IR 05000029/1986002

Insp Rept 50-029/86-02 on 860107-0214.Violation Noted: Failure to Provide Adequate Procedure for Conducting Tech Spec Required Surveillance of Process Radiation Monitoring Sys

ML20140E810
Person / Time
Site:	Yankee Rowe
Issue date:	03/24/1986
From:	Elsasser T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20140E786	List: IR 05000029/1986002 ML20140E783 ML20140E798
References
50-029-86-02, 50-29-86-2, NUDOCS 8603280204
Download: ML20140E810 (15)

Text

-_.

'

.. .

.

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /86-02 Docket N Licensee N DPR-3

'

Licensee: Yankee Atomic Electric Company 1671 Worcester Road Framingham, Massachusetts 01701 Facility Name: Yankee Nuclear Power Station Inspection at: Rowe, Massachusetts Inspection Conducted: January 7 - February 14, 1986 Inspector: H. Eichenho - ior Resident Inspector

"

Approved By:

T. Elsasser@sf, Reactor Projects Section 3C Date Summary: Inspection on January 7 - February 14, 1986 (Report No. 50-29/86-02)

i

Areas Inspected: Routine o~nsite regular and backshift inspection by the resident inspector (99 hours0.00115 days <br />0.0275 hours <br />1.636905e-4 weeks <br />3.76695e-5 months <br />). Areas inspected included: Review of licensee action on pre-vious findings, operational safety verification reviews, reviews of events requir-ing telephone notification to the NRC, review of plant events, review of radiologi-cal controls, Plant Information Report reviews, maintenance observations, Licensee Event Report reviews and followup, surveillance observations, and Plant Operations Review Committee activitie Results: One violation was found involving failure to provide an adequate procedure for conducting TS required surveillance of Process Radiation Monitoring System (Section 3). Areas needing increased licensee attention involve the classification of certain activities as-surveillance when it should be more appropriately identi-fied as maintenance activities (Section-10), and traceability to calibrated test and measuring equipment (Section 11). The licensee's housekeeping practices and its philosophy that maintains the control room annunciators in a clearly " black-board" status were viewed as continuing licensee strengths.

G l t

. . . - - , - _ _ . . . - . , , . - _._,,~..,.,my.m.. m-.,-.,, .e.,-, , ,,. - . . , . . . . . , . . . , , ,..r.-, r . - . . -, ....,r.--.. ._ m_., _ l

.- - . . . .. .

.

DETAILS Persons Contacted Plant Operations B. Drawbridge, Assistant Plant Superintendent T. Henderson, Technical Director N. St. Laurent, Plant Superintendent-The inspector also interviewed other licensee employees during the-inspection, including members of the Operations, Radiation Protection, Chemistry, Instru-ment and Control, Maintenance, Reactor Engineering, Security, Training, Tech-nical Services, and General Office Staff ' Summary of Facility Activities

'

At the start of the inspection period on January 7, 1986 the plant was at. full

.

power. Dose Equivalent Iodine levels in the reactor coolant were in the range of 4-6% of the Technical Specifications (TS) limit throughout the inspection period. The plant was.at full load until January 25, 1986, when a planned load reduction to 73% and subsequently 65% was implemented by the licensee to per-form maintenance on the No. 2 Heater-Drain Pump (excessive packing leakage)

and turbine throttle valve exercise, respectively. The plant . returned to full

~

power status on January 26, 1986, and remained at the full power level until January 31, 1986.- On this date a plant load reduction was implemented to the

'76% power level to allow removal of the No. 3 Boiler Feed Pump from service due to a leaking pump seal. The plant was returned to full power status on February 1, 1986.

At the end of the' inspection period the plant was at full powe . Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (85-18-02) Determine the appropriateness of the lic-ensee's review and approval of activities controlled by procedure OP-2120, System Component Isolation, Pressure / Leak Test and Return to Service. This procedure was a " fill-in-the-blank" type' of procedure, which when utilized-would not receive further review and approval from the onsite review' committee

(PORC), or the Plant Superintendent. Inspector concerns had involved the potential = failure of-the licensee to implement' required reviews when utilizing this procedur ,

The licensee had cancelled this procedure at PORC meeting 86-9 on February 4,- 1986, and stipulated that all hydrostatic testing not presently covered l by existing procedures will be performed in accordance with one-time type l

'

procedures developed for the specific test activity. The licensee's actions have satisfactorily resol'ved all inspector concerns.

