changed and to I
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Mr. T. C. McMeekin. November 4, 1993 1
alert them of any changes. Finally, the team found that commitments that affected that plant's FSAR were captured by the FSAR update process and'were reflected in the McGuire FSAR. The team did not identify any items of i
significance in its review of commitments made in response to the specific issues.
I The team thanks the plant staff for its open participation in their discussions and cooperation in providing the team the information necessary to conduct an efficient audit.
If you have any questions or comments concerning this report, please contact me at (301) 504-1484 or Eric J. Leeds at (301) 504-1133.
Sincerely, i
/s/
1 Victor Nerses, Project Manager Project Directorate 11-3 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation
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Mr. T. C. McNeekin ' November 4, 1993 alert them of any changes. Finally, the team found that commitments that affected that plant's FSAR were captured by the FSAR update process and were reflected in the McGuire FSAR. The team did not identify any items of significance in its review of commitments'made in response to the specific issues.
l The team thanks the plant staff for its open participation in their discussions and cooperation in providing the team the information necessary to i
conduct an efficient audit.
If you have any questions or comments concerning l
this report, please contact me at (301) 504-1484 or Eric J. Leeds at (301) 504-1133.
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l Sincerely, Victor Nerses, Project Manager Project Directorate 11-3 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation j
Enclosure:
Audit Report i
cc w/ enclosure:
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Mr. T. C. McMeekin Duke Power Company McGuire Nuclear Station 1
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Mr. A. V. Carr, Esquire Mr. Dayne H. Brown, Director Duke Power Company Department of Environmental, 422 South Church Street Health and Natural Resources Charlotte, North Carolina 28242-Division of Radiation Protection 0001 P. O. Box 27687 Raleigh, North Carolina 27611-7687 County Manager of Mecklenberg County 720 East Fourth Street Mr. Alan R. Herdt, Chief Charlotte, North Carolina 28202 Project Branch #3 U. S. Nuclear Regulatory Commission Mr. R. O. Sharpe 101 Marietta Street, NW. Suite 2900 Compliance Atlanta, Georgia 30323 Duke Power Company McGuire Nuclear Site Ms. Karen E. Long 12700 Hagers Ferry Road Assistant Attorney General Huntersville, NC 28078-8985 North Carolina Department'of Justice J. Michael McGarry, III, Esquire P. O. Box 629 Winston and Strawn Raleigh, North Carolina 27602 1400 L Street, NW.
Washington, DC 20005 Mr. G. A. Copp Licensing - EC050 Senior Resident Inspector Duke Power Company c/o U. S. Nuclear Regulatory P. O. Box 1006 i
Commission Charlotte, North Carolina 28201-12700 Hagers Ferry Road 1006 Huntersville, North Carolina 28078
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Mr. T. Richard Puryear U.S. Nuclear Regulatory Commission Nuclear Technical Services Manager 101 Marietta Street, NW. Suite 2900 Westinghouse Electric Corporation Atlanta, Georgia 30323 1
Power Systems Field Sales 2709 Water Ridge Parkway, Suite 430 1
Charlotte, North Carolina 28217 Dr. John M. Barry Mecklenberg County Department of Environmental Protection 700 N. Tryon Street Charlotte, North Carolina 28202 l
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1 C0f91ITMENT MANAGEMENT AUDIT OF THE MCGUIRE NUCLEAR STATION JUNE 7-11, 1993 I.
Scope and Participants The purpose of the audit conducted at McGuire was to assess the effectiveness
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of the licensee's programs for identifying and controlling commitments that affect the facility's current licensing basis. The audit. focused on three principal areas:
(1) managing commitments made to the U.S. Nuclear Regulatory Commission (NRC), (2) reporting changes to commitments made to the NRC, and (3) maintaining and updating the Final Safety Analysis Report (FSAR). The team reviewed the licensee's administrative procedures involving action tracking; control of design, configuration, test and experiments; and others.
To examine the programs in actual practice, the team reviewed the status of coinnitments made by the licensee to the NRC in response to specific issues.
