IR 05000346/1987008

Insp Rept 50-346/87-08 on 870401-0531.Violations Noted: Licensed Operators Working in Excess of Tech Spec Requirements & Failure to Follow Procedures

ML20234C694
Person / Time
Site:	Davis Besse
Issue date:	06/24/1987
From:	Defayette R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20234C685	List: IR 05000346/1987008 ML20234C681 ML20234C686
References
50-346-87-08, 50-346-87-8, NUDOCS 8707060618
Download: ML20234C694 (27)

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U.S. NUCLEAR REGULATORY COMMISSION I

REGION III-

- Report No. 50-346/87008(DRP)

Docket No. 50-346 Operating License No. NPF-3 Licensee: Toledo Edison Company-Edison Plaza, 300 Madison Avenue  ;

Toledo,.0H 43652 Facility Name: Davis-Besse 1 Inspection At: Oak Harbor, Ohio In'spection Conducted: April 1 through May 31, 1987 Inspectors: P. M. Byron D. C. Kosloff K. Sullivan, Technical Specialist, Brookhaven Nat'l Laboratory R. Lofaro, Technical Specialist, Brookhaven Nat'l Laboratory Approved By: R De t f Reactor Projects-Section 2B 6 k '

Ddp-Inspection Summary Inspection on April 1 through May 31,-1987 (Report No. 50-346/87008(DRP))'

hreas Inspected: Routine, unannounced inspection by resident inspectors I of licensee action on previous inspection findings, operational safety, )

independent measurement of RCS leak rates, maintenance, surveillance, Licensee Event Reports', quality assurance, . followup of Regional reques Results: Of the eight areas inspected, no violations or deviations were identified in six area Four violations were identified in the areas of operational safety (licensed operators working in excess of TS requirements (Paragraph 3.c) and failure to follow procedures (Paragraph 3.d); and maintenance (housekeeping (Paragraph 5.a) and uncontrolled work (Paragraph 5.b)).

B707060618 ADOCK O 87 g h PDR PDR Q

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DETAILS 1. Persons Contacted D. Shelton, Vice President, Nuclear D. Amerine, Assistant Vice President, Nuclear S. Piccolo, Acting Performance Engineering Manager D. Wilczynski, Manager, Configuration Management  !

+*L. Storz, Plant Manager  !

+*S. Smith, Assistant Plant Manager, Maintenance S. Jain, Nuclear Engineering Director

+* Flood, Assistant Plant Manager, Operations E. Salowitz, General Superintendent, Outage and Program Management

• L. Ramsett, Quality Assurance Director l Grime, Industrial Security Director

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+ + Beyer, Nuclear Projects Director

• Stewart, Nuclear Training Director M. Schefers, Information Management Director T. Myers, Nuclear Licensing Director J. Scott-Wasilk, Nuclear Health & Safety Director P. Hildebrandt, Engineering General Director

+J. Wood, Systems Engineering Director

+*G. Honman, Compliance Supervisor B. Carrick, Design Engineering Director

• D. Haiman, Nuclear Engineering General Manager

+*J. Dillich, Technical Support, Engineering J. Miller, Technical Support, Engineering D. Stephenson, Senior Licensing Specialist

• L. Young, Licensing, Fire Protection J. Haverly, Fire Protection

+J. Moyers, Quality Verification Manager

• Briden, Chemistry and Health Physics General Superintendent S. Zunk, Ombudsman D. Harris, Manager Quality Systems

+*J. Sturdavant, Licensing Principal W. Rowles, Assistant to Senior Vice President, Nuclear K. Updike, Metrology Laboratory Manager

+G. Skeel, Nuclear Security Operations Manager

+L. Wade, Quality Control Supervisor USNRC

+ Byron, Senior Resident Inspector

+*D. Kosloff, Resident Inspector

• Denotes those personnel attending the May 5, 1987, exit meetin i

+ Denotes those personnel attending the June 4, 1987, exit meetin i

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2. Licensee Action on Previous Inspection Findings (92701) (Closed) Open Item (346/81023-01): Replace solenoid on the demineralized water containment isolation valve with a solenoid j with a bigger discharge orifice. The replacement was controlled 1 by Facility Change Request (FCR) 81-01 The inspectors reviewed .]

FCR 81-013 and Maintenance Work Orders (MW0) 2-81-0013 and 2-81-0013-02. This item is close (Closed) Open Item (346/84006-01): Replace governors on the Auxiliary Feedwater (AFW) Pump Turbines. FCR 83-136 required that the Woodward PG-PL governors on the AFW pump turbines be replaced with new Woodward PGG governor FCR 83-136 and MW0's 2-83-0136-28 and 2-83-0136-29 were reviewed by the inspector The inspectors observed the governors installed on the turbines and verified that

.the new governors operated properl The inspectors also observed a maintenance training class presented by a representative of the governor manufacturer. This item is close (Closed) Open Item (346/84018-02): . Validate the Electrical Distribution Manual. The licensee issued the Electrical Distribution Manual, Drawing No. 12501-E-1040A, as a controlled document in response to a previous open item. The technical content of the manual had not been validated and errors were found. The licensee was to develop a procedure to validate the manual. A validation procedure was developed and is documented in Memorandum AN86-0035,

" Change to LER 82-28 Re: SWS Design," dated 01/16/86. The electrical distribution manual was reviewed to verify that it has been update The drawing was found to be current with the most recent update being Revision 22 dated 04/02/87. This item is close (Closed) Violation (346/85001-02A): The licensee was using uncontrolled technical manuals in lieu of approved procedures for calibration of instrumentation required to verify compliance with the technical specification Two specific examples cited include calibration of level transmitter LT-CF3B2 and flow transmitter FT-4522. Corrective action included a review of safety-related systems to ensure all applicable instruments are calibrated using approved procedure Memorandum DSM-87-25095, "LCTS ID #900," dated 03/09/87 documents the review performed by the licensee to verify that all applicable instruments are calibrated using approved procedures. In addition, the procedures for calibration of LT-CF3B2 (IC 2701.89.00, " String Check at 51-ISLCF3B2 Core Flooding Tank 1 Level,") and FT 4522 (ST 5071.06.01, "AFW Controlotron Flowmeter Calibration,") were reviewed. These procedures were found to be properly approved and available for use. This item is close l l

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. (Closed) Violation (346/85001-028): The licensee had not established approved calibration procedures for the calibration of measuring and test equipment (M and TE). . The licensee committed to establish a new calibration lab and to develop procedures for calibrating M and T i The inspectors interviewed the Metrology Lab' oratory Manager and toured.the.new metrology' laboratory. The lab was operational and well staffed. The inspectors examined files which contained approved procedures for calibration of M and TE items. The inspectors reviewed Procedure LM-1003.00, " Calibration of Torque Multipliers," in detail to verify proper approvals and conten In addition, Procedures LM-0001.01, " Measuring and Test Equipment ,

Calibration," and LM-0002.01 " Measuring and Test Equipment Control l and Storage," which control operation of-the metrology laboratory i were reviewe This item is close f. (Closed) Open Item (346/85004-08): Change Technical Specification  ;