,

This item is considered closed.

!

. .

.

.

, 3 (Closed) Unresolved Item (85-24-01). Licensee to assess the operability of-the No. 4 Steam Generator.(SG) Blowdown Monitor during the period December 26-31, 1985. Subsequent to the end of-the last inspection period, the inspec-tor again observed the recorder trace for this monitor to be reading in an erratic fashion. This occurred on January 8, 1986. The indication was similar

-

to that observed in the prior inspection period, and when compared to the recorder traces for the three other channels it appeared to be an.off-normal i indicatio The inspector questioned the licensee as to the operability of this TS Section 3.3.3.1 (Table 3.3-4) required monitor. The licensee was unable to provide an assessment of the operability of the No._4 SG Blowdown Monitor, based upon recorder traces.-Therefore, the Shift Supervisor (SS) requested that.the

, Radiation Protection Department perform Procedure OP-4801, Functional Test and Alarm Settings of the Process. Radiation System. Because the instrument

,

channel failed to meet the acceptance criteria of the functional test, the licensee declared the monitor inoperable and entered the associated action

statement of TS Section 3.3.3.1. Maintenance Request (MR) 86-60 was issued

'

to investigate and repair the instrument channe The inspector's observations on January 8,1986, reaffirmed the NRC belief that meaningful qualitative criteria does not exist for the operators to ade-quately assess the performance of this instrument channel during channel checks.

I TS Table 4.3-3 requires the licensee to perform a once per shift channel check-l for the SG Blowdown Monitors. TS Definition 1.10 defines a' channel check as a qualitative assessment of channel behavior during operation by observatio The determination shall include, where possible, comparison of the channel indication and/or status with'other indications and/or status derived from

.

independent instrument channels measuring th'e same parameters. Licensee Pro-cedure AP-2007, Maintenance of Operations Departmental Logs. Attachment l'A",

requires the control room operators to perform a once per shift channel

'

.

operability check on the SG Blowdown Monitors that consists of verifying that-recorders are operating.and indicating, meters indicating upscale from 10 cpm, power on green lamp lit, failure lamp not lit, alarm switches in operate, and

, high and warning lamps off. Contrary to TS definition 1.10, AP-2007 does not

.

require comparison of channel indications, and is therefore inadequate for

. performing the requir.ed channel chec Failure to establish a written pro-cedure in sufficient detail to ensure the proper performance of an operability channel check of the SG Blowdown Monitors is considered a violation (50-29/

86-02-01); unresolved item 85-24-01 is considered closed. The inspector con-cluded that the licensee's failure to investigate the apparent discrepancy

!

in the No. 4 SG Blowdown Monitor on two separate occasions was attributed to the. failure of AP-2007 in providing the necessary qualitative criteria for determining operability of the Monito It should be noted that the-licensee's failure to perform an adequate channel

, check is very similar to a prior violation (85-07-02) related to qualitative

assessments-as described in Inspection Report 50-29/85-07. This suggests that

!

the licensee needs to assess its current pr.actices involving operability checks, to ensure that further deficiencies do not exist.

t

.. .

4. Operational Safety Verification Reviews Daily Inspection During routine facility tours, the following were checked: manning, ac-cess control, adherence to procedures and LCOs, instrumentation, recorder

~

traces, protective systems, control rod positions, Containment tempera-ture and pressure, control room annunciators, radiation monitors, radi-ation monitoring, emergency power source operability, control room and shift supervisor logs, tagout logs, and operating orders. No inadequacies were identified except as noted below:

