ML20209E044
| ML20209E044 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 04/11/1987 |
| From: | Shymlock M, Linda Watson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20209E018 | List: |
| References | |
| TASK-1.C.2, TASK-TM 50-424-87-01, 50-424-87-1, IEIN-86-061, IEIN-86-61, NUDOCS 8704290419 | |
| Download: ML20209E044 (39) | |
See also: IR 05000424/1987001
Text
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p2 Ric UNITED STATES
oq'o NUCLEAR REGULATORY COMMISSION
2
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o REGloN il
5 $ 101 M ARIETTA STREET N.W., SUITE 2900
- 8
o ATLANTA, GEORGIA 30323
s,
.....
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Report No.: 50-424/87-01
Licensee: Georgia Power Company
P. O. Box 4545
Atlanta, GA 30302
Docket No.: 50-424 License No.: NPF-61
Facility Name: Vogtle 1
Inspection Conducted: January 5 - 9 and January 12 - 16, 1987
Inspector: h OM
L. J./ Watson, Team Leader
'/!87
Dath Signed
Team Members: B. R. Bonser
M. S. Lesser
A. R. Long
P. B. Moore
G. Nejfelt
l T. J. O'Connor
'
W. K. Poertner
M. B. Shymlock
C. L. Vanderneit
Approved By: WO
M. B. ShymlocY, Chief
M8,887
Date Signed
Operational Programs Section
Division of Reactor Safety
SUMMARY
Scope: This routine, announced inspection was conducted in the areas of
surveillance program administrative controls and implementation, maintenance
program administrative controls and implementation, Technical Specifications
applicability to as-built systems, control room activities and plant
procedures. Corrective action for findings described in NRC Inspection
Reports 424/85-36, 424/86-60 and 424/86-117 were reviewed.
Results: One violation was identified involving four examples of failure to
follow procedures. No deviations were identified.
8704290419 870417
O ADOCK 05000424
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REPORT DETAILS
1. Persons Contacted
Licensee Employees
- #*P. D. Rice, Vice President, Project Engineering
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- G. B. Bockhold, Jr., General Manager, Nuclear Operations
- T. Greene, Plant Manager
- E. M. Dannemiller II, Technical Assistant to General Manager, Nuclear
Operations
- C. E. Belflower, QA Site Manager
- M. A. Griffis, Maintenance Superintendent
- J. F. D'Amico, Manager, Nuclear Safety and Compliance
- W. C. Gabbard, Senior Regulatory Specialist
- C. E. Felton, Vogtle Coordinator, Nuclear Operations
- L. F. Ray, Shift Supervisor
- P. D. Rushton, Plant Training and Emergency Planning Manager
- W. E. Burns, Nuclear Licensing Manager
- R. M. Bellamy, Plant Support Manager
- T. A. Seitz, Corporate Nuclear Office of Quality Assurance
- J. E. Swartzwelder, Deputy Manager, Operations
- H. A. Jaynes, Maintenance Engineering Supervisor
- A. L. Mosbaugh, Assistant Plant Support Manager
- M. L. Hobbs, Instrument and Controls Superintendent
,
- R. E. Conway, Senior Vice President and Project Director
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- J. A. Edwards, Senior Regulatory Specialist
- W. F. Kitchens, Manager, Operations
- L. Russell, Operations Procedure Coordinator
d*C. F. Meyer, Superintendent, Operations
fA. Caudill, Superintendent, Operations
,
- H. Varnadoe, Plant Engineering Supervisor
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Other licensee employees contacted included engineers, technicians,
operators, mechanics, and of fice personnel.
! NRC Resident Inspectors
- J. F. Rogge
- R. J. Schepens
, +*H. Livermore
j * Attended exit interview on January 9, 1987
- Attended exit interview on January 16, 1987
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2. Exit Interview
The inspection scope and findings were summarized on January 9 and 16,
1987 with those persons indicated in paragraph 1 above. The
inspectors described the areas inspected and discussed in detail the
inspection findings listed below. No dissenting comments were
received from the licensee.
IFI Number Status Description / Reference Paragraph
424/87-01-01 Open VIOLATION - Failure to follow procedure for
1) confirmation of test results for vital battery
surveillance (paragraph 7.a.1), 2) QA hold point
review and Shift Supervisor approval to work MWO
(paragraph 7.b.1), 3) verification by maintenance
technicians that drawings and vendor manuals were
current revisions (paragraph 8.a), 4) review and
initialing operations logs (paragraph 10.b)
424/87-01-02 Open IFI - Review of provisions for determining that
acceptance criteria are met (paragraphs 7.a.8
and 12.11)
424/87-01-03 Closed IFI - Followup on adequacy of functional tests
and work instructions for maintenance (paragraphs
8.c and 12.jj)
424/87-01-04 Open IFI - Completion of QA review of DR on mounting
of radiation monitors (paragraphs 7.b.1 and
12.kk)
424/87-01-05 Closed IFI - Determination if temporary modifications
negated surveillance tests completed after
preoperational tests (paragraphs 9 and 12.11)
424/87-01-06 Open IFI - Miscellaneous Findings on Surveillance and
Maintenance Program Review (paragraphs 7.b.3 and
12.mm)
424/87-01-07 Closed IFI - Use of Master Setpoint Document (paragraphs
12.nand12.nn)
424/86-117-01 Closed IFI - Administrative controls for independent
verification of the restoration and testing of
plant equipment did not conform to the guidance
of NRC IE Notice 84-51 (paragraph 12.c)
424/86-117-02 Closed IFI - Venting followup items including high point
vents on AFW and procedure revisions for system
venting (paragraph 12.d)
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424/86-117-03 Closed IFI - Procedure revisions to include adequate
subcooling margin requirements (paragraph 12.e)
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424/86-117-04 Closed IFI - Correction of valve identification and
i system lineup discrepancies (paragraph 12.f)
424/86-117-05 Closed IFI - Correction of technical concerns in Unit
- Operating Procedures (paragraph 12.g)
424/86-117-07 Open IFI - Correction of discrepancies on labeling
of valves and equipment (paragraph 12.h)
424/86-117-09 Open IFI - Correction of discrepancies in RVLIS
surveillance procedure and followup on vendor
recommendations (paragraph 12.1)
424/86-117-10 Closed IFI - Procedure revision to include check of
i equipment actuation on Control Room ventilation
start (paragraph 12.j)
424/86-117-11 Closed IFI - Procedure prerequisites are general and not
well understood by operators (paragraph 12.k)
424/86-117-12 Closed IFI -
Clarification of cleanliness levels
(paragraph 12.1)
424/86-117-13 Closed IFI - Review of events covered by Abnormal
Operating Procedures (paragraph 12.m)
IFI - Licensee to review annunciator response
424/86-117-14 Closed
j procedures for technical adequacy, walkdown
ARPs and revise ARPs involving annunciators
, on the main control board, as appropriate,
prior to fuel load. Remaining ARPs to be
reviewed within 90 days (paragraph 12.n)
!
424/86-117-15 Closed IFI - Resolution of ISI test data for CCW pump
(paragraph 12.0) ,
424/86-117-16 Closed IFI - Resolution of acceptance criteria for
RHR differential pressure on recirc flow
(paragraph 12.p)
424/86-117-17 Closed IFI - Resolution of water hammer in NSCW ESF
chillers (paragraph 12.q)
424/86-117-18 Closed IFI - Review of implementation of the surveil-
lance program administrative controls and
tracking system (paragraph 12.r)
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424/86-117-19 Closed IFI - Review of test control and configura-
tion control for surveillances performed
prior to release to the Operations Department
(paragraph 12.s)
424/86-117-20 Closed IFI - Revise procedures to clarify use of
Staggered Test Basis for determining frequency
of test (paragraph 12.t)
424/86-117-21 Closed IFI - Review of the justification for the use
of pre-operational tests to meet surveillance
test requirements (paragraph 12.u)
424/86-117-22 Closed IFI - Corrective action to assure control of
4 twelve hour surveillances (paragraph 12.v)
424/86-117-23 Open IFI - Resolution of various technical issues
in regard to surveillance procedure adequacy
(paragraph 12.w)
424/86-117-24 Closed IFI - Licensee to implement operational phase
corrective and preventive maintenance program
(paragraph 12.x)
424/86-117-25 Closed IFI - Resolution of Technical Specification
3/4.7.5 wording
the Ultimate Heat in regparagraph
Sink (ard to availability 12.y) of
424/86-117-26 Closed IFI - Corrective action for locking or system
lineup verification of boron injection flowpath
< valves (paragraph 12.z)
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424/86-117-27 Open IFI - Followup on surveillance procedures
which have not been identified as complete
, on the Technical Specification / procedure
i cross reference tracking list and review of
completed cross reference tracking list
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(paragraph 12.aa)
424/86-117-28 Closed IFI - Procedure revision for consistent defini-
tion of surveillance test completion date and
time (paragraph 12.cc)
424/86-117-29 Closed IFI - Review of implementation of special
triggering mechanisms to assure completion of
special condition surveillances (paragraph
12.dd)
424/86-117-30 Closed IFI - Controls on location of BOP operator
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(paragraph 12.ee)
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424/86-117-31 Open IFI - Verification of key control and access
to plant equipment by operations staff (para-
graph 12.ff)
424/86-117-32 Closed IFI - Revise TS and procedure for 18 month check
of reactor trip breaker UV and shunt coil trip
(paragraph 12 99)
424/86-117-33 Open IFI - Resolution of miscellaneous technical
concerns on operating procedures (paragraph
12.hh)
424/86-60-10 Closed IFI - Adequacy of shift turnover procedures
(paragraphs 10.b and 12.00)
424/86-96-05 Closed IFI - Review of completed surveillance procedures
(paragraph 12.bb)
TMI It e T.C.2 Closed Shift Relief and Turnover (paragraphs 6 and 10.b)
Although proprietary material was reviewed during the inspection, no
proprietary material is contained in this report.
3. Licensee Action on Previous Enforcement Matters
This subject was not addressed in the inspection.
4. Unresolved Items
]
- No unresolved items were identified during the inspection.