(TS) for the 1E station batterie The licensee initiated FCR 82-29 to change the TS to conform with the NRC Standardized Technical Specifications (STS). The inspectors verified that Amendment No. 100 to the TS revised the surveillance requirements of the D.C. distribution system including the batteries and battery chargers. This item is close g. (Closed) Open Item (346/85004-10): Management involvement in the utilities training program was found to be weak. To correct this the licensee formed a management level training oversight and review committee chaired by the Nuclear Services Director. Later inspection showed this committee rarely met and had no record of meeting action Following a reorganization, the committee was disbanded and a new Training Review Board was formed. The licensee committed to review the new Training Review Board and determine if it provided the proper management level for oversight of the training progra The inspectors reviewed Memorandum M85-41, " Response to LCTS No. 888,"

dated 06/03/85, which documented the licensee's Training Review Board organization review. The Board has members at the proper management level to effectively oversee the training program. The inspectors reviewed the licensee's organization chart to verify that the proper management levels are represented on the Training Review Board. .The review board is chaired by the Plant Manager who reports directly to the Vice President, Nuclear. Based on these findings, this item is close h. (Closed) Open Item (346/85009-02): Revise physics testing procedure to identify acceptable initial rod positio The inspectors reviewed l Procedure ST 5010.03.07, "Zero Power Physics Testing." The procedure was revised to identify the required initial rod position for performance of the ejected rod worth measuremen This item is close _ - - - . _ _ _ _ - . _ - - - - - . . . _ _

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i. (Closed) Open Item (346/85022-02): Revise Procedure MP 1410.72

"(MSIV) Maintenance" to specify all critical dimensions which are to be set or recorded during maintenance. The licensee-issued Temporary Modification Request (T-MOD) No. T-10332 to MP 1410.72 which added the required dimensions. Major modification request No, M-9194 was issued to incorporate the T-Mod into the next revision to MP 1410.72. This item is close j. (Closed) Open Item (346/85025-02): Implement a procedure to control a qualification card for the shift supervisors' administrative assistant The inspectors reviewed Procedure AD 1828.23 " Shift Supervisors Administrative Assistant Training." AD 1828.23 includes a requirement a qualification card and this has been implemented by the licensee. This item is closed, k. (Closed) Open Item (346/85025-10): Issue a maintenance procedure for Emergency Diesel Generator (EDG) governor installation and adjustmen The inspectors reviewed Procedure MP 1700.84 "EDG Governor Removal, Installation and Adjustment" and consider it meets the requirements of the Open Item. This item is close . (Closed) Open Item (346/85025-11): Preventative Maintenance (PM)

on a tachometer was scheduled then cancelled, however, the next calibration due date was inadvertently advanced as if the maintenance had been performe This indicated a generic problem for all PM scheduling. The licensee committed to revise the PM scheduling system to include a PM specialist who will monitor and implement the PM progra The inspectors reviewed Memorandum PS-86-187, "LCTS ID No. 1837 -

Due February 16, 1986," 02/10/86 which documents the establishment of the revised PM program. The inspectors interviewed the PM Program '

Manager, who explained that all PM work orders are now routed through the PM specialist who confirms the work was completed then adjusts the PM schedule accordingly. The inspectors consider that the licensee's corrective action is adequat This item is close m. (Closed) Open Item (346/85025-13): A local leak rate test determined that containment block Valve SA 2010 was leaking excessively. The licensee committed to determining what type of change was required to assure extended operability of the valv It was determined that the valve seats should be replaced with a soft trim design. The inspectors reviewed Facility Change Request FCR 85-0314, and Maintenance Work Order 2-85-0314-01 and as-built Drawing V5026-30 to verify the work was performed. The inspectors reviewed Procedure ST 5064.01, which has been completed 10/27/86, to verify that the valve had been leak checked satisfactorily after the modification had been made. This item is close ..

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n. .(Closed) Open Item (346/85025-14): Containment purge and exhaust valves with resilient seals are subject to gross leakage failure The failure can result from deterioration over a period of time or it may occur suddenly following normal valve operation. The licensee committed to revise the technical specification requirements for leak testing these valves'after every us The inspectors reviewed Appendix A of.the technical specification to verify that the new requirements for leak checking the valves after every use are incorp' orated. The inspectors also reviewed Procedures AD 1838.02.15 Performance of Surveillance and Periodic Tests," SP- 1104.21.11 " Containment Purge System Procedure," and ST 5061.02.09 " Containment Vessel Local Leak Rate Test," to verify that proper procedures were in place to coordinate and perform the leak checks. A typographical error was found on Page 4 of Enclosure 22 of ST 5061.02.09. The maximum acceptable leak rate for penetration 34 should be 150,000 SCCM instead of 15,000 SCC The error makes the procedure more conservative. The. inspectors notified the licensee of this error and it will revise the procedur This item is close (Closed) Open Item (346/85025-16): Failures of Safety Features Actuation System (SFAS) radiation monitors. It was believed that grounding of the units to'rebar within the concrete walls to which they were attached was the cause. To correct this, the licensee committed to installing insulated mounts on all monitor Facility Change Request FCR-85-0042, which specified the work to be i done, and Maintenance Work Orders 2-85-0042-01 through -05 indicate i the work has been completed as of 02/18/86. The inspectors reviewed the changes with the cognizant Systems Engineer who stated that in addition to the insulated mounts, shock mounts were also installed on the monitor circuit boards. In spite of these modifications, however, the spurious signal and failure problems still occur, although less frequently. The licensee is analyzing the failures that have occurred since the modification has been completed. The development of additional corrective action based on the results of the analysis is an Open Item (346/87008-01(DRP)). This item is close (Closed) Violation (346/85025-18): During testing of the auxiliary feedwater pumps the No. 1 steam generator (SG) was inadvertently pressurized. Tne cause was improper closure of a block valve due to human error. Corrective actions included a review of all applicable procedures which control activities that have a potential of

.overpressurizing the SG to ensure a vent path is provided and training for personnel on proper valve positionin Memorandum (DA 86-1239), "LCTS 1912," documents the results of the review performed to identity procedures which required modification Four Operating Procedures, SP 1106.06.25, " Auxiliary Feedwater l

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System," SP 1106.20.14, " Main Feed Pump and Turbine", SP 1106.28.02,

"MDFP Operating Procedure," and SP 1106.07.09, " Main Feedwater

' System," were reviewed to. verify the proper changes were made. In addition, Maintenance Procedure MP 1401.31.03, " Auxiliary Feedwater System ASME Section XI Inservice Hydrostatic Test," and thirteen Test Procedures were also reviewed for proper change Memoranda BQT-0NL-203-01, " Training Plan for Limitorque Operation,"

and MA 86-0059, " Verification of Training" were reviewed to verify that the proposed training had been performed. This item is closed, (Closed) Open Item (346/85025-20): Implement a program for handling of " static sensitive" equipmen The inspectors reviewed Procedure IC 2701.64.00, " Guidelines.for Handling of Static-Sensitive Components," to verify that proper

