ML20235W921
ML20235W921 | |
Person / Time | |
---|---|
Site: | Sequoyah ![]() |
Issue date: | 07/13/1987 |
From: | Jenison K, Mccoy F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF SPECIAL PROJECTS |
To: | |
Shared Package | |
ML20235W908 | List: |
References | |
50-327-87-36, 50-328-87-36, NUDOCS 8707230776 | |
Download: ML20235W921 (35) | |
See also: IR 05000327/1987036
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UNITED STATES
pft Mooq'o
NUCLEAR REGULATORY COWIMISSION
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101 MARIETTA STREET, N.W.
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ATLANT A, GEORGI A 30323
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Report Nos.:
50-327/87-36, 50-328/87-36
Licensee:
Tennessee Valley Authority
500A Chestnut Street
Chattanooga, TN 37401
Docket Nos.:
50-327 and 50-328
License Nos.: DPR-77 and DPR-79
Facility Name:
Sequoyah Units 1 and 2
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Inspection Conducted: May 26, through June 5,1987
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MI24,/A
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Dafe Sig(ecT [
Inspection Team Leader:
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,
K. M. Jinisco, oeHTorRespt
sTecTor
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Team Members:
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P. E. Harmon, Resident Inspector
C. L. Vanderniet, Reactor Engineer
B. A. Breslau, Reactor Engineer
P. G. Humphrey, Resident Inspector
T. B. Powell, Resident Inspector
S. G. Tingen, Reactor Inspector
G. A. Schnebli, Reactor Inspector
P. M. Chan, Consultant from Lawrepce Livermore National Laboratory
J. E. Weed, Cons . tant rom L wfe'nce Livermore National Laboratory
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Approved by:
a
_
D(tfSign6d
F. R. McCof, Chief, ProjectT5ection 1
Division of TVA Projects
Office of Special Projects
Summary
Scope: This special announced inspection involved inspection onsite by a team
of Office of Special Projects resident inspectors and NRC Region II reactor
engineers.
Inspection was conducted in the areas of:
surveillance program
review; surveillance observation; system lineups; followup of events; review of
licensee identified items; and review of inspector followup items.
Results:
One violation was identified.
327,328/87-36-01; Inoperable Chlorine Detection System, paragraph
12.d.
One unresolved item was identified.
327,328/87-36-02; Identified inadequacies in SI-218.2, SI-270.2 and
SI-166.40, paragraphs 5.a and c.
8707230776 870716
ADOCK 05000327
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REPORT DETAILS
1.
Licensee Employees Contacted
- H. L. Abercrombie, Site Director.
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J. T. La Point, Deputy Site Director
L. M. Nobles, Plant Manager-
- B. M..Willis, Operations and. Engineering Superintendent
- B..M. Patterson,~ Maintenance Superintendent
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R. 'J. Prince, Radiological Control Superintendent
- M. R. Harding, Licensing Group Manager
L.
E~. Martin, Site Quality Manager
D. W. Wilson, Project Engineer
R.'W.- Olson, Modifications Branch Manager
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. J. M. Anthony, Operations Group Supervisor
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- R. V. Pierce, Mechanical' Maintenance: Supervisor
M. A. Scarzinski, Electrical Maintenance Supervisor
- H. D. Elkins, ~ Instrument Maintenance Group Manager
R. S. Kaplan, Site Security Manager
J_. T. Crittenden. Public Safety Service Chief
- P., W. Fortenberry, Technical Support Supervisor
- G. B. Kirk, Compliance Supervisor
- D. C. Craven, Quality Assurance Staff Supervisor
J. H. Sullivan, Regulatory Engineering Supervisor
- J.-L. Hamilton, Quality Engineering Manager
D.:L. Cowart, Quality Engineering Supervisor
H. R. Rogers, Plant Operations Review Staff
- R. H..Buchholz, Sequoyah Site Representative
- M. A. Cooper, Compliance Licensing Engineer
- R. P. Denise, Surveillance Instruction Review Program Manager
Other licensee employees contacted included technicians, operators, shift
engineers, security force members, engineers and maintenance personnel,
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- Attended exit interview
2.
Exit Interview
The inspection scope and findings were summarized with the Site Director
and members of his staff on June 5,
1987.
One violation (327,328/87-
36-01) as described in this report's Summary paragraph was discussed. No
deviations were discussed.
The licensee acknowledged the inspection
findings.
The licensee did not identify as proprietary any of the
material reviewed by the inspectors during this inspection.
During the
reporting period, frequent discussions were held with the Site Director,
Plant Manager and other managers concerning inspection findings.
3.
Unresolved Items
Unresolved items are matters about which more information is required to
determine whether they are acceptable or may involve violations or
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deviations.
One unresolved item (327,328/87-36-02) was identified during
this'inspec; ion. This unresolved item addresses the technical adequacy of
Surveillance Instruction (SI) -218, SI-270.2 and SI-166.4. Each of these
procedures is discussed in detail in paragraphs 5.a and c of this report.
4.
Surveillance Program Review (61700, 61726)
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The licensee's submittal of March 24, 1987 (Gridley/Ebneter), described
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the Sequoyah surveillance instruction review and revision program.
The
intent of this program, as described in this document, was to ensure all
Technical -Specification (TS) requirements were addressed and' that
surveillance instructions and their supporting instructions, covered by .
the program scope, were technically adequate to fulfill the surveillance
requirements of the Sequoyah TS.
As a result of this review, the
following issues were identified:
a.
A
long
term
surveillance
instruction
program
to
address
administrative consistency, achieve standard format and organization,
and make enhancements was mentioned in the licensee's submittal, but
was not discussed in detail.,
b.
The licensee has established a second independent group of reviewers,
referred- to as the surveillance instruction verification and
validation-(SIVV) group which conducts fie'id validations of completed
PORC approved procedures.
This group was not clearly addressed in
the submittal.
c.
Part II to Appendix F checklist of SI-1. Surveillance Program, is
titled " Administrative Adequacy."
The licensee stated in its
submittal that "Part II of the checklist is not being completed for
this program." This statement implies that Part II to Appendix F
will not be completed prior to the startup of Sequoyah Unit 2.
The
licensee explained that certain items in Part 11 are from upper-tier
documents and are checked to ensure necessary compliance.
The inspectors took exception to this portion of the program and
identified several aspects in the licensee's Part II (administrative
adequacy) checklist which could affect the technical adequacy of the
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performed surveillance as e result of its implementation.
The
following five items appeared to be the most likely to affect the-
ability of the surveillance to perform its intended function:
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consideration of common mode failure possibilities (Part II,
item 1)
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requirement for SRO approval to perform the SI (Part II, item 6)
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verification of impact on redundant loops (Part II, item 7)
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verification of performance consistency (Part II, item 18)
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requirements for independent verification (Part II, item 21)
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After a review of additional information supplied by the licensee it
was determined that the site ' quality assurance staff had identified
the same issue and a considerable amount of negotiation, in the form
of meetings and written memos, had taken place over what portions of
the topics discussed in SI-1 Appendix
F,
Part II, were to be
addressed in some fashion prior to the startup of either unit. It was
agreed 'upon between the two parties in a Memo (Martin /Denise) dated
February 25, 1987, that selected requirements from upper tier
documents that also appear in Part II of Appendix F would be
completed. The list of selected governing requirements from upper -
tier documents included those issues identified by the NRC in
addition to other issues.