5. List of Abbreviations
i ACCW(S) Auxiliary Component Cooling Water System
AFW Auxiliary Feedwater System
A0P Abnormal Operating Procedure
ARP Annunciator Response Procedure
BIT Boron Injection Tank
B0P Balance of Plant
CBCS Containment Building Cooling System
CCP Centrifugal Charging Pump
CCW(S) Component Cooling Water System
CSS Containment Spray System
CVCS Chemical and Volume Control System
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DR Deficiency Report
ECCS Emergency Core Cooling System (s)
EDG Emergency Diesel Generators
E0P Emergency Operating Procedure
EQ Environmental Qualification
EQDP Environmental Qualification Data Package
ESF Engineered Safety Feature
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F Degrees Fahrenheit
FSAR Final Safety Analysis Report
HFAS High Flux at Shutdown
HVAC Heating, Ventilation and Air Conditioning
HX Heat Exchanger
IEN NRC Office of Inspection and Enforcement Notice
IFI Inspector Followup Item
IST Inservice Test
LP Lineup Procedure
MDAFW(P) Motor Driven Auxiliary Feedwater (Pump)
MLB Monitor Light Board
M0V Motor Operated Valve
MSIV Main Steam Isolation Valve
MWO Maintenance Work Order
MWPG Maintenance Work Planning Group
NLO Non-Licensed Operator
NPMIS Nuclear Plant Maintenance Information System
NRC Nuclear Regulatory Commission
NSAC Nuclear Safety and Compliance Section
NSCW Nuclear Service Cooling Water System
P&ID Piping and Instrumentation Diagram
PORV Power Operated Relief Valve
PRZR Reactor Coolant System Pressurizer
QA Quality Assurance
RER Request for Engineering Evaluation
RHR Residual Heat Removal System
R0 Reactor Operator
RVLIS Reactor Vessel Level Indication System
RWST Refueling Water Storage Tank
SI Safety Injection
SIS Safety Injection System
S0P System Operating Procedure
SS Shift Supervisor
SSMP System Status Monitoring Panel
STS Standard Technical. Specifications
TCP Temporary Change to Procedure
TDAFW(P) Turbine Driven Auxiliary Feedwater (Pump)
TS Technical Specification
UOP Unit Operating Procedure
VCT Volume Control Tank
6. Review of TMI Items (TI 2515/65)
(Closed) TMI Item I.C.2. Shift Relief and Turnover. The inspector ,
reviewed the implementation of the requirements of TMI Item I.C.2 and i
determined that the licensee had completed the actions necessary to meet I
these requirements. This review is documented fi paragraph 10.b of this i
report. TMI Item I.C.2 is closed. ;
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7. Surveillance Program and Procedure Review (42450B)
During the inspection ending December 12, 1986, the inspectors had
determined that the licensee had not yet fully implemented the surveil-
lance program administrative controls except on a small number of systems
which had been accepted by the Operations Department. This item had been
identified as IFI 424/86-117-18. During this inspection, the inspectors
reviewed the implementation of the surveillance program and a number of
additional surveillance test packages. Although several concerns and
one example of a failure to follow procedure were identified; in general,
the results of this review indicated that the surveillance program was
adequately implemented. The review conducted is documented below. IFI
424/86-117-18 is closed,
a. Review of Completed Surveillance Packages
The inspectors reviewed completed active surveillance packages. The
surveillance reviews were performed to verify that specific controls
were established and the surveillance system was working in accord-
ance with procedure 00404-C, Surveillance Test Program. The
inspectors reviewed the following:
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System was readied by Operations before performance of the
surveillance.
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Prerequisites were completed and if not completed, adequate
justification was provided for prerequisites which were
marked not applicable.
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All procedural steps were completed or marked appropriately.
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Acceptance criteria were met and completed surveillances
were included in the surveillance tracking system.
- Data packages supported the acceptance criteria.
- Task sheets were attached and completed in accordance with
procedure 00404-C, Surveillance Test Program.
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Appropriate reviews were completed as required.
The surveillance packages reviewed were:
SURV. TASK TITLE COMPLETED DATE
14225-101 Operations Weekly Surveillance Logs 1/14/87
14235-102 On Site Power Distribution Operability 1/10/87
Verification
14420-101 Solid State Protection System Train A 1/01/87
(B) Operability Test
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14420-102 Solid State Protection System Train A 1/10/87
(B) Operability Test
14423-106 Source Range NIS Analog Channel 1/14/87
Operational Test
14805-101 Residual Heat Removal Pump and Check 1/09/87
Valve Inservice Test
14811-101 Boric Acid Trant.fer Pumps and Discharge 1/08/87
Check Valves Ir. service Test
14850-102 Cold Shutdown Valve Inservice Test 1/08/87
14890-1 Diesel Generctor Operability Test Not recorded
14895-101 ECCS Check Valve Refueling Inservice 9/27/86
14896-101 ECCS Check Valve Cold Shutdown Inservice 9/22/86
14980-111 Diesel Generator Operability Test 1/09/87
14980-1 Diesel Generator Test Not recorded
(Fuel Oil Sampling for Water)
24342-1 Pressurizer Level Control F-121 Not recorded
Channel Calibration
24519-101 R. C. Pressure (Wide Range) Protection I 10/21/86
P-405 ACOT and Channel Calibration
24519-103 R. C. Pressure (Wide Range) Protection I 1/07/87
P-405 ACOT and Channel Calibration
24597-1 Containment Cooling Units 5, 6, Not recorded
7 & 8 - Condensate Detection L-17094
24626-101 Containment Vent Effluent Air Particulate 1/08/87
Monitor 1RE-2565A
24681-101 Meteorological Station 10M Wind Direction 10/30/86
Channel Calibration
24684-C Meteorological Station 60M Wind Speed Not recorded
Channel Calibration
24688-101 Meteorological Station 10M Ambient and 9/12/86
and 10-60M Delta Temperature Channel
Calibration
24737-101 Time History Accelerograph AXT-19903 12/04/86
24737-102 Time History Accelerograph AXT-19903 12/04/86
24739-101 Peak Acceleration AXR-19910 1/02/87
24806-101 Refueling Water Storage Tank Level L-990 1/15/86
ACOT and Channel Calibration
24840-101 Containment Pressure High Transmitters 1/02/87
RTT Sensors PT-934
28210-101 Main Steam Line Safety Valve Test 4/86
thru 120
28211-101 RHR Suction Relief Valve Test 2/20/86
28211-102 RHR Suction Relief Valve Test 1/09/86
28215-101 Safety Relief Valve IST 1 PSV-8010A 3/04/86
28215-102 Safety Relief Valve IST 1 PSV-80108 2/27/86
28215-103 Safety Relief Valve IST 1 PSV-8010C 3/05/86
28290-101 Containment Spray Nozzle Flow Test N/A
28711-101 Diesel Fuel Oil Storage Tank Cleaning 9/08/85
28711-102 Diesel Fuel Oil Storage Tank Cleaning 9/09/85
28712-101 Diesel Fuel Oil Piping Pressure Test 3/23/84
28820-C Battery Charger Load Test Not recorded
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28905-C Motor Operated Valve Thermal Overload Not recorded
and Bypass 18 Month Test
28910-102 Class 1E 18 Mo. Battery Inspection 12/08/86
and Maintenance
28912-102 Class IE Quarterly Battery Inspection 1/02/87
and Maintenance
54708-101 Containment Isolation and Containment 10/14/86
Ventilation Isolation - Manual
Initiation
54820-101 Train "A" SI Pump Response Time Test 9/28/86
54822-101 Train "B" SI Pump Response Time Test 9/28/86
54825-101 Train "B" CCWP Response Time Test 9/25/86
The following items were identified during the inspection:
(1) On procedures 28910-101,102,103, and 104, Class 1E 18-Month
Battery Inspection and Maintenance, the inspector noted that
the recorded data indicated that intercell resistance on
rack to rack and tier to tier jumpers exceeded the Technical
Specification requirement of 50 X 10-6 ohms. The Surveillance
Task Sheets (STS), which listed the TS requirement as part of
the acceptance criteria, had in each case been signed off as
meeting acceptance criteria. The licensee was questioned about
the signoffs. The licensee stated that the engineer had signed
off the step because the excess resistance was attributed to the
cable length between the rack to rack and tier to tier jumpers.
The inspector requested the evaluation of the cable resistance
value. The licensee stated that an evaluation had not been
performed. Since the cable resistance had not been determined
and subtracted from the total resistance, the value of the cell
to cell resistance was not known.
Procedure 00404-C, Surveillance Test Program, Step 4.5.4.1,
requires an independent reviewer to confirm that test results
satisfy acceptance criteria. The reviewer signed the STS
indicating that the acceptance criteria were met.
10 CFR 50, Appendix B, Criterion V, requires that activities
affecting quality be accomplished in accordance with documented
instructions, procedures, or drawings. This requirement is
implemented by Section 17.2, Operations Quality Assurance
Program, of the FSAR. The failure to follow procedure 00404-C
to confirm that test results met the acceptance criteria for
the rack to rack and tier to tier jumpers on the vital batteries
is identified as an example of violation 424/87-01-01.
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(2) On data sheet 2 of procedure 14423-106, Source Range NIS Analog
Channel Operational Test, performed on January 14, 1987, the
normal reading taken from the Neutron Level Drawer Meter
exceeded the upper limit values given on the data sheet. A
note on the data sheet directs the test performer to add the
pre-test indication on meter NI-101 to the upper limit values
for specific switch positions given on the data sheet. This
would raise the upper limit. Nowhere on the- data sheet,
however, is the reading on NI-101 documented. This makes the
true upper limit unclear and makes it appear the procedure is
unsatisfactory when in fact it is satisfactory. The licensee
agreed to change the procedure to include the reading on NI-101
on the data sheets.
No violations or deviations were identified.
(3) On procedure 14423-106, the High Flux at Shutdown (HFAS) set-
point was not checked. A note on the proceddre stated that the
i HFAS setpoint would be set after two fuel bundles were loaded
t
in the reactor vessel. The inspector questioned the licensee
on the triggering mechanism for establishirg the HFAS setpoint.
The licensee stated it was part of startup test procedure
- 1-500-01, Initial Fuel Load Test Sequence. The inspector
verified this and had no further comments.
1 No violations or deviations were identified.
(4) On procedure 14895, ECCS Check Valve Refueling Inservice Test,
completed September 17, 1986, required flow rates which were
marked "LATER" had been changed to specific values without a
proper procedure revision. This item had also been identified
by the licensee's QA audits and was being followed by QA.
No violations or deviations were identified.
(5) Procedure 14811, Boric Acid Transfer Pumps and Discharge Check
Valves Inservice Test, had been identified as not acceptable by
the IST group but NSAC was showing the surveillance to be
acceptable. This item was also identified in a QA audit and
was being followed by QA.
No violations or deviations were identified.
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(6) The inspector questioned the absence of dates on a number of
Task Sheets attached to active surveillances. The licensee
provided verification that the problem was corrected and the
! surveillance tracking system was working as delineated in
procedure 00404-C, Surveillance Test Program. The inspector
had no further questions.
No violations or deviations were identified.
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(7) Surveillance procedure 14896-101, Revision 0, which was
completed and reviewed by the licensee on January 12, 1987,
was not revised in accordance with the outstanding TCP, No.
14896-187-1. The flow rate criterion on Data Sheet 1, for
the emergency core cooling system (ECCS) check valve cold
shutdown inservice test, was not changed from 3,000 gpm to
3,788 gpm, as required by this TCP nor was another TCP
written to change the flow rate criterion.
No violations or deviations were identified.
(8) The inspectors noted that items 1, 4, 5, and 7 raised questions
about the reviews required to assure that acceptance criteria
were met. The review of the licensee's procedures to assure
that adequate administrative controls exist for review of
acceptance criteria and determination that the acceptance
criteria are met is identified as inspector followup item
424/87-01-02.