Three of these issues, generic in nature, were the following:
" Service Water System Problems Affecting Safety-Related Equipment" Generic Letter 88-14
" Instrument Air System Problems Affecting Safety-Related Equipment"
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" Steam Binding of Auxiliary Feedwater Pumps" The remaining issues were specific to McGuire, involving licensee commitments made in licensee event reports (LERS) and responses to notices of violation (NOVs). The team also reviewed the licensee's design-basis document (DBD) program to determine how a commitment from the program would be captured in the commitment management process.
-1 The team relied on standard NRC inspection practices in conducting the audit of specific commitments.
In conducting the audit, the team performed system walkdowns, reviewed applicable documentation (including' design change packages (DCPs), training records, and procedures), and interviewed plant staff. A detailed review for each issue specified above is contained in the appendix to this report.
The audit was conducted by Eric J. Leeds and Steven R. Stein from the NRC's Office of Nuclear Reactor Regulation.
II. FindinghandConclusions The following are the team's findings and conclusions for the three major areas of focus:
(1) conmiitment management, (2) reporting changes to conmiit-ments made to the NRC, and (3) maintaining and updating the FSAR.
Commitment Manaaement: The team found that commitments affecting the plant's current licensing basis were being implemented and maintained.
In its review of licensee commitments made in response to specific issues, the team found no significant deficiencies in' identifying, tracking, implementing, or main-taining licensee commitments involving design changes, equipment, procedures or programs. The licensee controlled conmiitments through an action tracking system promulgated in Nuclear System Directive (NSD) 208, " Problem Identification Process (PIP)." Commitments made to the NRC were identified and tracked to implementation in the PIP. However, the licensee did not have
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Identification Process (PIP)." Comitments made to the NRC were identified and tracked to implementation in the PIP. However, the licensee did not have i
a systematic process for ensuring that implemented commitments would not be subsequently modified or deleted. The licensee greatly relied on the expe-rience and corporate memory of its staff to ensure comitments were not 1
altered or deleted after they were implemented.
Reportino Chances to Commitments Made to the NRC: The licensee evaluated and reported changes to commitments made to the NRC through an informal, undocu-mented process. The licensee's compliance group evaluated each change to a comitment on a case-by-case basis to determine if NRC notification was i
necessary. The licensee indicated that it reported changes to commitments in the same manner as that in which the original comitments were made, based on an understanding with the NRC resident inspectors.
For changes to older j
commitments, the evaluation typically included discussions with the resident inspectors, regional section chief, or the NRC project manager. The licensee relied on the knowledge and experience of its staff to identify comitments that had changed and to report any changes to the compliance group.
1 The team identified one isolated example in which the licensee had signif-icantly changed a commitment that was not reported to the NRC. The licensee
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had committed in its response to Generic Letter 89-13 to revise an emergency operating procedure for the component cooling water system, but later decided not to revise the procedure. The licensee indicated that it would revise the commitment in the next update of the status for the generic letter issue.
This item is discussed in more detail in the appendix-to this report.
Maintainino and Vodatino the Final Safety Analysis Report: Although in 1
transition, the licensee's programs and processes for plant modifications,
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10 CFR 50.59 reviews, and updating its FSAR were adequate to ensure that l
changes affecting the FSAR were evaluated and included as appropriate. The team did not identify any problems in the incorporation of FSAR changes with the modifications it reviewed. The team confirmed a weakness, previously identified by the licensee, in coordinating FSAR changes that were the result of modifications with the compliance group. At the time of the audit, the licensee, on the basis of the identified weakness, initiated an effort to review and improve its process for updating its FSAR. The licensee maintained its FSAR in electronic form, which was available for use on a computer network. The licensee planned to make the electronic form the official version and to incorporate continual, on-line updating.
III. Discussion A.
Commitment Manacement The team found that comitments affecting the plant's current licensing basis were being implemented and maintained.
In its review of licensee comitments made in response to specific issues, the team found no significant deficien-cies in identifying, tracking, implementing, or maintaining licensee commit-ments involving design changes, equipment, procedures, or programs.