The incorporation of these reviews into
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the licensee's " post lessons learned" portion of the SI-1 Review and
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Verification Program was verified by the inspectors.
However, the
interpretation of these requirements are much more subjective. than
the technical issues 1-nvolved in the surveillance review process.
Therefore, NRC will verify the incorporation of these issues into the
SI-1 program during the followup inspection.
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5.
Surveillance Instruction Review (61700, 61726)
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The
inspectors
conducted
indepth
technical
reviews
of
specific
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surveillance
in order to determine whether the surveillance of
safety-related systems and components was being conducted in accordance
with technically adequate and properly approved instructions, as required
by the TS, inservice inspection (ISI), inservice testing (IST) programs
for pumps and valves, and NRC approved fire protection program.
In
addition, -the inspectors observed and reviewed TS required surveillance
testing and verified that testing was performed in accordance with
adequate procedures; that test instrumentation was calibrated; that
Limiting Conditions for Operations (LCOs) were met; that test results met
acceptance criteria requirements and were reviewed by personnel other than
the individual directing the test; that deficiencies were identified, as
appopriate, and that any deficiencies identified during the testing were
prcperly reviewed and resolved by management personnel; and that system
restoration was adequate. For complete tests, the inspector verified that
testing frequencies were met and tests were performed by qualified
individuals.
The review was completed in three sections, and included Appendix A and B
procedures that were indicated in the submittal mentioned above.
The
first section of the review involved Appendix A procedures that the
licensee required to be reviewed and validated prior to Unit 2 startup. The
second section of .the review involved Appendix B procedures thtt the
licensee determined to not require a review prior to Unit 2 startup (refer
to the discussion in paragraphs 4.c and 5 b. of this report.) The third
part of the review involved a field observation and review of procedures
performed in the field by the licensee.
The three review sections are
discussed below:
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Appendix A of. the TVA SI review program submittal addressed those TS
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sis and supporting f. instructions that were required for startup,
operation, and safe shutdown of Sequoyah Unit 2 to the point of the
next refueling. This set of procedures did not include all instruc-
tions encompassed by the license.
The review described in the
licensee's aforementioned submittal includes technical construction
of the surveillance document, technical review within the responsible
section, quality individual (QI) or informal Plant Operations Review
Committee (PORC) review, possible quality assurance (QA) or independ-
ent review group (IRG) review, independent SIVV group review and
field validation, PORC review, and observer validation.
- During the review conducted by the inspectors a determination was
made of whether or not the instruction was able to perform its
technical intent as written, and whether the instruction fu11 filled
the requirement of the surveillance requirement for which credit was
taken by the licensee.
SI 1, Part II issues were identified in
nearly all of the surveillance
reviewed.
The determination of
adequacy in this report is meant to indicate.whether the procedure is
technically adequate.
If administrative issues ' were identified,
credit was given to the licensee's corrective action program for
addressing these issues.
The inspectors reviewed the following instructions:
SI-217.2; Periodic Calibration of Reactor Coolant Pump Under-
"
voltage Relays
This SI had been resubmitted to the review process.
SI-169.2;
Periodic
Calibration
of
Diesel
Generator
Instrumentation
The inspector considered SI-169.2 to be adequate.51-218.2; Periodic Functional Test of Reactor Coolant Pump
Undervoltage Relays
Lack of Engineering Units:
Acceptance Criterin paragraphs
6.1.3, 6.1.4, 6.2.3 and 6.2.4 designate various voltage levels
which are considered acceptable however the proper engineering
units are not included in the section to clarify if the voltages
measured are Vac or Vdc.
This SI is a bench test of a component where an input is
supplied and the output (acceptance criteria) is measured and
recorded. There is no provision in the SI to measure and record
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the test input, voltage and frequency,. This test input must
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be selected to represent the same value(s) that the component
will experience when installed and in service.
Specifically
Section 6.14 does not reference or conform to vendor's instruc-
tions to verify, for a range of input voltage, the proper
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operation of the component.
The expected variability of the
input (specification +/- range) is not reviewed or addressed in
the SI., .
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The procedure is considered to be inadequate and. will be
addressed by .a licensee submittal committed to by the site
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director 'at . the time of the exit.
The submittal is to be
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reviewed by the NRC for technical merit prior to the startup of
either unit.
This will be identified as Unresolved Item 327,
328/87-36-02.
SI-235; 6.9KV Emergency Bus Loss of Voltage Overvoltage and
Degraded Voltage Relay Calibration
This procedure had been resubmitted to the review process. The
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inspector reviewed a non-PORC opproved version of the procedure
and had no issues.
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SI-230.2; Periodic tunctional Test of RCP Underfrequency Relays
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There were no t.
, cal deficiencies identified.
This procedure
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is adequate.
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SI-102 E/A; Die >el Generator Annual Electrical Irspectior.s
The inspector reviewed the incorporation of vendor manual
recommendations in the SI and identified no technical issues.
This SI is a verification of the . data obtained in MI-10.1,
Diesel Generator Annual Electrical Inspection.
It explicitly
requires the timely performance 1 of the MI, evaluates its- data,
and seeks approval or remedial actions.
This procedure is adequate.
SI-102 E/1.5Y; Diesel Generator 18 Month Electrical Inspections
This.SI was cancelled by the licensee.51-246; Recalibration Procedures for Reactor Coolant Flow
Channels
SI-94.2 is not listed as a technical reference in this SI.
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SI-94.2 schedules a series of IMI-99, cc6.13A-24A channel
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calibrations which calibrate these same transmitter channels.
This procedure is considered to be adequate.
SI-100; Vital Battery operability
This procedure is considered adequate.
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SI-266.2.3; 60-Month Inspection of Molded Case Circuit Breakers
5I-1 Appendix
F,
Administration Adequacy- stated that -the
procedure must be clear and be performed the same way every
' time.
Note 4 in Section 6.0 of SI-266.2.3 allows the
performance of the procedure in a out-of-sequence manner. This
allows the completion of steps such as Sections 6.3 (recording
as found conditions), and 6.4 (transferring vital load) to be
done after steps such as Sections 6.8 and 6.9 (tripping of the
breaker). This is an example of an SI-1 Appendix F Part II item
which may affect the technical adequacy of the surveillance. As
discussed above credit for licensee's corrective action in this
area will be given.
51-1 Appendix F, Technical Adequacy Methodology 1 stated that
the testing methods used in the procedure have been verified
against the applicable industry standards.
SI-266.2.3 lists a
NEMA standard "AB 2 1984" as a reference. The inspection of the
circuit breaker under load as recommended in the NEMA AB 2 1984
. (Section 2, Paragraph 1) standard is not covered in the SI.
This issue of incorporating vendor recommendations is an SI-1,
Appendix F, Part II issue identified by the licensee for which
credit for licensee corrective action is given.
This procedure is adequate.
SI-270.2;
Fuses- for
Containment
Conductor
Overcurrent Protection
TS 4.8.3.1.a.3 has an asterisk that allows for the substitution
of an inspection and maintenance program in lieu of a 10%
sampling test plan, until the completion of an NRC generic
study.
The TS inspection plan made no provision to allow a
partial inspection of the fuses.
The licensee is currently conducting a total sample of the
installed fuses. SI-270.2 allows for the inspection of only 10%
of the fuses and thus does not meet the requirement of the TS if
the inspector's interpretation is correct.