No violations or deviations were identified.
b. Field Review of Surveillance Instructions
The inspectors performed a field review of surveillance procedures
by observation of surveillances in progress or by walkdown of
procedures in the field. The following concerns were identified:
(1) The inspector observed chemistry technicians dismantling a
radiation monitor identified as 1RE-12444C. When the inspector
asked to review the MWO under which the technicians were
performing the work, they replied that they were dismantling
the monitor via surveillance procedure 34223-C, Rev. 1, Channel
Calibration of the Gaseous Effluent Monitors. The inspector
reviewed the procedure and associated attachments to determine
if the procedure was being followed properly. The inspector
determined that the technicians had not obtained the signature
of the shift supervisor prior to performing work or the
signature for review of QC holdpoints.
The inspector noted that, step 5.1 of procedure 34223-C,
Prerequisites, states, " Ensure a Quality Control (QC) represent-
ative has signed the checklist indicating a QC review of the
procedure for hold points. If hold points are indicated, notify
QC prior to starting." Additionally, step 5.2 states, " Notify
the Operations Shift Supervisor, or his designee, of the work
to be performed and obtain his signature authorization."
Neither of these signatures had been obtained. When the lead
technician was questioned on these steps, the technician stated
that verbal approval had been obtained from the Shift Supervisor
to perform the work.
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10 CFR 50, Appendix B, Criterion V, requires, in part, that
activities affecting quality be accomplished in accordance with
documented procedures. VEGP FSAR, section 17.2, Operations
Quality Assurance Program, also requires that activities
affecting quality be accomplished in accordance with documented
procedures. The activities described above were not accom-
plished in accordance with procedure 34223-C in that the
signature of a QC representative had not been obtained for the
hold point review, indicating that the review was not accom-
plished, and the signature of the Shift Supervisor had not been
obtained to authorize performance of the work. The inspector
later verified that the Shift Supervisor had provided verbal
approval. The failure to follow procedure 34223-C is identified
as an example of violation 424/87-01-01.
During the review, the inspector questioned whether or not the
radiation monitor was seismically and/or environmentally quali-
fied equipment and if provisions existed in the procedure to
maintain these qualifications. The inspector determined that
Vogtle administrative procedure 00350-C, required that work
performed on seismically or environmentally qualified equipment
be done under the control of an MWO. The inspector questioned
the use of surveillance procedures to control removal and
restoration of seismic and/or environmentally qualified
equipment. Resolution of this issue was identified as
IFI 424/87-01-04.
During subsequent inspections, the inspector was informed by
the licensee that radiation monitor 1RE-12444C was seismically
qualified and the technicians were not taking any special
precautions to maintain the equipment qualification. The
licensee generated Deficiency Reports (DRs) 1-87-0203, on the
disassembly of monitor RE-12444-C; and,1-82-0204, on detector
removal and reinstallation for monitors RE-0020A and RE-00208.
A Request for Engineering Review (RER) was written for problem
resolution and MW0s were written to cover the remaining work.
Regarding the concern of whether or not the EQ of the monitors
was compromised by the routine disassembly and reassembly, the
inspector reviewed the system description 9002-DRMS-002 to
ascertain what is required to maintain EQ. The system descrip-
tion indicates that no specific removal or replacement proce-
dures are required. Nomal safety precautions and general shop
techniques were adequate for this task. The portion of the
monitor that could degrade the EQ of the monitor is never
opened for these routine calibrations. Since these calibration
activitics do not directly affect the seismically sensitive
areas of the equipment, the original procedure was not clearly
in violation of administrative procedure 00350-C, which requires
MW0s to be written for work performed on seismic or environ-
mentally qualified instrumentation. However, the licensee
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stated that all procedures that affect radiation monitors that
have seismic and/or environmental concerns are being reviewed
and revised as deemed appropriate.
Procedure 39350-C, Initial Calibration of Gaseous Process
Monitors, was written to require an MWO for the removal or
reinstallation of any components on radiation monitor RE-2562.
This system is seismically qualified per FSAR Table 11.5.2-1.
Other calibration procedures will be revised similarly in the
near future to cover all of the monitors in this table. The
inspector was concerned that simply placing this caution in the
calibration procedure would not guarantee that a technician
would not start with the procedure for the removal of the
detector; then use the procedure for the calibration and find
out that an MWO was required to implement precautions so as not
to jeopardize the EQ of the equipment.
The inspector then reviewed the licensees EQ program in order to
determine whether or not it provided adequate assurance that EQ
is maintained. The inspector interviewed personnel from the
Maintenance and Engineering departments as well as the Work
Planning Group. The EQ program is implemented under procedure
20009-C, Rev. 1. The inspector found the procedure to be
satisfactory. Any equipment that must be EQ had an associated
package of information called the Environmental Qualification
Data Package (EQDP). These EQDP's were numbered and controlled
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documents. Each package was divided into nine parts. The parts
are:
(a) EQDP equipment identification list
(b) Environmental summary sheet
(c) NUREG 0588 Checklist
(d) Master listing - seismic
(e) Seismic qualification and recorder data sheets
(f) Calculations
(g) Maintenance / replacement information
(h) EQ design change signoff form
(1) Miscellaneous information
The inspector reviewed four EQDP's: Relief Valves; Radiation
Monitors; Limitorque Valves; and Rosemount Transmitters. The
inspector determined that the packages were comprehensive and
found the information easily accessible.
. .
_
14
The inspector reviewed three procedures to determine if the EQDP
information had been implemented into these procedures. These
procedures were: 22402-C, Rosemount Transmitter Removal and
' Reinstallation; 28211-C, Relief Valve Test Procedure; and
25240-C, General Bolted Flange Torquing Procedure. All of
these procedures compared favorably with their respective EQDP.
The inspector reviewed the licensee's Nuclear Plant Maintenance
Information System (NPMIS) to observe how EQ equipment was
flagged to prevent compromise of the EQ requirements. All
equipment had a safety classification that was reviewed whenever
an MWO was written against the equipment. In accordance with
Regulatory Guide 1.60, Design Response Spectra for Seismic
Design of Nuclear Power Plants, the licensee uses a project
classification matrix (Table C13-1 from the VEGP Project
Reference Manual) that delineates what safety classification
code is used to designate safety related equipment and whether
the equipment is EQ or not. All of the equipment with a safety
classification that indicates either seismic or environmental
qualification must be reviewed by QC. In addition, the Work
Planning Group engineer and the Environmental Qualification
Group engineer must both sign off on any EQ equipment that
all proper reviews have been performed, the EQDP had been
referenced, and the installation / replacement documents are
accepta,ble.
Finally, the inspector reviewed constructica documents to
determine if the equipment had been installed correctly. The
most important aspect of the seismic qualification of the
radiation monitors is the e, led upon which they are mounted
during normal operation. All seismic modeling of the equipment
was performed assuming that the sled was instaited the way that
it was designed. The inspu, tor found that probNms had occurred
with the installation of the sled. These are detailed in
Readiness Review finding M-13. Correspondence from F. B. Marsh
of Bechtel Western Power Division to J. A. Bailey of Southern
Company Services discussed the specifics and stated that the
deficiency was not reportable under the rules of 10CFR 50.55(e).
A Deviation Report (DR) CD-9158 was generated on December 19,
1987 to address and disposition the discrepant condition. The
DR, which details the evaluation that determined the condition
was ratisfactory, appeared adequate to the inspector. The DR
had not been sent to QC for approval.
Overall, the inspector found the licensee's EQ program to be
satisfactory and in some aspects, exemplary. IFI 424/87-01-03
will remain open pending review of the revisions of all radia-
tion monitor procedures that affect those monitors listed in
FSAR Table 11.5.2-1, and the closing out of CD-9158.
,
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(2) Sections of procedure 24519-1, Rev. 2, Reactor Coolant Pressure
(Wide Range) Protection I 1P-405 Analog Channel Operational
Test and Channel Calibration, which apply to the analog channel
operational test using the manual system, were observed. The
operational test failed. As-found readings fell outside the
expected band. Section 4.20, Summing Amplifier Card Field
Calibration, of procedure 23300-C, Rev.1, Field Calibration
Procedure, was performed and the appropriate sections of
procedure 24519-1 were repeated.
No violations or deviations were identified.
(3) An inspection of portions of the field performance of procedure
24634-1, CR Air Intake Process Radio Gas Monitor Analog Channel
Operational Test & Channel Calibration, and procedure 24623-1,
Containment Low Range Area Monitor Analog Channel Operation Test
and Channel Calibration, was performed. The inspector had no
comments.
The inspector reviewed procedure 24183-1, Rev.1 Fuel Handling
Building Effluent Radiogas Monitor, ARX-2533. The inspector
noted an inconsistency betwcen the procedure and panel in that
labeling for a connector was IAJ3 versus J3 on the panel. An
LED which was unmarked on the remote / control box, did not light
as indicated by the procedure. No LED was provided on unit
IRT-1005 as indicated in step 4.1.3.6.b.
The inspector reviewed procedure 24756-1, Rev. 2, Steam
Generator Level (Narrow Range) Protection Channel II, IL-553.
The inspector noted that the location of equipment was
determined using an out of date drawing due to the time required
to pull new drawings.
After this walkdown, the inspector encouraged the licensee to
evaluate the distribution of drawings from Document Control.
Requests for drawings by the inspector to the technicians, who
were performing work in the plant, typically resulted in a
50-minute wait in Document Control. The inspector was concerned
that the opportunity to use obsolete information would be more
likely if the people who needed the information consistently
found obtaining new drawings difficult. Prompt distribution can
greatly enhance compliance with drawing and document control
,
requirements. During two surveillances, which were witnessed by
I
the inspector, technicians spent approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> to find
equipment that was either erroneously listed in the procedure
(e.g., local indication for radiation area monitor) or moved in
a modification (e.g., a steam generator level transmitter). The
'
inspector asked the technicians in both instances, after a
twenty-minute search, if it would be more expedient to check
the drawings. In both cases, the technicians thought the
equipment would be located any moment and the time spent to
obtain a drawing was unnecessary.
16
.
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The inspector reviewed procedure 24634-1, Rer.1, Control Room
i
Air Intake (1RE-12116) Process Radio Gas Monitor. During the
surveillance, remote control test box was removed. This item
was identified to the licensee as part of IFI 424/87-01-06.
The equipment was later determined to be used only for testing
,1 and did not affect the operation of the safety related monitor;
'
however, the Readout Control Box (RCB) was removed and used to
perform calibrations on other monitors without any tracking,
i.e., no MWO was issued. Deficiency Report 1-87-161 was written
to document this occurrence and engineering report 87-0036
was generated to perform an evaluation of the incident. The
engineering report determined that the RCB is interchangeable on
the monitors and there is no problem with using them in this
manner. Still, the removal of the RCB does require a MW0 and
the licensee showed the inspector a procedure that cautioned
personnel performing this action with a RCB to generate a MW0.
The procedure was a draft copy. Until the procedure is revised,
this part of IFI 424/87-01-06 will remain open.