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instruction is provided for handling static sensitive equipmen The inspectors determined that IC 2701.64.00 is included in work packages requiring handling of such items. The inspectors interviewed a nuclear maintenance training instructor, who explained the training process now in place which uses a film demonstrating proper handling of static' sensitive items. All personnel who might handle static sensitive items have.taken or will be required to take this trainin Portable work station equipment is currently available. This item is close (Closed) Open Item (346/85025-21): During maintenance on a safety-related pump, vibration measurements were taken using a procedure which was not approved for use on Nuclear Safety-Related Equipment. The licensee committed to have the procedure properly approve The inspectors reviewed Procedure MC 7005.01.02, " Vibration Monitoring," to verify that it had been approved for use on safety-related equipment. This item is close ; (0 pen) Open Item (346/85025-24): It was found that licensing and training department procedure approvals and designations did not correspond to changes made during a reorganization of department The licensee committed to reestablishing proper procedure approvals and designations. A followup inspection (Inspection Report No. 50-346/86005) indicated that licensing procedures were-incorporated into a proper divisional manual, however, training 4 department procedures had no Additionally, the NQAM manual I had not been updated to reflect these new divisional manual Procedure NG-AV-115, " Preparation and Control of Nuclear Group Division and Department Procedures," 10/31/86, was reviewed to verify that the proper procedural approvals are specifie Sample procedures were also compared with the licensee's utility organizational chart to verify proper approvals. The reviewed procedures include Training Division Procedure NT-DP-0002,

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" Development, Review, Approval and Control of Nuclear Training Division Procedures," 10/24/86, Licensing Procedure NSL-LIC-001,

"USAR Annual Update," 01/31/87 and Maintenance Procedure MP 1401.15.01, "Yarway Steam Trap Maintenance." In addition, the training division procedures manual NTDP-INDEX, " Nuclear Training Division Procedures Manual," Rev. 4, 10/24/86, was reviewed to verify that all training procedures had been coordinated into a division level manual. The NQAM was also reviewed, however, no reference was found to the licensing or training procedures manual Memorandum HA86-0418, "LCTS Item #2150 Incorporation of Division Procedures in the NQAM," states that Revision 12 of the NQAM addresses the usage of these manuals, however, this could not be verifie This item will remain open until it can be verified that the NQAM has been updated to address the usage of the licensing and training division procedures manuals, t. (Closed) Violation (346/85030-IIA 3): A wiring check on Valve MS 106 revealed that a 15 amp fuse was used as a replacement for a 10 am fuse. This indicated a deficiency in the procedures used for valve maintenance. The licensee upgraded the procedures used to ensure that the proper design drawings were used to obtain replacement part informatio The inspectors reviewed Procedure MP 1410.63, " Electrical Maintenance Guidelines" to verify the proper changes had been made. The procedure was found to have a temporary modification request attached to it with the proper change. The inspectors interviewed the PM Program Manager, who explained that upgraded program included increased training and numerous verifications to mitigate future problem The current maintenance program appears adequate to prevent similar errors. This item is closed, u. (Closed) Open Item (346/85037-03): Establish a shop and staff training program under an administrative procedure. The inspectors reviewed Procedure AD 1844.16, " Training and Qualification of Maintenance Personnel," which meets this requirement. This item is close i v. (Cicsed) Open Item (346/85037-04): Deficiencies in the commitment tracking program for maintenance. The deficiencies include inadequate position description for tracking clerk and the fact that the tracking clerk only works three days a wee The licensee has given the responsibility of the commitment tracking program for the Maintenance Department to the station corrective  ;

action coordinator who is a full time employee of the Technical '

Support Department. The inspectors also reviewed the position description for the station corrective action coordinator and found it to be complet This item is close l

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. (Closed) Open Item (346/85037-05): Determine md ntenance staff'

training needs. The licensee submitted maintenance training programs to the Institute of Nuclear Power Operations (INPO)

for accreditation. By letter dated December 11, 1986, from :

Z. T. Pate (INPO) to P. M. Smart (TED) the licensee was-informed o .

z the National Nuclear Accrediting Board's accreditation of training l programs for nonlicensed operator, reactor operator, senior reactor l operator / shift supervisor, instrument and control technician, electrical maintenance personnel and mechanical maintenance personnel. This item is close (Closed) Violation (346/86005-02): Inadequate update of the Safety Analysis Report (SAR). (A) The July 1984 annual review of the FSAR was found not to reflect modifications to the pressurizer code safety relief valves which were completed on July 30, 1982. (B) In February 1986 following the July 1985 annual submittal the FSAR was found not to reflect modifications to the-service water. pump rooms-ventilation system completed on September 22, 1984. The inspectors review of the modified updated safety analysis report determined the i modifications listed above to be fully implemented. The. licensee

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has established nuclear group procedures for the Plant Modification Process NG-NE-301 and the updated safety analysis report (USAR)

Revision Process NG-NL-80 The inspectors review of these procedures verified that a more appropriate method has been established for identifying when plant modifications should be incorporated into the data base for the next annual USAR revision. This item is close (Closed) Open Item (346/86007-01): Add an Alert Emergency Action Level (EAL) for loss of all onsite and all offsite AC electrical power that lasts less than fifteen minutes. The inspectors reviewed revised Emergency Plan Implementing Procedure HS-EP-1500 " Emergency Classification." This procedure identifies an alert emergency classification during the condition of a loss of offsite power and all onsite AC power which lasts less than 15 minutes. This item is close (Closed) Open Item (346/86007-02): Evaluate the rationale for including a 15 minute duration in the Site Area Emergency EAL for loss of all annunciators and the station compute The inspectors !

reviewed Procedure HS-EP-1500 Rev. 1. This procedure now requires l a Site Area Emergency EAL if all annunciator alarms and station computer were lost during a plant transient regardless of time duration. This item is close a (Closed) Open Item (346/86007-03): The licensee must reevaluate the i Alert EAL for fires potentially affecting safety systems regardless if offsite fire fighting assistance was requested or required. The licensee revised HS-EP-1500 " Emergency Classification" which was reviewed by the inspectors. The procedure now requires that any fire at the station which has the potential to damage or degrade a safety system will be classified as an Alert. This item is close !

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t bb. (Closed) Open Item (346/86007-04): The EAL for " Hazards to Station Operations" did not include an unusual event EAL for the condition of a turbine rotating component failure causing a rapid plant shutdow The inspectors reviewed' Procedure HS-EP-1500 " Emergency Classification." The table of emergency. action level conditions titled " Hazards to Station Operations" was found to identify an unusual event classification for the condition of turbine rotating component failure causing rapid' plant shutdown. This item'is close cc. (Closed) Open Item (346/86007-05): Revise the earthquake Emergency Action Level (EAL) for the unusual event classification to include provisions for classification if the station's seismic monitoring equipment is partially or totally out of service or out of calibration. The inspectors reviewed procedure " Emergency Classification." The table of Emergency Action Level Conditions

" Natural Events" identifies an unusual event classification for the condition of any earthquake felt in plant or detected by station seismic instrumentation. This item is close dd. (Closed) Open Item (346/86012-06): Conflicting requirements for returning equipment to service following modifications. The Nuclear Quality Assurance Manual (NQAM) required that plant manager's review -

by complete before equipment could be returned to service which Procedure AD 1801.00 " Station Modification Acceptance Test Program,"

states that the shift supervisor can declare a system operational prior to plant manager's approval. The inspectors reviewed the revised Nuclear Quality Assurance Manual and determined that the conflict had been eliminated. This item is close ee. (Closed) Open Item (346/86026-02): Verify that all Steam Generator Owners' Group (SG0G) guidelines and action levels have been incorporated into procedures. The inspectors reviewed Procedure PP 1101.04.28 " Operational Chemical Control Limits" and found that the procedure implemented SG0G guidelines and action levels. The inspectors reviewed Nuclear Mission Policy and Organization Manual Volume 1 " Chemistry Control" and Volume 4