The licensee controlled comitments through an action tracking system promul-gated in NSD 208, " Problem Identification Process (PIP)." Comitments made to,
the NRC were identified and tracked in the PIP until they were implemented.
However, the licensee did not have a systematic process for ensuring that implemented commitments would not be subsequently modified or deleted.
The licensee's system for managing comitments before NSD 208 was issued was Station Directive 3.1.7, "McGuire Action Directory (MAD)." The MAD process had required that changes to programs, procedures, work requests, or other station items resulting from commitments made to an outside agency be properly footnoted with a reference to the commitment. The licensee had recently (November 1,1992), issued new administrative controls for procedures, NSD 703, " Administrative Instructions for Station Procedures,"
that included identifying by footnote all procedural steps that were commitment items. However, the team found that very few procedures referenced commitments or footnoted the procedural steps that were comitments. The team found that many procedural steps that were commitments had survived multiple revisions without having been annotated. The licensee indicated that it i
relied greatly on the experience and corporate memory of its staff to ensure that implemented commitments were not subsequently altered or deleted.
For plant modifications, the licensee's design change process did not provide specific guidance to its staff to review previous modifications for comit-ments. Although there was no defined process requiring review of previous 9'
commitments for design modifications, the team did not identify any examples-l in which a committed modification was inadvertently altered by a subsequent modification. The team attributed this to the experience level of the engi-neering organization and the multiple levels of review and approval required by the design change process.
In the review of modification packages per-l formed as the result of commitments, the team found several examples of modifications being clearly identified as commitments made to specific issues.
The team also found several examples of modification packages in which the l
associated commitments were not referenced.
B.
Reportino Chances to Commitments Made to the NRC The licensee evaluated and reported changes to commitments made to the NRC through an informal, undocumented process. The site compliance group had reached an understanding with the NRC resident inspectors to inform the NRC of changes to commitments in the same manner as that in which the original commitment had been made, whenever practical. Notification of such changes was typically made during implementation of the commitment, although changes i
to older commitments have also been reported in the original manner, when possible. Although infrequently, the compliance group determined on a case-by-case basis whether or not to inform the NRC when the plant staff identified i
changes to older commitments to the group. This determination included discussions with the resident inspectors, the NRC regional section chief, or NRC project manager depending on the source of the commitment (safety evalua-tion report, NOV, LER, or letter) and the significance of the change.
The licensee required commitments in procedures to be identified with a foot-note but did not have requirements for identifying changes made to commit-ments. The licensee relied on the skill and experience of its staff to recognize that a commitment had been changed and to provide the information to the compliance group. The licensee provided to the team several examples of its staff recognizing a change to a commitment and past notifications to the NRC of changed or deleted commitments.
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A recent example of licensee personnel recognizing a changed commitment was the deletion of a continuous watch on the refueling canal to ensure cleanli-ness and exclusion of foreign material. The watch was initiated in response j
to an NRC notice of violation but was dropped from the associated procedure in i
1991. At the time of the audit, a licensee staff member discovered that the deleted procedural requirement had been a commitment made to the NRC, and the licensee entered the issue into the PIP. The licensee had not yet determined if it would inform the NRC of the dropped commitment because the issue had not l
been fully investigated and other efforts had been initiated to control foreign material in the refueling canal because of problems encountered during the current outage.
The team identified two examples in which commitments were significantly changed from those in the original docketed correspondence and were not reported to the NRC.
In the first example, the licensee stated in its second t
supplemental response to Generic Letter (GL) 89-13 that an emergency procedure and abnormal operating procedure involving the component cooling water system would be revised. Although the abnormal operating procedure was revised, the emergency procedure was not, and the licensee indicated that it did not intend to change the procedure. The licensee indicated it would report the change to i
the commitment in its next supplemental response to GL 89-13.
