ML20212Q169
| ML20212Q169 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 08/27/1986 |
| From: | Kaufman S, Rogers J, Veeder L PARAMETER, INC. |
| To: | |
| Shared Package | |
| ML20212Q150 | List: |
| References | |
| NUDOCS 8609040036 | |
| Download: ML20212Q169 (73) | |
Text
ENCLOSURE 1 TECHNICAL REVIEW REPORT NRC REGION I INSPECTION NO. 50-443/86-27 REVIEW OF SEABROOK, UNIT 1, TECHNICAL SPECIFICATIONS PUBLIC SERVICE OF NEW HAMPSHIRE NEW HAMPSHIRE YANKEE DIVISION NRC DOCKET NO. 50-443 NRC CONTRACT NO. NRC-05-86-156 ONSITE ACTIVITIES CONDUCTED May 5-16, 1986 Prepared for:
Under Contract with:
U.S.N.R.C. Region I Parameter, Inc.
631 Park Avenue 13380 Watertown Plank Rd.
King of Prussia, PA 19406 Elm Grove, WI 53122 NRC Liaisen Personnel:
Authors:
T. Elsasser L. Veeder l
l A. Cerne J. Rogers l
D. Ruscitto S. Kaufman D. Beckman i
8609040036 860827 PDR ADOCK 05000443 G
TABLE OF CONTENTS SECTION TITLE PAGE EXECUTIVE
SUMMARY
1
1.0 INTRODUCTION
4 1.1 PURPOSE
1.2 BACKGROUND
& GENERAL SCOPE 1.3 GENERAL EVALUATION CRITERIA 1.4 GENERAL EVALUATION METHODS 2.0 EVALUATION...................................
7 2.1 CONATAINMENT ISOLATION SYSTEMS.........
8 2.2 CONTAINMENT & SUPPORT SYSTEMS..........ll 2.3 CONTAINMENT DEPRESSURIZATION AND......
14 COOLING SYSTEM 2.4 SERVICE WATER AND ULTIMATE............
17 HEAT SINK 2.5 AC SOURCES............................
19 2.6 DC SOURCES............................
26 2.7 ONSITE POWER DISTRIBUTION.............
29 2.8 EMERGENCY PEEDWATER AND CONDENSATE.... 32 STORAGE TANK 2.9 BORATIO!' SYSTEMS......................
37 2.10 ENGINEERED SAFETY FEATURES............
40 INSTRUMENTATION AND ACTUATION 2.11 SAFETY INJECTION AND RESIDUAL.........
43 HEAT REMOVAL SYSTEMS 3.0 GENERAL CONCLUSIONS.........................
46 APPENDICES PERSONS CONTACTED INSPECTION PLAN INSPECTION DATA SHEETS
Executive Summnry EXECUTIVE
SUMMARY
The authors, under contract with Parameter, Inc., and in accordance with the direction of the Nuclear Regulatory 1
Commission, conducted an inspection at the Seabrook Nuclear Power Station, Unit 1:
to determine whether the draf t Technical Specifications (TS) and the Final Safety Analysis Report (FSAR) are compatible with the as-built plant configuration and operating characteristics; and, to determine whether the draft Technical Specification Requirements are definitively measurable.
The inspection was concentrated on plant systems, structures and components identified as having particular significance with respect to. minimizing the severity of potential accidents and accident consequences.
The systems evaluated included:
containment and related support systems, containment spray systems, emergency core cooling systems (ECCS), soluble poison reactivity control (boration) systems, electrical power systems, and selected secondary plant systems and components.
The facility descriptions and operating characteristics for the systems, structures and components found in the FSAR, the NRC Safety Evaluation Report (SER) and the proposed TS were compared to licensee drawings, procedures and actual plant hardware to establish whether the as-built configuration of the systems, structures and components is compatible with the safety analyses and proposed TS.
Licensee documents reviewed included: Piping and Instrumentation Drawings', Logic Diagrams, Electrical Schematics and One Line Diagrams, Operating and Emergency Procedures, Surveillance and Inservice Test Procedures, Calibration Procedures and data, Maintenance Procedures, Preoperational Test Procedures and data, l
Administrative Procedures, calculations, and correspondence. In l
situ plant equipment was visually inspected on a sampling basis to verify that actual installations agreed with the various docum nts.
Surveillance Procedures were also reviewed to verify that the surveillance methods planned by the licensee were consistent l
with the requirements of the draft TS and that the proposed TS l
requirements were definitively measurable or determinable.
At the time of the inspection the draft TS were still under development by the licensee in conjunction with the NRC Office Page 1
l
~ _ __,
l Executive Summ:ry of Nuclear Reactor Re'gulation (NRR).
The inspection was conducted using draft TS promulgated by NRC on March 13, 1986, and using pending revisions to that draft provided by the licensee.
These revisions had been submitted to and were under review by NRR.
4 The licensee's programs for preparation of surveillance and operating procedures were in place.
Approximately fifty percent of the procedures reviewed during the inspection had been reviewed and approved by the Station Operation Review Committee (SORC).
The inspection determined that the draft Technical Specifications were compatible with the as-built systems, structures, and components in the areas inspected and that compliance with the Technical Specifications could be definitively measured or determined.
Because both the proposed TS and the licensee's implementing procedures were still under development, many plant
~
l configuration, operating characteristic, and parameter details j
remained to be firmly established.
The licensee's programs for accomplishing this appeared to be functioning satisfactorily in most areas. Several inconsistencies and areas of concern were identified with respect to these activities and were presented to the licensee during the inspection.
These observations l
included:
The finalization of TS will involve many changes in its setpoints, quantitative Limiting Conditions for Operation, l
Surveillance Requirement acceptance criteria, and other numerical limits and criteria.
These changes will require a rigorous licensee program for revising and confirming the l
accuracy of the facility operating, surveillance, preoperational, and inservice test proc'Ldures for verification and implementation of the TS.
The licensee's planning in this regard was in progress but incomplete at i
l the close of the inspection.
At the time of the inspection, the licensee's surveillance and inservice test procedures and other operating documents were either approved or in the process of review for approval.
The draft and approved procedures reviewed during this inspection contained numerous technical and editorial 3
i errors, some of which, if uncorrected, could have led to eventual plant operation in violation of TS.
Examples include incorrect system alignments which could result in TS violations or unacceptable system operation, procedure acceptance criteria less conservative than the corresponding TS criteria, and other similar deficiencies.
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Exrcutive Summ ry 1
Additionally, the Operations Department programs and procedures reviewed did not adequately address independent verification of the proper performance of system alignment and return to service activities per NUREG
- 0737, Clarification of TMI Action Plan Requirements, requiring substantial revision of the procedures prior to use.
These findings indicated a need for additional rigor in and management attention to the procedure review and approval processes.
Some inconsistencies were identified between the draft TS, the FSAR, related design documents, and plant procedures.
These inconsistencies typically involved the preliminary status of the TS and recent changes in either reviewed documents or the physical plant.
Examples include a change l
in the design of the condensate storage tank piping connections not incorporated in the PSAR, changes in the design of the 120 VAC power system not yet reflected in the plant drawings and procedures.
The findings in each category above were generally resolved by the licensee during the inspection; in most cases, the resolution involved confirmation that' corrective action had been taken or that the item was being actively pursued by the licensee or a commitment by the licensee to evaluate the item and implementation actions subject to later confirmation'by NRC.
CONCLUSION The Technical Specification preparation process appears to be j
functioning properly.
The Technical Specifications and l
implementing procedures reviewed appear to be compatible with the as-built plant configuration.
That information which is still under development for incorporation into the Technical Specifications and implementing procedures appears to be subject l
to sufficient management control to assure adequate completion of the process.
Discussion of the specific findings with NRC Region I personnel j
ahs indicated a need for the licensee to document their position and/or corrective measures on the noted items.
NRC Region I will conduct reviews and inspection followup as necessary to j
determine the acceptability of the licensee's actions.
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INTRODUCTION 1.0 - INTRODUCTION 1.1 - PURPOSE The purpose of this inspection was to assist the Nuclear Regulatory Commission in determining that the Seabrook Nuclear
)
Power Station, Unit 1, Technical Specifications were compatible with the as-built configuration of plant systems, structures and components and that the Technical Specification requirements were definitively measurable or determinable.
1,2 - BACKGROUND AND GENERAL SCOPE Startup testing and subsequent plant operation at commercial nuclear power plants has demonstrated ':h a t discrepancies sometimes exist between the plant's Technical Specifications (TS), Final Safety Analysis Report (FSAR), Safety Evaluation Report (SER), and as-built plant configuration.
During low power physics testing at the Grand Gulf Nuclear Station, Unit 1, significant discrepancies of this nature were identified and subsequently corrected.
This inspection was conducted to gain additional assurance that the proposed Seabrook Unit 1 TS are compatible with the assumptions and requirements of the safety evaluations performed and the as-built plant configuration.
Parameter, Inc.
was requested to assist NRC Region I in performing this inspection at the Seabrook Unit 1 site.
The general scope of the inspection included:
1 Report Section 2.1 CONTAINMENT ISOLATION SYSTEMS 2.2 CONTAINMENT AND SUPPORT SYSTEMS 2.3 CONTAINMENT DEPRESSURIZATION AND COOLING SYSTEMS 2.4 SERVICE WATER SYSTEM AND ULTIMATE HEAT SINK 2.5 AC POWER SOURCES 2.6 DC POWER SOURCES 2.7 ONSITE POWER DISTRIBUTION 2.8 EMERGENCY FEEDWATER SYSTEM AND CONDENSATE STORAGE TANK 2.9 BORATED WATER SYSTEMS 2.10 ENGINEERED SAFETY FEATURES INSTRUMENTATION 2.11 SAFETY INJECTION AND RESIDUAL HEAT REMOVAL SYSTEMS Page 4
INTRODUCTION The following general categories of documents were reviewed:
Technical Specifications Final Safety Analysis Report NRC Safety Evaluation Report (with Supplements 1-3)
Piping and Instrumentation Diagrams (P& ids)
Instrumentation and Control Logic Diagrams Electrical One Line Diagrams Electrical Schematic Diagrams Instrument Loop Drawings Plant General Arrangement & Layout Drawings Preoperational Test Procedures and test data Surveillance Test Procedures (OXs)
Maintenance Procedures (MXs and IXs)
Operating Procedures (OSs)
Emergency Operating Procedures (EOPs)
Inservice Test Procedures Administrative Control Procedures Setpoint Calculations Loop Calibration Procedures and data 1.3 - GENERAL EVALUATION CRITERIA The above systems and documentation were reviewed with respect to:
The compatibility of the draft TS with the as-built configuration of the systems, structures and components; The consistency of the draft TS with the documents listed in 1.2 above; The capability to definitively measure or determine compliance with the TS requirements considering both the software and hardware available; and, The adequacy of the licensee's surveillance and inservice test programs to provide for the implementation of the TS Surveillance Requirements.
1.4 - GENERAL EVALUATION METHODS Prior to the onsite inspection activities, the plant systems information and draft TS were reviewed to identify those systems, structures and components which were particularly significant with respect to preventing or mitigating the consequences of analyzed accidents.
Those systems were given inspection priority, resulting in the listing of Section 1.2 i
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INTRODUCTION above.
the onsite inspection activities, the facility During descriptions, operating characteristics and related information found in the propcsed TS, the FSAR, and the SER were compared.to the licensee documents listed in Section 1.2.
Concurrently, the TS were evaluated to confirm that the performance criteria and requirements established therein were. definitively measurable or determinable.
Particular emphasis was given to the ef ficacy of surveillance tests and inservice tests established by the licensee to demonstrate conformance with TS and the requirements of 10CFR50.55a The detailed inspection plan used to conduct the onsite activities is provided as Appendix 1.0 to this report.
Key evaluation items included:
Plant drawings were reviewed to establish that the plant design and construction documents were compatible with the FSAR, TS, and SER.
Preoperational and functional tests were reviewed to verify that the "as tested" system configurations were consistent with the FSAR, TS, and SER.
Surveillance Tests were reviewed to verify their conformance with the TS and to establish that the TS requirements could be definitively measured.
Emergency, Maintenance, and Inservice Test Operating, procedures were ruviewed to establish their conformance with the TS and accuracy with respect to the design and construction documents and with the as built plant.
A listing of persons contacted during the inspection is provided in Appendix 1.1.
The inspection involved about 340 onsite inspection hours during the period May 5 - 16, 1986.
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EVALUATION 2.0 EVALUATION GENERAL In addition to the specific inspection and review items listed in Appendices 2.1 - 2.11, the following documents were reviewed and used, in part, for the evaluation of the licensee's various programs for TS implementation:
OS1490.01 PERIODIC LOCKED VALVE VERIFICATION OP 10.1 OPERATION AND CONTROL OF LOCKED VALVES SM 6.2 STATION OPERATING PROCEDURES OAIT.02 CHANGES TO OPERATING DEPARTMENT PROCEDURES EMERGENCY OPERATING PROCEDURES (EOPs, FRGs, ECAs)
ABNORMAL OPERATING PROCEDURES STATION SURVEILLANCE TEST CONTROL PROCEDURE OP 10.2 OPERATIONS DEPARTMENT INDEPENDENT VERIFICATION PROCEDURE Page 7
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Evaluation 2.1 CONTAINMENT ISOLATION SYSTEMS 2.1.1 EVALUATION CRITERIA AND SCOPE The containment isolation systems are comprised of the valves, piping and actuators required to isolate the systems penetrating containment following design basis accidents to prevent the release of fission products and to ensure protection of the public in accordance with 10CFR100 guidelines.