The inspector also noted during plant walkdowns that an ambient
temperature difference of 8 to 10 existed between the Control
Building normal air conditioning room temperature gauge and the
ESF air conditioning room temperature gauge,1-1539-TIC-13150
and 1-TSH-13151. The inspector requested the licensee to
investigate if the instruments were operable. In a letter dated
January 12, 1987, the licensee stated that an investigation had
revealed that the instruments served separate functions, i.e.,
monitored different rooms. However, as a result of this
finding, the inspector later determined that the licensee had
written maintenance work order (MW0) 18700997 to correct the
discrepancy between these instruments, since both instruments
measured the same ambient room temperature. This is considered
acceptable; however, the action did not correspond to the
January 12, 1987 response. No followup is considered necessary
for this item.
Other concerns involving emergency lighting which was out in
a stairwell, the failure of personnel to close fire doors
and a question on the wire bend radius of cable at location
A-1813-M3-027 were promptly answered or corrected by the
licensee. The wire bend radius was determined to be within
specification. These concerns had also been identified as
part of IFI 424/87-01-06. These concerns are considered closed.
No violaticns or deviations were identified.
!
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8. Maintenance Program and Procedure Review (42451B, 357438)
During previous inspections, reviews had been conducted of the administra-
tive controls for plant maintenance, the technical adequacy of maintenance
procedures and the implementation of the maintenance program. The review
included an assessment of the corrective maintenance program; an assess-
ment of the preventative maintenance program; a review of equipment
control including the removal and restoration of equipment, equipment
status tracking and functional testing requirements; verification of
control of special processes, housekeeping and system cleanliness; and,
document review and field verification of the implementation of the
maintenance program. The program had not been fully implemented under
the operational quality assurance program at that time. Followup on the
implementation of the program was identified as IFI 424/86-117-24.
During this inspection, the inspectors reviewed procedure 00350-C,
Maintenance Program, Rev. 5, dated December 3,1986. This procedure
was the administrative procedure which governed maintenance activities
during operation. Additionally, the inspectors witnessed several
maintenance activities in progress including the processing of mainte-
nance work orders (MWO) in accordance with the requirements of 00350-C.
The inspectors also reviewed completed work packages that were accom-
plished under the operational QA program. The inspectors verified that
the licensee had implemented its planned maintenance program. Based on
the review, IFI 424/86-117-24 is closed.
The field review consisted of observing 14 MW0s which addressed various
aspects of plant maintenance. The inspector noted that MW0's, with one
exception, were appropriately filled out and all MW0s reviewed addressed
such areas as QC hold points and proper initial review by other depart-
ments. The inspector noted a number of cross outs which detracted from
legibility. The inspector identified the following items:
a. The inspector determined that maintenance personnel had not verified
that approved drawings, procedures and vendor manuals included in
MW0s in use in the field were the current revision. Procedures
00103-C, Document Distribution and Control, and 00101-C, Drawing
Control, required that drawings, procedures and vendor manuals be
verified as current every seven days. These procedures also required
that any documents which affected the revision to be noted on the
affected working copy. In addition, procedure 20050-C, MWPG Work
Order Processing, requires that working copy documents be verified
current prior to their issuance to the field; and, procedure 20407-C,
Maintenance Conduct of Operations, states that it is the responsi-
bility of the user to ensure that only current, approved working copy
documents are used. The maintenance personnel observed by the
inspector had failed to perform the seven day review for drawings on
MW0s 18700429,18700453 and 18624440 and for vendor manuals on MW0
18624165.
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10 CFR 50, Appendix B, Criterion V, requires that activities
affecting quality be accomplished in accordance with documented
instructions, procedures or drawings. The failure to follow
procedures 00101-C, 00103-C and 20407-C is identified as an
example of violation 424/87-01-01.
During the week of January 12, 1987, the inspector determined that
the drawings and vendor manuals included in the MW0s reviewed were
the latest revisions. The Maintenance Department issued a memorandum
to all maintenance department supervisors and foremen requiring them
to review all work packages in their possession to assure that all
working copy documents are the latest revision.
Deficiency Report (DR) 1-87-0185 was written by the licensee to
document the finding. The licensee stated that the Quality Assurance
Department will perform random audits of the maintenance program.
Additionally, the licensee will consider incorporating into the
, appropriate Maintenance Department procedure the requirement that
foremen and supervisors verify weekly that working copy documents are
'
the latest revision.
b. Paragraphs 4.1.2.c through e of 00350-C, stated that MW0s were not
required for certain activities which do not involve safety-related,
seismic or environmentally qualified equipment. The inspector
interviewed members of the Maintenance Work Planning Group concerning
the process used in making this determination and documentation of
the review. The MWPG stated that equipment addressed by paragraphs
c, d, and e of 00350-C was contained in the Nuclear Plant Management
Information System (NPMIS) which delineates all of the pertinent
information on the safety-related, seismic and environmental qualifi-
cation classifications of equipment. If the foreman is in doubt, an
MWO is submitted which will be reviewed for procedural applicability.
Additionally, paragraph d, which addresses labeling, was being
performed under operations procedure 10016-C, Equipment Labeling
Guidelines.
No violations or deviations were identified.
c. The inspector noted that MW0 18624097 did not have a functional
test assigned in block 32 as required by procedure 00350-C. During
review of other maintenance work orders the inspectors noted that
MW0s appeared weak in the area of functional testing. This item is
of particular concern in light of the number of findings identified
by the Quality Assurance Department related to the failure to assign
functional testing to MW0s. These findings are documented in audit
reports No. OP15/TP02-86/20, #045-II, July 12 thru August 5,1986;
No. OP15-86/45, November 17 thru December 5, 1986; and No. OP15-87/03,
January 6 thru 11,1987. The inspectors identified this item as IFI
424/87-01-03.
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19
The inspector reviewed the corrective action for this item during
the week of January 12, 1987. In response to the item, the licensee
had issued procedure 20051-C, Maintenance Work Order Functional
Tests, to provide guidelines for proper functional test assignments.
The licensee also plans to revise the MWO processing procedure to
assign the functional testing requirements after the work has been
accomplished. In addition, the licensee established a review team
assigned the task of assessing the quality of the MW0s being issued
by the Maintenance Work Planning Group and returning to the MWPG
those MW0s lacking sufficient direction or adequate functional
testing. The work conducted under MWO 18624097 was complete and
awaiting the assignment of the appropriate functional testing. The
inspector determined that the licensee had implemented procedures
which provided adequate direction and review to ensure that MWO
instructions are sufficiently detailed and are assigned the appropri-
ate functional testing. IFI 424/87-01-03 is closed. The IFI number
will remain assigned to the item to allow tracking of the finding.
No violations or deviations were identified.
9. Review of Aaministrative Controls for Temporary Modifications (424518)
During the inspection, the inspector noted that there were numerous
temporary modifications installed in the plant. The inspectors determined
that the licensee had a mechanism to review temporary modifications and
their effect on system operability once the system was formally turned
over to operations. However, the licensee was performing surveillances on
systems that had temporary modifications installed. Therefore, the
validity of the surveillance could be affected for surveillance tests
completed after preoperational testing and prior to establishing configu-
ration control by Operations. This concern was identified as Inspector
Followup Item 424/87-01-05.
During the week of January 12, 1987, the inspection team conducted a
review of the licensee's procedures. Procedure 00350-C, Maintenance
Program, addressed the removal of temporary modifications to ensure
that proper documentation was provided and that the functional testing,
including assessment of its impact on surveillances, was performed.
Procedure 00307-C, Temporary Modifications, addressed the methods utilized
to ensure that temporary modifications are properly identified, docu-
,
mented, controlled and evaluated.
While under the jurisdiction of the Start Up Manual, Procedures SUM-10,
Temporary Modification Control, and SUM-22, Maintenance Work Orders,
,
adequately addressed the subject of temporary modifications including the
'
assessment of its impact on surveillance tests.
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20
The aforementioned maintenance and temporary modification procedures
ensure that work / temporary modifications performed on a system will verify
that surveillances are active and document that components / systems are
functioning properly and capable of performing their intended safety
function. Temporary modifications which were in place during pre-
operational testing which was utilized to satisfy surveillance require-
ments were adequately addressed by the constraints imposed by Section 4.4
of procedure 00404-C, Surveillance Test Program. Under the pre-
operational test program, the test supervisor was responsible for
reviewing the temporary modification log for items which may preclude
completion of the test or invalidate the test results upon completion.
Specifically, paragraph 4.4.6.1 required that " documentation for the
completed procedure or work activity shall be carefully reviewed to ensure
that satisfaction of the surveillance requirements is clearly documented
and that the conditions during the period of the test are the same as
would be experienced during the operational phase surveillance test
procedure. Discrepancies shall be noted in the comments section of the
documentation check list."
As a further area of discussion, it should be noted that test / surveil-
lance procedures contain steps which require the introduction of
modifications which place the system / component into a configuration such
that the test / surveillance procedure attains the required objective. The
introduction of such modifications is reviewed with the development of the
procedure. The inspector feels that all concerns regarding temporary
modifications have been addressed and therefore inspector followup item
424/87-01-05 is closed. The inspector followup item number will remain
assigned to the item to allow tracking of the item.
No violations or deviations were identified.
10. Control Room Activities Review (424508)
a. The inspector reviewed control room administrative procedures and
verified documentation maintained in the control room to assure
the documentation was being maintained in accordance with procedures.
Documents reviewed were:
Reactor Operator & Shift Supervisor Logs
LC0 Log i
!
Standing Orders
Jumper & Lifted Wire Clearance Log
Operations Reading Book
Disabled Aanunciator Log
The inspector also checked 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Technical Specification valve
position verification requirements applicable to the ECCS subsystems. ,
These verifications were being performed properly. The inspector had l
no comments.
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It was noted previously that numerous administrative controls
established for the management of those plant and control room
activities conducted under the direction of licensed operatcrs
were not implemented. These findings were documented in NRC
Inspection Report 424/86-117. However, during this inspection
the inspectors noted a marked improvement in this area. The
administrative controls were implemented and review of record,
logs and checklists indicated thorough input and current status.
The inspector had no further comments in this area.
No violations or deviations were identified.
b. (Closed) Inspector Followup Item 424/86-60-10 (TMI Action Item
I.C.2). Shift Relief and Turnover. The inspector reviewed procedure
10004-C, Shift Relief, Rev. 3, and the shift turnover process to
ensure adequate controls were in place to provide for a complete
shift turncver and the meeting of TMI action item I.C.2 requirements.
The inspector's review included observation of control room activity,
review of logkeeping and log review, and a review of all procedures
governing shift turnover.
The inspector noted that adequate controls appeared to be in place
to maintain access to the control room in an orderly manner. The
operators also appeared to display a professional manner and surveil-
lance of the control boards appeared to be adequate.
The Reactor Operator (RO), Balance Of Plant (80P), and Non-Licensed
Operators (NLO) utilize rounds sheets to log and record plant
parameters. The inspector reviewed the rounds sheets of the R0, B0P,
and the NL0s. These sheets appeared to be properly completed and to
adequately meet the part of TMI action item I.C.2 which requires that
the licensee provide assurance that plant parameters were within
allowable limits. The rounds sheets of the NL0s are reviewed by the
R0, B0P, and Shift Supervisor (SS) to ensure knowledge of plant
parameters not indicated in the control room. The rounds sheets of
the R0 and the B0P are also reviewed by the SS. The inspector
determined that these reviews appeared to be taking place and that
the operators in the control room were cognizant of the status of the
plant.