--

On January 9, 1986, the licensee implemented MR 86-62, Main Coolant Hot Leg High Temperature Annunciator NA-35, which resulted in the recalibration of all four hot leg alarm setpoint instruments to 558 degrees Fahrenheit from the previous setting of 555 degrees Fahren-heit. This action was taken to remove the continuous alarm that resulted from the No. 4 Main Coolant Loop temperature operating above the prior alarm setpoint and was approved via a temporary change, as allowed in T5 Section 6.8.4,.to Procedure OP-6201, Re , Main Coolant Hot Leg Narrow Range & Wide Range Temperature Chan-nels Calibration, prior to recalibration of the four MC loop tem-perature indication channel The inspector reviewed the licensee's Core XVIII Performance Analy-sis, dated August 1985, and determined that the current loop oper-ating temperature and revised high alarm setpoint is consistent with the envisioned operating and design thermal-hydraulic parameter for this core. However, the inspector did express some concern to the licensee because the Operations Department did not initiate tempor-ary changes to the following procedures which were affected by the setpoint change: 1) OP-3534, Rev. 8, Main Coolant Hot Leg High Tem-perature Alarm Response Procedure, and 2) AP-2011, Rev. 15, Opera-tions Department Log Control - Rowe Station Log No. 2. It was also noted that the licensee's Systems Training Manual, Chapter 13 - Main Coolant, specifies the previous 555 degrees Fahrenheit setpoint for the NA-35 alarm setpoint. The above referenced procedures were changed by the licensee on January 10, 198 The inspector determined that when implementing setpoint changes to instrumentation the. licensee does not have a formal or' systematic administrative mechanism to take 'nto account all applicable reviews and documentation actions; such as, when appropriate, 50.59 reviews, preimplementation Onsite Review Committee reviews, FSAR uodates, Operator Training Manual updates, and plant procedure revision The inspector has recommended to licensee representatives that the development of a systematic approach to instrument setpoint changes be considered as a station-practice in the near futur I

.. .

--

Throughout the inspection period, there were only two annunciators (one involving the Safety Injection Tank level and the other for the Neutron Shield Tank Temperature) which were categorized as spurious alarms, since they were not traceable to actual plant con-ditions. The above-described action for the change in setpoint for the high Main Coolant hot leg temperature alarm is reflective of the licensee's program of maintaining meaningful alarm parameters and reducing any unnecessary ' continuous alarm conditions when they are not indicative of actual off-normal plant' operation. The in-spector regards the licensee's philosophy and practice of maintain-ing the control room annunciators in as close to a " black-board" status as possible to be a notable licensee strengt b. System Alignment Inspection Operating confirmation was made of selected piping system trains. Ac-cessible valve positions and status were examined. Power supply and breaker alignments were checked. Visual inspections of major components were performed. Operability of instruments essential to system perform-ance was assessed. The following systems were checked:

Emergency Diesel Generator (EDG) unit standby verified during tours

--

of the EDG rooms and control room board status review

--

Steam Driven Emergency Feedwater Pump unit' standby verified during tours of the Auxiliary Boiler Room Low and High Pressure injection systems verified during tours of

--

the Safety Injection Building and control board status review

--

Motor driven Emergency Feedwater Pump standby status verified during tours of the Primary Auxiliary Building c. Biweekly and Other Inspections (1) During Plant tours, the inspector observed shift turnovers; compared boric acid tank samples and tank levels to the Technical Specifica-tion; and reviewed the use of radiation work permits and Health Physics procedures. Area radiation and air monitor use and opera-tional status were reviewed. Verification of tagouts. indicated the action was properly conducted. There were no inspector identified deficiencies in this are (2) Observations of Physical Security On January 7, 1986, the inspector held a discussion with the SAS Operator relative to the implementation on compensatory measures which were required to be in place at the time due to i g erable Security System features. Based upon the inspector's interview, the SAS Operator exhibited weaknesses in the level of knowledge of what

- - - - - - - - - - - - - - - - - - - - - - - . - - - - . . - - - --_

,

. .