" Chemistry and Health' Physics Section Major Responsibility Areas" and determined that they included appropriate statements regarding water chemistry control including organizational responsibilities and guidance on monitoring, data management, trending and trainin This item is closed, ff. (Closed) Open Item (346/86026-04): Establish a formal plant procedure to describe the QA/QC program for the chemistry /

radiochemistry laborator The inspectors reviewed Procedures AD 1842.02.01, " Chemistry Quality i Control Program," and AD 1842.05.00, " Radiochemistry Quality Control Program," to verify that an appropriate QA/QC program had been

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established. These procedures include requirements for a blind sample interlaboratory cross check program and instructions for

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preparing control charts to verify accuracy of instruments and analytical methods. The inspectors interviewed a Chemistry Specialist and a Lab Foreman. They toured the laboratory and examined various control charts to verify that the QA/QC program was functioning as described in the procedures. This item is close g (Closed) Open Item (346/86026-05): Prepare control charts to observe trends in chemistry analyses and instrument calibration The inspectors reviewed Procedure AD 1842.02.01, " Chemistry Quality Control Program," to verify that control charts are required to be prepared as part of the QA/QC progra The inspectors also examined control charts being used in the chemistry laboratory. This item is close h (Closed) Open Item (346/86026-07): Evaluate the response of Thermoluminescent Dosimeters (TLDs) to the 81 Kev energy line of Xe-133 and the attenuation effects of closed plastic bottles and housing materials. The licensee has replaced the plastic bottles with perforated plastic cages. The inspectors verified the installation of the perforated plastic cages and found them ;

to be the same type used by the NRC. This item is close ~

l i (Closed) Unresolved Item (346/87004-11): Quality Assurance Audits not performed to requirements but to implementation documents. The licensee reviewed completed audits and determined that its previous finding had been in error. The inspectors randomly selected fifteen audits which had been performed after September 1986. The inspectors noted that two of the fifteen were based on the requirements. The others used the requirements in the checklist, but were not the basis of the audit. The licensee repeated its commitment to perform more audits based on the requirements. This item is close . Operational Safety Verification (71707)

The inspectors observed Control Room operations, reviewed applicable logs and conducted discussions with control room operators during the months of April and May. The inspectors verified the operability of selected emergency systems, reviewed tagaut records and verified proper return to service of affected component Tours of the reactor, auxiliary, turbine, water treatment and service water buildings were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks, and excessive vibrations and to verify that maintenance requests had been initiated for equipment in need of maintenance. The inspectors by observation and direct interview verified that the physical security plan was being implemented in accordance with the station security pla The inspectors observed plant housekeeping and cleanliness conditions i and verified implementation of radiation protection control During the months of April and May, the inspectors walked down the accessible portions of the Service Water and Auxiliary Feedwater (AFW) system <

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These reviews and observations were conducted to verify that facility operations were in conformance with the requirements established under technical specifications, 10 CFR, and administrative procedures, During the walkdown of the AFW system, the inspectors found what ,

appeared to be heat damage on an electrical flex conduit (Sealtite) i associated with the motor operator for MS 107, a containment isolation valve for the main steam supply to the AFW pump turbine Due to modifications to the AFW steam supply lines, the uninsulated parts of the valve now remain at higher temperatures during plant operation. The wiring in the Sealtites near the valve may now be exposed to more heat than was experienced before the modification The licensee will investigate this situation to determine whether the long term heat load on the wires inside the Sealtites is excessiv This item is an Unresolved Item (346/87008-02(DRP))

until the inspectors can review the licensee's evaluation of the conditio During the walkdown of the AFW system, the inspectors also observed a fire barrier penetration for a steam supply line for the AFW pump turbines. The penetration was sealed with low density Bisco foam which becomes brittle and turns to powder when exposed to temperatures above 425 degrees F for some undetermined period of time. Due to modifications to the AFW steam supply lines, the steam line now remains above 425 degrees F during plant operation. No signs of deterioration were noted by the inspectors. The penetration seal ,

had been inspected by the licensee but, since no heat damage was !

apparent, the only deficiency written against the seal was for physical damage (a gouge). The licensee's seal inspection program requires that any damaged seal be subject to a complete engineering evaluation. There are over 6000 seals in the pi ct and the licensee is still conducting its inspectio At the time of ti.: inspectors'

discovery the licensee had not yet evaluated the identified seal due to a backlog of unevaluated seal deficiency reports. This will remain an Open Item (346/87008-03(DRP)) pending the inspectors review of the licensee's evaluatio At approximately 2:45 a.m. on May 24, 1987, a security officer observed a shift supervisor who was apparently sleeping. The event was obs9rved by two other security officers and four operations j personnel. The security officers called their supervisor who ]

arrived at the control room about 3:10 a.m. and observed that I the shift , supervisor was awake and fully aler I At the time of the observed inattentiveness, the shift supervisor was reading a procedure in his office which is located outside of the Control Roo The plant was in cold shutdown (Mode 5). The licensee immediately initiated an investigation and Region III dispatched an independent inspection tea i l

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Details of the event'and subsequent inspection are described in Inspection Report No. 50-346/87015. The inspectors consider that some of the solutions to operator inattentiveness should be addressed by human factor consideration c. Technical Specification (TS) 6.2.3 requires that administrative procedures be developed and implemented to limit the working hours of facility staff who perform safety-related function Senior reactor operators (SRO's) are included in the TS as an example of facility staff who perform safety-related functions. The licensee's shift supervisors.and assistant shift supervisors are licensed SR0's. The TS requires that adequate shift coverage be maintained without routine heavy use of overtime. The TS also requires that, if overtime is required on a temporary basis due to unforeseen problems, four guidelines shall be used. One of the guidelines is that an individual should not be permitted to work more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any seven-day period, excluding shift turnover tim The TS requires that any deviation from the guideline be authorized by the Plant Manager, his designee, or higher levels of management, in accordance with established procedures and with documentation of the basis for granting the deviatio The inspectors reviewed the unit log for the period from March'26 through April 22, 1987, and found that one SR0 had been on duty as shift supervisor for 76 hours8.796296e-4 days <br />0.0211 hours <br />1.256614e-4 weeks <br />2.8918e-5 months <br /> during the seven-day period from Sunday, April 5 through Saturday, April 11, 1987. The inspectors also found that the SR0 had been on duty as a shift supervisor for 70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br /> from March 26 through April 1, 1987. The SR0 had been on duty as shift supervisor a total of 178 hours0.00206 days <br />0.0494 hours <br />2.943122e-4 weeks <br />6.7729e-5 months <br /> during the 20-day period from March 26 through April 14, 1987. The inspectors then reviewed the working hour schedules for all the SR0's on duty as Shift Supervisors and Assistant Shift Supervisors for the period that the plant was operating from March 26 through May 8, 1987. The inspectnrs found that during this period the SR0 discussed above was also scheduled to work 68 hours7.87037e-4 days <br />0.0189 hours <br />1.124339e-4 weeks <br />2.5874e-5 months <br /> in a seven-day period, another shift supervisor was scheduled to work 80 and 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br /> in two seven-day periods, and five other shift supervisors and assistant shift supervisors were scheduled to work between 64 and 76 hours8.796296e-4 days <br />0.0211 hours <br />1.256614e-4 weeks <br />2.8918e-5 months <br /> in six different seven-day period Use of overtime due to unforeseen circumstances is allowed by the TS while the plant is operating at power (Mode 1). However the licensee's use of overtime was not due to unforeseen circumstances as defined in Generic Letter No. 82-12. A letter dated July 31, 1980, from D. G. Eisenhut to all power reactor licensee's and ;

applicants, referenced by Generic Letter No. 82-12, states that 1 overtime shall not be routinely scheduled to compensate for an inadequate number of personnel to meet shift crew staffing requirements. Further guidance given to the NRC staff on the use of overtime was given in an October 28, 1983, internal memorandum from D. G. Eisenhut (NRR) to C. E. Norelius (Region III), CLARIFICATION OF THE TERM " DEPUTY PLANT MANAGER" .AS USED IN GENERIC LETTER 82-1 The memo stated that "The goal of the NRC is that each plant be l

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.- j staffed with sufficient numbers of personnel so that there should be no need for a licensee to resort to more or less routine use of overtim That is, there should be adequate numbers of properly trained personnel to handle normal work requirements, including training, while working normal eight-hour days and 40-hour weeks.