While reviewing the narrative logs, the inspector noted on
January 15, 1987, that the SS log had no initialed review by
the day shift SS for the previous night's log entries. When
questioned as to the apparent lack of a review, the SS told the
inspector that he did not review the previous night's logs and that
he was not required to review his own logs by procedure because
the verbal turnover from the off-going SS was adequate. The
inspector showed the SS where procedure 10004-C, Revision 3, Shift
Relief, required the on-coming operator to review and initial the
._. -. - - . ,
22
narrative logs completed since the last shift worked by that operator
or for the preceding 5 days, whichever is less. The SS stated that
he was referring to direction received from procedure 10001-C,
Revision 3, Logkeeping, however, when he showed the procedure to
the inspector he noted that he was incorrect and that he was also
required to review his narrative logs by this procedure.
The failure to review and initial the Shif t Supervisor narrative
logs is a failure to follow approved plant procedures in accordance
with 10 CFR 50, Appendix B, Criterion V. This item is identified as
an example of violation 424/87-01-01.
During the review of procedure 10004-C the inspector identified a
discrepancy between the procedure and the On Shift Operations
Supervisor (0505), R0, and B0P checklists. These checklists are
provided in procedures 11870-C,11872-C, and 11869-C, respectively.
The procedures require each on-coming OSOS, R0, and 80P to review the
following logs in addition to the rounds sheets and narrative logs:
Special Conditions Surveillance Log, Clearance Log, Lif ted Wire Log,
and Temporary Modifications Log. The OSOS, R0, and 80P checklists
were missing the appropriate check blocks for each of the above logs.
This was brought to the attention of the licensee and the checkshetts
were modified to reflect the intent of the procedure.
The TMI action item also required implementation of a system to
evaluate the effectiveness of the shift relief turnover procedure.
Step 3.12 of procedure 10004-C states that the 050S shall make an
evaluation of shift relief and turnover at least semiannually. The
results of this evaluation were to be forwarded to the Operations
Manager for disposition. Although the statement contained in the
licensee's procedure directed the Operations Superintendent to
perform an evaluation, the procedure provided no instructions on how
the evaluation was to be performed. The inspector discussed this
item with the licensee and the licensee issued a revision to the
Non-Technical Specification Activities sheet. Prior to the revision
the sheet merely restated the step in the procedure and provided no
further direction. The revision provides direction to the OSOS by
listing several specific items to be addressed during the evaluation.
This revision appeared to satisfy the final requirement of the TMI
action item. TMI Action Item I.C.2 and IFI 424/86-60-10 are closed.
11. Inspection and Enforcement Notice Review (92701)
The inspector reviewed the licensee's response to IE Notice 86-61,
Failure of Auxiliary Feedwater Manual Isolation Valve. The inspector l
discussed the notice with the licensee and determined that the preventive
maintenance requirements for manual isolation valves were determined on a
case-by-case basis during the formulation of the PM program. Based or
this review this item is closed.
_ . - _ _ - _ - _ _ - _ _ _ _ _ _
23
12. Inspector Followup Items (92701)
a. (Closed) Inspector Followup Item 424/85-36-02. Evaluation of
Operational Event Reports. The IFI involved a concern that the
licensee tended to address items programmatically rather than
technically. The applicant had committed to reopen and reevaluate IE
Information Notice 85-23 and reevaluate preoperational testing
associated with differential pressure transmitters. The inspector
reviewed a March 14, 1986 memorandum from Ron Bone, GPC to Bob Lide,
GPC which provided the technical evaluation of the preoperational and
startup testing of the differential pressure transmitters and an
evaluation of IE Information Notice 85-23. The inspector did not
identify any concerns with the licensee's disposition of the evalua-
tion findings. In addition, the inspector reviewed five additional
IE Information Notice evaluations and identified no concerns. This
item is considered closed.
b. (Closed) Inspector Followup Item 424/85-36-03. Performance of Safety
Evaluations and Duties and Responsibilities of Plant Review Board.
The IFI concerned the lack of procedural requirements to submit
safety evaluations for unreviewed safety questions and Technical
Specification changec to the Plant Review Board for review. The
inspector reviewed a revised copy of 00051-C, Review and Approval of
Procedures, which added this requirement. This item is closed.
c. (Closed) Inspector Followup Item 424/86-117-01. Independent
Verification. The inspector reviewed procedure 00308-C and deter-
mined that the licensee had met the NRC g'aidance in regard to
independent verification. The inspector verified that independent
verification was being performed in accordance with procedure
00308-6, Independent Verification Policy. The inspector observed the
performance of a Boric Acid Transfer Pump tag-out and checked a
co.'pleted RHR system lineup. This item is considered closed.
d. (Closed) Inspector Followup Item 424/86-117-02. Lack of Vents on
AFW Piping at Apparent System High Points. The inspectors had noted
in a system walkdown of the Auxiliary Feedwater System that there
were no high point vents on the AFW side of the first check valve
between the AFW system and the main feedwater bypass line for stecm
generators 1 and 4. The inspectors were concerned that any back-
leakage and subsequent steam formation of main feedwater through
those check valves would become trapped in the highpoints and could
result in water hammer upon AFW initiation. There were no provisions
within the procedure, 13610-1, to monitor these highpoints for l
1eakage and steam formation, nor to take action, upon detection of ,
steam formation, to resolve water hanner concerns. The inspector !
reviewed the analysis performed by the licensee for backleakage into )
the AFW system and determined that the present design and monitoring
procedures provide adequate assurance that backleakage will not occur l
or result in waterhammer in the AFW system. This item is closed. -
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e. (Closed) Inspector Followup Item 424/86-117-03. Precautions on
Maintaining Subcooling Margin. Item a was closed in Inspection
Report 424/86-117. In regard to Item b, which concerned A0P 18009-1,
Steam Generator Tube Leak, the inspector had determined that Step 5,
" Response Not Obtained", required the reduction of RCS temperature
from 557 F to 500 F prior to isolation of the faulted SG if the
faulted S/G was not immediately identified. The procedure then
required the subsequent identification and isolation of the faulted
S/G and RCS depressurization to 25-50 psig greater than the faulted
S/G pressure. Under these conditions, RCS subcooling margin would be
approximately 5 F, which is substantially less than the 28 F sub-
cooling margin parameter delineated in procedure 19200-1, F-0,
Critical Safety Function Status Trees, for assuring adequate core
cooling in the Emergency Operating Procedure Network. In addition,
no instructions were given to isolate the cold leg accumulators at
950 psig.
The inspector reviewed the revision of the procedure that had been
reviewed and approved by the Plant Review Board. (The revision was
handwritten at the time of the review.) Prior to the steps that
depressurized the RCS to 25-50 psig of the faulted S/G, the licensee
i
had inserted the following steps: "If pressurizer pressure lowers to
less than 1000 psi, accumulators should be isolated." and, "During
cooldown, maintain at least 50 F RCS subcooling." These changes
adequately addressed the problems described above and Item b of IFI
424/86-117-03 is closed.
f. (Closed) Inspector Followup Item 424/86-117-04. Correction of Valve
Identification and Lineup Discrepancies. Each item identified in IFI
424/86-117-04 is addressed separately below.
Item a. NSCW valve 1-1202-X4-205, shown to be on the return line
l of the train "A" reactor cavity cooling coil, was listed on the
alignment checklist of procedure 11150-1, Rev.1, but was not on
the P&ID, nor was it found in the system during a system walkdown.
The licensee provided the inspector a Temporary Change to Procedure
(TCP) form number 11150-1-87-2, generated and approved on January 8,
1987, which corrected the checklist. The TCP required final approval
by the Plant Review Board by January 22, 1987. Item a of IFI
424/86-117-04 is closed.
Item b. A vent valve on the NSCW system on the outlet from the
lube oil cooler for the centrifugal charging pumps on train A was
not on the valve lineup verification list of procedure 11150-1,
Rev. O. This discrepancy had been corrected on Rev.1 of this
procedure. Item b of IFI 424/86-117-04 is closed. l
l
ltem c. This item was closed in Inspection Report 424/86-117. .
1
! Item d. This item was closed in Inspection Report 424/86-117. I
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Item e. The CS system alignment procedure, 11115-1, and the CS
system P&ID, drawing 1X4DB131, did not agree. The CS drawing
contained two valves, X-40 and X-127, on a flushing line downstream
of the B train CS pump that were not included in the alignment
procedure. The valves were verified to exist during the CS system
walkdown. The drawing indicated that the valves were both normally
closed. Also, in the same flushing connection, the CS alignment
procedure showed valve U4-012 closed. The CS P&ID showed the valve
locked open. The inspector reviewed procedure 11115-1 and determined
that the licensee had corrected the discrepancies. Item e of IFI
424/86-117-04 is closed.
Iten f. The IFI concerned the removal of a reference to a obsolete
controller from a procedure. No followup review was considered
necessary.
Item g. The inspector noted that CTB Cooling Unit Outlet Dampers
were required to be locked open per Containment Heat Removal System
drawing 1X4DB212. Procedure 13120-1 did not include the locking
requirement and the locking method. The inspector determined that
the licensee had corrected the discrepancy. Item g of 424/86-117-04
is closed.
g. (Closed) Inspector Followup Item 424/86-117-05. Discrepancies in
Unit Operating Procedures. Each item identified in IFI 424/86-117-05
is addressed separately below.
Item a. Item a was closed in Inspection Report 424/86-117.
Item b. Item b was closed in Inspection Report 424/86-117.
Item c. Procedure 12006-1, step 2.2.5, paraphrased a Technical
Specification requirement. The paraphrase was incorrect. The step
should have read "... and at least one loop in operation with the
reactor trip breakers open." The inspectors verified that 12006-1
had been corrected. Item c of IFI 424/86-117-05 is closed.
Item d. Procedure 12006-1, Section C4.1, Preparation for Continuing
Unit Cooldown, required action be taken to accivate protection
against cold overpressurization. Only one method of cold over-
pressure protection was addressed, the use of PORVs. The procedure
also should have addressed the two other mear of cold overpressure
protection and a mechanism to declare which method was providing
protection. The procedure should have addressed the implementation
of the TS :urveillance requirement on the RHR relief valves which
must be completed prior to taking credit for the RHR reliefs. The
inspector verified that procedure 12006-1 had been changed. Item d
of IFI 424/86-117-05 is closed.
l
.
-
g -
. -. . .
26
Item e. Procedure 12005-1 did not include a requirement in the
i
Limitations section to refer to TS 3.4.1.2. The inspector verified
that procedure 12005-1 had been changed. Item e of IFI 424/86-117-05
is closed.
Item f. Procedure 12006-1 did not include a precaution to assure
that when the reactor is in the source range, positive reactivity
additions will only be made by one controlled method at a time.