Containment isolation is initiated when sensors monitoring accident diagnostic parameters trip.
Phased isolation is used whereby all systems penetrating containment except Engineered i
Safety Features (ESF) and related systems are automatically isolated.
There are typically two isolation valves per line, one on either side of the containment penetration.
Containment isolation valves as shown in draft TS Table 3.6-2 and FSAR Table 6.2-83 and ESF Actuation System trip setpoints,
and response times shown in draft TS tables 3.3-3, 3.3-4 and 3.3-5 were used as the basis of inspection.
That equipment was reviewed with respect to the criteria and methods of Sections 1.3 and 1.4 of this report.
See Appendix 2.1 for a listing of 4
documents reviewed. Proposed TS 3/4.6.3 and 3/4.3.2 were compared to the documents listed in Appendix 2.1.
2.1.2 Discussion I
An as-built configuration review of the systems included a f
sampling of system piping configuration, instrumentation, operating logic, setpoints, and system operating parameters and limits.
In addition, selected draft and approved surveillance tests, operating procedures and preoperational tests were reviewed to determine that the design features were accurately reflected and that operating methods were consistent with the j
proposed TS.
Specifically, the following system features and operations were reviewed:
System accident functions Isolation valve initiating logics Isolation valve closing times System testing and alignment methods I&C functional tests System surveillance testing A visual inspection of portions of the system and selected equipment established that the design features were accurately translated into the as-built plant.
The visual inspection also i
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Evaluation 4
found satisfactory comparison of the systems and equipment with the proposed TS.
2.1.3 Observations and conclusions The following inconsistencies or deficiencies were identified.
The licensee either corrected the items or provided confirmation that the items would be evaluated and appropriate disposition made.
1.
FSAR Table 6.2-83 contains
- e. listing of containment isolation valves, their respective containment penetrations, and valve isolation stroke times.
TS Table 3.6-2 contains the listing of containment isolation valves and respective stroke times which will become Limiting Conditions for Operation upon issuance of the facility operating license.
The FSAR Table included valves not listed in the TS Table.
i The licensee committed to revise TS Table 3.6-2 to include the following secondary system valves:
i, a.
"Section A.
Phase A Isolation":
Steam Generator Blowdown Valves SB-V9, 10, 11, 12.
b.
"Section E. Other":
Main Steam Valves MS-V86, 88, 90, 92, 204, 205, 207, 027, 44, 45, 46, 47.
Feedwater Isolation Valves FW-V30, 39, 48, 57, 76, 82, 88, 92.
2.
Additional differences between the Tables' valve stroke time listings were identified:
Containment On Line Purge Valves, COP-V1, 2, 3, 4, had a f
a.proposed TS isolation time of 2 seconds while FSAR Table 6.2-83 listed the stroke time as 5 seconds.
b.
RCP Thermal Barrier Cooling Valves CC-V1092, 1095, 1101, 1109, had TS closing times of 30 seconds. The FSAR listed no i
closing times.
The licensee further advised that these valves would be removed from the TS Table, subject to NRR I
approval, because of the removal of their classification as containment isolation valves.
Valve closing times for valves RC-FV-2894 and 2896 are c.
shown as 1 second in the FSAR but are listed as not applicable in the TS Table.
3.
FSAR Table 6. 2-83 includes a column cross referencing to various PSAR Figure 6.2-94 sheet numbers.
The column I
requires editorial' correction of erroneous references.
i Page 9
Evaluation The licensee acknowledged the above findings and advised that a major revision of FSAR Table 6.2-83 was in progress and that these discrepancies would be addressed and resolved with NRR.
Additionally, a major study is underway to confirm or revise the valve closure times in the FSAR and TS which will address the relevant findings above and result in FSAR and TS revisions where appropriate.
The licensee further advised that, for item 2. b 'a b o v e,
justification of valve reclassification would be submitted for NRC review in conjunction with the ongoing TS revision process.
Additional NRC:RI review of the above items will be conducted as necessary during future inspections.
Except as noted above, the as-built configuration of the systems and equipment reviewed compared satisfactorily with the documents reviewed and the TS requirements were found to be definitively measurable.
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Evaluation 2.2 CONTAINMENT AND SUPPORT SYSTEMS 2.2.1 EVALUATION CRITERIA AND SCOPE The primary containment structure is a reinf orced concrete cylinder with a hemispherical dome and a reinforced concrete i
foundation.
A welded steel liner plate is anchored to the inside face of the concrete as a leaktight membrane.
The secondary containment (containment enclosure) is comprised of a reinforced concrete cylindrical structure with a concrete hemispherical dome.
The ESP equipment cubicles and pipe and electrical penetration areas are located within the Secondary containment.
I The conta$nment enclosure system serves as a radiological barrier and includes an emergency cleanup system which maintains the enclosure at a negative pressure of -0.25 inches.of water gage (w.g.).
The above systems, equipment and structures were reviewed with respect to the criteria and methods of Sections 1.3 and 1.4 of i
l this report.
See Appendix 2.2 for a listing of documents reviewed.
Proposed TS 3/4.6.1.2,
.3,
.4,
.5, and.7; TS 3/4.6.5.1 and
.2 and 3/4.0.5 were compared to FSAR Sections 6.2, Containment Systems, and 6.5, Fission Product Removal and Control Systems, and the documents listed in Appendix 2.2.
2.2.2 Discussion An as-built configuration review of the systems included a sampling of containment building and enclosure and containment system features including ductwork configuration, fans, filter trains, doors, I&C setpoints and operating logics, system operating parameters and limits.
The circuits and logic functions of the Solid State Protection System (SSPS) were i
included in the review.
i l
In addition, selected draft and approved surveillance tests, operating procedures and preoperational tests were reviewed on a i
sampling basis to determine that the design features were accurately reflected and that operating methods were consistent with the proposed TS.
l Test methods and results of the preoperational tests were used l
on a sampling basis to verify that the systems functioned within the parameters of the design requirements.
Where a test proved Page 11
Evaluation the functions of a logic circuit, the detaile'd procedures and results were compared with the logic and elementary diagrams to i
verify that the test accurately reflected the circuit design and that the system war consistent with the design bases reflected in the FSAR, SER, and TS.
Specifically, the following system features and operations were reviewed:
Normal system alignment and operations i
System accident functions Filtered containment building exhaust Post-DBA operations System testing and alignment methods IEC functional tests System surveillance testing A visual inspection of portions of the system and selected equipment established that the design features were accurately translated into the as-built plant.
The visual inspection included verification of the system piping and ductwork, flowpath and component configuration, control station instrumentation, simulated partial performance of systems alignments and tests, and general comparison of the systems with the TS.
2.2.3 Observations and Conclusions l
The following inconsistencies or deficiencies were identified.
i The licensee either corrected the items or provided confirmation that the items would be evaluated and appropriate disposition made.
I 1.
During system walkdown inspections, system valve configuration and labeling was confirmed.
One instance of an unlabeled valve, PAH-V14 (PAB Air Handling Sytem Valve) was found.
The licensee initiated action to have an identification tag installed.
Inspection of the Primary Auxiliary Building filter room fan 2.
enclosure (Dwg F-6-4108, Elev. 81' 0") found that various cleanup system filters were not yet installed (Filters "F",
"A" and "C").
These items were confirmed to be included on the licensee's Incomplete Items List (IIL) and were scheduled for completion under filter vendor direction.
3.
PSAR Section 6.2.1.1.b.5 (Page 6.2-6a) states that the design normal containment pressure is between 12.1 and 14.7 Proposed TS 3.6.1.4 requires that the containment psia.
pressure normal operating band be maintained between 14.6 Page 12
Evaluation and 16 psia.
The licensee was unable to reconcile the above dif f erences during the inspection and advised that the matter would be reviewed, the correct pressure range confirmed, and appropriate document revisions submitted to NRR.
Additional NRC:RI review of the above items will be conducted as necessary during future inspections.
Except as noted above, the as-built configuration of the systems and equipment reviewed compared satisfactorily with the documents reviewed and the TS requirements were found to be definitively measurable.
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Evaluntion 2.3 CONTAINMENT DEPRESSURIZATION AND COOLING SYSTEM 2.3.1 EVALUATION CRITERIA AND SCOPE The primary containment is maintained below design pressure and temperature following a DBA by the parallel action of the containment building spray (CBS) system and the emergency core cooling systems (ECCS) and by the passive heat sinks such as structural components.
The CBS is comprised of two identical, independent and redundant trains, each having 100% heat removal capacity.
CBS is actuated during a DBA when containment pressure reaches a "Hi-3" pressure setpoint of about 18 psi.
Borated water from the Refueling Water Storage Tank (RWST), mixed with fission product scavenging spray additives, is pumped through the contaiament dome spray nozzles.
Automatic transfer of CBS pump suction from the RWST to the containment sump (recirculation mode) occurs at low-low j
RWST level.
i The above systems, equipment and structures were reviewed with respect to the criteria and methods of Sections 1.3 and 1.4 of this report.
See Appendix 2.3 for a listing of documents reviewed.
Proposed TS 3/4.6.2.1 and
.2, and TS 3/4.2.1 and
.2 were 4
compared to FSAR Sections 6.2, Containment Systems, and 6.5, i
Fission Product Removal and Control System, and the documents listed in Appendix 2.3.
2.3.2 Discussion An as-built configuration review of the systems included a sampling review of system piping configuration, instrumentation, operating logic, setpoints and system operating parameters and l
limits.
This review included the features and methods for l
system valve alignment, pump operations, and recirculation l
actuation.
Selected draft and approved surveillance tests, operating procedures and preoperational tests were reviewed on a sampling basis to determine that the design features were accurately reflected and tlat operating methods were consistent with the proposed TS.
i A visual inspection of portions of the system and selected equipment established that the design features were accurately translated into the as-built plant.
The visual inspection l
included a walk through of selected system operations to verify Page 14 l
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I A
Evaluation the accuracy of surveillance and operating procedures and compliance with the TS requirements.
2.3.3 Observations and conclusions The following inconsistencies or deficiencies were identified.
The licensee either corrected the items or provided confirmation that the items would be evaluated and appropriate disposition made.
1.
FSAR Section 6.2, page 6.2-6, states that the containment spray me.ximum overall system response time is approximately 65 seconds assuming loss of.offsite power (LOP) and only one operable CBS pump.
The maximum response time without a loss of offsite pcwer is given as approximately 36 seconds.
Proposed TS Table 3.3-5 lists the overall system response time as 37 seconds with LOP and 27 seconds without LOP.
The licensee was queried about the substantial difference between the accident analysis values from the FSAR and the TS and whether the TS values were achievable.
The licensee was unable to provide the reason for the differences but did provide data acquired during preoperational test 1-PT-(I)-39.2, Loss of Offsite Power with SI Test, Revision 1, demonstrating that the actual system response times were 47 seconds (with LOP) and 28 seconds (without LOP).
A licensee preoperational test supervisor advised that the licensee was evaluating the reasons for the differences between the FSAR and TS values.
2.
Procedure OX1406.01, Containment Spray System Valve Verification, Revision 00, provided instructions for ASME Section XI Inservice Testing of CBS valves and required reference to Procedure TC 3.2, Inservice Testing of valves, Figure 5.2, for a listing of testing requirements for the CBS valves.
The figure entries for valves CBS Penetration Isolation valvels CBS-Vll and 17 show stroke time acceptance criteria of 13 seconds in contrast to the criteria of 10 seconds from FSAR Table 6.2.83.
The source of the data in TC 3.2 was not available.
The licensee's Mechanical Engineering Department advised
- that, in response to prior NRC questions on the establishment of authoritative valve stroke times, the licensee had issued an Engineering Services Request (ESR) to Page 15
Evalu2 tion Yankee Atomic Energy Corp. Engineering in January 1986 to review the overall subject.
A report is expected in the near future which will provide the bases for correction of affected procedures, the FSAR and TS.
The licensee further advised that recent meetings had l
occurred with NRR concerning these and other changes needed to the Inservice Test Program and Procedure TC 3.2 Additional NRC RI review of the above items will be conducted as necessary during future inspections.
Except as noted above, the as-built configuration of the systems and equipment reviewed compared satisfactorily with the documents reviewed and the TS requirements were found to be definitively measurable.
Page 16
Evaluation 2.4 SERVICE WATER SYSTEM AND ULTIMATE HEAT SINK 2.4.1 EVALUATION CRITERIA AND SCOPE The Station Service Water System (SWS) transfers heat from various loads in both the primary and secondary systems to the Ultimate Heat Sink (UHS).
The Atlantic Ocean and the SW Cooling Tower can both serve as the UHS.
The ocean serves as the normal and emergency source of water for the SWS heat loads except in the case of seismic failure of the intake and/or discharge structures.
In that event, the cooling tower is utilized.
The SWS consists of two independent, redundant trains, each of which supplies cooling water to a primary component cooling water (PCCW) heat exchanger, diesel generator jacket water cooler, a secondary component heat exchanger, the condenser water box priming pump seal water heat exchangers, and to the fire protection system.
The above systems, equipment and structures were reviewed with respect to the criteria and methods of Sections 1.3 and 1.4 of this report.
See Appendix 2.4 for a listing of documents reviewed.
Proposed TS 3/4.7.4. and
.5, and TS 3/4.0.5 were compared to the documents listed in Appendix 2.4.
2.4.2 Discussion An as-built configuration review of the systems included a sampling review of system piping configuration, instrumentation, operating logic, and system operating parameters and limits.