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Regardless of the normal staffing levels, however, situations may arise where overtime must be used to assure adequate shift coverag For axample, an operator may fail to report for his assigned shift, !

necessitating that an' operator from the previous shif t be held over to provide coverage. Similarly, maintenance work on a safety system or component may be in progress at the end of a normal shift and the i licensee may deem it preferable to complete the effort by using the same workers on overtime rather than to change crews for the remainder of the-job. These types of situations are provided for in the overtime guidance . . . .

The licensee's inadequate control of the work schedules for the shift supervisors and assistant shift supervisors is a violation (346/87008-04(DRP)) of TS 6. Although the licensee had not identified the use of overtime as a violation of NRC requirements, it had initiated adequate corrective action before it was informed of the violatio As a result of the licensee's investigation ,

(discussed above) of the sleeping SRO, the licensee has initiated a five-section, eight-hour shift rotation for operations personne This action was a commitment listed in the licensee's letter, Serial No. 1-732, of May 29, 1987, from the Vice President - Nuclear to the Region III Regional Administrator. Subsequent to the inspection period the inspectors verified that the five-section, eight-hour-shift rotation had been initiated. The root cause of the violation was the licensee's lack of understanding of the overtime T Although Generic Letter 82-12 provides some clarification of the TS, the licensee may have received a verbal opinion from an NRC staff uember which caused it to believe its interpretation was correct. -As a result.of discussions between the inspectors and the licensee's staff the licensee now understands the_TS requirement and the root cause of the violation has been corrected. Because the licensee's corrective action is adequate and has been verified, this item is close The licensee is using staff SR0's to fulfill the five shift commitmen One shift supervisor position is being filled by a single SR0 while the other is being filled by two SRO's alternating on each shift rotation. A fourth SR0 will be used l as a backup. 10 CFR 55, which establishes procedures and criteria for operator's licenses, was revised on May 26, 1987, and redefined the requirements for maintaining an active license and.for resuming the functions of a license if it has not been maintained. In order to maintain a license active, the licensed operator must have performed the functions of an operator or senior operator on a i

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minimum of seven 8-hour or five 12-hour' shifts per calendar quarte The previous rule was less specific in this regard and generally was interpreted to that individuals in a qualified requalification program satisfied the definition of " active."

The new regulation is silent as to the' effective date of that part of the regulation and it is not clear if there is a '" grace" period for such persons to become-or stay qualifie Therefore, the licensee's use of such staff persons as shift supervisors wil remain an Unresolved Item (346/87008-05(DRP)) pending resolution by the _ inspectors of an official interpretation of the rul On April 27, 1987, an equipment operator found the alarmed fire door between the Auxiliary Feedwater (AFW) Pump Rooms ope The door also prevents a pressure transient in one room from affecting, the other room. . Investigation by the licensee revealed that an insulating crew was in the area and blocked the door open to allow easier passage. The insulators notified the' Central Alarm Station (CAS) that the door would be blocked open. Security logged'the action and did not respond to the open door alarm. The workers left the area and failed.to close the door and notify CAS. In additio the security officer stationed at the AFW No. 2 pump room entrance was unaware that the insulators failed to close the door between the-

. pump rooms. The security officers function is to log access to the area and he is not required to be aware of the status of the room Technical Specification (TS) 3.7.10 requires that when a fire-barrier has been breached a fire watch must be established within one hour. It was determined that the fire door was left unattended for approximately 14 minutes and therefore TS 3.7.30 was not violated. However, TS 6.8.la requires that written procedures shall be established and implemented for the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33. Generic Guidance Memorandum POL.22, which is used as a procedure by the licensee, requires that the shift supervisor be notified prior to a fire door being blocked open. This was not done and therefore this is a violation of (346/87008-06(DRP)).

The licensee determined that the instruction signs on the doors were confusing and contractor craft personnel did not receive sufficient training. The licensee reviewed its findings with the inspector The licensee initiated corrective action by clarifying door instruction signs and specific additional training for contractor craft personnel. The licensee is also reviewing other doors for similar problems. The inspectors have reviewed the corrective action and consider it to be satisfactor This item is close l l On May 10, 1987, the licensee was operating the motor driven feed ,

pump with the unit in cold shutdown (Mode 5). The operators were l performing a valve lineup in preparation to place the steam generators i in wet layup. An operator mistakenly shut a suction valve which resulted in the pump seizing. The licensee disassembled the pump

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and observed that bushings had failed and the wear ring was damage The licensee sent the damaged pump to the vendor, Ingersoll-Rand, to be repaired. The pump has been reinstalled and is operationa f. At 9:05 a.m. on May 12, 1987,.'a roving security patrol observed an open fire door. The security officer notified CAS and then closed the. door._ The shift supervisor went to investigate the incident and found the door open;at 9:20 a.m.. The licensee still maintains i an hourly fire watch patrol.that covers the rooms'on both sides of the door thus there was no technical specification violation. In addition, the adjacent room was occupied by contractor personne The licensee identified that contractor. electricians had gone through the door in the 15 minute interval. This appears to.be another example of insufficient training. This is an Open Item (346/87008-07(DRP)) pending the inspectors' review of the licensee's evaluatio g. Employee Assistance Program: Recently the licensee referred an employee to its Employee Assistance Program (EAP). The licensee reviewed the event with the inspectors. The inspectors asked the licensee what type of feedback it received from the program. The licensee stated that with company referrals it was provided with'

feedback as to the employee's general condition, but that for self referrals there was no feedback mechanism. The licensee believes confidentiality is needed in order to encourage employee self referral The inspectors asked the licensee how it could meet the requirements of 10 CFR 55.11(a)(1) and 10 CFR 55.31(d) for EAP self-referral CFR 55.11(a)(1) requires that a licensed operator not have a physical or mental condition which might cause impaired judgement or motor coordination and 10 CFR 55.31(d) states that each licensee is subject to all applicable rules and regulations of the commissio The licensee was unable to respond to the question and later stated that the area of concern had not been addressed. The inspectors suggested to the licensee several times that it should address this issu The inspectors finally met with the licensee on April 16, 1987, to discuss their concerns. The licensee explained the EAP to the inspectors. The inspectors consider that there is sufficient feedback with company referrals to enable the licensee to fulfill its obligation However, that part of the program relating to self referrals has to be reviewed to ensure that regulatory requirements are me A discussion was held relating to the implementation of the EAP and the apparent conflicts with the legal requirements. The plant manager related his experiences with EAP's at other utilities and the methods used to reduce or minimize conflicts. The inspectors stated that their concern was limited to the 45 licensed operators while the plant manager was concerned about almost everyone within the protected are .k

. 1 The licensee stated that it would attempt to find a solution which accommodated all concerns and would meet with the inspectors when an accord had been reached. This is an Open Item 346/87008-08(DRP).