The inspector verified that 12006-1 had been changed. Item f of
IFI 424/86-117-05 is closed.
j h. (0 pen) Inspector Followup Item 424/86-117-07. Discrepancies in
Equipment Labeling. Each item identified in IFI 424/86-117-07 is
addressed separately below.
i Item a. Name tags were missing from RHR valves HV-8701B and
1205-027. The licensee stated that one of these tags had been
replaced and the other had been ordered. These valves will be
examined during a subsequent inspection to assure that these actions
l are taken. Item a of IFI 424/86-117-07 is open.
l Item b. The inspector determined that the B train controller at
the remote shutdown panel was still labeled as 4. Item b of IFI
424/86-117-07 remains open.
Item c. The TDAFW panel SG level gauge was not labeled wide range or
narrow range. The procedure did not indicate the range. An AFW to
SG bypass flow gauge was not labeled with engineering units. The
inspector verified that the SG level gauge had been labeled. The
bypass flow gauge had not been labeled. Item c of IFI 424/86-117-07
remains open.
Item d. Item d was closed in Inspection Report 424/86-117.
Item e. Item e was closed in Inspection Report 424/86-117.
Item f. The inspector had noted that engineering units were not
displayed on strip chart recorder scales for main steam temperature
and other recorders. The inspector subsequently reviewed labeling
of main control board strip chart recorders for engineering units.
'
Although the main steam temperature had been correctly labeled by
the licensee, other recorders still had no units. Item f of IFI
1 424/86-117-07 remains open.
Item g. The inspector noted that remote handwheels in the CVCS
system including BIT valves and charging crossover were not labeled.
The applicant stated that handwheels had been installed recently and
labeling was planned but had not been completed. The inspector
,
conducted a tour of the auxiliary building levels containing the CVCS
.
system and noted a greatly improved level of labeling for the remote
i
manual valve operators, however, the inspector noted several remote
<
<-,--,.-----.,,,--m- ,- ----.-w.,, ,-p.m, w w -.----w.,-n..-,.m-- . - , ,- -,,-,..,,--,n ,,-y . ,,--,.--m-e-,- yme --
27
manual valve operators in the waste gas disposal area which lacked
tags. The licensee stated that final efforts were being completed in
assuring the adequacy of valve labeling. No additional followup is
considered necessary. Item g of IFI 424/86-117-07 is closed.
Item h. The CS alignment procedure, 11115-1, lists two sets of
120V AC CS MOV space heater breakers. A check of the 120V AC breaker
<
panels (IAYD1 and 18YD1) identified the breakers as being labeled
" spares." The applicant is determining if these breakers are
utilized for the M0V space breakers. Item h of IFI 424/86-117-07
remains open.
i. (0 pen) Inspector Followup Item 424/86-117-09. Review of Reactor
Vessel Level Indication System. Four concerns were identified during
the review of RVLIS involving procedure nomenclature, instrumentation
references in procedure 14228-1, a vendor recommendation for a
control room annunciator that had not been provided, and a vendor
recommendation for periodic checks of locally indicating null meters.
The inspector was provided a Daily Schedule Control Sheet which
indicated that the null meters would be checked by Operations
quarterly. It is noted that the RVLIS will be tested when the
reactor coolant system is at system operating pressure during startup
testing. The inspector will review the reuining items and the
results of the RVLIS testing after startup. IFI 424/86-117-09
remains open.
j. (Closed) Inspector Followup Item 424/86-117-10. Procedure Revision
to Include Check of Equipment Actuation on Control Room Ventilation
Start. The inspector reviewed procedure 13301-1, which had been
revised in Rev.1 to include steps that verify that the outside air
supply dampers close on manual actuation of Control Room Toxic Gas
Isolation. IFI 424/86-117-10 is closed.
k. (Closed) Inspector Followup Item 424/86-117-11. Adequacy of
Procedure Prerequisites. The inspectors had identified that scme
of the prerequisites in S0Ps and surveillance procedures were too
general. Interviews with licensee personnel indicated that it was
not clear to them what was required to be verified to satisfy
selected prerequisites. By letter dated January 14, 1987, the
licensee committed to implement additional controls of prerequisites
until the procedures were reviewed and modified to clarify prerequi-
sites. The licensee stated that standing order 1-87-04 had been
issued to Operations to require that prior to initial use of any
procedure being used in the control room the Shift Supervisor and
operator will review the prerequisites / initial conditions section
to ensure clarity and understanding of the required conditions. The
order contains provisions to upgrade prerequisites by submitting
comments / changes via an attachment to the letter. Based on this
commitment, IFI 424/86-117-11 is closed.
. . _ -. ._. _ _ _ _ _
28
,
f
1. (Closed) Inspector Followup Item 424/86-117-12. Clarification of
Cleanliness Levels. The IFI involved clarification of the cleanli-
'
ness zone designations in Section 4.1.d of procedure 00254-C, Plant
Housekeeping and Cleanliness Control, to ensure that all open RCS
- components, as well as the refueling cavity, would be classified as
Level II. The licensee revised the Level II cleanliness requirements
in 00254-C, Section 5.4, to specifically include any system that
could allow contaminates to reach the RCS. This revision meets the
intent of the IFI and IFI 424/86-117-12 is closed,
i
! m. (Closed) Inspector Followup Item 424/86-117-13. General Review
i of Abnormal Operating Procedures. Topics from Regulatory Guide
1.33, Revision 2, February 1978, were verified to have procedures
established. The following contingencies were implemented by the
procedures listed below:
l Procedure Revision
Event Number Number
Loss of Condenser Vacuum - 18011-1 1
18023-1 1
Loss of Containment Integrity - 17005-1 2
- Loss of Feedwater - 17009-1 0
18016-1 1
>
Conditions Requiring Emerg. Boration - 17010-1 3
18007-1 1
Fuel Cladding Failure - 17005-1 2
18006-1 1
High Activity in Coolant or Offgas - 17100-1 2
, 17213-1 0
18009-1 2
Pressure Control Malfunction - 18011-1 1
Plant Fires - 17103-C 0
, 18038-1 2
i Abnormal Releases of Radioactivity - 18009-1 2
j Based on this review, procedural implementation of Regulatory
'
Guide 1.33 is adequate and IFI 424/86-117-13 is closed.
n. (Closed) Inspector Followup Item 424/86-117-14. Annunciator Response
Procedure (ARP) Discrepancies. The inspector reviewed the licensee's
commitment to conduct a review of ARP's to determine the adequacy of
initial operator actions, the accuracy of window labelling, and the
overall adequacy of each procedure. The inspector reviewed Main
Control Board (MCB) ARP's (panels 1 through 20) and concluded that a
thorough review had been performed on these procedures and the
procedures accurately reflected the annunciator windows and provided
sufficient initial operator action. The inspector also reviewed
,
several of the review packagos for the annunciator panels, particu-
'
larly those on the MCB. All of the reviews appeared to be comprehen-
sive and competent. Although the ARP's for the annunciators that are
(
.-
29
!
not on the MCB have not all been revised as yet; the reviews that
were completed were adequate and the licensee program for completion
of the reviews was determined to be adequate. Therefore, IFI
424/86-117-14 is closed.
During the review of the corrective action for IFI 424/86-117-14,
the inspector detennined that the ARPs referenced a Master Setpoint
Document in lieu of giving an actual setpoint for certain annunciator
alarms. Interviews with several operators indicated that they did
not know where to find this document. In addition, personnel in the
Operations Department were not sure as to the exact form or location
of this document. Followup on the licensee's actions to establish
the document or to replace the references to the document in the
ARP's with the actual setpoint was identified as IFI 424/87-01-07.
This IFI was subsequently reviewed during this inspection and the
inspector determined that the licensee had taken corrective action
for the IFI. This review is documented under paragraph 12.nn for IFI
424/87-01-07 in this report.
o. (Closed) Inspector Followup Item 424/86-117-15. Acceptability of
Baseline IST Data for Section XI ASME Pump Testing. This item
concerned baseline data obtained on four of six Component Cooling
Water (CCW) pumps which was below the data obtained during preopera-
tional testing. The inspector requested engineering justification
for the operability of these pumps prior to fuel load. The inspector
discussed with the licensee the ASME Section XI code, the licensee's
ISI program, the inherent error in the measuring equipment, and the
configuration of the preoperational test versus that of the ISI test.
Pump curves from the manufacturer were compared with the preopera-
tional data and the baseline data. The licensee provided adequate
justification as to the operability of the CCW pumps in question.
, IFI 424/86-117-15 is closed.
p. (Closed) Inspector Followup Item 424/86-117-16. Technical Specifica-
tion on the Discharge Flow of the RHR Pump. The inspector had
determined that the discharge pressure on the recirculation flow of
RHR pump B was equal to 180 psid. TS 4.2.5.f required the discharge
,
pressure to be 1180 psid. The licensee had stated that a TS revision
had been requested to change the value to be 1165 psid. The inspec-
tor subsequently reviewed the TS revision whIch incorporated the
-
change. IFI 424/86-117-16 is closed,
q. (Closed) Inspector Followup Item 424/86-117-17. Resolution of Water
Hanner in NSCW. The item concerned the waterhammer that had occurred
on the NSCW system during the Loss of Offsite Power test. The
licensee's analysis, which concluded that the waterhammer did not
impair the operability of the system, was reviewed and found to be
acceptable. IFI 424/86-117-17 is closed.
-
.- -
.-_- - -. - -- - - - . . . - - --
_
.
- .