In the second example, which was made in response to NOV 50-369/90-11-02, the j
licensee changed several procedures to verify the final position of certain ventilation dampers after the dampers were tested. Subsequently, the licensee modified the system, removing the need for testing, and deleted or changed the requirements in test and emergency procedures. The team did not believe notification of the NRC was necessary because the reason for the original commitments had been removed in a controlled fashion (facility modifications) i and other commitments for daily verification of damper position remained in i
effect. Generic Letter 89-13 and NOV 50-369/90-11-02 are discussed in more detail in the appendix to this report.
C.
Maintainino and Updatino the Final Safety Analysis Report (FSAR)
The licensee had recently changed its FSAR updating process and procedures and decentralized the updating responsibility from the corporate level to the individual nuclear stations. McGuire station procedures also were in transi-tion as all three of the licensee's nuclear stations moved from individual station directives to nuclear site directives in a corporate-wide nuclear policy manual. The licensee maintained the McGuire FSAR in an electronic form that was available to employees through a company-wide computer network. The licensee indicated that it planned to eventually use the electronic form as its official version of the FSAR and to incorporate continual, on-line updating.
During its latest FSAR update, the first under the decentralized organization, the licensee discovered a weakness in the link between the plant modification process and the FSAR update process. The team found the same problem when it reviewed the applicable procedures and interviewed compliance and engineering personnel. The procedures governing the modification, 10 CFR 50.59 review, and FSAR update processes were inconsistent in identifying the responsible recipient for 10 CFR 50.59 and modification packages that indicated needed changes to the FSAR.
Several engineers were not sure who was to be informed of FSAR changes resulting from modifications. However, the team found that
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the necessary FSAR changes had been made, or were being properly identified for future updates, for the selected modifications it reviewed.
The licensee had recently initiated a process improvement effort to evaluate and enhance its FSAR update process. The effort was scheduled to be completed in time for the next required update of the McGuire FSAR.
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APPENDIX 1
SPECIFIC ISSUES REVIEWED AT MCGUIRE t
I To examine the implementation of the licensee's programs, the team reviewed the licensee's response to the following specific issues:
" Service Water System Problems Affecting Safety-Related Equipment"
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" Instrument Air System Problems Affecting Safety-Related Equipment"Bulletin 85-01
" Steam Binding of Auxiliary Feedwater Pumps" Notices of Violation 50-370/86-21-03, 50-370/87-35, 50-369-370/
88-33-01, and 369-370/90-11-02 Licensee Event Reports 370-87-04-1, 369-87-14-1, 370-87-18-1, 370-87-22, 369-87-37, and 369-88-02 t
i The Design-Basis Document Program 3
GL 89-13. " Service Water System Problems Affectina Safety-Related Eauipment" t
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The licensee's control and implementation of commitments in response to GL 89-13 were acceptable. The licensee documented actions taken to address l
GL 89-13 in its initial response of January 26, 1990, and submitted additional information as well as informed the NRC of changes to its initial commitments in two supplemental responses on November 19, 1990, and May 13, 1992. The licensee's commitments included hardware modifications, procedure changes, periodic testing, and technical evaluations. The licensee had completed most of the actions planned including piping inspection and repair programs, revision of operating and maintenance procedures, a single failure analysis of the service water system, and heat exchanger testing. Actions that still remained to be completed included modifications to the component cooling and spent fuel cooling systems to allow flushing of assured make-up lines and a study to assess biofouling control alternatives.
The team identified one anomaly with regard to the implementation of the licensee's commitments made in response to GL 89-13. The licensee stated in l
its second supplemental response (May 13, 1992) to GL 89-13 that an emergency procedure and abnormal operating procedure involving the component cooling water system would be revised. Although the abnormal operating procedure was revised, the emergency procedure was not, and the licensee's operations staff indicated that it did not intend to change the procedure. However, the compliance group and the system engineer were not aware of the decision'not to revise the emergency procedure, and the NRC had not been informed of the change.
The team reviewed the licensee's justification for not revising the emergency procedure and had no objections. The licensee indicated it would report the change in its next supplemental response to GL 89-13.
4 A.
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i GL 88-14. " Instrument Air System Problems Affectina Safety-Related Eauipment" The licensee responded to GL 88-14 in six letters to the NRC between May 8, 1990, and December 2, 1991.