The licensee has documented in a telephone log that in 1982,
this issue was discussed with the NRC and a 10% sample was found
to be acceptable.
The inspector reviewed this log and its
interpretation is subjec'.ive.
The applicable fuses are sorted
and sampled by manufacturer type, but AI-16 allows the substi-
tution of fuses. The substitution process could affect the fuse
population so that certain type of manufacture's fuses may no
longer be adequately represented by its 10% sample.
The sub-
stitution of fuses based on equivalents may not be indicated in
the the original tracking mechanism.
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The procedure is considered to be inadequate and will be
addressed by a licensee submittal committed to by the site
director at the time of the exit.
The submittal is to be
reviewed by the NRC for technical merit prior to the startup of
either unit. This will be included as the second example under
Unresolved Item 327,328/87-36-02.
IMI-30; Containment and Auxiliary Building Ventilation Systems
The procedure had not completed the PORC approval process.
SI-90.62; Reactor Trip /ESF Instrumentation Quarterly Functional
Tests
The procedure is considered to be adequate
IMI-92-IRM-FT; Nuclear Instrument Intermediate Range Functional-
Test
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This procedure had not completed the PORC approval process.
IMI-99; Channel Calibration 6.16A, Channel Calibration of Loop 2
Reactor Coolant Flow Channel 1
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This IMI is one of a series of 12 identical IMIs (IMI-99
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CC 6.13A to 6.24A) that address the calibration of redundant
channels for transmitting a reactor coolant flow trip signal.
This IMI was compared against one other of the series to
determine if the test was conducted that same way each time.
This IMI is considered to be adequate.
IMI-92; IRM-CAL, Nuclear Instrumentation System Intermediate
Calibration
This procedure had not completed the PORC approval process.
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IMI-99, CC 11.52A; Online Channel Calibration of Delta T/T
Average Channel 1 Rack 2 (note:
to be compared against other
loops and channels)
IMI-99 data package cover sheet a, sheet 1 of 1 (see IMI page 4)
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under " Steps of instruction to be performed" allows some or all
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of the IMI. steps to be performed. This is an SI-1, Appendix F,
Part II issue that was identified in a generic manner by the
licensee.
Credit will be allowed for licensee corrective
actions.
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Technical Adequacy regarding the TS 4.3.2.1.2 requirement was
not clearly obvious' as to where it was performed. This requires
that the logic for the interlocks be demonstrated.
This procedure was determined to be adequate only if it is
performed in the indicated series sequence.
TI-76; Electrical Maintenance Post-Maintenance Testing
This procedure was determined to be adequate,
SI-483; Procedure for Removing a Reactor Protection Channel From
a
Service
This procedure was not PORC approved.
SI-181.2; Fire Hose Hydrostatic Test
This procedure was determined to be adequate.
SI-46.2; Component Cooling Water Pump
The procedure required a change to incorporate the recently
obtained new base line pump data and the FSAR requires a change
to recognize the new design acceptable pump flow rate stated in
the procedure.
The inspector was informed by the licensee that
the changes to the procedure and FSAR are in the process of
being made to recognize the new design acceptable pump flow rate
stated in the procedure.
The inspector was informed by the
licensee that the changes to the procedure and FSAR were
requested.
This procedure does not address common mode failure which is an
SI-1, Appendix F, Part II issue generically identified by the
licensee for which licensee corrective action is identified.
This procedure will be adequate when the procedure changes and
FSAR updates are reconciled.
SI-45.5; Essential Raw Coolant Water Pump
SI-1, Appendix F, Administrative Adequacy, requires the SI-45.5
to be understandable and to be performed the same way each time.
A review of this surveillance revealed the following SI-1,
Appendix F, Part II issues that were identified by the licensee
in a generic manner:
Date of authorization is not documented.
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Sources are not specified for removing power from the
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valves as required by the procedure.
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No reference is made to the vendor's manual.
Procedure did not address common mode failure criteria.
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This procedure was determined to be adequate.
SI-128.4; Residual Heat Removal Pump 2A-A Performance
Steps 6.3.3 and 7.2.3 do not specify location to install
ultrasonic flow instrument. Positioning is described in another
procedure therefore, this is not a technical issue. However,
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this is an SI-1, Appendix F, Part II issue with respect to the
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requirement to perform the procedure that the same way each
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time.
Steps 6.3.1, 7.3.1 and 6.7.2 do not define what a " sat" level is
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This is also an SI-1 Appendix F,
Part II issue.
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The two issues identified above are in the category of items
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identified by the licensee for which licensee corrective action
is being implemented.
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This procedare is considered to be adequate.
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SI-130.1 and SI-130.2; Motor Driven Auxiliary Feedwater Pumps
The inspector noted the following SI-1 Appendix F,
Part II
issues:
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Vendor manuals were not listed in the references.
Procedure did not address common mode failure criteria.
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SI-37.3; Containment Spray Pump 2A-A
The inspector considered the procedure to be adequate.
SI-129; Emergency Core Cooling Safety Injection Pump Operability
The following SI-1, Appendix F, Part II issues were identified:
Vendor manuals were not listed in the references.
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Procedure did not address common mode failure criteria.
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Conclusions for this section of the review are as follows:
(1) Several issues were identified by the licensee prior to the NRC
concerning those review items in the SI-1, Appendix F, Part II.
Both the licensee and the NRC have determined that items in this
review area may affect the ability of the surveillance to
perform its intended function.
The licensee currently has
corrective actions in place to ensure that these type issues
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will not invalidate any procedures. The SI-1, Appendix F, Part
II review corrective actions will be inspected during the next
NRC SI inspection currently scheduled for the month of
July 1987.
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(2) Two - pro:edures SI-218 and SI-270.2 were determined to be
inadequate and were di scussed wit'. vtcious levels of TVA
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management. The licensee committed to submit a TS interpretation
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to the NRC concerning these two surveillance.
The Site
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Director made this committment at the time of the exit. The
submittal is to be reviewed by the NRC for technical merit prior
to the startup of either unit.
b.
Appendix B of the licensee's submittal includes those procedures that
are not required to be reviewed or revised by the licensee under the
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SI-1 program prior to the startup of Unit 2.
The inspectors reviewed
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the following instructions from Appendix B:
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S1-150; Special Test Exceptions for Group Height and Insertion
Limits
SI is adequate and not required to be revised prior to Unit 2
restart.
SQA-126; Liquid Solid and Hazardous Waste Management
SI is adequate and not required to be revised prior to U
restart.
SI-181; Fire Hose Hydrostatic Test
This SI has been cancelled and replaced by SI-181.1, Fire Hose
Hydrostatic Test, that covers non-TS outside fire hoses, and
SI-181.2, Fire Hose Hydrostatic Test, that covers both TS and
non-TS inside fire hoses. SI 181.1 is adequate and not required
to be revised prior to Unit 2 restart.
SI-181.2 has been
discussed in the previous section.
SI-701; Visual Inspection of Fire Doors
SI is adequate and not required to be revised prior to Unit 2
restart.51-506.11; Testing Procedures for Activated Charcoal
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SI is adequate and not required to be revised prior to Unit 2
restart.51-506.12; Test Canister Results for Spare Charcoal Tray
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SI is adequate and not required to be revised prior to Unit 2
restart.
SI-656; Waste Gas System Gross Leakage Test
SI is adequate and not required to be revised prior to Unit 2'
restart.