30
r. (Closed) Inspector Followup Item 424/86-117-18. Implementation of
Surveillance Program. During the inspection ending December 12,
1986, the inspectors had determined that the licensee had not yet
fully implemented the surveillance program administrative controls
except on a small number of systems which had been accepted by the
Operations Department. During this inspection, the inspectors
reviewed the implementation of the surveillance program and a number
of additional surveillance test packages. Although several concerns
were identified and one example of a failure to follow procedure was
identified; in general, the results of this review indicated that the
surveillance program was adequately implemented. The review is
documented in paragraph 7 of this report. IFI 424/86-117-18 is
closed.
s. (Closed) Inspector Followup Item 424/86-117-19. Review of Test
Control and Implementation of Configuration Control during
Performance of Surveillance Testing. The inspectors had determined
that in some surveillances performed during the preoperational
testing, the prerequisites were not always satisfied prior to
beginning the test. It was not clear in the cases reviewed whether
or not credit would be taken for the test. The inspectors reviewed a
number of completed surveillance packages and observed additional
performances of surveillance testing. No additional instances of
failure to satisfy prerequisites or establish system configuration
were noted. The inspector rereviewed the performance of the MDAFW
surveillance procedure,14807, and determined that the system had
been retested. Additional information on the review of the surveil-
lance program is provided in paragraph 7. IFI 424/86-117-19 is
closed,
t. (Closed) Inspector Followup Item 424/86-117-20. Revise Procedures to
Clarify Use of Staggered Test Basis for Determining Frequency of
Test. The inspector had determined that although the Surveillance
Test Coordinator was correctly tracking surveillances required on a
staggered test basis, the test frequencies specified in certain
surveillance procedures did not mention the requirement for stagger-
ing the tests. The inspector determined that procedure 00404-C,
Surveillance Test Program, has been revised to include the TS
definition of staggered test basis. The inspector reviewed the
deficient procedures identified and determined that the surveillance
procedures had been revised to specify that the tests are to be
performed on a staggered test basis where appropriate. IFI
424/86-117-20 is closed.
u. (Closed) Inspector Followup Item 424/86-117-21. Review of
Justifications for Use of Preoperational Tests to Meet TS
Surveillance Requirements. The inspectors reviewed the
preoperational test data used to take credit for the 18 month
surveillance tests of the emergency diesel generators (EDG) and
the battery chargers. The inspectors reviewed the pre-op tests
with the engineers responsible for the EDGs and the battery
- _ _ . ._ _ _ _ _ , . _
. __
31
chargers. The review included a step by step table-top walkthrough
uf the effected surveillances with a comparison of the pre-op data
used to take credit for required data in the surveillances. In both
cases the inspectors determined that the pre-op data appeared to be a
valid substitute for the data required for the surveillance and that
the licensee did an adequate job in the justification of the use of
the pre-op data. The inspector discussed the controls with the
licensee which will be utilized for assuring that startup tests are
appropriately evaluated if the tests are to be used in lieu of
surveillance tests. The inspector determined that the licensee made
significant improvements in the evaluation of the use of other tests
in lieu of surveillance tests and took steps to assure that surveil-
lance tests were performed in those cases where other tests did not
satisfy the surveillance test requirements. The inspector had no
additional questions. IFI 424/86-117-21 is closed.
v. (Closed) Inspector Followup Item 424/86-117-22. Corrective Action to
Assure Control of Twelve Hour Surveillances. The inspector reviewed
procedure 14000-1, Rev. 3, Operations Shift and Daily Surveillance
Logs, which now specify that surveillances be performed within
two hours of each shift. Procedure 10000-C, Rev. 3, Conduct of
Operations, had been revised to require that the On Shift Operations
Supervisor or the Shift Supervi::or ensure that procedure 14000-1
be performed within the first two hours of each shift. IFI
424/86-117-22 is closed.
w. (0 pen) Inspector Followup Item 424/86-117-23. Miscellaneous
Technical Issues Identified in Review of Surveillance Program.
This IFI included examples of various technical concerns identified
during the review of surveillance procedures and/or surveillance
program implementation. Each concern is identified separately below
by the paragraph number in Inspection Report 424/86-117.
Paragraph 7.c. Procedure 14721-1 required SI pumps to be operated
during the test; however, there was no provision to open and rack out
the motor supply breakers upon test completion. TS 4.5.3.2 requires
the motor supply breakers to be open while in Modes 4, 5 and 6. The
inspector was shown a draft revision to the procedure which included
adequate steps. The procedure additionally specified that maximum
allowed flow was 650 gpm although TS 4.5.2.h.2.b allows up to 660
gpm. Although the requirement was conservative, it was inconsistent
with other requirements in the procedure. The same draft revision
also corrected the allowable flew to 660 gpm. Procedure 14460-1 did
not require venting through valve 1-1204-X4-827, SI Pump Miniflow I
Vent Valve. TS 4.5.2.b.1 requires the venting of ECCS pump discharge !
piping high points at least once per 31 days. The applicant stated
that a Temporary Change Procedure (TCP) would be initiated. The
procedure additionally referred to the A SI pump as 1. The inspector I
verified that the procedure was corrected. Procedure 14000-1 did not l
specify that the surveillances on page 17 were to be performed in !
modes 1 or 2 only. The inspector verified that the procedure was
v
.vr
_ _ _ _ _ ___ _____ _ ____ _ . _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
32
corrected. The correction of minor comments on procedures 54821-1,
which referenced a deleted TS table, and 55016-1, which contained a
typographical error in a TS reference, was verified. The comments on
the surveillance procedures for the safety injection system in IFI
424/86-117-23 are considered closed.
Paragraph 7.e. A review of procedure 00404-C, Surveillance Test
Program, Rev. 2, dated December 3, 1986; 00405-C, Commitment
Identification, Tracking, and Implementation, Rev. 3, dated
October 22, 1986; and 00051-C, Procedures Review and Approval,
Rev. 5, dated December 1,1986 indicated that the mechanisms to
govern changes to procedures which implement technical specification
commitments and changes to technical specification commitments which
are implemented in procedures were in place. The aforementioned
procedures will ensure that if changes occur, the changes will be
reflected in the surveillance task cross reference report and the
master surveillance report. It should be noted that procedure
14935-1, Rev. I draft, which prompted this concern, was approved. A
review of the associated paper work revealed that the individual
responsible for the commitment review failed to identify the deletion
of a commitment. The appropriate corrections were made when the
error was identified to the reviewer. This part of IFI 424/85-117-23
is closed.
A review of procedure 14721-1, ECCS Subsystem Flow Balance Test,
Rev.1, dated January 2,1987, discloses a revision which changes
the applicability of the procedure to modes 1, 2, 3 and 4. This
is consistent with TS 4.5.2 and 4.5.3.1. This part of IFI
424/86-117-23 is closed.
Paragraph 7.f. Section 6.0, Acceptance Criteria, in both revisions
of procedure 14806-1 did not include observation of proper lubricant
level or check of calibration due dates. Section 8.0 of draft Rev.1
did not include the date of the applicable edition of ASME B&PV code,
Section XI. The inspector verified that these items had been
corrected. These comments are considered closed. Procedure 54701-1:
(1) did not meet the requirements of TS 4.8.4.2.b, (2) failed to
require the opening and locking of valve 1-1206-U6-029 after comple-
tion of the test, (3) did not include a step to unlock and close
valve 1-1204-U6-018, and (4) did not include independent verification
of the position of 1-1206-U6-018. The inspector verified that
the licensee had corrected these items. This portion of IFI
424/86-117-23 is closed.
Paragraph 7.g. The valve numbers in TS 3/4.6.1.7 were incorrect.
Valves HV-2624 A and B, 4 inch isolation valves in the Containment
Building Post LOCA Exhaust system; and, HV-2627 A and B and HV-2629 A
and B, containment purge and exhaust isolation valves, were not
included in the statement of the LCO. The valve numbers in surveil-
lance requirement 4.6.1.7.1 were not all 24-inch containment purge
33
and exhaust isolation valves as indicated. HV-2624 A and 8 were 4
inch Containment Building Post LOCA Exhaust isolation valves.
HV-26268 and HV-26-288 were 14-inch Containment Building mini-purge
supply and exhaust isolation valves. The inspector verified that the
numbers in the TS were corrected. This portion of IFI 424/86-117-23
is closed.
Paragraph 7.h. The reference to paragraph 7.h in Inspection
Report 424/86-117 was a typographical error. Coments in this
section were evaluated and no followup was considered necessary.
Paragraph 7.i. While witnessing the MDAFWP testing, the inspector
noted in procedure 14807 that no step was included in the system
restoration to place handswitch HS5131A back into automatic. The
system restoration section of procedure 14807, Rev.1, now includes a
step to place handswitch HS5131A back into automatic at the conclu-
sion of the MDAFW surveillance test, and to independently verify this
step. This portion of IFI 424/86-117-23 is closed.
Paragraph 7.J. The inspector noted that the physics curve book
had not been completed. During a subsequent inspection, the
inspector determined that the physics curve book was near completion.
The majority of the reactivity data, which had been extracted from
WCAP-11338 and reformatted, had been provided to Reactor Engineering
for review. This portion of IFI 424/86-117-23 will remain open until
completion of the curve book is reviewed.
x. (Closed) Inspector Followup Item 424/86-117-24. Implementation
of the Operational Phase Corrective and Preventive Maintenance
Program. This item is closed as discussed in paragraph 8 of this
report,
y. (Closed) Inspector Followup Item 424/86-117-25. Ultimate Heat Sink
Technical Specification Clarification. A revision was to be made to
the ultimate heat sink TS to clarify the wording, remove ambiguities,
and modify a surveillance so that it could be realistically met. The
inspector determined that the changes had been approved and would be
included in the TS. IFI 424/86-117-25 is closed.
z. (Closed) Inspector Followup Item 424/86-117-26. Verification of
Position of BIT Isolation Valves. A review of procedure 11006-1,
Chemical and Volume Control System Alignment for Start-up and Normal
Operation, Rev. 3, dated December 29, 1986, contains a revision which
calls for the verification of BIT isolation valves 1-HV 9803 A & B
in the open position with the Limitorque handwheel lon ed. This
revision satisfies TS requirement 4.5.2.b.2 by designating these
valves, which are in the ECCS flow path, as locked valves, thereby
excluding them from the 31 day correct position verification. The
inspector field verified that the appropriate locks were installed.
IFI 424/86-117-26 is closed.
34
aa. (0 pen) Inspector Followup Items 424/86-117-27. TS / Surveillance
Procedure Cross Reference List and Surveillance Procedure Completion.
Some procedures referenced in the TS / surveillance procedure cross
reference list had not been written and/or had not been identified in
the cross reference list. Procedure 53002-C was shown in the cross
reference list for BOL moderator temperature coefficient surveillance
(TS 4.1.1.3.a) but the licensee did not plan to use the procedure for
the initial startup test and it had not been written. This procedure
will be an integrated low power physics testing procedure to be used
for reloads. The inspectors confirmed that the procedure to be used
was adequate to meet the surveillance requirements. The TS cross
reference list did not show which startup tests are used to satisfy
surveillance requirements. Startup testing will be observed in
future inspections.
The inspectors reviewed a portion of the cross reference list to
confirm that procedures required for Mode 6 had been identified
and completed. The inspectors provided several minor comments to
the licensee for resolution, but determined that the cross reference
list was adequate for startup. IFI 424/86-117-27 will remain open
pending further review of the status of procedures required for power
operation. IFI 424/86-96-05, which involved the review of the
completion of procedures required to meet TS surveillances, is
closely related to IFI 424/86-117-27. Based on the review of the
surveillance program documented in paragraph 7 and the followup to be
conducted to close IFI 424/86-117-27, IFI 424/86-96-05 is closed.
bb. (Closed) Inspector Followup Item 424/86-96-05. Review of Surveil-
lance Procedure Completion. This item is closed as documented in
paragraph 12.aa.
cc. (Closed) Inspector Followup Item 424/86-117-28. Procedure Revision
for Consistent Definition of Surveillance Test Completion Date and
Time. Administrative surveillance tracking procedure 00404-C, was
revised by Revision 4 to correct a discrepancy between Section 2.5
and its surveillance task sheet completion instructions, note 20,
concerning the surveillance official completion date and time. A
surveillance test is now consistently considered complete only after
the test results have been reviewed. Therefore, IFI 424/86-117-28 is
closed.
dd. (Closed) Inspector Followup Item 424/86-117-29. Review of Special
Condition Surveillance Test Triggering Mechanisms. The inspector
reviewed documentation to determine whether or not the applicant has
adequate triggering mechanisms to ensure certain special condition
surveillances are performed. A computer printout listing all special
condition surveillances for mode 6 and all modes was reviewed. The
list contained approximately 112 surveillance requirements, the
department responsible for triggering, the department responsible for
.