.

his required actions were to be. This condition was brought to the attention of the licensee's Security Supervisor for corrective ac-tion. Furthermore, there appeared to be confusion about-the use of the Security System Deficiencies Log which is specified in Procedure DP-0474, Loss / Degradation of Security Systems and Compensatory Measure The inspector verified that: 1) appropriate remedial action was taken for the individual who exhibited a weakness in his knowledge level about required compensatory measures, and 2) the licensee's security contractor issued Temporary /Special Procedure No. 86-1 on January 8, 1986 to aid the CAS and SAS Operators in ensuring that proper compensatory measures remain in effect at all time No additional deficiencies were noted by the inspector in this area daring the inspection perio (3) Fire Protection and Housekeeping There were no inadequacies noted in the licensee's performance in regards to either fire protection or housekeeping practices. Through the licensee's strong commitment to proper housekeeping conditions and practices, the plant has now been returned to the high level of perfonnance that existed prior to the last refueling outage that ended in December, 198 . Review of Events Requiring Telephone Notification to the NRC The circumstances surrounding the following event requiring NRC notification via the dedicated ENS-line was reviewed. A summary of the inspector's review findings follows:

On February 1,1986 at 2:50 p.m. , the licensee notified the NRC via the ENS-line that the Security System was to be removed from service for the perform-ance of system maintenance. Compensatory measures were instituted by the lic-ensee. The system was fully returned to service by 6:53 p.m. and the compen-satory measures terminated. A subsequent ENS call was made at 7:25 p.m. to update the NRC on the system statu The inspector determined that this event was a moderate loss of physical security' effectiveness (i.e., a major loss of physical security effectiveness but, properly compensated), with the licensee's appropriate use of the ENS in compl 73.71(c)ying with the the

. In addition, 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> reporting licensee submitted requirement to NRC:stipulated Region Iinits10 CFR five day written report describing the even No inadequacies were identified as a result of the inspector's review of this even . _ _ _ _ _ _ _

.

.

7 Inspector Review of Plant Events At 10:10 a.m. on January 31, 1986, the licensee implemented an unscheduled controlled plant load reduction at 10% per hour from full load in accordance with procedure OP-2107, Rev. 11, Changing Generator Load. This action was taken due to excessive leakage from one of the seals on the No. 3 Boiler Feed Pump. At approximately 76% of full power, the pump was removed from service to perform the required maintenanc At 6:30 p.m. on the same day, the maintenance activities w;re completed and a plant load increase at 2% per hour was initiated. The plant achieved full load status at 6:00 a.m. on February 1, 1986. No abnormalities in equipment or plant response were noted during the. unplanned load change No inadequacies were identifie . Radiological Controls Radiological controls were observed on a routine basis during the reporting period. Standard industry radiological work practices, conformance to radio-logical control procedures and 10 CFR Part 20 requirements, were observe Independent surveys of radiological boundaries and random surveys of non-radiological areas throughout the facility were taken by the inspecto There were no deficiencies identified by the inspector as a result of review-

-ing the licensee's activities in this are . Plant Information Reports (PIRs) -

PIRs prepared by the licensee per AP-0004 were reviewed. The inspector deter-mined whether the conditions were reportable as defined in the TS and whether the licensee's system of problem identification and corrective action is being-effectively utilized. The following PIRs were reviewed:

PIR N Occurrence Date Report Date Subject 85-12 11/21/85 1/10/86 Liquid Spill in the Safe Shutdown Building While Performing 0P-2.1 " Pressure Leak Test of CH-V-773 and SI-V-646" 85-14 11/29/85 1/21/86 Damage to No. 2 LPSI Pump Seals and Casing Gasket During Perform-ance of ISI System Leakage Test Except for the following comments, the inspector had no further question PIR 85-12: This event was reviewed in Inspection Report 50-29/85-18 (Section 8). Further comments, contained in Section 3 of this report, address the lic- i ensee's use'of procedure OP-2120. To prevent recurrence of incidents of this

{

l

!

.

.