SI-727; Auxiliary Feedwater Full Flow Test
SI. is adequate and not required to be revised prior to Unit 2
restart.
TI-56; Electrical Penetration Replacement Structure Integrity
Test
SI is adequate and not required to be revised prior to Unit 2
restart.
TI-75; Hydrostatic Pressure Test Required by ASME Section XI
This test instruction has been deleted by the licensee and will
be incorporated into the 265 surveillance instruction series.
SI-153.1; Periodic Calibration of Hydrogen Recombiner System
Instruments
During review of SI-153.1 the inspector was informed that a
revision was in process because the licensee has determined that
the SI does not currently meet TS (LER 327 86-042).
Licensee
review of tM S Ci is now in progress and will be completed prior
to Unit 2 startup.
This procedure is determined to be inadequate and requires
revision prior to startup of Unit 2.
SI-70.3; Channel Calibration of Steam Generator Wide Range Level
SI is adequate and not required to be revised prior to Unit 2
restart.
SI-85.2; Channel Calibration of the Containment Sump Level and
Flow Monitoring Instrumentation in the Reactor Coolant System
Leakage Detection System
The following SI-1, Appendix F, Part II issues were identified.
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Checklist Item B.1, Appendix F checklist indicates "Yes"
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without a reference document paragraph or other reference
to appropriate standards, vendor recommendations, etc.,
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The procedure does not address common mode failure.
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SI-85.2 does not address redundant loops or equipment in
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.non-tripped condition. The appendix F review (revision 5)
is not correct.
It indicated "Yes" when it should be "No."
This procedure is adequate and does not require revision prior
to Unit 2 restart.
51-81; Functional Test of Source Range Neutron Flux Channel at
least Once per 7 Days During Refueling
The following SI-I, Appendix F, Part II issues were identified:
Appendix F, Part II was not completed on either of the
-
review checklists provided to the inspector.
-
The procedure did not address common mode failure.
The procedure was adequate and does not require revision prior
to the startup of Unit 2.
SI-87; Remote Shutdown Monitoring Instrumentation - Residual
Heat Removal Temperature Channel Calibration
No SI-1, Appendix F, supplemental checklist was completed.
SI-87 is being revised by the licensee.
SI-94.4; Reactor Trip Instrumentation Refueling Outage Channel
Calibration
The following SI-1 Appendix F, Part II issues were identified:
-
Calibration
SI-94.4
omitted
TS-4.3.3.7.B.9
which is
designated in the SI cross
index.
SI-94.4 omitted
TS-4.3.1.1.1.B.15 in the cross index.
-
Applicable
standards
or vendor documents were not
identified.
-
Conflicting requirements exit between SI-94.4 and SI-94.5.
This procedure was determined to be administratively inadequate
and required to be revised prior to startup of Unit 2.
1
SI-125;
Channel
Calibration
of
Seismic
Monitoring
!
Instrumentation
.
This procedure does not address common mode failure criteria.
_ _ _ _ _ _ _ _ _ _
-
- _ _ _ _ - _ _ _ _ _ _ - _
_ _ .
,-
..
.
13
This procedure is currently under review and a revision will'be
issued prior to Unit 2 restart.51-227.1; Post-Maintenance Response Time Test of Reactor Trip
Breakers
The following SI-1, Appendix F, Part'II issues were identified:
The SI-1 Review Checklist, Revision 3 did not address the
-
administrative adequacy appendix items F.II.1-22.
The SI-1
review
cover sheet remarks for technical
-
adequacy items
F.I.1.3.5,
et al, states that "This
procedure is not used to take credit for any TS and
includes no TS setpoints of response times."
While the
SI-227.1
may not measure TS values directly, it does
impact associated equipment in the reactor trip system.
This SI is adequate and is not required to be revised prior to
Unit 2 restart.
SI-247.100; Response Time Testing of the Engineered Safety
Feature Instrumentation
This procedure does not address common mode f ailure criteria.
This SI is adequate and is not required for Unit 2 startup.
CC-7.13.b; Offline Channel Calibration of Loop 1 Steam Generator
Level Channel IV
This procedure is under licensee review and is not required for
Unit 2 startup.
CC-5.52.b; Offline Channel Calibration of Pressurizer Level
Channel II
The SI-1 Appendix F review checklist was not correct and did not
represent the status of CC-5.52.b.
The written checklist
assumed for some items that a " rewrite" was made and would be
incorporated, and it was not.
The licensee determined that a
rewrite would be incorporated later as an enhancement.
This procedure was determined to be adequate and not required to
be revised prior to the startup of Unit 2.
CC-7.24.b; Off-line Channel Calibration of Loop 4 Steam
Generator Level Channel II
This procedure is under review and not required for Unit 2
startup.
_ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _
__m-
.
o,
of
14
~
-CC-9.5.b; Off-line Channel. Calibration of Loop 2 Generator Steam
Pressure Channel IV
This procedure is under review and not required for Unit 2
startup.
IMI-92; NIS Power Range Channel Functional Test
No SI-1 Appendix F checklist was provided for IMI-92.
IMI-92 is being reviewed by the licensee and is not PORC
approved.
RT-7.14; Response Time Test Procedure of Loop 1 Steam Generator
Level
This procedure doas not address common mcee failure criteria,
which is an SI-1, Appendix F, Part II issue.
This.SI is adequate and is not required for Unit 2 startup.
RT-6.23; Response Time Test Loop 4 Reactor Coolant Flow Channel
II
This procedura does not address common mode f ailure criteria
which is an SI-1, Appendix F, Part II issue.
This SI is adequate and is not required for Unit 2 startup.
RT-7.24; Response Time Test Loop 4 Steam Generator Level Channel
II
151s procecure aoes not address common mode failure criteria,
l
wid th i:, ar. 5; 1, Appendix F, Part II issue.
P4
S! is adequate and is not required for Unit 2 startup.
i
Ri-9.3; Response Time Test Procedure of Loops 1 and 2 Steamline
Differential Pressure Channel I
This procedure does not address common mode failure criteria,
which is an SI-1, Appendix F, Part II issue.
q
This SI is adequate and is not required for Unit 2 startup.
RT-9.9; Response Time Test Procedure of Loops 3 and 4 Steam
Differential Pressure Channel I
l
This procedure does not address common mode failure criteria
l
which is an SI-1, Appendix F, Part II issue.
1
_ _ _ _ _ _ _ - _ - _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ . _ _ - _ _
-
- - _ - _ .
L.
' .
15
This SI is' adequate and is not required for Unit 2 startup.
RT-11.8; Response Time Test of Delta T/T Average Channel IV Rack
13
SI is adequate and is not required for Unit 2 startup.
Response Time Testing Engineered Safety Feature
Actuation Slave Relay K605
SI is adequate and is not required 'for Unit 2 startup.
Response Time Testing Engineered Safety Feature
Actuation Safety Injection Signal with Station Blackout
The following SI-1, Appendix F, Part II' issues were identified:
TS 3/4.8.1.2 is not referenced in this RT.
-
The RT does not verify for redundant system configurations.
-
The RT is adequate and is not required for Unit 2 startup.
RT-916; Response Time Test Procedure of the Refueling Water
Storage Tank Level Channel IV
This procedure does not address common mode failure criteria,
which is an SI-1, Appendix F, Part II issue.
This SI is adequate and is not required for Unit 2 startup.