Selected draft and approved surveillance tests, operating procedures and preoperational tests were reviewed on a sampling basis to determine that the design features were accurately reflected and that operating methods were consistent with the proposed TS.
A visual inspection of portions of the system and selected equipment established that the design features were accurately translated into the as-built plant.
The visual inspection included a walk through of selected system operations to verify I,
the accuracy of surveillance and operating procedures and l
compliance with the TS requirements.
l Specific system features and operations reviewed included:
I normal and emergency lineups of the PCCW heat exchanger, diesel generator jacket cooler, and the secondary component heat i
exchanger.
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=
1 Evaluation 2.4.3 Observations and Conclusions The following inconsistency was identified in the draft TS.
Miscellaneous procedure editorial discrepancies were identified to and corrected by the the licensee.
1.
A prior draft revision of TS Surveillance Requirement 4.7.4.b.2 provides for testing to verify that "each service water system pump starts automatically upon loss of or failure to start of the redundant pump".
The current revision of the draf t TS stated that auto start of the redundant pump must be verified "upon loss of power test signal".
Discussion with the licensee determined that the latter TS revision was misworded and will be corrected.
The licensee intended that the subject testing be performed in conjunction with periodic loss of off site power testing which simulates the appropriate conditions.
The licennee advised that this matter was being referred to NRR for revision of the TS.
Addition'al NRC:RI review of the above item will be conducted as necessary during future inspections.
Except as noted above, the as-built configuration of the systems and equipment reviewed compared satisfactorily with the documents reviewed and the TS requirements were found to be definitively measurable.
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Evaluttion i
i 2.5 AC POWER SOURCES 2.5.1 EVALUATION CRITERIA AND SCOPE The AC Power Sources include two unit auxiliary transformers (UATs) which are arranged to receive power from either the turbine generator or from the 345 KV grid back-fed through the generator step-up transformers (GSUs).
During startup and shutdown, auxiliary power can also be provided by the reserve auxiliary transformers (RATS) which also receive power from the 345 KV grid.
Standby power is provided by two redundant diesel engine generator systems which supply sufficient capacity for safe shutdown of the reactor after a loss of offsite power coincident with a loss of coolant accident (LOCA).
Vital instrumentation and control power is provided by six uninterruptible power supplies (UPSs), each having two sources of power.
The normal source is the AC Distribution System and the alternate is the DC Distribution System.
The UPSs contain inverters which convert the DC to AC power.
The AC Power Sources were reviewed with respect to the criteria and methods of Sections 1.3 and 1.4 of this report.
See Appendix 2.5 for a listing of documents reviewed. Proposed TS 3/4.8.1 was compared to the documents listed in Appendix 2.5.
2.5.2 Discussion The review of the systems and equipment included the normal, abnormal, and emergency operations described by the FSAR and the licensee's procedures.
The system configuration drawings, system operating parameters and limits, surveillance tests, and operating procedures and preoperational tests were reviewed on a sampling basis to determine that the design features were accurately reflected and that operating methods were consistent with the proposed TS.
Specifically, the following system features and operations were reviewec:
Normal and abnormal system alignments and operations Emergency system alignments and operations After loss of offsite power (LOP)
After LOP with LOCA System testing alignments and methods System equipment operability testing l
Page 19 1
Evaluation Diesel Generators Diesel Generator Auxiliaries Equipment ratings 4
Associated equipment / systems interfaces A visual inspection of portions of the system and selected equipment established that the design features were accurately translated into the as-built plant.
The visual inspection also i
verified that the system configuration, bus arrangement, control room instrumentation and controls were in agreement with the TS.
2.5.3 Observations and Conclusions The following inconsistencies or deficiencies were identified.
The licensee either corrected the items or provided confirmation that the items would be evaluated and appropriate disposition made.
l 1.
The following procedure discrepancies represented deviations from TS requirements,or the potential for TS violations during operation or surveillance testing:
a.
Procedure OX1426.01, DG 1A Operability Surveillance, Revision 00, section-4.1.5, required loading of the DG to "approximately 610 0 KW" over a ten minute period.
TS 4. 8.1. 2.1. 6, which the procedure is intended to satisfy, requires loading of the DG to greater than or equal to 6083 KW in less than or equal to 120 seconds.
As written, the procedure would not provide complete assurance that the above TS Surveillance Requirements would be met.
A licensee Procedure Change (S86204) was issued to correct l
the above.
l b.
Procedure OX1426.01 (above), section 4.1.4, provides a l
voltage acceptance criteria of 4160 12% (83.2) VAC.
The corresponding TS acceptance criteria is 4160 1420 VAC.
Frequency tolerances were also provided as percentage limits vice hertz.
In addition to the technical error, percentage tolerances require conversion to engineering units by the procedure performer for each performance.
Good human factor practices would employ pre-calculated values, in engineering units corresponding to instrument scaling.
The licensee advised that section 4.1.4 would be corrected (Procedure Change S86204) and that their practices for specifying tolerances and parameters would be reviewed in Page 20
Evaluation light of the above.
c.
TS 4.8.1.2.a.4 requires verification of lubricating oil in storage as a periodic surveillance.
Although OX1426.01 (above) referenced satisfaction of this TS requirement, it i
was not addressed in the body of the procedure.
The licensee acknowledged the finding and has changed the procedure to delete its applicability to the above TS (Change S86204).
Station Memo No. SS 24723 documented assignment of this TS for coverage by a maintenance surveillance procedure.
4
- d. The above procedure (and others) were noted not to address actions to be taken for special 30 day reporting to NRC per TS 4.8.1.3 if a DG f ails to start during testing.
The licensee considers that their surveillance result review 4
process and personnel training are sufficient to ensure that such reporting requirements are met.
Additional NRC:RI review of the above item will be conducted as necessary during future inspections.
2.
The NRC Safety Evaluation Report, March 1983, Section 9.5.7, states that the applicant agreed to incorporate manufacturer's recommendetions for periodic operation of the DG rocker arm lube oil ';.relube" function.
Implementation of this commitment via a formal procedure could not be identified during the inspection.
1 The licensee had, however, included the item on a periodic testing and maintenance schedule in the control room which, if properly implemented, appears to be adequate for satisfaction of the above commitment.
Note however, that for this example and others reviewed l
during this inspection, the licensee does not appear to have l
a method for identifying or permanently assuring that l
commitments to the NRC remain in effect and are not l
inadvertently deleted or modified.
l Additional NRC RI review of the above item will be conducted as necessary during future inspections.
I 3.
The following observations are examples of procedures containing incorrect TS information, numerical values or references, or other similar errors.
a.
Procedure OX1446.01, AC Power Source Operability Weekly Surveillances, Revision 00, references TS 4.8.1.1 and i
i Page 21
(
-r_.--
,m,
,r,.,_._._.___--
,,,.__..-nr%.,.
,_,_-m,,
_.r.._,,,
i Evaluation 4.8.1.2 but satisfies only TS 4.8.1.1.1.a.
TS 4.8.1.2 applies to the DGs.
Additionally, the procedure stated its applicability as Operational Modes 1-4 only and appeared to be applicable in Modes 1-6.
Further the Repetitive Task Sheet for this procedure included similar incorrect TS applicability.
The procedure was revised by -Change No. S86210 to correct the above.
b.
Procedure OX1426.01 DG 1A Operability Surv.eillance, Revision 00, section 3.0 included a reference to an apparently nonexistent TS Table.
The reference was deleted by licensee Procedure Change S86210.
c.
Procedure OX1426.01 (above) included an incorrect i
applicability statement for TS 4.8.1.1.2 which included all DG testing requirements including those up to a 10 year frequency of performance, well in excess of the actual TS requirements covered by the procedure.
The licensee committed to correct the reference.
I d.
Procedure OX1446.03, Electrical Bus Operability (Operating), Revision 00, page 4 of 12, included three l
incorrect equipment identifications for the lineup i
verification:
As-Found Correct Tie line breaker between Tie line breaker between j
4 Bus E61 and E63 Bus E61 and E62 Tie line breaker between Tie line breaker between Bus E63 and E63 Bus E62 and E63 I
Bus E66 (AFO)
Bus E63 (AFO)
The procedure was corrected by Change S86243.
II e.
Procedure OX1446.04, Electrical Bus Operability f
l (Shutdown), Revision 00, Data Form OX1446.04B, contained an l
incorrect listing of "UPS-llB" in the data blocks for Vital Panel 1B.
The correct reference was "DC Bus llB" per j
Drawing F-310042.
The licensee corrected the above in Procedure Change No. S86244.
I f.
The licensee's engineering methods use " node numbers" to discretely identify-the configuration characteristics of the electrical systems.
Current application of these identifications is inconsistent and the licensee's policies Page 22
i Evaluation 1
appear to be in transition.
The node numbers are included in label information on most circuit breakers, wireways, etc.
The labeling was found absent from UPS-lE and -lF circuit breakers but was in place on the other four UPS units.
One licensee representative advised that long term consideration was being given to 4
removel of node numbers from all equipment in that it was i
information extraneous to operational needs.
I Drawing No. F-310043 for the six UPS units did not provide node numbers for all circuit breakers in the units (although circuit breaker node numbers were labeled in the field for UPS Units lA, 1B, 1C, and 1D).
Similarly, the node numbers were included as equipment identification in the data sheets of procedures OX1446.03 and.04.
A licensee representative stated, for this example, that the drawing would be revised to include the node numbering.
~
The licensee was advised that their overall policy for electrical equipment identification and labeling should be reviewed for consistency.
g.
Procedure OX 1446.02, 18 Month Bus E5 and E6 Offsite Power Supply Transfer Operability Test, Revision 00, Repetitive Task Sheet, identifies the applicable Operational Modes as 1-4; the same sheet requires " shutdown" plant j
initial conditions.
The licensee confirmed that, although the test can be l
performed in any Mode, it is preferred to perform it in Modes 5 or 6 and issued Change No. S86211 to correct the RTS.
i h.
Procedure OS1026.07, Aligning DG 1A Controls for Auto Start, Revision 01, referenced TS without providing a specific section reference and referenced FSAR Tables 8.3-1 and 8.3-2 which addressed subjects unrelated to the procedure.
Change No. 086267 was issued to correct the i
procedure, including incorporation of a reference to TS 4.8.1.1.1.2.a.6.
l i.
Procedure OX1426.01, DG 1A Operability Test, Revision 00, Repetitive Task Sheet did not correctly contain nor reference the acceptance criteria of procedure section 4.1.2.
Change S86204 was issued to correct the procedure RTS.
i f
j.
The RTS for OX1426.01 (above) indicated that the test l
was only required in Modes 1-4 vice All Modes (Modes 1-6).
i Page 23 4
1 Evalu2 tion
\\
Change S86204 was issued to correct the procedure by addition of Modes 5 and 6.
4.
TS 4.8.1.2, AC Sources - Shutdown, requires performance of the requirements of TS 4.8.1.1.1, 4.8.1.1.2 (except for 4.8.1.1.2.a.6) and 4. 8.1.1. 3 in Modes 3-6.
The explicit wording in the current revision of draft TS implies that satisfaction of "all" requirements of TS 4.8.1.1.1 and
.2 would be required prior to Mode entry or change (per TS 3/4.0.4),
including the 18 month through 10 year surveillance requirements, i.e.
reperformance of the surveillances.
Possible clarifying changes to the TS wording were discussed with the licensee who advised that the existing wording was identical to that in NRC Standard TS, Revision 5.
Discussions with NRC confirmed that only verification of prior satisf action of the surveillance requirements within the frequencies specified by TS 4.8.1. was intended.
5.
FSAR Section 8. 2.1. 3. a.1, page 8.2-5, states that
" structures such as lighting poles adjacent to the SF-6 j
(offsite power) bus runs, are located such that their l
failure will not jeopardize the availability of the offsite power circuits outlined in GDC (General Design Criteria) 17".
Two exceptions to the above were identified.
Overhead power lines and poles supplying the construction site are currently installed over and in proximity to the bus runs and are of sufficient size to inflict damage to at least one offsite circuit (and possibly three, depending on failure mode) should they fail.
Similarly, security light poles are installed immediately adjacent to the bus duct runs.
Failure of one light pole could inflict damage to at least one offsite circuit.
I The licensee advised that the construction power lines, poles, and associated structures is the Exeter-Han.pton Electric temporary power line (34.5 KV) and will be removed by the end of May, 1986 by a subcontractor.
The licensee stated that an evaluation of the security light poles had been initiated in response to the finding via l
Request for Information No. RFI 116797 to determine if the poles constitute a threat to the SF-6 bus runs.
j Additional NRC RI review of the above item will be conducted p
ac necessary during future inspections.
Page 24
f Evaluation 6.
TS 4.8.1.1.2.e.2 provides for verif ying the operability of the DG air intake preheaters and their power and control circuitry.
No heaters are installed and the licensee advised that they had been deleted from the station design.
During the inspection, the licensee confirmed, through discussions with NRR, that this TS requirement is being reviewed by NRR and is proposed for deletion in a future TS revision.
Except as noted above, the as-built configuration of the systems and equipment reviewed compared satisfactorily with the documents reviewed and the TS requirements were found to be definitively measurable.
I i
Page 25 i
Evaluation 2.6 DC POWER SOURCES 2.6.1 EVALUATION CRITERIA AND SCOPE The DC Power Sources consist of the station batteries and chargers providing power for direct current load groups, vital control and instrumentation systems, and control and operation of Class lE and non-Class 1E electrical equipment.
The safety related portion of the system consists of four 125 VDC batteries and chargers separated into two trains, "A"
and "B".