.

type, all hydrostatic testing will be performed using existing specific pro-cedures or licensee developed one-time procedures for the specified test. This will ensure a thorough review of test instructions, valve lineup, etc., thus reducing the likelihood of error. Additionally, the licensee counseled per-sonnel who write and approve hydrostatic test procedures, as well as those who perform the test, on the importance of ensuring that procedures are com-plete and accurate, and that the tests are performed in a manner that will not adversely affect the plan PIR'85-14: The licensee has determined that the damage to the No. 2 LPSI pump seals and casing gasket was a direct result of a test being conducted impro-perly due to 0P-2120 containing incomplete information. The PIR specifies that the corrective action specified above for PIR 85-12 will preclude recurrenc The inspector identified no violations regarding the licensee's actions as-sociated with these events, and noted that the licensee determined the cause of the occurrence and specified appropriate short term and long-term correc-tive action . Monthly Maintenance The inspector observed and reviewed maintenance and problem investigation ac-tivities to verify compliance with regulations, administrative and maintenance procedures, codes and standards, proper QA/QC involvement, safety tag use, equipment alignment, jumper use, personnel qualification, radiological con-trols for worker protection, fire protection, retest requirements, and re-portability per Technical Specification. The following activities were in-cluded:

--

Maintenance Request (MR) 86-60, No. 4 Steam Generator Blowdown Monitor Failed OP-4801 Functional Test

--

MR 86-62, Main Coolant Hot Leg High Temperature Panel Alar MR 86-83, No. 3 Charging Pump Loss of Speed Control

--

MR 86-142, No. 3 Service Water Pump (P6-3) Check Valve, Motor and Breaker-Complete Inspection

--

MR 86-153, No. 4 Steam Generator Blowdown Monitor Fails Low

--

MR 86-191, PR-LI-8 Pressurizer Water Level of Main Control Board Indi-cates Loss Regarding MRs 86-60 and 86-153, inspector comments concerning equipment operability is contained in Section 3 of this report. Regarding MR 86-191, the Plant Operators initiated this MR on January 28, 1986, due to the PR-LI-8 Pressurizer Wide Range level indicator reading a lower value than other Main Control-Board (MCB) instruments measuring this plant parameter. The licensee initiated procedure AP-6007, Rev. 4, I&C Department Corrective Maintenance,

. -

. .

.

to investigate and correct the apparent error in this instrumentation channe The inspector reviewed the completed procedure and determined that it provided 1) an appropriate reference to TS 3.3.1, Table 3.3-1, 2) Shift Supervisor's release of equipment authorization, 3) the necessary instructions to bypass the RPS trip function during maintenance and the stipulation that this would necessitate implementation of Action Statement No. 8 of TS Table 3.3-1, and 4) step by step instructions detailing the necessary actions to be taken by operations and I&C personne This instrument, which is a single instrument channel trip in the RPS for protection against high pressurizer water level (trips at less than or equal to 200 inches, functions as a limiting safety system setting for Main Coolant System overpressurization and prevents water relief through the pressurizer safety valves), was indicating nonconservatively and lower than other indi-cating channels. As part of its investigation, the licensee implemented on January 31, 1986 portions of procedure OP-4626, Rev.11, Pressurizer Wide Range Level Channel (PR-L-8). As a result, the licensee demonstrated that the instrument channel was operable and at the same time identified and cor-rected the problem associated with a shift in the level transmitter's outpu The licensee determined that prior to corrective action being taken, an ex-pected value of 140 inches resulted in an indication of 133 on the MCB mete The licensee's corrective action necessitated an entry into the Vapor Con-tainer to perform a zero adjustment on the transmitter. This level indicating channel was last calibrated on December 2, 198 The licensee's actions as a result of an observed discrepancy between instru-meni.dtion channels for a plant parameter appears to indicate an increased sensitivity oy plant operators to identify and correct potential off-normal instrumentation situations. Additionally, the inspector observed 1) the plant operators acknowledgment in control room logs that entry was made into the action statement of the TS and the log was appropriately used to document im-portant activity and equipment status, and 2) the record keeping system utilized by the I&C Department provided almost instant access to all relevant documents pertaining to the maintenance activities' performed on this instru-mentation channe The inspector observed no inadequacies as a result of reviewing licensee maintenance activities listed above and encouraged the licensee to maintain the record keeping activities of the I&C Department at the excellent level of performance observe . Review of Licensee Event Reports (LERs)

LERs submitted to NRC:RI were reviewed to verify that the details were clearly-reported, including accuracy of the description of cause and adequacy of cor-rective action. The. inspector determined .:hether further information was re-

. quired from the licensee. whether generic implications were indicated, and whether the event warranted onsite followup. The following LERs were reviewe _ .- - ___ . , .- .. . ..