,
Conclusions for this section of the review are as follows:
1
(1) Several issues were identified by the licensee prior to the NRC
j
concerning those review items in the SI-1, Appendix F, Part II.
Both the licensee and the NRC have determined that items in this
,
review area may affect the ability of the surveillance to
i
perform its intended function.
The licensee currently has
j
corrective actions in place to ensure that these type issues
]
will not invalidate any procedures. The SI-1, Appendix F, Part
II review corrective actions will be inspected during the next
NRC surveillance instruction inspection currently scheduled for
the month of July 1987.
In addition the licensee's submittal was reviewed to determine
what type of review and revision the Section
"B" type procedures
should have received.
The licensee stated in its SI-1 program
submittal that " Instructions not required for startup and
operation, but which have been or will be used to verify ability
i
to restart, will be reviewed to confirm that the instruction was
adequate for its last performance and fulfilled TS surveillance
requirements." The licensee did not describe a review process
_ - _ _________-_____ __-_.
_ _ _ - _ _ _ _ _
__-
..
.
16
different than that for Appendix A procedures. If credit is to
be taken for a previous performance of the procedure then the
procedure is being "used" to verify ability for restart and
should go through a comprehensive review. This was discussed at
the exit and the licensee agreed in the exit meeting to submit a
description of what type of review Appendix "B" procedures were
to get prior to the startup of Unit 2.
(2) Two procedures SI-153.1 and SI-94.4 were determined by the
licensee and the NRC to be inadequate and were discussed with
various levels of TVA management.
c.
The following instructions were reviewed and observed during perform-
ance in the field. The procedures that were performed by the licensee
were PORC approved and were either previously licensee validated or
were to be validated in the future.
SI-21; Auxiliary Building Gas Treatment System
The inspector. reviewed a partial performance of this procedure
to determine it's technical adequacy. The following comments
resulted:
-
Step 5 of the procedure contains the notation " Note: Shut
down fuel handling exhaust f an(s) if running (so heater
flow switch will make)." This should be included as a step
requiring a sign-off rather than inserted as a note to the
operator and an additional step included to re-align this
fan when restoring the system.
-
Step 7.2 requires making an entry in the "QM Tracking Log."
At the present time, this log is non existant per the
operator.
The procedure was determined to be technically adequate as
performed.
However, the two SI-1, Appendix F, Part II issues
require corrective action by the licensee.
IMI-26; High Pressure Fire Protection System
This procedure has not been reviewed through the procedure
review and update program.
The inspector observed calibration of pressure switch (system
- 26, address 0252) performed on Work Request #B232420.
The
procedure used did not provide step-by-step instructions for the
performance of the calibration.
SI-46.3; Component Cooling Water Pump 2A-A
_ ______-____-_______________ _ _ _ __-_
- _ _ _ _ _ - _ _ . _ _ _ _ - _
..
.
17
!.
The operators failed to observe precaution 4.2 which required
the operator to assure the heat exchanger in use for RHR cooling
was not used for the pump test. This error was not noticed until
pointed out by an NRC inspector just prior to performing the
test.
This is a violation and is discussed in more detail in
Inspection Report 327,328/87-30.
SI-50; 72 Hour Chemistry Requirements
No technical problems were noted by the inspector.
This
procedure was determined to be adequate.
SI-64; Valve line-up for the Boric Acid System
The inspector performed an in progress review of the activities
specified in this procedure and determined the procedure to be
adequate.
SI-151; Six Month Requirement on Hydrogen Recombiner System
The inspector determined the procedure to be technically
adequate and met the surveillance requirements of TS 4.6.4.2.a.
However, a problem in wording was noted during performance.
Step 6.1.9 reads as follows: " Verify that after the recombiner
temperature has stabilized greater than or equal to 700 degrees
F,
each thermocouple reads within 50 degrees F in either
direction when compared to the other two thermocouple..."
The operator and two procedure reviewers could not interpret the
statement "in either direction" for the 50 degree requirement.
The procedure is currently being revised to improve, among other
things, the wording in Step 6.1.9.
This is considered to be an
SI-1, Appendix F, Part II issue for which the licensee is taking
corrective action.
SI-180; Fire Pump Start Test, for 1B-B Fire Pump
l
No discrepancies were noted during the performance of the
procedure.
The procedure is adequate.
IMI-99, FT 6.11; Functional Test of Reactor Coolant Loop 4 Flow
!
Channel II
The inspector performed an in progress review of the activities
specified in this procedure and determined the procedure to be
technically adequate.
IMI-99, FT 7.8; Functional Test of Steam Generator Level Loop
Channel III
_ _ - _ _ _ _ _ _ _ _ _ _ ___- .__-_--____ _ -
_ _ _ _ - _ _ _ -
. _ _ . _ _ _ _ _ _
<
.-
18
The. inspector performed an in progress review of the activities.
specified in this procedure and determined the procedure to be
technically adequate.
SI-100.1; Vital Battery System Weekly Inspection
The inspector noted no technical deficiencies with this
procedure performance and determined the procedure to be
adequate.
SI-102 E/M; Diesel Generator Monthly Electrical Inspections for
2B-B Diesel Generator
The inspector noted no technical deficiencies with this
procedure performance and determined the procedure to be
adequate.
SI-7; Electrical Power System, Diesel Generator (DG) 2B-B
The inspector noted r.o technical deficiencies with this
procedure performance and determined the procedure to be
,
l
adequate.51-102 M/M; DG Monthly Mechanical Inspections for 2B-B DG
A failure to adequately control plant activities was identified
I
by an NRC inspector, in that Step 6.2 of SI-102 M/M requires the
l
starting air isolation valves to be closed during performance of
Steps 6.2 - 6.16 to prevent the DG from being started or rolled
during the preliminary checks. The requirement is for personnel
and equipment protection during the time when some of the DG
inspection covers are opened for inspections. Step 6.17 returns
the air start isolation valves to their normal open position.
During the performance of these procedural Steps, SI-166.36,
l
listed below, was being performed in parallel.
Step 4.2.3 of
'
SI-166.36 required these valves to be opened in series after
test gages were installed downstream of the valves. This was
accomplished by the operator prior to Step 6.17 in SI-102 M/M.
This conflict in the performance of these two procedures in
parallel was identified to the personnel involved by an NRC
inspector present duting the testing. This is discussed in more
detail in Inspection Report 327,328/87-30.
SI-166.40, Pressurizer PORV and Block Valve Operability Test
The inspector reviewed the performance of this test and
determined the following problem areas:
The Pressure Operated Relief Valve (PORV) did not meet the
-
time response requirement for stroke testing (step 3.5).
q
It appeared that in operations mode 5, the valve will not
l
. - - _ _ _ - _ _ _ _ _ _ - _ _ _ - - _ _ _ _ _ _ _
. _ - _ .
.
.
19
stroke in the required time frame as a result of the low
system pressure.
-
The procedure, Step 3.5,
specified that the temperature
alarm (XA-55-5A, window #30 from TE-68-331)
should
annuniciate at 20 degrees above ambient. A review of the
instrument calibration records by the plant
operators
revealed that the alarm should annunciate at 140 degree F.
(Work Request, No. 8248159, was initiated to evaluate the
condition.)
This procedure was determined tc be inadequate because it was
unable to perform its intended function when it was subjected to
the specific plant conditions that existed during the observed
performance. The procedure was written to allow its performance
during mode 5.
However, no consideration was given to the
unusually low RCS pressure in effect at the time this test was
performed.