Each train provides DC power to inverters for the vital AC system.
The non-safety related portion of the DC systems consists of two 125 VDC batteries and chargers supplying inverters for the plant process computer and auxiliary power panels feeding non-vital equipment.
The DC Power Sources were reviewed with respect to the criteria and methods of Sections 1.3 and 1.4 of this report.
See Appendix 2.6 for a listing of documents reviewed. Proposed TS 3/4.8.2 was compared to the documents listed in Appendix 2.5.
2.6.2 Discussion The review of the systems and equipment included the normal, abnormal, and emergency operations described by the FSAR and the licensee's procedures.
The system configuration drawings, system operating parameters and limits, surveillance tests, and operating procedures were reviewed on a sampling basis to determine that the der.ign features were accurately reflected and that operating methods were consistent with the proposed TS.
Specifically, the following system features and operations were reviewed:
Independence of redundant power sources Normal and abnormal system alignments and operations Emergency system alignments and operations System testing alignments and methods System equipment operability testing Batteries Chargers Equipment ratings Associated equipment / systems interfaces Page 26
I Evaluttion A visual inspection of portions of the system and selected equipment established that the design f eatures were accuiately translated into the as-built plant.
The visual inspection also verified that the system configuration, bus arrangement, control room instrumentation and controls were in agreement with the TS.
2.6.3 Observations and conclusions The following inconsistencies or deficiencies were identified.
The licensee either corrected the items or provided confirmation that the items would be evaluated and appropriate disposition made.
The following procedure discrepancies represented deviations 1.
from TS requirements or the potential for eventual TS violations during operation or surveillance testing:
a.
Procedure MX0506.03, Quarterly Battery Surveillance, Revision 00, included several examples of minor disagreements with TS 4.8.2.1 and its acceptance criteria, apparently due to the use of an earlier version of draf t TS for procedure preparation.
Examples include:
Section 4.6 of the procedure requires the average battery electrolyte temperature to be 1 60 degrees F.
Current draft TS requires a minimum temperature of 65 degrees F. resulting in an nonconservative procedure acceptance criteria.
Similar, but conservative, discrepancies were found in the licensee's usage of "<" and "<" or ">" and ">" between the procedures and the TS 4.8.2 acceptance criteria involving maximum electrolyte levels and specific gravities in section 4.1 and table 10.3 of the procedure.
The Repetitive Task Sheet for the procedure does not identify the applicable TS but procedure section 2.2 indicates that the procedure satisfies TS 4.8.2.1 which includes surveillance requirements (7 day, 18 month, and 60 i
month requirements) not actually included in the test.
The Maintenance Department representative advised that all (about 35) maintenance surveillance procedures would be h
reviewed versus the as-issued TS when they become available.
b.
Procedure MX0506.05, Station Battery Performance j
Revision 00, section 2.2, indicates that the Discharge Test, satisfies TS 4.8.2.1.e and f, however the procedure j
acceptance criteria of the procedure and the Repetitive Task I
Sheets do not address TS subsection f.
Page 27 n
i Evaluation Additionally, TS 4.8.2.1.f and procedure section 3.1.2 define degradation of the battery to be "when the battery capacity drops more than 10% of rated capacity from its average on previous performance tests".
The procedure, however, provides no direction for the performance of evaluation of prior data versus current data.
Further, Acceptance Criteria 4.1 of the procedure requires the battery capacity to be " equal to or greater than 80%"
but does not define or reference a value for the capacity.
TS 4.8.2.1.e requires the capacity to be 80% of the
" manufacturer's rating when subjected to a performance discharge test".
The licensee advised that the procedure would be revised to correct the above and provide instructions for evaluation of prior and current test data and actions to be taken on unacceptable test results.
c.
Procedure MX0506.06, Station Battery Charger Capacity Test, Revision 00, stated its applicability as TS 4.8.2.1.
The test only performs portions of the Surveillance Requirements of this TS but also performs portions of TS 4.8.2.2.
See prior licensee commitment for procedure review and revision for "as-issued" TS status.
I Except as noted above, the as-built configuration of the systems and equipment reviewed compared-satisfactorily with the documents reviewed and the TS requirements were found to be definitively measurable.
4 4
i i
l Page 28 l
L
Evaluation a
2.7 ONSITE POWER DISTRIBUTION 2.7.1 EVALUATION CRITERIA AND SCOPE The onsite AC power distribution systems include the 13.8 KV distribution systems, including connections from the UATs and RATS; the 4160 VAC distribution system including the standby diesel generators and connections from the UATs and RATS; the 480 VAC and the 120 VAC distribution systems.
1 The onsite DC power distribution systems consist of the 125 VDC vital distribution system consisting of two vital busses in each i
of trains "A"
and "B"
and the 125 VDC non-vital system i
consisting of two busses.
Both the AC and DC systems are designed to provide two separate i
and redundant distribution systems for all Class lE nuclear safety related. equipment and loads.
The 13.8 KV system is classified as non-safety related but all other voltage levels in both the AC and DC systems serve Class lE safety related equipment or loads.
Both the AC and DC power distribution systems and associated equipment were reviewed with respect to the criteria and methods
{
of Sections 1.3 and 1.4 of this report.
See Appendix 2.7 for a i
listing of documents reviewed. Proposed TS 3/4.8.3 was compared 1
to the documents listed in Appendix 2.7.
4 2.7.2 Discussion 4
~
The review of the systems and equipment included the normal, abnormal, and emergency operations described by the FSAR and the licensee's procedures.
The system configuration drawings, system operating parameters and limits, surveillance tests, and operating procedures were reviewed on a sampling basis to determine that the design features were accurately reflected and that operating methods
]
were consistent with'the proposed TS.
i l
Specifically, the following system features and operations were reviewed:
I Normal and abnormal system alignments and operations Emergency system alignments and operations
+
System testing alignments and methods Equipment ratings Associated equipment / systems interfaces t
Page 29
Evoluttion 4
A visual inspection of portions of the system and selected equipment established that the design features were accurately translated into the as-built plant.
The visual inspection also verified that the system configuration, bus arrangement, control room instrumentation and controls were in agreement with the TS.
2.7.3 Observations and Conclusions The following inconsistencies or deficiencies were identified.
The licensee either corrected the items or provided confirmation that the items would be evaluated and appropriate disposition i
made.
1.
Procedure OS1047.02, Transferring Power Supplies to 120V AC Vital Instrument Busses, Revision 01, was reviewed in conjunction with associated drawings and during a walk I
I through simulating procedure performance.
Numerous l
disagreements were identified between power supply and load l
information presented in the procedure, the associated l
drawings (Appendix 2.7) and the as-built physical i
installation.
Examples are as follows:
i The procedure contains twelve " Caution" blocks, each a.containing a statement which warns that, when transferring power supplies from one of bus supply sources to the other, the panel is momentarily deenergized. The Caution block then lists the loads that are powered from the specific vital I
instrument panel.
i Six of the twelve caution blocks were reviewed and all were l
l found to missing loads that were shown on the associated vital panel schedule-drawing.
Additionally, loads were identified by the caution block that did not appear on the vital panel schedule drawing.
b.
A field inspection of two of the six vital instrument j
panel directory cards found circuit identifications that did not agree with either the drawings or procedures.
Panel l
wiring was not physically traced to determine whether the panel wiring agreed with the panel directory card.
l i
i i
Page 30
Ev31untien l
Example Discrepancies Panel Panel Drawing Procedure Caution I.D.
Information Block Information 1-PP-1A PP-1A LOSS OF POWER (MISSING) 1-PP-1B PP-1B LOSS OF POWER (MISSING) l-PP-1B (MISSING)
ED-PP-1B NONVITAL INST.
DISTRN PANEL 3B l-PP-lC PP-lC LOSS OF POWER (MISSING) 1-PP-lD PP-lD LOSS Of PWER (MISSING) 1-PP-3D (MISSING)
ED-PP-3D NONVITAL INST.
DISTRN PANEL 3D 1-PP-lE DESCRIPTIONS FOR (MISSING)
CIRCUITS 9, 10, 15, 16, 19, AND 20
)
1-PP-lF DESCRIPTIONS FOR (MISSING) i CIRCUITS 9, 10, 12, 15, 16, 19, AND 20 The licensee stated that the system had recently undergone major modification and that drawing revisions were in process but not yet incorporated into the procedure.
The licensee advised that a program is in place to assure prompt i
review of design changes by the station operating departments to ensure that plant or procedure impacts are dispositioned in a saf e and timely f ashion.
This program was not reviewed but was referred for review to an NRC RI region-based inspector who was onsite for an unrelated review of the licensee's operational procedure program.
The licensee advised that the procedure would be revised as the design information became available.
Additional NRC RI review of the above item will be conducted an necessary during future inspections.
4 l
t Page 31 i
v-.-,
,,.ymy
.m.,,
Evolu0 tion 2.8 EMERGENCY FEEDWATER SYSTEM AND CONDENSATE STORAGE TANK 2.8.1 EVALUATION CRITERIA AND SCOPE The Emergency Feedwater (EFW) System provides a supply of high pressure feedwater to the secondary side of the steam generators for Reactor Coolant System heat removal following a loss of normal feedwater.
The EFW consists of one full capacity motor driven pump and one full capacity steam turbine driven pump.
A motor driven startup feedwater pump serves as a backup to the EFW system and is normally used to supply feedwater during plant startup and shutdown.
The condensate storage tank has a total capacity of 400,000 and contains a dedicated 200,000 gallons of water for use by the EFW pumps as well as normal makeup water supply for the condensate system.
The startup feedwater pump can also be aligned to draw water from the EFW dedicated supply.
The EFW systems and equipment were reviewed with respect to the criteria and methods of Sections 1.3 and 1.4 of this report.
See Appendix 2.8 for a listing of documents reviewed.
l Proposed TS 3/4.7.1.2 and.3 were compared to the documents listed in Appendix 2.8.
2.8.2 Discussion i
i An as-built configuration review of the systems included a sampling review of system piping configuration, instrumentation, l
operating logic, and system operating parameters and limits.
l Selected draft and approved surveillance tests, operating j
procedures and preoperational tests were reviewed on a sampling basis to determine that the design features were accurately j^
reflected and that operating methods were consistent with the l
proposed TS.
l A visual inspection of portions of the system and selected l
equipment established that the design features were accurately j
translated into the as-built plant.
The visual inspection included a walk through of selected system operations to verify l
the accuracy of surveillance and operating procedures and compliance with the TS requirements.
I i
i Page 32
[
Evaluation 2.8.3 Observations and Conclusions The following inconsistencies and comments on the draft TS were identified during the review.
Miscellaneous procedure editorial discrepancies were identified to and corrected by the licensee.
l.
FSAR Section 6.8 discusses the use of the startup feedwater pump as a backup to the EFW system in the event of a loss of both EFW pumps.
Proposed TS 3/4.7.1.2 (March 13, 1986) requires three independent EFW pumps and associated flow paths to be operable which includes and treats the startup pump as one of the three pumps above rather than as a
" backup" system as discussed in the FSAR and SER.
This treatment of the backup pump as an additional EFW pump appears inappropriate.
The pump is located in the turbine building,which is not a class 1 stucture.
In addition, the only portion of the startup feed pump subsystem that is designed as a safety system is the discharge line to the EFW system.
The remainder of the subsystem was not designed nor analyzed as a safety system.
The current proposed TS (March 13, 1986 version) could result in a loss of both EFW pumps without aligning the startup pump as a backup to the system, reducing the reliability and availability of the EFW system if a station blackout occurs with both EFW pumps inoperable.
The licensee has prepared a proposed change to the existing draf t TS that will provide consistency between the TS and FSAR and which appears to better meet the intent of both the FSAR and the existing TS.
The proposed change will require the startup feedwater pump to be electrically and mechanically aligned to the EFW system in the event that both EFW pumps become inoperable, providing additional system response capability not currently required by the existing TS.
The proposed TS wil add Action Statements and surveillance requirements which treat the startup pump as a backup to the EFW system.
2.
Procedure OX1426.01, Emergency Feedwater Monthly Valve Verification, Revision 00, included an incorrect system alignment.
Due to a recent system modification, two valves, FW-V67 and 73, EFW Pump A & B Flow Test Valves, had been replaced by V346 and 347 respectively. (See Section 2.7 of this report for similar findings regarding design changes.)
Additionally, four valves used for steam generator Page 33 i
.. - ~
Evaluntion recirculation (FW-V1452, 153, 154, 155) were required to by procedure to be locked open for automatic system operation.
The correct position for these valves would be locked closed.
If these valves are open during normal operation, high pressure, high temperature feedwater would be admitted to the EFW System possibly causing EFW pump overheating and vapor binding.
Further, with these valves open, an EFW actuation would permit emergency feedwater to bypass the steam generators by flowing into the main feedwater system upstream of the isolation valves.
In either case, the capability of the EFW system could be substantially reduced.
The licensee corrected the valving errors via Change No.
S86196.
3.
Procedure OX 1426.02, Emergency Feedwater System Turbine Driven Pump Monthly Test, Revision 00, section 3.6 permitted the operator to throttle instrument isolation valves to reduce gage fluctuations.
The procedure did not state which valves could be throttled nor required the operators to l
restore the valves at completion of the test.
Indiscriminate throttling of instrument transmitter isolation valves can materially affect the instrument's response time for automatic actuation of safety related functions, particularly if restoration to full open conditions is not assured.
a The licensee submitted a change for the specific procedure i
(S86196) and stated that it was not station policy to permit such activities.
l 4.