,. .

i LER N Event Date Report Date Subject 50-29/85-05 11/15/85 12/13/85 Switchgear Room Fire Barrier 50-29/85-06 11/20/85 12/20/85 Condensate Pump. Trip Circuit Inoperable 50-29/85-08 12/06/85 01/03/86 No. 4 Steam Generator Blow-down Monitor Inoperative-50-29/85-09 12/09/85 01/08/86 Reactor Scram 50-29/85-10 12/28/86 01/27/86 Inadvertent Reactor Scram i During Maintenance Activity LER 50-29/85-05, Switchgear Room Fire Barrier. Documentation of the licensee's corrective actions and inspection ~ findings is contained in Inspection Report 50-29/85-18, Section 7.

!' LER 50-29/85-06, Condensate Pump Trip Circuit: Inoperable. Documentation

of the licensee's corrective actions and inspection findings is contained

in Inspection Report 50-29/85-18, Section 7.

l LER 50-29/85-08, No. 4 Steam Generator Blowdown Monitor Inoperable. This

event represented an_inoperability of this process monitoring. instrument l due to an apparent backleakage of feedwater through the blowdown to.

! feedline cross-connect check valve BF-V-894. The action statement in TS 3.3.3.1 required an-operable continuous-monitor be placed in service I within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. However, the licensee could not meet this condition due-i to the backleakage precluding the effluent path from the steam generator _.

i from reaching the monitor. The plant was in Mode 2 at the time of this

incident. Proper operation was verified on December 7, 1985; however, l the problem recurred on December 9, -1985. Immediate corrective action consisted of flushing the BF-V-894 check valve utilizing an Emergency Boiler Feed Pump. The licensee-is performing an engineering evaluation

,

!

to determine corrective action to prevent recurrence. The inspector _noted that this event was detected by-the licensee as a result of chemistry analysis that is considered to be part of a strong Chemistry Progra This LER remains open pending the completion'of the licensee's engineer-ing evaluation.

, LER 50-29/85-09, Reactor, Scram. Documentation,of the licensee's correc-tive actions and inspection findings is contained in Inspection Report j 50-29/85-24, Section 6.

l LER 50-29/85-10, Inadvertent Reactor Scram During Maintenance Activity.

! Initial inspector review of the plant trip and . licensee action' were -

1 documented in Sections 6 and 7 of Inspection Report 50-29/85-24. The l licensee attributed this event to personnel error; i.e., allowing the i conduct of surveillance procedure OP-4601, Revis' ion 15, Nuclear Instru-

!

I

_ . __

.. .

11'

mentation Channels Functional. Test,'which because of plant conditions would result in a channel actuation with only one channel being necessary to trip the RPS. In reviewing the' details of the event, the. inspector determined that: (1) I&C had reques.ted that the No. 3 Intermediate Range (IR) Channel be released for maintenance, and (2) the Shift Supervisor released the equipment via the initiation and use of surveillance pro-

,

cedure OP-460 Because the plant 15 MWe, the RPS Startup Rate (SUR) trip power levelwas protection at the time was lessinthan automatically effect. By conducting 0P-4601, a channel actuation was effected, and the' trip occurred because only one channel was necessary to trip the RP Inspector concerns associated with this event involved the release of equipment for an activity which appears to have been classified surveil-lance rather than maintenance. The inspector reviewed the contrcl room log for . December -28,1985 and noted that no mention was made by the plant operators as to their intent to enter Action Statement No. 3 of TS Table 3.3-1, which would have been required for maintenance on the IR Channe Based on interviews with licensee personnel, the inspector confirmed that the activity had been considered a surveillance, rather than maintenance activit As a result, the operational constraints imposed by the TSs

.