This is the third example to be included under
Unresolved Item 327,328/87-36-02.
SI-166.36; Diesei Starting Air Valve Test
The inspector noted no technical deficiencies with this
procedure.
Control of plant activities issues identified in
SI-102 M/M above and failure to comply with a required step in
SI-166.36 were identified and are further discussed in Inspec-
tion Report 327,328/87-30.51-234.6; TS Fire Detectors
This test was being run as a conditional surveillance to retest
panel 615 af ter repairs resulting from water damage.
When the
test deficiency log was reviewed there were three deficiencies
against this surveillance. The deficiencies were:
-
Computer
printer
which
would
prevent
verification of alarms.
-
Module DM-30R was not wired per DWG's 45W1699-26,27.
-
Improper voltage across TB907-2 and TB907-6.
There was no documented evaluation (such as a justification in
the deficiency dispositon) whether continuing the test before
the deficiencies were corrected would invalidate the test.
A
review of SI-1 indicated that once a ceficiency was documented
on a work request (WR) the SI could be closed and the deficiency
tracked by the WR.
The administrative controls of SI-1 are inadequate in the area
of test deficiencies in that:
-_
- __ - ___-___ _ _ _ _ _ _ _ _ _ - _ _ _ - _ ____ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _
_ _ _ _
. _ _ _ _ _ _ _ _ _ _ _
_ _ _ _
- ___- - __
_
.
.-
20
Testing is . allowed to continue with known de'iciencies
-
against the equipment without an evaluation by a competent
authority on the affect the deficiencies would have on
the intent of the test.
The SI is allowed to be closed and the equipment declared
-
operable with known deficiencies against the equipment.
The above are examples of where SI-I does not provide appro-
priate controls on test deficiencies during SI performance.
This same issue was identified by the licensee's SIVV group.
Credit will be allowed for licensee corrective actions.51-297; Pressurizer Heater Capacity Check
The inspector reviewed in progress performance of this procedure
and found no technical inadequacies.
This procedure was
determined to be adequate.51-400.1; Liquid Waste Effluent Batch Release-Monitor Tank
The inspector observed in progress performance of the procedure
and found no technical inadequacies.
This procedure was
determined to be adequate.
SI-257; Periodic Functional Of RCP Protective Devices
The inspector observed in progress performance of'the procedure
and found no technical inadequacies.
This procedure was
determined to be adequate.
SI-62; Containment Vacuum Breakers
The inspector observed in progress performance of the procedure
and found no technical inadequacies.
This procedure was
determined to be adequate.
SI-104; Auxiliary Building Crane Interlocks
The inspector observed in progress performance of the procedure
and found no technical inadequacies.
Thi s procedure was
determined to be adequate.
SI-102; E/SA Diesel Generator Semi-Annual Electrical Inspection
l
The above procedure was observed and the follov,ing deficiencies
were identified:
-
Name of switches in procedure do not match the labels on
the switches used during the test (e.g., Remote-local in
l
_ _ _ - _ _ _ _ _ _ _ _ _ _
_ - _ _ _ _ _ _
. _ -
._
_-
_
.
.
21
l
procedure but panel label is lockout relay). (Note: This
procedure had not yet been reviewed by the SI Program.)
-
During the first attempt to run section 6.2 the craftman
failed to record the time it took to receive five start
attempts (5 + 1/2 seconds required). The test was stopped
in mid-section and supervision called.
All , steps actually
accomplished to this point were not documented (e.g., the
fact that five start attempts occured).
Supervision
pointed out the SQM-1 allows the remaining steps to be
completed if a review is performed of preceeding steps,
control logic, and equipment configuration to determine
correct step to start the reperformance.
The res its of
this review are to be presented to the responsible Foreman
or the Shift Engineer who is to ensure the actions planned
are correct.
Following the Shift Engineer's review, the
operator realigned the lockout relay so that he could
,
recommence Section 6' 2.
During the second run of section
.
6.2, the value recorded for the time to receive five start
attempts did not meet the acceptance criteria (i.e. ,. 5 +
1/2 seconds allowed, 5.6 seconds measured).
The craftsman
in charge of the test did not document the test deficiency
at the time the deficiency occurred.
These type of
problems have been addressed by the licensee in the newly
implemented SQA-1, System of Standard Practice.
Credit
will be given to the licensee for identification and prompt
corrective action.
-
The craftsman was questioned about the training he had
received in the administrative requirements of SQM-1 and
SI-I.
The craftman's supervisor and section training
,
representative were contacted to determine if objective
evidence was available to show that training had occurred.
Objective evidence was not supplied by the licensee to
support the training of the craftsman directing this
specific test.
10 CFR Part 50, Appendix B, Criterion 2
" Quality Assurance Program, requires a program that
provides for indoctrination and training of personal
performing activities affecting quality as necessary to
assure
that
suitable
proficiency
is
achieved and
maintained. This is an example of a failure to provide a
program to train test personnel in the administrative
requirements of the surveillance program and is another
example of Unresolved Item 327,328/87-30-05.
SI-8; Boric Acid Flow Paths-Temperature Verification
Recorders which are required for temperature readings in this
procedure are not correctly identified in the procedure.
The
procedure identifies the recorders by the panel number that it
serves and not by the label that is affixed to the recorder
_ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _
-_-
_
. _ _ _
_ _ - - _ _ _ _ -
..
.
22
itself.
These labeling inconsistencies have been identified by
the licensee and a revision to SI-8 is in progress.
There were no technical deficiencies identified in the procedure
and the procedure was determined to be adequate.
SI-166.19; AFW Check Valve Test During Operation
The performance of this procedure was suspended because it
conflicted with SI-75 which was already in progress.
It
appeared that an inadequate review of SI-166.19 was conducted by
the shift engineer who approved the performance .of SI-166.19.
This test was one of the tests that was rescheduled to allow the
NRC to observe its performance.
During the performance of SI-166.19, operators attempted to
isolate 2-LCV-3-148A even though level controller LIC-3-148 was
removed from service in accordance with SI-75. The continuation
of SI-166.19 would have required the discontinuation of SI-75
which was in progress.
The testing interferences were not
identified by the shift engineer or the operator until the level
control valves were manipulated and the NRC inspector questioned
the operator.
This type of failure to control plant activities
has been addressed by the licensee in the newly implemented
SQA-1, System of Standard Practice. Credit will be given to
the licensee for identification and prompt corrective action. A
table-top review of SI-166.19 was completed by the inspector
using approved plant electrical and mechanical drawings and no
technical deficiencies were discovered.
This procedure was
determined to be adequate.
6,
Maintenance Observations (62700) (62703)
a.
Station maintenance activities of safety-related systems and
components were observed and reviewed as a portion of the SI review
and field observation to ascertain that they were conducted in
accordance with approved procedures, regulatory guides, industry
codes and standards, and in conformance with TS.
The following items were considered during this review:
LCOs were
met while components or systems were removed from service; redundant
components were operable; approvals were obtained prior to initiating
the work; activities were accomplished using approved procedures and
were inspected as applicable; procedures used were adequate to
control the activity; troubleshooting activities were controlled and
the repair record accurately reflected what actually took place;
functional testing and/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; QC hold points were established where
,
'
required
and were
observed;
fire
prevention
controls were
implemented; outside contractor force activities were controlled in
=
_ - _ _ - _ _ _ _ - - _ _
- _. ___- ____ - _ ______ _ _
.