Procedure OX1426.02 (above), precaution 5.1.1 and the precaution following step 8.1.4 require the operator to open the EFW pump discharge valve (shut for the test) if an automatic system actuation occurs during the test.
The I
valve is required to be normally locked open except during surveillance testing.
The procedure did not contain instructions requiring l
relocking of the valve nor for independent verification of valve realignment following testing as required by NUREG 0737, Clarification of TMI Action Plan Requirements and the i
licensee's commitments thereto.
Although some of the other Operations Department procedures contained some level of instruction for independent verification of equipment return to service or realignment, Page 34 i
Evoluntion no departmental policy had been issued and the various procedures were not consistent or adequate to meet the NUREG 0737 requirements.
1 The licensee had drafted procedure OP 10.2, Operations Department Independent Verification Procedure, prior to the 4
inspection.
Although the licensee had not yet approved and j
issued the procedure, the licensee stated that the department's procedures would each be revised as required to incorporate the provisions of OP 10.2.
OP 10.2 appears to satisfy the requirements of NUREG 0737.
5.
FSAR Table 14.2-3, sheets 16 and 17 specifies the preoperational testing requirements for the EFW system, including stroke time (closure) testing of the system valves l
to meet the criteria of TS Table 3.6-1.
Table 3.6-1 does f
not list valve closing times ;
Table 3.6-2 does, but does i
not include the EFW valves.
l l
The licensee initiated action to add the valves to TS Table 3.6-2 and revise FSAR Table 14.2-3 to reference the correct TS table.
~6.
FSAR Section 9.2.6, Condensate Storage Tank, states that, to ensure that 200,000 gallons of water is available for EFW system operation, all penetrations that are not Class 3 l
(safety related, seismic, etc.) will be located above the elevation needed to ensure that 200,000 gallons are i
available for EFW.
I FSAR Section 10.4 states that there will be no connections to condensate system from the condensate storage tank below
(
that 200,000 gallon elevation.
f A plant modification has been installed but not reflected in j
the FSAR that provides an alternate suction from the bottom of the tank to the startup feed pump.
The penetration is normally isolated from the tank by a manual, locked closed valve.
I Although the modification provides significant operational flexibility in light of the startup feed pump's role as an EFW backup, the licensee was unable to confirm that a safety j
analysis of the design had been performed nor confirm that the installation was in accordance with construction standards commensurate with its location.
The licensee committed to evaluate the penetration and make FSAR submittals to NRR as appropriate.
Page 35
Evaluation Additional NRC:RI review of the above item will be conducted as necessary during future inspections.
7.
FSAR Section 9.2.6.5.d states that the condensate storage tank will be maintained at a minimum temperature of 50 degrees F. and that a heating system is provided for that purpose for cold weather conditions.
The TS were silent with respect to this temperature limit and no administrative controls were found which discuss a minimum tank temperature or the actions to be taken if the temperature should approach this value.
The licensee stated their interpretation of the FSAR to be a description of the instrumentation and heating system and that the temperature limit has no safety analysis significance but is there for freeze (cold weather) protection only.
The temperature is monitored continuously via thermocouple output to a main control room computer and i
a local readout.
The heating system is designed to operate automatically at a 50 degree tank temperature.
Tank temperature monitoring and followup actions should be considered incorporation into the plant cold weather bill procedure.
Freezing or ice formation in the tank can render the EFW system inoperable.
In circumstances where the heating system does not maintain the tank sufficiently above freezing due to a malfunction or extremely cold weather, alternate methods for heating the CST should be identified, including the temperature at which these actions should be initiated.
Additional NRC:RI review of the above item will be conducted as necessary during future inspections.
l Except as noted above, the as-built configuration of the system compared satisfactorily with the documents reviewed.
The TS requirements reviewed were definitively measurable.
i 4
i Page 36 1
1 Evaluation 2.9 BORATED WATER SYSTEMS 2.9.1 EVALUATION CRITERIA AND SCOPE Redundant reactivity control is provided by the boron soluble poison addition function of the Chemical and Volume Control System (CVCS) via the boric acid storage tanks (BATS) and the Boron Thermal Regeneration System (BTRS) and from the Refueling Water Storage Tank (RWST).
These subsystems and equipment were reviewed with respect to the criteria and methods of Sections 1.3 and 1.4 of this report.
See Appendix 2.9 for a listing of documents reviewed.
Proposed TS-3/4.1.2.5,
.6 and.7 were compared to the documents listed in Appendix 2.9.
2.9.2 Discussion The subsystems listed above provide the capability to reduce nuclear core reactivity under normal, abnormal, and emergency conditions.
The features of these systems reviewed included normal, emergency, and gravity boration flow paths from the BATS to the RCS via the CVCS and the abnormal and emergency flowpaths from the RWST.
The as-built configuration portion review of the systems included a sampling review of system piping configuration, instrumentation, operating logic, and system operating parameters and limits.
Selected draft and approved surveillance tests, operating procedures and inservice tests were reviewed on a sampling basis to determine that the design features were accurately reflected and that operating methods were consistent with the proposed TS.
A visual inspection of portions of the system and selected equipment established that the design features (except as noted in 2.9.3 below) were accurately translated into the as-built plant.
The visual inspection included a walk through of selected system operations to verify the accuracy of t
surveillance and operating procedures and compliance with the TS requirements.
2.9.3 Observations and Conclusions The following inconsistencies and comments on the draft TS were identified during the review.
Miscellaneous procedure editorial discrepancies were identified to and corrected by the licensee.
1
)
Page 37.
Evaluntion 1.
TS 3/4.1.2.7, Limiting Condition for Operation (LCO),
Unborated Water Sources - Shutdown, revised as submitted by the licensee, requires BTRS outlet valve CS-V302 or Moderating Heat Exchanger outlet valve CS-V305 to be closed in Modes 4, 5, or 6.
The Action Statement for the same TS requires the BTRS demineralizers to be bypassed if either valve is open.
The actual wording would place the licensee into the action statement even if complying with the LCO.
The licensee plans to correct the above in a TS resubmittal to NRR.
2.
Operating Procedure OS1002.02, Operation of Letdown, Charging, and Seal Injection, Revision 00, contains the
" system initial valve lineup".
The lineup' required the charging pump discharge valves (CS-200 and 210) to be open but did not require them to be locked open to assure their
{
availability for high pressure safety injection service.
I i
The licensee evaluated the valve lineup and issued Change No. 086261 to lock the valves open.
3.
FSAR Section 9.3.4.3.f which describes CVCS heat tracing states that heat tracing is not required for any CVCS components which contain 4% wt. boric acid, providing these components are located in a room maintained at 65 degrees F.
or higher.
Temperature control is required to prevent boron
]
precipitation and crystallization from blocking the lines.
J l
The emergency boration lines through valves CS-V426 and V442 appeared to exit the 65 degree controlled environment and i
were not heat traced.
The licensee committed to evaluate these lines to determine if heat tracing is required.
t Additional NRC:RI review of the above item will be conducted as necessary during future inspections.
4.
FSAR Sections 9.3.4.2.e.13 and 9.3.4.2.f state that the i
boric acid storage tank solution will be maintained between 4 and 4.4 % wt. (7000-7700 ppm).
TS 3.1.25 and 3.1.2.6 require a minimum concentration of 7000 ppm but do not address a maximum concentration.
The licensee stated that the maximum concentration of 7700 ppm had been deleted from the latest revision to NRC 1
Standard Technical Specifications but that administrative controls are in place to maintain the actual concentration I
Page 38
--,.-,,,.c--_.m._
-. - ~. -
.._m,,.,-__
_m_.,m__,____y.,,
.--.-._,w--
Evaluation below the administrative limit of 7700 ppm.
T 5.
FSAR Section 9.4.4.b states that the control switch, status lights, and pump trouble alarms for the charging pump auxiliary lube oil pumps are located on the Main Control Board.
These items are not located on the MCB but are local at the pumps.
Trouble alarms are available in the control room via the plant process computer.
The licensee plans to submit a change to the FSAR to reflect the as-built status of these controls.
6.
Procedural errors were found in surveillance tests OX1408.01, 18 Month Emergency Boration Flow Test, and in Operating Procedure OS1008,01 for the CVCS System.
The surveillance tests contained acceptance criteria for RWST temperature of >35 degrees F.
vicet a minimum TS 3.1.2.5 temperature of 50 degrees F.
OS1008.01 contained a caution step involving boric acid flow control settings for flushing operations which required clarification.
The licensee corrected both procedures during the inspection.
Except as noted above, the as-built configuration of the system compared satisf actorily with the documents revi ewed.
The TS requirements reviewed were definitively measurable.
i Page 39
Evaluation 2.10 ENGINEERED SAFETY FEATURE (ESP) INSTRUMENTATION 2.10.1 EVALUATION CRITERIA AND SCOPE Engineered Safety Feature Instrumentation was reviewed in conjunction each respective mechanical or electrical system in Sections 2.1 - 2.8 and 2.11 of this report.
The results of those separate reviews are summarized below.
The ESF instrumentation for each respective system was reviewed with respect to the criteria and methods of Sections 1.3 and 1.4 of this report.
See Appendix 2.10 for a listing of relevant documents reviewed.
2.10.2 Discussion Proposed TS 3/4.3.1 and.2 and Tables 3.3-1, 3.3-3, 3.3-4, and 2.2-1 were compared to the various documents listed in the Appendices to verif y that the trip and calibration setpoints agreed.
Table 3.3-4 contains a listing of the reactor trip, safety injection actuation and containment isolation trip setpoints.
2.10.3 Observations and Conclusions A number of inconsistencies were identified with one remaining unresolved at the end of the inspection.
1.
Each of the Instrument Department Calibration Procedures listed included tolerance bands that could result in the "as calibrated" or "as-left" instrument setpoints exceeding the i
TS trip setpoint limits.
Typically, the TS limits for instrument setpoints include a
" Trip Setpoint" expressed as a finite limit, e.g. I 18.0 psig containment pressure.
Allowance for drift between calibrations is then provided by TS as an " Allowable value",
e.g. 1 18.7 psig containment pressure.
1 In further example, TS 3/4.3.2 requires that the ESF instruments be operable with their trip setpoints set
" consistent" with the values shown in the Trip Setpoint column of Table 3.3-4 The TS then provides Actions for actual setpoints found "less conservative" that the Trip Setpoint column, requiring instrument readjustment to be " consistent with the Trip Setpoint value.
Page 40
Evaluntion The licensee has established tolerance bands for each instrument based on the statistical setpoint analysis provided by their NSSS vendor and performed in accordance with methodology approved by NRR.
This methodology is discussed in TS Basis 2.2.1, Reactor Trip System Instrumentation Setpoints, which states that a setpoint is considered to be adjusted consistent with the nominal value when the "as measured" setpoint is.within the band allowed for calibration accuracy.
The TS Limiting Conditions for Operation and Surveillance Requirements become a part of the facilities Operating License conditions whereas the TS Bases are provided for information and are not license conditions.
As a result, although the licensee's procedural setpoints may comply with the guidelines of the TS Bases, they appear to be in conflict with the finite limits provided by the LCO's and Surveillance Requirements as indicated by the following examples:
TS Trip Tolerance Procedure Parameter Setpoint per Procedure IX1662.151 RCS Flow 1 90%
89.5 - 90.5%
IX1662.220 SG Lo Level
> 17.0%
16.9 - 17.1%
IX1662.313 RCS Pressure
<2385 psig 2382 -2387 psig IX1662.313 Lo Press. SI 11850 psig 1848 - 1852 psig In summary, the licensee's procedures may be technically acceptable and conservative with regard to setpoint development in light of the TS Bases and NSSS setpoint methodology. However, their implementation will result in the specific provisions of the TS LCO being exceeded and is contrary to normal NRC policy for compliance with finite TS limits.
Clarification of the TS or revision of the licensee's procedure policies appears necessary to resolve the above.
At the close of the inspection the licensee was initiating communication with NRC:RI and NRR to pursue this resolution.
It should be further noted that, even with the tolerances added, all examples identified remained within the
" Allowable Value" limits of the respective TS tables and are therefore initially conservative with regard to the safety analysis, although sufficient margin for eventual instrument l
l Page 41 i
Evolu2 tion drift could not be confirmed.
Further, the licensee could not confirm during the inspection that other instruments' calibration tolerances would not approach the Allowable value limits.
2.
Surveillance Procedure IX1662.315, P-403 RC Loop 4 Hot Leg Pressure Protection Channel IV Calibration, Draft, verifies the pressure at which the RHR hot leg suction valves receive an automatic closure signal.
The RHR suction valves are required by TS 3/4.5.2 to close at a pressure < 660 psig.
Similar to finding 2.10.3.1 above, the tolerance band in the procedure would allow setting of the pressure as high as 668 psig.
In this case, the licensee modified the procedure so that the tolerance band maximum setpoint is 660 psig.
3.
All of the Instrument Department surveillance procedures reviewed appeared to adequately address independent verification of equipment return to service with only minor clarification required.
The restoration step in each procedure requires "second person verification that the channel is returned to service" along with signature blocks.
Because portions of the return to service actions are shared between the Instrument and Operations Departments and can be performed separately, clarification was needed to ensure proper performance.
The licensee issued Standard Practices Instruction No. 20 to address the steps required for satisfactory completion of second person verification.