were not considered. The activity was controlled by procedure 0P-4601 rather than procedure AP-0207, Revision 6, Equipment Control, which specifies that permission to release equipment or systems shall be granted by the Shift Supervisor, who prior to granting permission shall verify that the equipment or system can be released, and shall determine how long it may be out of service (the basis for the time that the equipment may be out of service is the TS limits). AP-0207 further re-quires that granting of such permission be documente The inspector determined that when performing maintenance activities the use of surveillance procedures may be appropriate to control certain ac-tivities but, by themselves do not provide the documentation or assurance that the requirements of AP-0207 are performed. The inspector noted that in Inspection Report 50-29/85-15, Section 7, a similar observation in-

volving classification of a maintenance activity being inappropriately specified by the Operations and I&C personnel as surveillance, resulted in failure to properly acknowledge the operational constraints imposed by the TSs. At that time, the Assistant Plant Superintendent (APS) as-sured the inspector that the TS implications of proposed maintenance between the I&C and Operations Department would receive added attentio On January 17, 1986, the inspector held a discussion with the Plant Superintendent (PS) and the APS to discuss inspector concerns on this matter. The PS acknowledged the inspector's comments and concerns, and indicated that appropriate corrective measures would be.take On January 17, 1986, the Operations Department issued Special Order 86-13, which describes the relationships between surveillance and maintenance activities, places appropriate guidance on the required operator actions when utilizing a surveillance procedure during the conduct of maintenance, and dcscribes in more detail the operator's considerations for releasing

!

.

. .

1 TS. required equipment and the manner in which it must be documente Additionally, the I&C Department emphasized equipr.ent release require-

,

ments for maintenance activities during a recent department training session. The licensee aho plans to revise OP-4601 to clarify the high startup rate scram precautions and to provide new prerequisite The inspector has determined that the licensee was fully responsive to

'

this issue by virtue of the corrective actions implemented, and has demonstrated a satisfactory level of awareness to the requirements in subsequent maintenance activitie The inspector will continue to review the licensee's performance in acknowledging and documenting the applicability of TS requirements during future inspection . Monthly Surveillance Observation The inspector observed tests and parts of tests to assess performance in ac-cordance with approved procedures and LCOs, test results (if completed), re-moval and restoration of equipment, and deficiency review and resolution. The following tests were reviewed:

--

OP-4204, Rev. 31, Test of the Safety Injection Pumps and Determination of ECCS Subsystem Leakage

--

OP-4211, Rev. 17, Emergency Feedwater System Operability Test

--

OP-4232, Rev. 15,. Vapor Container. Inspection

--

OP-4615, Rev. 5, Safety Injection Accumulator Level Switch Operational Check and Check of Functions Performed by Level Switches Based upon a' review of licensee activities in tiiis area the inspector noted the following: The inspector has observed that plant operators specify the completion of surveillance procedures in the control room log. To be more fully responsive to the requirements stipulated in procedure AP-2007, Rev. 17, Maintenance of Operations Department Logs, the inspector recommended for

,

consideration by the Plant Operations Manager-(P0M) that the control room personnel record the time that a surveillance activity was initiate The POM indicated that this matter would be taken under consideratio During the review of completed procedure OP-4615, the inspector noted that the " REMARKS" section of the procedure indicated that the procedure was not performed verbatim, in that, the system fluid was not available and demineralized water was used instead. The I&C personnel did not' pro-perly implement a temporary change to the procedure as required by the plant administrative procedures and TSl administrative requirement , _ , _ . _ _-.

-

.