In its letter of December 2, 1991, the licensee listed 12 comitments made in the previous letters, indicated that all but one of the commitments were complete, and provided a completion date of January 1, 1994, for the remaining commitment. The team reviewed 6 of the i
4 12 listed commitments and several other actions discussed in the earlier i
letters. The team found that the completed comitments and other actions had been implemented and had not changed significantly since being implemented.
The remaining commitment, development of periodic preventive maintenance procedures for selected air-operated valves, was in progress. The responsible engineer was aware of the comitment's completion date and was working to meet the schedule.
The licensee did not enter its specific comitments in response to GL 88-14 into its action tracking system, although it properly implemented or con-trolled the implementation of commitments and other actions.
It had entered seven GL 88-14 items into its previous database, the McGuire Action Directory (MAD), for tracking to completion. The items the licensee tracked came from the corporate regulatory compliance group's review of the initial McGuire i
response to the generic letter and included additional detail to the response and tracking delays in system testing. The one remaining commitment was not~
listed in the current PIP tracking system because it had not been entered into the previous MAD system.
Bulletin 85-01. " Steam Bindina of Auxiliary Feedwater Pumos" The McGuire Nuclear Station was 1 of 32 operating pressurized water reactor (PWR) facilities that were not required to respond to NRC Bulletin 85-01 because the plant was in compliance with its requirements before the bulletin was issued.
The licensee had implemented the actions described in the bulletin in response to actual instances of steam backleakage into the auxiliary feedwater (AFW) system at McGuire.
The team reviewed the licensee's actions for detecting and preventing steam binding of the AFW pumps and the procedures in place to recognize steam binding and for restoring the AFW system to an operable status should steam binding occur.
The team reviewed the applicable procedures, performed a system walkdown to verify the procedural steps for recovering a steam-bound AFW pump, and located the instrumentation for measuring the temperature of the AFW pump discharge pipe. The AFW pump discharge piping temperature was monitored continuously, and an alarm would alert the control room operators in the event of steam backleakage. The alarm response procedure described the actions necessary to recover the AFW pumps if they become steam bound. No deficiencies or anoma-lies were noted.
NOV 50-370/86-21-03:
Inadeauate Procedure for Reactor Trio Breaker Response Times The NOV was issued because an inadeqate procedure for testing the response times for reactor trip breakers caused an inadvertent engineered safety feature isolation of one train of the feedwater system. The licensee commit-ted to add to the test procedure a caution statement that would require operator action if both the main and bypass breakers were to be open at the A-2 ~
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i same time. The licensee added the violation to its former tracking system (MAD) and fulfilled the commitment by adding the caution statement to the test procedure. The caution statement was later changed to a procedure step because it could require operator action and was more appropriately a step and not a caution.
1 The team found that the current procedures for testing reactor trip breakers still contained the associated steps after numerous revisions, although the steps were not footnoted or identified as commitments. The change from a caution statement to a procedure step was not a significant change and did not materially affect the commitment.
NOV 50-370/87-35:
Inocerable Missile Shield The NOV was issued because missing bolts resulted in an inoperable reactor vessel missile shield and equipment hatch, which was a violation of McGuire's technical specifications.
In its response to the NOV, the licensee committed to revise a deficient maintenance procedure and to conduct inspections of similar structures using a recently completed design study. The licensee entered into its then-current tracking system (KAD) two items (one for each unit) to track completion of the inspections developed from the design study.
The team found that the current revision of the associated maintenance procedure contained the added controls for removal and replacement of bolts for missile shields. The procedural requirements were footnoted with a reference to a problem identification report (PIR) that the licensee had written when it discovered the original problem. The PIR also identified and documented completion of the structures inspections using the design study and included the words, "This is an NRC commitment."
NOV 50-369-370/88-33-01: Wrono EDG Started for EDG Test Procedure I
The NOV was issued because the licensee inadvertently started a Unit 1 emer-gency diesel generator (EDG) when performing an operability test on a Unit 2 EDG. The licensee listed six corrective actions in its response to the NOV and included five of the six actions in its former MAD system for tracking.