1 i
l l
l Page 42 i
Evaluation i
1
]
2.11 SAFETY INJECTION AND RESIDUAL HEAT REMOVAL SYSTEMS l
2.11.1 EVALUATION CRITERIA AND SCOPE f
The High Pressure Safety Injection System (CVCS Charging Pumps),
Intermediate Pressure Safety Injection (SI Pumps) and the Low j
Pressure Safety Injection function of the Residual Heat Removal 1
(RHR) system provide the means to inject water to the core during a loss of coolant accident and to provide long term, post accident core recirculation cooling.
1 These subsystems and equipment were reviewed with respect to the criteria and methods of Sections 1.3 and 1.4 of this report.
See Appendix 2.11 for a listing of documents reviewed.
I i
Proposed TS 3/4.5.2,
.3 and.4 were compared to the documents j
listed in Appendix 2.11.
2.11.2 Discussion i
j The features of the systems reviewed included normal, abnormal i
and emergency operations as described in the FSAR and the licensee's draft and ap, roved procedures.
The as-built configuration portion review of the systems l
included a sampling review of system piping configuration, instrumentation, operating logic, and system operating parameters and limits.
Selected draft and approved surveillance tests, operating procedures and inservice tests were reviewed on i
a sampling basis to determine that the design features were accurately reflected and that operating methods were consistent with the proposed TS.
i l
l A visual inspection of portions of the system and selected equipment established that the design features were accurately translated into the as-built plant.
The visual inspection included a walk through of selected system operations to verify the accuracy of surveillance and operating procedures and compliance with the TS requirements.
2.11.3 Observations and Conclusions The following inconsistencies were identified during the review.
Miscellaneous procedure editorial discrepancies were identified to and corrected by the the licensee.
1.
FSAR Section 6.3, Emergency Core Cooling System, Figure 6.3-2 incorrectly shows the High Head SI flowpath as going Page 43
Evaluation through the Boron Injection Tank.
" Notes" associated with that figure also reference 12% wt. boric acid solution.
The Boron Injection Tank and 12% boric acid have been eliminated from the facility design and are no longer a part of the ECCS.
Other similar references have been removed.
The licensee intends to submit an FSAR change to correct the above.
2.
Surveillance Procedure OX1456.02, Monthly ECCS Valve Verification, is completed to satisfy TS 4.5.2.b.
Two valves, CS-460 and -461, RWST Suction Isolation to the Charging System, would be incorrectly positioned as open vice closed by the verification.
Opening the valves would result in supplying 2000 ppm borated water to the reactor, causing an unnecessary plant transient.
The procedure also lists the control switch position next to the required valve position with only one " Initials" block.
It was unclear whether the valve position or the control switch position was actually being verified.
Also, the independent verification valve list appeared to contain up to 31 valves which would not require independent verification while performing this procedure.
The licensee evaluated the valve lineup and issued Change No.
S86212 to correct the above.
3.
Surveillance Procedure OX1413.02, RHR System Interlock Checks, Draft C, is performed to satisfy TS 4.5.2.d.1 which requires that the pressure interlocks for the RHR suction isolation valves be verified every 18 months.
The acceptance criteria listed in section 4.0 of the procedure permit a tolerance band on the pressure netpoint which could result in the procedure acceptance criteria being satisfied with a pressure less conservative than allows by TS.
See Section 2.10 of this report for further discussion.
The final conditions required by the test demand that the RHR suction valves be closed and independently verified.
This lineup condition can be inappropriate in that this test may be performed during plant heatup or cooldown.
4 Further, the independent verification steps of the procedure are inappropriate in that they address only the hot leg i
i Page 44 l
t
Evaluation suction valves and omit other RHR system valves which would require independent verification for Mode changes, etc.
The licensee produced a more current draft of the procedure (in review at the time of the inspection) which appeared to address the above.
4.
Operating Procedure OS1005.05, Safety Injection System Operations, Revision 00, contains a thirty page valve lineup as an attachment to the procedure.
The procedure only appeared to address starting and stopping of SI pumps and the draining and filling of SI accumulators.
No instructions were provided regarding the valve lineup.
Procedure. step 3.5 further states that " performance of this procedure will require independent verification of valve position" but does not identify which valves are to be verified nor the verification methods.
The licensee processed Procedure Change No. 08625'3 to correct the above.
Except as noted above, the as-built configuration of the system compared favorably with the documents reviewed and the TS requirements reviewed were definitively measurable.
i Page 45
_j
GENERAL CONCLUSIONS 3.0 cemen4L CONCLUSIONS The inspection determined that the proposed (draft) Technical Specifications were compatible with the as-built plant configuration and operating characteristics in the areas inspected and that the Technical Specification' Surveillance Requirements were definitively measurable.
In general, the licensee's design control process appears to be working effectively.
The findings below indicate that the problem areas identified typically involve documentation programs rather than the functional aspects of the f acility's engineering and construction.
Although discrepancies were identified betweOn the FSAR, TS, and as-built plant, the discrepancies were of limited safety impact and will be subjected to review in the licensing process prior to plant operation.
Additional deficiencies were identified in the plant's various procedure development, review, approval, and implementation processes.
The existing procedure review processes for Maintenance Department procedures appear to be rigorous.
A majority of the Maintenance Department procedures reviewed had been approved by the Station operations review Committee and were found to be accurate when compared to the draft TS (Issue "4B").
The Operations Department procedure program is further discussed below.
The surveillance performance and procedure tracking program appears workable.
It identifies the surveillance frequencies and the status of all surveillances needed for an Operational Mode change.
The system relies upon data identified in procedure Repetitive Task Sheets (RTS) to ensure that the TS criteria have been met.
Based on the errors identified during this inspection, a rigorous review of the data and acceptance criteria' listed on the (RTS) will be necessary for the system to work effectively.
i Several errors in this regard were identified during the inspection.
The inspection also identified numerous inconsistencies between the draft Technical Specifications, the Final Safety Analysis Report, and the licensee's implementing procedure programs as discussed in Sections 2.1-2.11 of this report.
Page 46
GENERAL CONCLUSIONS Where inconsistencies were identified, the licensee provided resolution or demonstrated that the matter had been previously identified, was documented for eventual disposition, and/or that actions were in progress to achieve disposition as part of the licensing process.
Review of the licensee's programs for implementation of TS also identified the following apparent or potential problems of a general nature.
3.1 NUREG 0737, Clarification of TMI Action Plan Requirements, Item I.C.6, stipulates that measures be implemented to ensure that equipment important to safety is subject to independent verification of its restoration to service following testing (and maintenance).
Additionally, return to service (restoration) equipment alignment should be conducted using appropriately detailed instructions.
The licensee appears to have adequately implemented the above in the Instrument Department procedures.
The Operations Department had drafted but had not yet issued an administrative procedure (OP 10.2) that appeared to adequately address the above.
However, during the inspection, only one of Operations Department procedures reviewed addressed independent verification per the draft OP 10.2.
The remaining procedures either did not address independent verification or included inadequate or inconsistent instructions.
At the close of the inspection, Operations Department management stated that they planned to issue OP 10.2 and incorporate its requirements into all department procedures before the proposed fuel load date of June 30, 1986.
3.2 The procedure review process currently in place for review and approval of Operations Department procedures appears to require additional management attention to assure that accurate and complete procedures are available for licensed operations.
Eighty percent of the Operations Department procedures reviewed had completed the technical review process and forty six per cent of the procedures had been approved for use by the Station Operations Review Committee.
Approximately 20% of the procedures that had been approved contained errors that could result in system alignments or results contrary to the requirements of TS and the FSAR.
The affected procedures were all "important to safety".
l Page 47
GENERAL CONCLUSIONS The Operations Department management acknowledged the need for additional management attention and resources to improve the procedure preparation and review process.
3.3 Many of the existing operating and surveillance procedures are based upon prior versions of draft TS.
Licensee management elected to " freeze" the TS used for procedure developement to a version available several months prior to this inspection (Version "4B").
As a result, TS have continued to develop through the " proof and review" version and have incurred changes which were not yet reflected in the plant procedures.
An extensive effort will be necessary to identify and upgrade all impacted procedures to the "as-issued" TS when i
they become available.
The licensee's plans in this regard appear to be technically workable but will result in
~
significant schedule pressure to assure that the corrected procedures are acceptable and available at the time of license issuance.
This task will also require substantial management attention to assure avoidance of the review and approval process deficiencies identified in section 3.2 above.
3.4 Currently all safety related instrument setpoints are established in the center of an allowable instrument tolerance band.
This inspection determined that this could permit setting instruments in a manner which exceeds the TS finite trip setpoint value in a manner contrary to the TS (See section 2.10, this report).
Licensee resolution of this matter with NRC appears necessary to avoid future questions of TS compliance and potential enforcement l
action.
i Discussion of all the foregoing inconsistencies and deficiencies with NRC:RI indicated a need for the licensee to document their i
position and/or corrective measures on the noted item.
Region I will conduct reviews and inspection followup as necessary to determine the acceptability of the actions.
i i
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Snabrook Unit 1 Inspection Plan Page 1
APPENDIX 1.0 SEABROOK UNIT 1 - INSPECTION PLAN VERIFICATION OF AS'-BUILT CONDITIONS TO TECHNICAL SPECIFICATIONS AND FSAR/SER OBJECTIVES:
Conduct, on a sampling basis, reviews and inspections of as-built safety related systems, structures, and components in order to:
. determine whether the Technical Specifications and FSAR/SER are compatibile with the Seabrook Unit 1 as-built plant, and to determine whether Technical Specification requirements are definitively measurable.
GENERAL SCOPE The facility descriptions, operating characteristics, and related informat-ion found in the FSAR, SER and the proposed Technical Specifications (TS) will be compared to corresponding licensee drawings, procedures, and actual plant hardware to establish whether the as-built configuration of the systems, structures and components is compatible with the safety analyses and proposed (TS).
Concurrent with the above, the TS will be evaluated to confirm that the performance criteria and requirements established by the TS can be definitively measured or determined, i.e. that the means and methods to establish conformance with the TS requirements are responsive, sensitive, and sufficiently definitive to actually establish the required level of conformance.
Particular emphasis will be given to the efficacy of surveillance tests and inservice tests established by the licensee to demonstrate conformance with TS and the requirements of ASME B&PV Section XI and 10CFR50.55a.
Sesbrook Unit 1 In=paction Plan Page 2
In general, the systems, structures, and components to be reviewed will include a sample of the following:
Containment & Support Systems Containment Integrity Containment Leakage Containment Isolation Combustible Gas Control Containment Depressurization and Cooling Containment Spray System Spray Additive System Containment Enclosure Building Service Water System
. Ultimate Heat Sink ESF Actuation Instrumentation High Pressure Safety Injection & CVCS Residual Heat Removal Emergency Boration (Redundant Reactivity Control)
Refueling Water Storage Tank Auxiliary Feedwater Condensate Storage Tank Vital AC Power Emergency Diesel Generators Vital DC Power Onsite Power Distribution INSPECTION ITEMS Documents:
Technical Specifications Final Safety Analysis Report Safety Evaluation Report and Supplements Surveillance / Test Procedures Preoperational Test Procedures Inservice Test Procedures
(
Normal, Abnormal and Emergency Operating Procedures Process & Instrumentation Diagrams Elementary, Logic, and Loop Drawings Fabrication and Installation Drawings Equipment Technical Manuals Inspection Tasks:
(
l 1.
Identify the TS applicable to the subject systems and select a sample of requirements (Limiting Conditions for Operation, i
Surveillance Requirements, etc.) for inspection.
Review the corresponding sections of the FSAR and SER.
i I
Sembrook Unit 1 Inspection Plan Pcgs 3
2.
Obtain applicable as built (or Approved for Construction)
P& ids, Elementary Diagrams, Loop and Logic Diagrams, etc. for the subject systems.
Select areas of inspection by ioentifying (red lining) portions of each drawing.
Develop a listing of specific equipment items within the system area which are subject to the TSs.
3.
Verify for selected portions of each system that:
1) the proposed TS adequately reflect the system configuration depicted by the drawings, 2) the drawings match the information provided in the FSAR and SER, and 3) the proposed TS are consistent with the FSAR commitments and SER conclusions.
Confirm that the system configuration and equipment will support definitive measurement or determination of conformance with TS performance criteria and requirements 4.
Develop a checklist of items for field verification during system and procedure walkdowns.
5.
Identify and obtain the operating, surveillance and other pertinent licensee procedures applicable to the system areas and TS being reviewed.
Working from the drawings and TSs to the procedures, confirm that:
1) the procedure (s) adequately address the selected equipment and TS requirements identified in the FSAR and SERs, 2) procedures accurately reflect the installed (as-built) hardware configuration and condition, and 3) the test and or operating methods meet the TS or FSAR/SER requirements, commitments and analyses (review actual performance data where practical).
j 6.
Include procedure field verification items in checklist for system and procedure walkdowns.
7.
Conduct an in plant walkdown of subject systems to verify the results of the document review; confirm that:
1) the as built hardware configuration matches the information obtained from the document review, l
l 2) the installed hardware is adequately addressed in the l
procedures and TS,
Seabrook Unit 1 Inspection Plan Page 4
3) the licensee's test and operating methods are appropriate _
to the actual equipment, and 4) the equipment configuration and features provide for definitive determination or measurement of conformance with the TS.
8.
Review the licensee's program for correlating TS requirements to procedures and procedure revision needs, design change impact upon TS and TS implementing procedures, planning and scheduling of surveillance testing, etc.