The inspector determined that: 1) the actual performance of the test as conducted was not contrary to the intent of the procedure and 2) there were no safety issues associated with the manner in which the surveil-lance activity was conducted. The I&C Department Supervisor reviewed this incident in a departmental training session with I&C personnel shortly after the inspector identified the condition. Additionally, the I&C Supervisor brought the condition to the attention of Senior Plant man-agers for their review. Because this practice appears to be an isolated incident, is not indicative of the n_ormally high regard that the licensee maintains for the principal of following procedural requirements 3nd utilizing approved mechanisms to create procedure changes, and received immediate and appropriate corrective action, the inspector determined that enforcement action was not warrante c. As a resui. f reviewing the Emergency Feedwater System operability sur-veillance, performed in accordance with procedure OP-4211, the i'nspector discovered that 1) portable test instrumentation, used in Inservice In-spection (ISI) testing portions of the procedure, were not required to be recorded on the proceaure, and 2) the testing procedure did not in all cases specify the identification number of installed instrumentation that was to be used for recording process parameter data and that would subsequently be compared to TS required acceptance criteria or ISI per-formance requirement The inspector determined that the licensee performs ISI activities in accordance with TS Section 4.0.5, Surveillance Requirements for Inservice Inspection and Testing of ASME Code Class 1, 2, and 3 Component In addition, the licensee's QA Program, Section XI-Test Control, specifies that written test documents be reviewed to incorporate or_ reference calibrated instrumentation as a test prerequisite. Procedure AP-0218, Rev. 7, Test Control, requires the licensee to include in test procedures the requirements for special equipment or calibrated instrumentation as test prerequisite The ISI Coordinator, when questioned about the apparent procedural in-adequacy involving 0P-4211, showed the inspector his informal records documenting the use of specific portable measuring and test equipmen The ISI Coordinator indicated that when establishing test requirements he assures himself that the installed instrumentation to be used for data collection are incorporated in AP-6003, I&C Department Maintenance Pro-gram, and its computerized data base used to track equipment calibration status. The inspector concluded that informal documentation of measu-ing and test equipment used for surveillances was unacceptable due to the lack of traceability to the calibration records. Furthermore, the in-spector determined that not specifically identifying in the appropriate procedure the permanently installed instrumentation to be used for data collection was unacceptable for assuring that only calibrated test and measuring equipment was use e

. - -

The inspector also questioned the manner in which the equipment sign out-records were being utilized, i.e., instruments withdrawn from the tool crib by maintenance personnel were at times being listed for non nuclear safety use whort in fact they were being utilized on safety related sur-veillance activities. According to a Maintenance Department representa-tive, this condition may be due to a perception that surveillance, as

' compared to repairs, are not safety related activities. The Maintenance Supervisor agreed with the inspector that such actions were unacceptable, and therefore reciuired corrective measures. This item will be covered in an upcoming Maintenance Department training session, with the main-tenance personnel instructed in the proper classification of surveillance activities as they relate to safety class' equipmen '

The licensee has also agreed to revise procedure OP-4211 to incorporate the established programmatic controls associated with identifying and

,

documenting the use of calibrated portable and pernnently installed in-strumentation. The inspector will review in a subsmauent inspection -the acceptability of the licensee's revision cf this pi v edure (50-29/86-

,

02-02).

Based upon the NRC identified inadequacies in the lac cf procedural documentation associated. with the testing instrumentat ion for the Steam Driven Emergency Feedwater Pump surveillance, management attention to'

the review and identification of similar daficiencies a procedures governing QA activities is warranted - in particular, a they-relate to

'

ISI and/or TS surveillance testing of pumps and valve Corrective ac-tions needed should result in fully specifying calibrat.d instrumentation that is' to be used. This item remains unresolved pending further licensee action (50-29/86-02-03).

12. Onsite Review Committee

On January 14 and February 11, 1986 the inspector observed the meetings of the Yankee NPS onsite review committee (PORC) to ascertain that the provisions of TS 6.5.1. were me No unacceptable conditions were identifie . Management Meetings During the inspection period, the following management meetings were conducted or attended by-the inspector as-noted below:

--

The inspector attended an-exit meeting held on January 17, 1986, by a

,

region-based specialist at the conclusion of Inspection 50-29/86-01, re-'

view of the licensee's Startup Physics Testing Program,-onsite inspection.

, , . - - . ,,_ _ . - . _ , _ _ , , . - - . . . , - . . - . - -

., . .

e

--

The inspector attended an exit meeting on January 16, 1986, by a region-based specialist at the conclusion of Inspection 50-29/86-03, review of the licensee's Hot Licensing Program, onsite inspectio At periodic intervals during the course of the inspection period, meet-ings were held with senior facility management to discuss the inspection scope and preliminary findings of the resident. inspector.