.
23
accordance with the approved quality assurance (QA) program; and
housekeeping was actively pursued.
In the areas inspected, no viclations or deviations were identified.
7.
Licensee Event Report (LER) Followup (92700)
The following LERs were reviewed and closed. The inspector verified that:
reporting requirements had been met; causes had been identified;
corrective. actions appeared appropriate; generic applicability had been
considered; the LER forms were complete; the licensee had reviewed the
event; no unreviewed safety questions were involved; and no new violations
or deviations of regulations or TS conditions have been identified.
LERs Unit 1 (17)85-044 Safety Injection Pump Flow Above TS Limit
86-007 Failure To Test Trip Function Of Manual Safety Injection
Handswitch
86-008 Monthly Channel Check For Steam Generator Narrow Range
Remote Shutdown Instruments Not Performed
86-011 Setpoint For Containment Sump Level Was In Error Per TS86-013 Failure To Perform Adequate Testing Of ESF Systems86-014 Inoperability Of Auxiliary Building Gas Treatment System
86-015 Failure To Functional Test RCP UV And UF Devices And Breakers86-017 Failure To Test Radiation Monitors During Core Alterations86-018 Failure To Verify Indicated Power Availability Due To
Inadequate Procedure
86-023 Required Channel Calibration Of Flow Indicator Not Performed
86-027 Surveillance Requirement Cannot Be Performed For The Diesel
Generators86-028 Some Test Instruments Do Not Meet All ASME Section XI
Requirements86-031 Inadequate Procedures For Visual Local Stroke Timing Of ASME
Section XI Valves86-035 Failure To Follow A Surveillance Requirement Due To An
Inadequate Procedure
_ _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ . _ _
s
.
24
86-046 Personnel Error Resulting In Inadequate Verification Of.
Snubber Drag Force Trending
'86-051 Update On Valves Outside of Surveillance
Frequency Because Of An Inadequate Procedure
86-054 Inadequate Verification of 125 V DC Vital Battery Banks
Capacity Due To A Procedural Deficiency
86-056 Inadequate Verification Of Incore Detector Tips Removable
Contamination Levels Due To Administrative Deficiency
LERs Unit 2 (3)86-007 Procedural Error On A Surveillance Instruction Which Caused A
Technical Specification Violation
86-006 One Fire Detection Instrument Was Not Tested Because Of A
Procedural Deficiency
-87-003 Failure To Perform Inspection On ASME Section XI Equipment
Due To Procedural Inadequacy
The inspectors reviewed the following Licensee Event Reports but were
unable to close all of the LERs due to unfinished corrective actions on
- the part of- the Licensee.
The following is a list of the LERs reviewed
but not closed out with a brief description of the items needing comple-
tion prior to accomplishing the final closecut of the LER.
LERs Unit 1 (5)86-020 Failure To Perform A Quarterly Functional Test Per TS.
SI-244.2, Rev. 7, does not contain a channel functional check
for F-15-43.
SI-244 also does not contain a check for
F-15-43 although the LER states that the SI for Unit I should
be correct.
l
86-039 Two Surveillance Requirements Not Performed Because Of
Inadequate Procedures.
This item concerns the testing of the
total interlock functions for permissive P-4 in that two of
the five functions were not checked.
The LER states that a
new procedure will be written to test the total interlock
function before unit startup.
At the present time the
procedure has not been written. This is a requirement that
'
is to be completed prior to the start up of Units 1 and 2.86-042 Two Surveillance Requirements Not Performed Because Of
Inadequate Procedures.
Licensee has requested relief from
ASME, Boiler and Pressure Vessel Code,Section XI, Subsection
IWP-3100 for several safety-related pumps because of possible
'
_ - . _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
i
- _ - _ _
_ _ - - . _ _ _ -
..
.
25
damage to the pump by throttling on the pump miniflow recir -
culation valves during the running of the tests.
This relief
has not yet been granted from NRR.
Therefore, the corrective
action for this LER is incomplete. The corrective action of
this LER is to be completed prior to the restart of both
units.86-044 Inadequate Verification Of ECCS Flow.
Procedure SI-137.3 was
found to be inadequate in that it did not include RCP seal
pressure differential requirements.
The procedure is
currently awaiting review and approval, therefore, this LER
cannot be closed until the review has been completed.
The
corrective action of this LER is to be completed prior to the
restart of both Units 1 and 2.86-048 Inadequate Verification Of ECCS Flow Due To Procedural
Inadequacy.
SI-260.2 was found to be inadequate in that it
allowed the testing of the CCPs in other than conditions-
specified in the TS. A new procedure SI-260.2.1, is-to be
issued to cover the completion of this TS requirement in
mode 5 and SI-260.2 is to be revised as parts of the proper
corrective action for this LER.
Both procedures are cur-
rently awaiting review and approval, therefore,'this LER
c6nnot be closed until the review ha; been completed.
The
corrective action of this LER is to be completed prior to
the restart of Unit 1 only, it is not a Unit 2 restart item.
8.
Event Followup (93702, 62703)
Within the areas inspected, no deviations or violations were identified.
9.
Inspector Followup Item, Unresolved Item, and Violation Closeout
Open Items are metters of concecn to an inspector which are documented and
tracked in inspection reports to allow further review and evaluation by
inspectors.
The following open items have been reviewed and evaluated by
an inspector. The inspector where possible resolved the concern identi-
fied by evaluating licensee performance, and/or the adequacy of corrective
actions taken by the licensee in order to resolve the concern. Whe're this
was not possible, the item was reviewed (but not closed) and a brief
description of the current status of the the item was included.
Unresolved items are matters about which more information is required to
determine whether they are acceptable or may involve violations or
deviations.
Certain Unresolved items were reviewed and sufficient
information provided by the licensee in order to close the issue based on
the review described in the paragraph above.
Violations for which additional licensee corrective was required were
i
reviewed based on the review described in the first paragraph of this
section.
_
_ _ - _ _ _ _ _ _ _ _
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.
26
Items Which Have Been Closed
Violation 328/84-18-01; The licensee failed to provide within procedures a
step or steps to ensure that safety subsystems, such as portions of the
AFW system, are properly removed and restored to service with independent
verification during the performance of abnormal valve alignment. The NRC
inspector's review of corrective steps taken by the licensee indicated
satisfactory results were achieved.
Violation 327,328/84-18-02; The licensee failed to establish adequate
measures to assure that the design basis requirements, which were
specified in the licensee's FSAR paragraph 10.4.7.2.3 for the AFW system,
were correctly translated into specifications, drawings, procedures,'and
instructions.
The licensee's response of October 19, 1984, denied the
5
violation occurred and provided the basis for the denial .
The NRC's
response of July 10, 1986 indicated that existing regulatory requirements
did not clearly warrant enforcement action in this matter; therefore,
deleted this violation from NRC records.
Unresolved Item (URI) 328/84-18-03; Concerned the inoperability of main
feed pump "A"
control circuiting on June 30, 1984.
The NRC previously
noted in a July 10, 1986, response letter that a review of this matter
had concluded that the licensee's interpretation of applicable TSs were
correct and this unresolved item was administratively closed.
Inspector Followup Item (IFI) 328/84-18-04; Concerned the need to upgrade
operator training on the AFW system initiating circuitry and the SST
logic.
The NRC inspector determined af ter review that the licensee's
training letter appears to adequately address this subject.