TECHNICAL REVIEW REPORT OUTLINE Cover Sheet Table of Contents Executive Summary Introduction Purpose of Inspection Background and General Scope a
General Evaluation Criteria General Evaluation Methods Evaluation - By System for Each System Reviewed Scope & Evaluation Criteria References (Listed in Appendices)
Discussion Findings and Observations Conclusions General Conclusions r
Appendices Licensee Personnel Contacted Documents Reviewed (By System) i 1
APPENDIX l.1 REVIEW OF SEABROOK UNIT 1 TECHNICAL SPECIFICATIONS LICENSEE PERSONNEL CONTACTED DURING INSPECTION The inspection team met held discussions with and inspected plant systems with numerous licensee personnel.
Listed below are the licensee contacts who materially participated in the inspection and entrance or exit meetings.
NAME TITLE D. Abely Maintenance Dept. Manager R. Barkley Resident Inspector, USNRC D. Bemis Sr.
Operator R. Beuchel Engineer R. Bilodeaux Auxiliary Operator N. Blumberg Lead Reactor Engineer, USNRC S. Buchwald QA Supervisor A. Cerne Sr. Resident Inspector, USNRC R. Cooney Maintenance Supervisor J. Devincento Director, Engineering W. Dickson Lead Mechanical Engineer W.
Diprofio Construction Station Manager M. Feeney Auxiliary Operator J. Grillo Asst. Operations Manager R. Guillette Project Construction QA Manager R. Gwinn Sr. Mechanical Engineer W. Hall Regulatory Services Manager W. Hinton I&C Foreman G. Kingston Compliance Manager W. Julliam QA Engineer R. Lizzotte Admin. Services Manager G. Madel Shift Superintendent l
H. McNamarea Electrical Maint. Supervisor j
J. Malone Operations Admin. Supervisor l
W. Middleton QA Staff Engineer G. Mcdonald Construction QA Manager G. Momm Auxiliary Operator T. Murphy I&C Department Manager P.
Pelletier Auxiliary Operator D.
Perkins Licensing Engineer N. Perry Plant Operator l
N. Pillsbury Special Projects Manager l
N. Pond Sr. Operator T. Pucko Sr. Licensing Engineer D. Ruscitto Resident Inspector, USNRC V. Sanchez Site Licensing Supervisor I
Page 2
Appsndix 1.1 Parsonn Contacted R.
Savage Maintenance Supervisor j
E. Small DCC Department Supervisor R.
Strickland Shift Superintendent l
W. Sturgeon Nuclear Services Manager J. Tefft STD Project Engineer G. Thomas Vice President, NHY J. Vargas Engineer L. Walsh Operations Manager J. Warnock Nuclear Quality Manager K. Wilson Plant Operator K.
Zito Documentation
Data Shnets Pago 1
d' APPENDIX 2.1 INSPECTION REPORT DATA SHEET CONTAINMENT ISOLATION SYSTEMS TECHNICAL SPECIFICATIONS:
3/4.6.3 containment Isolation Valves 3/4.3.2.1-3 Engineered Safety Features Actuation System Instrumentation - Containment Isolation FSAR
REFERENCES:
5.45, 6.2, 6.5, 7.2, 9.4, 14.2 NRC SER
REFERENCES:
6.2, 6.5 DOCUMENTS REVIEWED:
NUMBER TITLE REVISION F-8050ll CVCS Purification P & ID 15 F-805010 Safety Injection System P & ID 15 F-805002 RCS Reactor Vessel, P & ID 9
I-RC-B20857 RCS Detailed Composite Diagram 2
C-509048 Safeguard Actuation Signals Westinghouse Functional Diagrams 8
C-509042 Reactor Trip Signals Westinghouse Functional 6
Diagrams EX1804.013 CVCS Cold Shutdown valve Test 00 OX1423.07 Containment Encl. Emerg. Exh. & Cooling Test 00 ASME Sect.XI Subsec. IWV, Boiler & P.V. Code 1983 s
OX1423.16 Containment Isol. Valves-Purge & Exh. Test 00 OX1426.01 D/G IA Operability Surveillance Test 00 IX1668.331 P-937 Containment Pressure (Protection Channel I) Calibration 00 IX1665.341 P-937 Containment Pressure (Channel I) 00 Operational Test
Duts Shsets Pcgo 2
APPENDIX 2.2 INSPECTION REPORT DATA SHEET CONTAINMENT & SUPPORT SYSTEMS TECHNICAL SPECIFICATIONS:
3/4.6.1 Containment Integrity 3/4.6.1.2 Containment Leakage 3/4.6.1.3 Containment Airlocks 3/4.6.1.4&.5 Containment Internal Pressure & Air Temperatures 3/4.6.1.7 Containment Ventilation System
-3/4.6.5 Containment Enclosure Building 3/4.6.5.1 Containment Enclosure Emergency Air Cleanup System 3/4.6.5.2 Containment Enclosure Building Integrity 3/4.0.5 IST Surveillance Requirements FSAR
REFERENCES:
3.1, 3.8, 6.2, 6.5, 9.4, 14.2 NRC SER
REFERENCES:
6.2, 6.5 DOCUMENTS REVIEWED:
NUMBER TITLE REVISION 1-MAH-B20504 Misc. Air Handling Containment and Purges 0
(COP. CAP) 1-LD-B20864 Leak Detection System 0
F-604128 Containment Structure Air Flow Diagram 12 F-604131 Containment Structural Purge Exhaust 11 SD-48 System Description, Containment Structural Detail 2
OX1423.08 Containment Enclosure Emergency Exhaust 00 Filter System 1-PT(I)-37.1 Preop Test Procedure-Reactor Containment Integrated Leak Rate (ILR) Test 1
10CFR50 App. J, Primary Reactor Containment Leakage Testing for Water Cooled Reactors IX1668.331 P-937 Containment Pressure (Protection Channel I) Calibration 00 IX1668.341 P-937 Containment Pressure (Channel I) 00 Operational Test OX1423.01 Containment 24 Hour Air Temperature Survey 00
Data Shnsto Pcga 3
i OS1023.66 Containment Enclosure Ventilation System 02 Operation OS1023.67 Containment Vent System Operation 01 OX1023.68 Containment Air Purge Operation 02 OS1023.69 Containment Online Purge Operation 02 h
Data Shosta Pcge 4
APPENDIX 2.3 INSPECTION REPORT DATA SHEET CONTAINMENT DEPRESSURIZATION & COOLING SYSTEM TECHNICAL SPECIFICATIONS:
3/4.6.2.1 Containment spray System 3/4.6.2.2 Spray Additive System 3/4.3.2.1 &.2 Engineered Safety Features Actuation System FSAR
REFERENCES:
6.5, 7.3, 9.2.2, 14.2 NRC SER
REFERENCES:
6.2, 7.3 DOCUMENTS REVIEWED:
REVISION NUMBER TITLE F805023 Containment Spray System 12 OX1406.01 Containment Spray System valve Verification 00 8
SD-20 System Desc. Containment Bldg. Spray System M-503253 CBS-SAT Disch. Valves & Ctat. Spr. Isol. Valves 6
M-503258 CBS-ECCS/Spr. Recirc. Signal Generation 7
M-503261 CBS-Safety Injection Monitor Lights 4
M-503260 CBS-Refuel Water Stor-TK Level Alarms 7
F-310007 & 8 Switchgear Bus-One Line Diagrams F-310027 & 33 Motor Control Centers-One Line Diagrams OX1406.02 Containment Spray Pump & Valve Test 00 OX1406.03 18 Month Ctat. Spray Auto Valve Actuation 00 1-PT-12.2 Preop Test Procedure - Containment Spray 1
Nozzle Test EX1B04.010 Containment Ventilation Valve Testing Draft M-310900 47 Sheets - Containment Spray System Schem.
Various IX1668.331 Containment Pressure (Protection Channel I)
Calibration 00
D tn Shacto Pcgo 5
APPENDIX 2.4 INSPECTION REPORT DATA SHEET SERVICE WATER SYSTEM AND ULTIMATE HEAT SINK TECHNICAL SPECIFICATIONS:
3/4.7.4 Service Water System 3/4.7.5 Ultimate Heat Sink 3/4.0.5 Surveillance Requirements (IST)
REFERENCES:
7.4, 9.2, 2.4, 11, 14.2 NRC SER
REFERENCES:
7.6.5, 9.2, 2.4.11 DOCUMENTS REVIEWED:
NUMBER TITLE REVISION 1-SW-B20794&S Service Water System Nuclear Detail 00 1-SW-B20792 Service Water System Nuclear Overview 00 1-RC-B20847 Reactor Coolant System-Detailed Composite 2
SD-24 Service Water System Description 5
M-503962 SW Cooling Tower Actuation 10 M-503967 SW Pump Sht. 1 5
1-PT-15.10 Service Pump Tests and Auto Start Preop Test 1
OX1416.02 18 Month Cooling Tower Auto Actuation Test 00 j
Tech Spec Logs Ultimate Heat Sink Level Check NA OX1416.01 Monthly SW System Valve Verification 00 FP #53041-02 Johnson Vertical Pumps Technical Manual 1-PT-15.2 Service Water Pumps and Tower Actuation 0
OS1016.01 Service Water System Fill and Vent-SOP 01 OS1016.05 Service Water Cooling Tower Operation 01 E-301107 Electrical Schematics various l
Data Shacts Page 6
APPENDIX 2.5 INSPECTION REPORT DATA SHEET A. C.
SOURCES TECHNICAL SPECIFICATIONS:
3/4.8.1 A. C. Sources FSAR
REFERENCES:
-8.3.1, 9.5 NRC SER
REFERENCES:
8.3.1, 9.5 DOCUMENTS REVIEWED:
NUMBER TITLE REVISION OX1447.01 Inverter ED-I-2A Trip Circuit Test 00 OX1446.01 AC Power Source Operability Weekly Surveillance- 00 OX1446.03 Electrical Bus Operability (Operating) 00 i
OX1446.04 Electrical Bus Operability (Shut Down) 00 OX1446.02 18 Month Bus E5 and E6 Offsite Power Supply Transfer 00 MS0512.02 A.C. Voltage Indicating Loop, Meter 00 I
OX1426.01 D/G IA Operability Surveillance (Monthly) 00 OX1426.02 D/G IA 18 Month Operability Surveillance 00 OS1026.07 Aligning D/G IA Controls for Auto Start 01 MX0539.03 Diesel Generator Inspection, Testing and PM 00 i
l OX1426.04 D/G IA 24 Hour Load Test 00 OX1426.03 Emergency Power Sequencer Operability Test 00 F-301704 480 V UNT Sub Buses E64 1&2 One Line Diagram 9
l F-301705 CLG TWR Elec SWGR RM460V MCC E513 1&2 One 8
Line Diagram C-309825 345KV Switching Station Equipment Single Line 0
l i
F-310002 Unit Electrical Distr One Line Diagram 15 I
F-310004 13.8KV SWGR Bus 1-1 One Line Diagram 11 F-310005 13.8KV SWGR Bus 1-2 One Line Diagram 11 F-310007 4160V SWGR Bus 1-E5 One Line Diagram 12 j
4160V SWGR Bus 1-E6 One Line Diagram 12 l
F-310008 F-310009 4160V SWGR Bus 1-3 & 1-4 One Line Diagram 10 F-310010 Diesel Gen DG-1A & DG-1B One Line Diagram 6
l F-310023 460V MCC E511 (DG Bldg) One Line Diagram 9
(
F-310024 460V MCC E512 (CTL Bldg) One Line Diagram 14 l
F-310026 460V MCC E531 (CTL Bldg) One Line Diagram 14 F-310027 460V MCC E521 (CTL Bldg) One Line Diagram 11 i
Data Shsets j
Pago 7
l F-310043 120VAC NV Instrumt Busses One Line Diagram 6
F-310054 120VAC NV Instrumt Busses One Line Diagram 5
F-310091 RES Aux XFMR Diesel Gen Tripping Diagram 0
F-310431 Control Bldg Elev 21-6 Elect Gen Arrgt 27 l
Dntn Shsste Pcge 8
APPENDIX 2.6 INSPECTION REPORT DATA SHEET D. C. SOURCES TECHNICAL SPECIFICATIONS:
3/4.8.2 D. C. Sources FSAR
REFERENCES:
-8.3.2 NRC SER
REFERENCES:
8.3.2 DOCUMENTS REVIEWED:
NUMBER TITLE REVISION MX0506.02 Weekly Battery Survefilance 00 MX0506.10 18 Month Battery Surveillance 00 MX0506.04 Station Battery Service Test 00 MX0506.03 Quarterly Battery Surveillance 00 MX0506.06 Station Battery Charger Capacity Test 00 ON1048.04 Operation Of Battery Chargers 2A and 2B 00 OS1048.01 125 VDC Vital System Operation 01 OX1447.01 Inverter ED-I-2A Trip Circuit Test 00 MXO506.05 Station Battery Performance Discharge Test 00 F-310041 125V DC & 120VAC Instr Buses Key One Line 5
Diagram l
F-310042 125V DC Vital Distr Sys One Line Diagram 10
(
F-310059 125V DC Nonvital Distr Sys One Line Diagram 5
F-310024 460V MCC E512 (CTL Bldg) One Line Diagram SH-1 14 F-310027 460V MCC E521 (CTL Bldg) One Line Diagram 11 F-310030 460V MCC E612 (CTL Bldg) One Line Diagram SH-1 14 l
F-310033 460V MCC E621 (CTL Bldg) One Line Diagram 13 l