4. Independent Measurement of Reactor Coolant System (RCS) Leak Rates (61728)

The inspectors verified the reactor cooling system inventory balance was performed according to TS and within the limiting conditions for operation. Also, the licensee's calculation technique for RCS leak rate determination was independently checked and verified using NUREG-1107,

"RCSLK9: Reactor Coolant System Leak Rate Determination for PWRs."

The independent calculated leak rates were within 0.1 gpm of the licensee's calculated leak rate . Monthly Maintenance Observation (62703)

Station maintenance activities of safety-related systems and components listed below were observed or reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides and industry codes or standards and in conformance with technical specification The following items were considered during this review: the limiting conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicable; functional testing or calibrations were performed prior to returning components or systems to service; quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were implemented; and, fire prevention controls were implemente Work requests were reviewed to determine status of outstanding jobs and to assure that priority is assigned to maintenance of safety-related equipment which may affect system performanc The following maintenance activities were observed or reviewed:

• Repair of the Motor Driven Feedwater Pump

• Testing of Control Room Emergency Ventilation System Service Water Control Valve * Installation of Main Steam Isolation Valve Nitrogen Syste * Testing and installation of new Pilot Operated Relief Valve (PORV)

• Replacement of RC 11, PORV block valv * Connection of ground wire to diesel fuel oil tan l l

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' The' licensee has demonstrated significant improvement in the areas of overall' housekeeping. However, there have been areas where the licensee still needs to improve its performance. The most notable is the area of housekeeping during the performance of maintenanc The lack of control in the storage of parts for the service water

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pumps is a housekeeping problem. . This lack of control previously resulted in two Unresolved Items (346/86014-02 and 346/86023-04).

The. inspectors also documented housekeeping concerns in Inspection

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1. Report No. 50-346/8700 'Another maintenance housekeeping problem resulted in the licensee declaring Emergency Diesel Generator (EDG) 1-2 inoperable after it

p -discovered fragments of rags being blown out of the EDG ventilation system duct work. Investigation revealed rags in.the duct work and

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plastic wrapped around a bearing. The' licensee determined that rags were brought into the area when preventative maintenance previously-had been performed. The excess rags were stored on the duct work m .rather than being removed from the area. This is another example of poor maintenance housekeeping practices and this, in combination with the other examples cited above, is a violation of 10 CFR 50, Appendix B, Criterion II which is implemented by the licensee's Nuclear Quality Assurance Manual (NQAM) (346/87008-09(DRP)). The rags had the potential of getting caught in the ventilation fans in

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a manner which would render the EDG room ventilation system inoperable. l This could have caused the EDG's to over hea ' On April 16, 1987, a licensee I&C technician discovered a temperature sensing bulb hanging in the Component Cooling Water (CCW) Pump Roo A digital thermometer and a heat gun were also found in the are Investigation by the licensee revealed that a system engineer had performed _ maintenance on the sensor while trouble shooting fan problem Maintenance Work Order (MW0) 1-87-1046-00 was written to troubleshoot problems with the CCW Pump Room ventilator fan, but had not been issued. The work performed by the system engineer was

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performed without benefit of an MWO which resulted in uncontrolled work being performed. This is a violation (346/87008-10(DRP)) of 10 CFR 50, Appendix B, Criterion II.

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6. Monthly Surveillance Observation (61726)

The inspectors observed technical specifications required surveillance testing on Auxiliary Feedwater System DB-M1-3100.04, " Calibration Check of PSL-106A, Auxiliary Feed Pump Turbine 1-1 Inlet Pressure Interlock" and the Safety Features Actuation System (SFAS), ST 5031.01, "SFAS Monthly Test" and verified that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that limiting conditions for operation were met, that removal and restoration of the affected components were accomplished, that test results conformed

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with technical specifications and procedure requirements and were reviewed by personnel other than the individual directing the test,  ;

and that any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personne The inspectors'also witnessed portions of the following test activities:

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• ST 5013.04 Control. Rod Exercising 9 st

• ST'5071.11 Auxiliary Feedwater Puq 1-1 Monthly Jog Test

• PT 5112.01 Emergency Lighting System Test 7. , Licensee Event Reports Followup (92700)

Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine snat reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had been accomplished in accordance with technical specification (Closed) LER 82039: Containment to shield building differential pressure exceeded Technical Specifications limit. 0n August 20, 1982, with the station in Mode 3, the. containment to shield building differential pressure reached a maximum of 25.2 inches of water exceeding the Technical Specification limit of 25.0 inches of wate .The licensee attributed the cause of this occurrence to a design error in the containment purge system valves. Normally the containment purge system valves would be used during plant heat up to reduce containment pressure. Due to design deficiencies concerning the valves ability to close under accident conditions the licensee has been committed to maintaining the valves closed whil in Modes 1 through Mode 4. The licensee has demonstrated during previous startups that containment pressure can be maintained b the use of the Hydrogen Dilution System. During this startup, however, the venting flow through the Hydrogen Dilution System had not been started at the apprcpriate tim The inspectors verified that Procedure PP 1102.02, " Plant Startup" had been^ revised to include the appropriate steps for opening the Hydrogen Dilution System exhaust, (Closed) LER 85016: During maintenance on the high pressure injection pumps, it was discovered that the startup suction strainers were still installed in the inlet piping at both pump The licensee committed to remove the strainers from both pumps and )

replace them with spacer ring .r +

n Review of Maintenance Work Orders (MWO) 1-85-2648-00 and

, 1-85-2648-01 indicates that the strainers have been remove The pumps were then realigned and vibration readings were take J t

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In addition,'LER 85-16 corrective action indicates that pumps in other systems:were also checked for startup strainers. No other occurrences were foun (Closed) LER 86003: Essential 4160V BUS Voltage High. During periods of plant shutdown the licensee had received numerous 4160V high voltage alarms. The licensee's analysis determined that the high voltage alarms were due to the light electrical load on the station transformers during unit outage periods. Since this condition presented the potential for exceeding the voltage rating of safety-related equipment, the licensee committed to reduce the 4160V bus voltage upon receipt of an essential bus C1 or D1 high voltage alarm. During performance of the System Review and Test Program, however, the licensee discovered that it had failed to meet this commitment. The failure to meet the commitment was caused by

' inadequate incorporation of the commitment into design documents and operating procedures. Corrective actions taken by the licensee include:

(1) The implementation of Facility Change Request (FCR) 85-0244 to provide two tap settings on station startup Transformers X01 and X0 The normal tap setting.(tap position 3) is to be used during plant: operation and a second tap setting (tap position 2)

is to be used during plant shutdown. The change in tap settings during plant outages will reduce the 4160V bus C1 and D1 voltages by approximately two and one half percen (2) The implementation of FCR 85-0327 to prepare a tabular drawing (Drawing No. 7749-E-1 SH. 3 R w. 0) for maintaining controlle documentation of station safety-related transformer tap setting (3) The implementation of FCR 85-0349 to revise the 4160V bus high voltage annunciator alarm setpoint. The maximum allowable motor operating voltage for the 4160V bus is 105.8%. FCR 85-0349 changed the annunciator alarm setpoint from 102% to 105% of normal bus voltage. Under FCR 85-0349 the former setpoint of 102% will alarm on the station computer to act as a pre-alar The revision of the 4160V high voltage alarm setpoint was required to minimize nuisance alarms during shutdown period (4) The licensee has implemented a modification to Alarm Procedures AP3001.15 and AP3001.14 to provide guidance upon receipt of a 4160V Bus C1 or D1 high voltage alar (5) Plant Shutdown and Cooldown Procedure PP1102.10 and Plant Startup Procedure PP1102.12 have been revised by the licensee to provide guidance for startup transformer tap change (6) Procedure NSL/LIC-004 Rev. O implements a licensing commitment tracking system (LCTS) which requires the review of NRC correspondence and incorporates commitment _-_----L

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The inspectors reviewed the licensee's corrective actions and verified that they had been complete d. (Closed) LER 86008: On January 8, 1986, the station experienced i a full safety features actuation system (SFAS) actuation. The 1 operator blocked the SFAS actuation. Borated Water Storage Tank .

isolation Valves DH2733 and DH2734 stopped without opening fully since the seal-in-circuit was blocke The licensee identified the cause of the SFAS actuation to be a lack of procedural adherence by personnel performing Maintenance Procedure MP1410.71. The licensee found that personnel performing MP1410.71 were relying on data sheets to carry out procedural steps and were not following the more detailed body of the procedure. The licensee's Engineering Department also confirmed that the design of the seal-in-circuit for the opening signal to isolation valve DH 2733 and DH 2734 causes the valves to stop moving when the SFAS is blocke The inspectors verified the following corrective actions taken by the licensee:

(1) Under FCR 86-0041 the licensee has performed a modification to the "0 PEN" control circuits of DH 2733 and DH 2734. The modification was implemented to ensure the valves stroke fully open upon a momentary SFAS actuatio (2) The licensee has revised Maintenance Procedure MP1410.71

" Periodic Maintenance 250/125 VDC instrument system, repJlated rectifiers, and battery chargers,".to incorporate human factors concerns. This procedure has been divided into two separate procedures; MP1410.70 "10KVA Inverter Inspection and Maintenance" and MP1410.71 " Battery Charger and Regulated Rectifier Maintenance."

The inspectors reviewed FCR 86-006, and found it to be fully implemented. Revised Maintenance Procedures MP1410.70, and MP1410.71 were reviewed and found to incorporate the change e. (Closed) LER 86009: Inadequate wire wrap connections. While observing a Consolidated Controls Corporation (CCC) field engineer perform modifications in the Steam and Feedwater Rupture Control System (SFRCS) cabinets the licensee noted that the field engineer was moving wire wrapped connections down the post to provide additional room for more connections. The licensee questioned this practice but was assured by the field engineer of its acceptabilit Subsequent pull tests performed by the licensee on the wire wrapped connections of concern determined that once a wrap is moved on its post its strip force was sharply reduce {

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The licensee has identified the cause of this occurrence as a failure of the field engineer to follow his own procedure (CCC Procedure No. QS-WR-104) which prohibits the probing of wire wraps as well as a lack of a station procedure which could be used to verify tne wor The licensee's corrective actions included the implementation of Maintenance Procedure IC2701.20 to provide the station with instructions for proper wire wraps. Additionally, under Maintenance Work Orders 1-86-0328-00 and 1-86-0328-01 the SFRCS logic racks were stripped and rewired on sit The individual logic modules of the SFRCS were rewired of fsite in compliance with MIL-STD-1130 The licensee performed a review of other major instrument systems to determine if other wire wrap problems exist. No deficiencies affecting operability have been identified, f. (Closed) LER 86011: Class 1E electrical equipment cabinets i were found to be missing bolts which are required for seismic qualifications. The licensee was to review all Class 1E electrical equipment and verify that the required fasteners were installe Maintenance Work Orders 1-86-1378-00, 1-86-1379-00, 1-86-1860-01 and 1-86-1860-02 were reviewed to verify that the proper fasteners had been installed. This work involved cabinets for battery charges,.

inverters and rectifiers as well as the distribution panel cabinet In addition, Maintenance Procedures MP 1410.70, "Cyberex 10KVA Inverter Inspection and Maintenance," Rev. 2, and MP 1410.71,

" Battery Charger and Regulated Rectifier Maintenance," Rev. 2, were reviewed to verify that instructions were in place to ensure that the fasteners are reinstalled after any maintenance on the cabinet The inspectors inspected the cabinets to verify that fasteners were in:talled and in us g. (Closed) LER 86022: Potential failure of Steam Generator Level Transmitters due to submergence during a Small Break Loss of Coolant Accident (SBLOCA).

During equipment qualification review the licensee determined that Level Transmitters LTRSP9A3 and LTSP9B3 would become submerged after approximately six hours following a SBLOC In the event of a SBLOCA (i.e., 0.04 sq. ft.) the level transmitters are used to control steam generator level by controlling the speed on the AFW pump turbin Later analysis determined that for greater than a 0.021 sq. f break no AFW was required to achieve natural circulation cooldow The licensee's analysis further determined that AFW was only needed for two hours following a SBLOCA of 0.02 sq. ft. or les Under this condition insuf ficient inventory would be released to allow submergence of the SG 1evel transmitter .

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. (Closed) LER 86031: Missed Surveillance. Surveillance Test ST.5084.01, " Station Batteries and Diesel Fire Pump Batteries,"

weekly test was completed late. The shift supervisors review of. the surveillance for operability was not completed until nine hours and 20 minutes after the time the surveillance was required including the allowable extension. With the surveillance requirement not satisfied the equipment is considered inoperable and the Limiting Condition for Operation (LCO) was not me The licensee identified the cause of this occurrence as a lack of a concise format for the review of surveillance tests due immediatel Corrective actions taken by the licensee and reviewed by the ,

inspectors include the following:

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.(1) Administrative Procedure AD 1838.02, " Surveillance and Periodic l Test Program," has been revised to include the requirement that I the technical specifications surveillance specialist will maintain a list of all scheduled surveillance tests that will go late within 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> In addition, revised Procedure AD 1830.02 shifts responsibility for review of completed surveillance tests not performed by operations personnel from the Shift Supervisor to the supervisor of the person performing the work. The test personnel supervisor then notifies the Shift Supervisor.of its completion. The Electrical Shop Foreman has been notified to hand deliver . ;

completed surveillance tests to the' shift superviso (2) Administrative Procedure AD 1839.05, " Shift' Turnover," has been revised to include the requirement that the Shift Supervisor and Assistant Shift Supervisor review the Surveillance Test Schedule and Surveillance Test Alert Report prior to assuming the shif (Closed) LER 86042: Main Steam Isolation Valve (MSIV) testing found to be inadequate. Surveillance Test ST5031.18 " Main Steam Isolation Vale Response Time Test" was identified by the licensee as requiring the MSIVs to close upon the simultaneous trip of two channels (Channel 1 and Channel 2) of the Steam and Feedwater Line Rupture Control System (SFRCS). The procedure, as written, would have permitted failures in the individual MSIV air circuits to go undetected. The licensee found the cause of the test deficiency to be due to an inadequate technical review of the procedur Corrective actions taken by the licensee include performance of Test Procedure TP851.11 "MSIV Operability Test" during restart to verify closure of both MSIVs by tripping each SFRCS channel individually, implementation of Surveillance Test ST 5031.20 " Main Steam Isolation Valve Response Time Test," which was reviewed and found to require the closure of both MSIVs upon an individual trip of either SFRCS Channel 1 or SFRCS Channel 2; and to avoid future occurrences, the