The sixth action, proper completion of the test, was completed at the time of the original violation and, therefore, was not entered into the MAD system.
The five corrective actions included reviewing the incident with the personnel involved, changing the EDG test procedure, adding several changes to the operations management procedure, and placing identification tags on the local relays for all four EDGs. The audit team reviewed the changes made to the test procedures for all four EDGs and the operations management procedure and verified the existence of the identification tags for both Unit 1 EDGs. The tags were in place and the procedural enhancements remained in the procedures after a number of revisions, although the enhancements were not footnoted or otherwise identified as commitments.
NOV 50-369-370/90-11-02: VC Valves Not Returned to Proper Position After Testino The NOV was issued when several valves (dampers) in the control room ventila-tion system were not reopened after testing, causing both trains of the system to be inoperable. The licervie committed to revise several maintenance and A-3
1 operations procedures to ensure the proper positioning of the dampers during operation. The licensee did not enter the violation or corrective actions into its former tracking system (MAD) to avoid duplication because it had documented the problem in a project identification report (PIR) before responding to the violation.
The team reviewed the associated maintenance, surveillance, and emergency procedures and found that some of the commitments had been deleted or significantly changed since they were originally implemented. The licensee had subsequently modified the control room ventilation system and removed the automatic closure feature of the dampers that was being tested periodically.
Therefore, the licensee removed the testing requirements for the dampers from the test procedures and removed verification of damper position from the emergency procedures. The twice-daily surveillance for damper position remained in the surveillance checklist.
The licensee changed its commitments in response to the NOV through a con-trolled process, its modification program, although it was apparently unaware that commitments had been changed. The team believed that notification to the NRC of the changes in commitments was not necessary because of the controlled manner in which the changes were made and the removal of the major source for the commitment had been removed.
Desian Basis Documentation Proaram The licensee was developing design basis documents for McGuire and had com-pleted documents for most of the plant systems. The DBDs included references to licensing correspondence (such as responses to generic letters and bulle-tins), existing modifications, and problem identification reports associated with the plant system.
The licensee's DBD process required any proSlems that were identified while the DBD was being developed to be entered into the plant's problem tracking and corrective action program, the problem identi-fication program (PIP). The licensee did not provide a separate listing or tracking mechanism for problems found through its DBD process. The licensee's process of including DBD-related problems in the PIP and annotating them in the associated DBD ensured that the problems would be identified and tracked to final resolution.
The licensee's intent was to maintain the DBDs current and included updating the documents in its modification program.
Revised pages of the affected DBD were issued as " limited edition" until the modification was completed. The changed DBD was then issued "as-built," reflecting the changes from the modification.
Licensee Event Reports (LERs)
The audit team reviewed the commitments associated with the corrective actions contained in the following six LERs:
LER 370-87-04-1 Containment hydrogen analyzer surveillance exceeded due to personnel error and administrative breakdown LER 369-87-14-1 Diesel generator 1A control power circuit breaker was inad-
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vertently left open due to personnel error
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LER 370-87-18-1 Inoperable fire barrier due to a wall sectbn being con-j structed without proper end connection treatment t
LER 370-87-22 Surveillance program inadequate to demonstrate operability l
of component cooling system heat exchangers j
LER 369-87-37 Waste gas surveillance sample was not obtained within tech-l nical specification time limit i
4 LER 369-88-02 A hanger clamp installed on containment isolation valve in j
an unacceptable location due to apparent personnel error 7
The sampled LERs contained commitments to a wide variety of corrective actions l
including hardware modifications, procedure revisions, and~ technical studies.
l The team did not identify any safety significant deficiencies with respect to the licensee meeting and maintaining the commitments in the sampled LERs.
The team noted that the majority of procedures that were revised were not footnoted and did not reference the associated commitment as required by the l
licensee's administrative procedures. Although not required by procedure, the team also noted that a number of modification packages referenced the commit-l ment and applicable documentation.
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