F-310043 120VAC Vital Instr Busses One Line Diagram 6
F-310431 Control Bldg Elev 21-6 Elect Gen Arrgt 27 i
{
1 i
k
Data Shssts Pcga 9
APPENDIX 2.7 INSPECTION REPORT DATA SHEET ONSITE POWER DISTRIBUTION TECHNICAL SPECIFICATIONS:
3/4.8.3 Onsite Power Distribution FSAR
REFERENCES:
- 8. 3 NRC SER
REFERENCES:
8.3 DOCUMENTS REVIEWED:
REVISION NUMBER TITLE OS1048.01 125 VDC Vital System Operation 01 OX1447.01 Inverter ED-I-2A Trip Circuit Test 00 OS1047.02 Transferring Power Supplies to 120V AC. Vital 01 Instrument Busses F-310051 480V UN Sub Bus E53 One Line Diagram 11 F-310052 480V UN Sub Bus E63 One Line Diagram 11 F-310054 120VAC NV Instrumt Busses One Line Diagram 5
F-310057 460V MCC E512 (Cont Bldg) One Line Diagram 11 Sheet 2 F-310058 460V MCC E612 (Cont Bldg) One Line Diagram 9
Sheet 2 F-310059 125 VDC Nonvital Distr Sys One Line Diagram 5
F-310066 460V MCC E515 (Ctl Bldg) One Line Diagram -
4
. Unit 1 F-310067 460V MCC E615 (Ctl Bldg) One Line Diagram -
4 Unit 1 27 F-310431 Control Bldg Elev 21-6 Elect Gen Arrgt M-310105 SH.E01a; UPS 1-I-1A Vital Instrument Distri- -
6 bution Panel 1-PP-1A Schedule M-310105 SH.E02a; UPS l-I-1B Vital Instrument Distri-6 bution Panel 1-PP-1B Schedule M-310105 SH.E03a; UPS 1-I-lc Vital Instrument Distri-6 bution Panel 1-PP-lC Schedule M-310105 SH.E04a; UPS 1-I-lD Vital Instrument Distri-5 bution Panel 1-PP-lD Schedule M-310105 SH.EH9a; UPS 1-I-lE Vital Instrument Distri-8 bution Panel 1-PP-lE Schedule i
DEta Shssto Pago 10 M-310105 SH.3H0a; UPS 1-I-lF Vital Instrument Distri-8 bution Panel 1-PP-lF Schedule F-301704 480V Unt Sub Busses E64 1 & 2 One Line Diagram 9
F-301705 Clg Twr Elec SWGR RM460V MCC E513 1 & 2 One Line Diagram 8
F-310002 Unit Electrical Distr One Line Diagram 15 F-310007 4160V SWGR Bus 1-E5 One Line Diagram 12 F-310008 4160V SWGR Bus 1-E6 One Line Diagram 12 F-310009 4160V SWGR Bus 1-3 & 1-4 One Line Diagram 10 F-310010 Diesel Gen DG-1A & DG-1B One Line Diagram 6
F-310011 480V UN Sub Bus 1-11 & 1-23 One Line Diagram 10 F-310012 480V UN Sub Bus 1-12 & 1-25 One Line Diagram 8
F-310013 480V UN Sub Bus E51 & E52 One Line Diagram 12 F-310014 480V UN Sub Bus E61 & E62 One Line Diagram 11 F-310015 480V UN Sub Bus 13 & 26 One Line Diagram 9
F-310023 460V MCC E511 (DG Bldg) One Line Diagram 9
F-310024 460V MCC E512 (CTL Bldg) One Line Diagram Sh-1 14 F-310026 460V MCC E531 (CTL Bldg) One Line Diagram 14 F-310027 460V MCC ES21 (CTL Bldg) One Line Diagram 11 F-310028 460V MCC ES22 & E622 One Line Diagram Cont 9
Bldg F-310029 460V MCC E611 (DG Bldg) One Line Diagram 9
F-310030 460V MCC E612 (CTL Bldg) One Line Diagram 14 F-310032 460V MCC E631 (CTL Bldg) One Line Diagram 13 F-310033 460V MCC E621 (CTL Bldg) One Line Diagram 13 F-310043 120VAC Vital Instr Busses One Line Diagram 6
F-310044 460V MCC 231 (CTL Bldg) One Line Diagram Sheet 1 11 F-310046 460V MCC E523 (Turb Bldg) One Line Diagram 8
F-310050 480V UN Sub Bus 14 & 21 One Line Diagram 9
l 1
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Data Shatte Prga 11 APPENDIX 2.8 INSPECTION REPORT DATA SHEET l
AND CONDENSATE STORAGE TANK TECHNICAL SPECIFICATIONS:
3/4.7.1.2 Emergency Feedwater System 3/4.7.1.3 Condensate Storage System FSAR
REFERENCES:
6.8, 9.2.6, 1o.4, 14.2-Table, 14.2-3 NRC SER
REFERENCES:
6.8 DOCUMENTS REVIEWED:
N_ UMBER TITLE REVISION FW-B20684 Feedwater System Overview PID 0
FW-B20688 Emergency Feedwater System Details PID 0
OX1436.02 Turb. Drives Emerg. FW Pump Monthly Op. Test Draft A CD-B20420 Condensate System Overview PID 0
CD-B20426 Condensate System Detail PID 0
E-O Reactor Trip or Safety Injection Draft FR-H.1 Response to Loss of Secondary Heat' Sink Draft ON1035.02 Startup Feed Pump Operation 1
l ECA 0.0 Loss of All A/C Power Draft ECA 2.1 Uncontrolled Depressurization of All S/G's Draft OS1036.01 Aligning the Emerg. Feedwater Sys. for Auto Draft FW-202026 Emergency Feedwater P & ID CLD HE CO-TK-25 cond. Storage Tank Capacity CWVE B
E-2 Cond. Storage Tank General Arrangement E
l E-5 Cond. Storage Tank Penetrations G-2 l-PT(I)-14.2 Emergency Feedwater Sys (HFT) 0 1-PT(I)-14.1 Emergency Feedwater Sys Preop Test 0
9763-M-310844 SHE 87/6r; F.W.
Isol Vlvs Development & Aux Contacts 5
9763-M-310844 SHE 87/6s; Feedwater Isol Vlvs Cable Schematic 4
9763-M-310844 SHE 87/61; Feedwater Isol Viv l-V30 Schematic 5
OS1236.02 Sys Abnormal Podc.-Response to EFW Sys Check Valve Leakage 0
l i
i
Data Shssts Pago 12 APP'ENDIX 2.9 INSPECTION REPORT DATA SHEET BORATION SYSTEM TECHNICAL SPECIFICATIONS:
3/4.1.2.5 Borated Water Source - Shutdown 3/4.1.2.6 Borated Water Source - Operating 3/4.1.2.7 Unborated Water Sources -Shutdown 3/4.1.2.2 Reactivity Control Sys Flowpaths - Operating FSAR
REFERENCES:
9.3.4 NRC SER
REFERENCES:
9.3.4, 7.6.1 DOCUMENTS REVIEWED:
NUMBER TITLE REVISION 1-PT-5.1 CVCS Charging Sys Operational Test 2
1-CS-B20720 CVCS Overview 0
1-CS-B20723 CVCS Purification Detail 0
1-CS-B20725 CVCS Charging Sys Detail 0
l-CS-B20727 CVCS Thermal Regeneration Detail 0
1-CS-B20728 CVCS Thermal Regeneration Detail 0
l-CS-B20729 CVCS Boric Acid Detail 0
l OS1008.01 CVCS Make Up Operations 0
i OX1408.01 18 Month Emergency Boration Test 0
OX1408.02 Boron Injection Flowpath Monthly Valve Align.
0 I
OX1408.04 Weekly Borated Water Source Evaluation 0
OX1408.05 BTRS Inoperability Surveillance 0
r-
-nw m
m Data Sheets Page 13 1
APPENDIX 2.10 INSPECTION REPORT DATA SHEET ESF INSTRUMENTATION TECHNICAL SPECIFICATIONS:
3/4.3.1 Reactor Trip System 3/4.3.2 ESF Actuation System DOCUMENTS REVIEWED:
NUMBER TITLE REVISION IX1662.321 P-445 PZR Press Prot. Ch I Test 0
IX1662.315 P-403 Loop 4 H/L Press. Prot. Channel IV 0 (Draft)
IX1662.313
.P-457 PZR Press Prot. Ch III Calib.
2 IX1662.151 F-414 RC Loop Flow Channel I Test 1
IX1640.220 L-552 5/6 "R" N.R. Level Channel II 1
C-509048 Safeguard Actuation Signal Westinghouse Funct. Diagrams 8
C-509042 Reactor Trip Signals Westinghouse Functional Diagrams 6
IX1668.331 P-937 Containment Pressure (Protection Channel I) Calibration 00 IX1668.341 P-937 Containment Pressure (Channel I)
Operational Test 00 M-503258 CBS-ECCS/SPR. Recirc. Signal Generation 7
M-503261 CBS-Safety Injection Monitor Lights 4
IX1668.331 Containment Pressure (Protection Channel I)
Calibration 00 d
i
Data Sheets Piga 14 APPENDIX 2.11 INSPECTION REPORT DATA SHEET EMERGENCY CORE COOLING SYSTEM TECHNICAL SPECIFICATIONS:
3/4.5.2 ECCS Subsystems - Tavg>350 F 3/4.5.3 ECCS Subsystems - Tavg<350 F 3/4.5.4 Refueling Water Storage Tank FSAR
REFERENCES:
6.3.1, 6.3.2, 6.3.3, 5.4.7, 14.2-3, Sheet 9 NRC SER
REFERENCES:
1 5.4.7, 6.3 DOCUMENTS REVIEWED:
NUMBER TITLE REVISION OX1456.02 Monthly ECCS Valve Verification 0
OX1406.12 18 Month Cont. Spray Recirc Sump Serv.
Draft OX1413.02 RHR Sys Interlock Checks Draft C 1-RH-B20660 RHR Sys Overview 2
2 1-RH-B20662 RHR Sys Train A 1-RE-B20663 RHR Sys Train B Cross-Tie 2
1-SI-B20446 SI Sys Intermediate Head Injection 2
1-SI-B20447 SI Sys High Head Injection 1
l-SI-B20448 SI Sys Low Head Injection Sh. 1 1
1-SI-B20449 SI Sys Low Head Injection Sh. 2 1
1-SI-B02450 SI Sys Low Head Injection Accumulators 1
0 i
OX1405.07 Qtrly SI Pump Flow Test 9763-M-503258 ECCS/ Spray Recirc Logic 7
OS1005.05 Safety Injection System Operation 0
OS1013.06 RHR Train B Shutdown 0
OS1002.02 Operation of Letdown, Charging and Seal Inj.
O l-PT(I)-9 ECCS Hot Functional Test 2
l l-PT(I)-38 ESF Integrated Actuation Test 2
9763-M-310890 SH-B49AB, SI Pump to C/L Isol V-ll4 5
l Schematic Diagram 9763-M-310890 SH-EH9/lla; A Train VLV Pos. Ind. Lt's 2
IX1662.321 P-445 PZR Pressure Prot. Ch I Test 0
IX1662.315 P-403 Loop 4 H/L Press. Prot. Channel IV O
4.3.5-30F CBS System Setpoint Calculations 5
OS1202.01 Sys. Abnormal - Loss of Letdown 0
Data Shaats PKga 15 OS1202.02 Sys. Abnormal - Loss of Charging 0
OS1202.04 Sys. Abnormal - Rapid Boration 0
OS1213.01 Sys. Abnormal - Loss of RHR During Shutdown Cooling 0
IX1662.313 P-457 PZR Press Prot Ch III Calib.
2 IX1662.151 F-414 RC Loop Flow Channel I Test 1
IX1640.220 L-552 5/6 "R" N.R.
Level Channel II 1
l l
l
i ENCLOSURE 2 UNRESOLVED ITEMS INSPECTION REPORT NO. 50-443/86-27 The following unresolved items, for which written response to address the specific issues has been requested of the licensee, were developed from a review of Inspec-tion Report No. 50-443/86-27, " Review of Seabrook Station, Unit 1, Technical Speci-fications," prepared under contract by Parameter, Inc.
1.
(86-27-01) Clarify the following two discrepancies:
a.
FSAR design normal containment pressure of 12.1-14.7 psia differs from the TS containment pressure normal operating band of 14.6-16 psia (Report Section 2.2.3, Item 3).
b.
FSAR containment spray maximum overall system response times either with or without loss of offsite power are substantially different (longer) than TS overall system response times (Report Section 2.3.3, Item 1).
2.
(86-27-02) Address the generic concern that the licensee does not appear to have a method for identifying or permanently assuring that commitments to the NRC remain in effect and are not inadvertently deleted or modified (Report Section 2.5.3, Item 2).
3.
(86-27-03) Discuss the impact of construction site power lines and poles and security light poles in proximity to the SF-6 (offsite power) bus runs with
(
respect to GDC17 (Report Section 2.5.3, Item 5).
4.
(86-27-04) State the current licensee position on the following two items:
a.
Impact of alternate suction piping from the bottom of the condensate storage tank to the startup feed pump and failure thereof (Report Section 2.8.3, Item 6).
b.
Need for TS limits or administrative controls on condensate storage tank minimum temperature requirements (Report Section 2.8.3, Item 7).
5.
(86-27-05) Describe corrective action regarding the emergency boration lines which appeared to exit a heat-controlled environment without heat tracing (Report Section 2.9.3, Item 3).
6.
(86-27-06) State the licensee position with regard to the tolerances estab-lished by the Instrument Department calibration procedures which appear to conflict with the finite limits provided by the TS LCO's and surveillance requirements (Report Section 2.10.3, Item 1).