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O revision of Procedure AD 1805.00.26, " Procedure Preparation and Maintenance" to give specific guidance during the performance of procedural review The following LER's were reviewed but are not yet ready to be closed:

~j. (0 pen) LER 82028: A service water swing check valve was found to be stuck open during testing. An LER was submitted 07/09/82. indicating the cause of failure to be corrosion due to design error in choosing the wrong material. The corrective action was to disassemble and clean the valve then return it to servic This was on 06/12/82 per Maintenance Work Order 82-180 Subsequent review by the inspectors of the LER noted that the corrective action did not address the root cause of failur The licensee ~was informed that the LER needed to be revised to reflect the root cause. This was acknowledged.by the licensee as documented in the Memorandum AN86-0035, " Change to LER 82-28 Re: SWS Design."

The close out package obtained for this review included only the original LER and the maintenance work order to clean the valv No revised LER or any documentation showing that the root cause of failure had been addressed was'available. This LER will remain open until the licensee demonstrates that corrective action has been taken to address the root cause of valve failur (0 pen) LER 86033: Modification degrading shield building integrit During an engineering review of modifications to some blowout panels in the shield building wall the licensee determined that the panels in Room 314 would no longer withstand the differential pressure during a LOC The licensee identified the cause of this error to be due to erroneous information in the stations Updated Safety Analysis Report regarding the blowout panel release pressure. The peak pressure anticipated in Room 314 in the event of a LOCA has been analyzed to be 4.5 PSI Under Facility Change Report (FCR)77-152 the blowout pressure rating of the panels in Room 314 was changed to 1.0 PSIG. The USAR, however, was never revised to reflect the 1.0 PSIG blowout pressure ratin Under FCR 86-107 the release pressure was changed back to 0.E PSIG to agree with USAR Subsection 3.6.2.7. Under FCR 86-107 Rev. A and MWO 2-86-0107-02 the licensee has changed the blowout pressure rating of the panels to 1.0 PSI The licensee has also completed a revised High Energy Line Break (HELB) analysis to ensure proper environmental qualification of the appropriate Auxiliary Building equipment with the blowout panel setpoint at 1.0 PSI ?

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d The inspectors found that USAR Subsection 3.6.2.7.1.5 still specifies the blowout pressure setpoint as 0.5 PSIG. The licensee intends to-revise-this section during the next annual update of the USA The safety evaluation'for FCR 86-107 Rev. A states that future safety evaluations will be performed to evaluate the environmental qualification of equipment in accordance with the results'of the revised HELB analysis and to perform a comparison with the 1977-analysi Based on the above, this item remain open pending full implementation of revisions to the USAR as well as the required safety evaluation . (0 pen) LER 86039: - During calibration of steam generator level transmitters it was discovered that the correction factor for static pressure span effects was being calculated. incorrectl It was determined that 54 Rosemount transmitters could be affected by this erro The licensee committed to correcting the calculation of the span effect, then determining the zero shift and recalibrating all affected transmitters. The corrected information was to be documented in each of the instrument data package Procedure IC 2702.52, " Instrumentation and Control Procedure IC 2702.52 Performance Test of Rosemount Differential Pressure Transmitters to Determine Static Zero Shift," Rev. 00 was reviewed to verify documentation of the proper. steps to determine static zero shift

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for each of the affected transmitters. It was found that seven transmitters were not included in the procedure. A " Procedure Development" modification sheet dated 09/16/86 was attached to the procedur It specifies the seven transmitters will be included in the procedure, however, the updated procedure was not available at the time of this revie An investigation report concerning the transmitters was also reviewed, " Investigation of 54 Rosemount Transmitters in Response to PCAQ 86-0336." In addition to including a safety evaluation, the report stated that of the 54 transmitters in use, 23 could be used as-is until the next scheduled calibration, 22 needed to be recalibrated immediately and nine required no change. Maintenance Work Orders 7-86-3309-00/05/06/07 and 15 through 23, along with 1-86-3457-00 through 03 were reviewed to verify that the 22 transmitters requiring immediate action had been recalibrated. The data packages for all but ten affected transmitters have been updated to include the revised static pressure span correction factors, as documented in Memoranda DSM-86-25037, "LCTS 2878" and DSM-86-25004,

"LCTS 2879". Of the ten transmitter data packages not updated, the memo,"PCAQ 86-0336," states that eight require no change due to the calibration method used. Two transmitters, however, are not accounted for as having their data packages updated. These include LT-5448A and

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LT-5448B. This LER remain open until (1) Procedure IC 2702.52 is 4 revised to include all transmitters and (2) documentation is provided '

indicating that that data packages for LT-5448A and LT-5448B have been update . ' Quality Assurance The inspectors frequently attend Quality Assurance audit exits. It has been noted that-the number of audit finding reports (AFR's) for failure to have procedures as required by the Nuclear Quality Assurance Manual (NQAM) has increased. The. inspectors reviewed the NQAM which was issued October 24,.1986, and observed that several of the reference procedures had not yet been. issued. The Nuclear Group Procedures'specifically referenced in the NQAM which have not been issued are:

NG-DS-203, Control of Special Processes NG-NE-303, Nuclear Plant Reliability Data System (NPRDS)

NG-QA-705, Management. Corrective Action The inspectors also noted that specified implementing procedures also had not been issued in many instance The inspectors have discussed their concerns with the licensee and it concurs with the. inspectors concerns. The licensee plans to draw up a matrix of NQAM required procedures and corresponding procedures which have been issued. A schedule of procedure completion will be issued after completion of the' matrix. This is an Unresolved Item (346/87008-11(DRP)) pending review of the licensee's corrective actions and implementation schedul . Regional Request (92701-T12515/67)

The inspectors reviewed the licensee's program for responding to faults in the control rod drive (CRD) system. The inspectors reviewed Procedure AB 1203.23.06 "CRD Malfunctions" and verified that it included the steps necessary to recover from a mispositioned control rod and provided ,

appropriate guidance for. verifying rod position when one form of normal indication is lost. The inspectors discussed abnormal rod operations-with operators and determined that they were familiar with AB 1203.2 The inspectors interviewed members of the training staff and reviewed the lesson plan and hand out used for training on AB 1203.23. The inspectors also reviewed Simulator Guide OLC CAS 5001 " Plant Startup from Hot Standby to 100% RTP with a Stack Main Feedwater Control Valve at 5% Open Position and a Dropped Control Rod at Greater than 60% PTP". The licensee's training program for CRD system malfunction is adequat . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. Unresolved items disclosed during the inspection are discussed in Paragraphs 3.a, 3.c, and >

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Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspectors, and which involve some action 3 on the part of NRC or licensee or bot Open items disclosed during the inspection are discussed in paragraphs 2 o, 3.a, 3.f, and . Exit Interview (30703)

The inspectors met with licensee representatives (denoted in Paragraph 1)

throughout the month and at the conclusion of the inspection and summarized the scope and findings of the inspection activities. The licensee acknowledged the findings. After discussions with the licensee, the inspectors have determined there is no proprietary data contained in this inspection repor i

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