.
35
completion, and the applicable procedures. The inspector audited 20
surveillance requirements to determine that adequate steps or
'
precautions had been inserted into the appropriate procedure to
trigger the required surveillance test.
In all but one case either an adequate procedure existed, a Temporary
Change Procedure (TCP) had been generated, or a revision was in the
approval process which the inspector reviewed. The inspector noted
one case where inadequate triggering mechanisms existed. Procedure
17034-1 did not contain a requirement to verify 125V battery opera-
bility after battery discharge or overcharge within 7 days as
required by TS 4.8.2.2. Although procedure 17034-1 had been desig-
nated to have the triggering mechanisms for the maintenance
department to perform the surveillance, the revision had not been
done. This was pointed out to the licensee. A TCP was immediately
processed. The inspector reviewed the TCP and found that the change
incorporated the appropriate triggering mechanisms.
! The inspector reviewed methods and procedures for departments to
- keep track of special condition surveillances. Draft procedure
50045-C, Engineering Special Condition Surveillances, was reviewed.
The procedure included a log for keeping track of active surveil-
,
lances. Discussions with responsible personnel indicated that the
draft copy reviewed by the inspector was not finalized for approval
and that additional EFPD sensitive surveillances, which were not
requirements for fuel load, were to be incorporated into the
procedure. The inspector reviewed chemistry procedures 31045-C, Rev.
4
4, Chemistry Logkeeping, Filing, and Record Storage; and, 30040-C,
Rev. 1, Reporting Chemistry Data to Operations Department. The
procedures were adequate to track surveillances in the Laboratory
Logbook. Special condition surveillances for the Instrumentation and
i Control Section were primarily associated with instrument calibra-
tions after a seismic event and one associated with RCS pressure
calibration after refueling. The following procedures were reviewed:
18036-C, Rev.0, Seismic Event; 50022-C, Rev. 3, Seismic Event Plan;
55039-C, Rev. O, Seismic Monitoring Instrument System; 12000-1,
Rev.1, Refueling Recovery. Items will be tracked through Operations
as equipment is placed inoperable. The Maintenance Department
triggered all of their special condition surveillances through the
,
planning and work order programs and did not have a log to keep
track of active surveillances; however, procedure 20051-C, Rev. O,
Maintenance Work Order Functional Tests, itemized surveillances to
be triggered after certain maintenance items. This was deemed
adequate. IFI 424/86-117-29 is closed.
ee. (Closed) Inspector Followup Item 424/86-117-30. Control on the
Location of the B0P Operator. The inspector reviewed procedure
10000-C, Rev. 3, which had been revised to state that the balance
of plant operator normally remains in the control room. IFI
424/86-117-30 is closed.
4
l
l
l
!
36
ff. (0 pen) Inspector Followup Item 424/86-117-31. Key Control . On
December 11, 1986, during the walk through of the reactor coolant
pump loop 1F-416 procedure, 24790-1, the inspector had observed
that the technician needed to go to the shif t clerk's office three
times to obtain the keys needed to open the reactor solid state
protection system (SSPS) cabinets to perform the surveillance
procedure. In a letter dated January 13, 1987, which referenced a
memorandum dated January 8, 1987, the licensee stated that the
,
control of keys to all panels and cabinets which require operator
access would be reviewed and validated. The memorandum stated that a
new key control cabinet had been added, that an up-to-date list of
keys had been completed and that the cabinet keys would be validated
by February 6, 1987. By memorandum dated January 15, 1987, a copy of
which was provided to the inspectors, the licensee stated that the
cabinet key controls would be in place by February 21, 1987. The
inspectors agreed that this date was acceptable. The memorandum also
,
stated in regard to locked doors inside the power block, that these
doors would routinely be left unlocked, except vital area doors,
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remote shutdown panel doors, essential 4160V AC switchgear room
doors and high radiation area doors. Due to the types of locks
on some of the interior doors, the licensee stated that certain
locks would have to replaced to allow the doors to be left unlocked.
.
The licensee stated that the locks would be replaced by April 1,
l 1987. IFI 424/86-117-31 will remain open until these actions are
verified.
gg. (Closed) Inspector Followup Item 424/86-117-32. Technical Specifica-
tion Change to Reflect 18 Month Surveillance of Under Voltage and
Shunt Trip Coils on Reactor Trip Breaker. The final TS draft did not
specify testing of the reactor trip breaker undervoltage (UV) and
shunt coils. Generic letter 83-28 required this testing to be
performed with an 18 month frequency, as a minimum. The inspector
verified that procedure 14701-1, Rev. 3, had been changed tn
incorporate these items to test the reactor trip breakers unde -
voltage and shunt trip. IFI 424/86-117-32 is closed.
hh. (0 pen) Inspector Followup Item 424/86-117-33. Miscellaneous
Technical Issues Identified in Review of Operations Procedures.
This IFI included examples of various technical concerns identified
, during the review of operations procedures. Each concern is identi-
fied separately below by the paragraph number in Inspection Report
424/86-117.
i Paragraph 6.b.6. Two alarm panels were not displayed above the
CCW operating switches in the control room as required by 18020-1
and ARP 17002-1. The inspector verified that the licensee had
taken action to correct these discrepancies. This portion of IFI
424/86-117-33 is closed.
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Paragraph 6.b.7. In procedure 18003-1 the following coments were
made. In step 4.1.2.9, which repeats a reactor coolant pump start
sequence, no reference was made to the reactor coolant pump restart
limitations identified by precautions 2.2.11.2 and 2.2.11.3. The
seal injection flow shown on Figure 1 showed six to eight gpm,
whereas item 2.2.6 specified 8 to 13 gpm. The flow logic in the
decision tree depicted in Figure 1 failed at both the " check No. 2
seal leakoff flow" block and at the " check injection and bearing
temperature" block since neither block provided a logical exit from
the block. The inspector verified that procedure 18004-1, Rev. 2,
corrected the:e items. This portion of IFI 424/86-117-33 is closed.
Paragraph 6.b.9. The inspector had identified concerns in that
procedure 13610-1 did not contain provisions for monitoring and
responding to adverse bearing oil temperatures for all three AFW
pumps and did not implement provisions for positioning and aligning
the turbine driven AFW pump overspeed test switch (HS-15130) and
speed control potentiometer. During a walkdown of the AFW system,
the inspectors noted that the turbine driven pump gland seal leakage
was approximately 3 to 5 times greater than that of the motor driven
pumps and appeared to be excessive. The licensee acknowledged the
concern. Procedure 11882-1, Outside Areas Round Sheets, did not
provide for a general inspection of the north Main Steam and
Feedwater valve room, the motor driven pump A pump room or the
turbine driven pump pump room. Also there are no items to check for
adequate pump gland seal leakage and adequate gland seal leakage
drainage from the gland seal leakage reservoir. The inspector
verified that all of the issues had been satisfactorily addressed by
the licensee except one. Gland seal leakage from the turbine driven
AFW purrp has not been dispositioned yet. IFI 424/86-117-33 remains
open to follow the corrective action on the gland seal leakage.
Paragraph 6.b.10. Steps 2.2.1 and 2.2.2 in CS system procedure
13115-1 which addresses TS limits did not include Mode 4 in the
applicable modes as required by TSs. The inspector verified that
the procedure had been revised. This portion of IFI
424/86-117-33 is closed.
Paragraph 6.b.11. Steps 2.2.1 and 2.2.2 in procedure 13120-1 did
not list the applicable TS modes. The inspector verified that the
procedure was revised. This portion of IFI 424/86-117-33 is closed.
Paragraph 6.c. The concern involved limiting excessive overtime
for personnel performing safety related functions. Limiting exces-
sive overtime is addressed by TMI Action Item I.A.1.3. Procedure l
00005-C, Rev. 2, Overtime Authorization, now includes the requirement I
of TS 6.2.2.e that overtime should not be routinely scheduled for l
personnel responsible for performing safety-related functions.
Procedure 10000-C, which applies to Operations personnel, also
had been revised to state that overtime should not be routinely
scheduled. This portion of IFI 424/86-117-33 is closed. l
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ii. (0 pen) Inspector Followup Item 424/87-01-02. Acceptance Criteria
Reviews. The IFI involved the review of the licensee's procedures
to assure that adequate administrative controls exist for review of
acceptance criteria and determination that the acceptance criteria
are met. This item is discussed in paragraph 7.a.8 of this report.
jj. (Closed) Inspector Followup Item 424/87-01-03. Implementation of
Controls to Assure Adequate MW0s and Assignment of Appropriate
Functional Testing. The inspector had determined that a MWO did
not designate the functional testing to be performed. In addition,
the inspector noted that QA audits indicated recurring problems in
the adequacy of MWO instructions and designation of functional tests.
The inspector reviewed the corrective action taken by the licensee.
This review is described in paragraph 8.c. of this report. IFI
424/87-01-03 is closed.
kk. (0 pen) Inspector Followup Item 424/87-01-04. Resolution of Concerns
on the Seismic and Environmental Qualification (EQ) of Radiation
Monitors. This IFI is discussed in paragraph 7.b.1 of this report.
11. (Closed) Inspector Followup Item 424/87-01-05. Review of Temporary
Modifications. This IFI is closed as discussed in paragraph 9. The
IFI number will remain assigned to allow tracking of the item.
mm. (0 pen) Inspector Followup Item 424/87-01-06. Miscellaneous Findings
on Surveillance and Maintenance Procedure Implementation. The
concerns, which are discussed in paragraph 7.b.3 of this report
included equipment mislabeling and an inadequate lighting safety
concern. The items were determined to be isolated cases and have
been corrected by the licensee. After obtaining additional informa-
tion from the licensee, the fire doors and a wire radius bend concern
were determined not to be issues. Therefore, with the exception of
one item, discussed in paragraph 7.b.3, IFI 424/87-01-06 is closed,
nn. (Closed) Inspector Followup Item 424/87-01-07. Reference of
Nonexistent Setpoint Document in Control Room ARP's. Control Room
ARP's were found to reference a Master Setpoint Document that was
used in lieu of giving the actual setpoint. No one in either the
Control Room or the operations department could produce or describe
the document. The licensee provided revised procedures for the
following ARPs that had previously been noted as deficient. The
procedures no longer referenced the Master Setpoint Document. The
procedures reviewed were 17001-1, Rev. 5; 17013-1, Rev. 3; 17014-1,
Rev. 3; 17015-1, Rev. 2; 17016-1, Rev. 2; 17017-1, Rev.1; and,
17020-1, Rev. 3. The inspector found that the revised procedures
were incorporated into the control room copies. The inspector
determined that the ARP's in the control room no longer referenced
the document. IFI 424/87-01-07 is considered closed.
oo. (Closed) Inspector Followup Item 424/86-60-10. Shift Relief and
Turnover. The item is discussed in paragraph 10.b.