IFI 327,328/86-44-03; The licensee's special report issued by the
Surveillance Review Committee dated July 10, 1986, involved approximately
15 potentially reportable TS issues and approximately 160 enhancement
items. The enhancement items were considered an inspector follow-up item.
A review of the licensee's Commitment Action Tracking System (CATS)
indicates that the 160 enhancement items plus 28 additional items have
been included in the CATS and being tracked to closure.
The inspector's
review of those items that have been closed, indicated closures appear to
be technically adequate.
Violation 327,328/85-46-04; The licensee inadequately established or
maintained surveillance instructions and system operating instructions
(i.e.,
inadequate acceptance criteria in SI-256; fuses with incorrect
amperage ratings listed in SOI 30.6, and IMI-99 prescribed inadequate
measuing and test equipment). The NRC's review of revised procedures and
the licensee training on the subject has provided adequate corrective
measures.
IFI 327,328/86-32-01; The TS requires testing of each diesel generator by
simulated loss of offsite power in conjunction with an ESF. The licensee
states initiation of both signals will accomplish no more than either
-
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27
l'
signal independently. A TS change was requested and granted to delete
this test requirement (TS change 107).
l
IFI 327,328/86-32-02; The TS requirement 4.8.1.1.2.d.4 was incorporated in
i.
SI-26.2A, Revision 13, but was not in SI-26.1A and B.
The NRC inspector's
review of SI-26,1A and B has determined that TS requirement 4.8.1.1.2.d.4
and 4.8.1.1.2d.7 have now been incorporated.
l
IFI 327,328/86-32-03; SI-40, SI-128, and SI-129, (Pump and discharge pipe
venting requirements for centrifugal charging pump residual hear removal
pumps, and safety injection pumps) do not list. acceptance criteria for
venting.
The inspector's review of these revised sis indicates that
acceptance criteria has now been included.
.
1
Violation 327,328/86-05; Failure to follow the requirements of SI-45.1 and
'
The NRC inspector discussed the issue with licensee engineers,
reviewed the revision to the sis and has determined that the pumps were
not inoperable during the period in question and that the procedure now
provides acceptable guidance for determining pump performance.
IFI 327,328/86-34-06; SI-137.3; Measurement of the controlled leakage to
the reactor coolant pump seals, did not account for any changes in the
position of valve FCV-62-87. The licensee's revised SI provided adequate
corrective action.
IFI 327,328/86-32-08; Review of the FSAR's minimum ECCS head capacity
curve revealed that the head capacity curve submitted as Amendment 3 to
the FSAR did'not cover the full range of SI pump ECCS flow rates. The NRC
inspector determined from his review of Amendment 4 to the FSAR that the
FSAR and SI-260.3 pump head curves are the same.
IFI 327,328/86-32-10; The licensee's channel calibration method specified
by IMI-99-CC-11.5B for the OPDT and OTDT reactor trip channels did not
measure a dynamic response of the OPDT and OTDT.
Review of the revised
procedure indicates adequate test coverage for measuring response time.
IFI 327,328/86-32-11; IMI-99-RT-11.5 response time test method did
not time the interval from when all monitored parameters of OTDT and
low-low Tavg exceed their trip setpoint at the channel sensor.
Review of the revised procedure indicates adequate test coverage for
measuring response time.
IFI 327,328/86-59-02; SI-40, Revision 35, Centrifugal Charging Pump
Test, and SI-37, Revision 27, Containment Spray Pump Test, did not
clearly cover paragraph IWP-4220 and IWP-4520 of ASME Section XI.
The licensee's clarification of these issues appears to be adequate
and review of SI-40 and SI-37 indicate the intent of ASME Section
XI requirements have been considered.
j
IFI
327,328/86-49-03;
The licensee identified,
through the SI-1
Appendix F SI Review Program, that certain pump parameters may not
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- _ _ - _
~.
.
28
have been maintained during the performance of SI-130.2, SI-130-130.1, and
SI-129.
This NRC inspector's review of the revised procedures indicated
that deficiencies noted during the SI-1 Appendix F reviews were
incorporated and the procedures appear to be adequate.
Several other
pump testing issues were identified in the subject IFI. Those issues were
closed in 327,328/86-60-11 and were not reviewed during the closure of
this issue.
IFI 327,328/86-32-09; SI-501 did not include sufficient detail to make
instruction clear to the performer.
Also, component labeling was not
consistent with procedural terminology.
The licensee's SI-I Appendix F
review and walkdown of SI-501 prompted procedural changes and installation
of component labeling which is consistent with procedural terminology.
i
The licensee s corrective action appears to be adequate.
IFI 327,328/86-31-08; AK and AKR type Low Voltage Power Circuit Breakers.
The licensee's document search indicates that this 10 CFR Part 21 item has
not been evaluated at the facility. The vendor letter dated September 13,
1985, indicated that the licensee was to be informed in a service letter.
The licensee is determining if the problem was reviewed and dispusitioned
in the Division of Nuclear Engineering.
It was determined by the licensee
that the problem is not applicable to the facility and therefore this item
is considered closed.
IFI 327,328/86-60-10; SI Program. This IFI addressed several other issues
which were grouped together in order to provide an overall look at the
'
licensee's SI Review and Revision Program. This item is complete with the
exceptions listed as open in the LER, IFI, UNR and Corrective Action
sections of this report. Those items will be followed individually. This
item is closed.
Items Remaining Open
URI 327,328/86-32-04; Pump performance data sheets from SI-45.1 and SI-46
indicated a common practice of lining-out and initialing original data,
then recording new data without documenting why the changes were made.
The licensee is still evaluating this practice to determine how wide
spread the issue is and how to handle future occurrences.
Corrective
action must be complete prior to restart of both Units 1 and 2.
IFI 327,328/86-32-12; Scaling data sheets in TI 41-68 contain several
,
'
scaling factor errors.
The inspector reviewed the draft revision of TI
41-68 which appears to address noted errors.
Pending review of an
approved revision of TI 41-68 thi s item will remain open.
Corrective
action must be complete prior to restart of both Units 1 and 2.
IFI 327,328/86-49-02; The licensee identified during a review of an
internal tracking system, that TS surveillance 4.7.9.e.3 and 4.7.9.f may
not have been complied with during the implementation of SI-162.2.
Additionally, during the performance of IMI-99.cc-12.9 the power operated
relief valve inadvertently opened due to a procedure error.
The
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29
inspectors review of the revised procedure indicates procedural errors
were adequately corrected but more information is required to assess
!
I
licensee's' corrective actions taken in addressing TS surveillance
requirements 4.7.9.e.3 and 4.7.9.f.
Violation 327/86-20-08; Approximately 20 vent, drain and test containment
isolation valves were not verified to be in the proper position when
SI-14, Verification of Containment Integrity, was performed on May 20,
1985. ' Review of licensee's corrective actions indicate all valves were
incorporated in either SI-14.1 or SI-14.2, 'xcept for 70-763. The status
of valve 70-763 is needed in order to close this item out.
Violation 327,328/86-26-01; Failure to adequately conduct TS 4.8.3.1
surveillance requirement and failure to establish and maintain an adequate
SI.
A review of the revised sis and design drawing series which were
established to control the list of circuit breakers appears to adequately
control and address the testing of molded case and lower voltage circuit
i
breakers.
The corrective actions have been satisfactorily completed;
however, the item remains administratively open pending final enforcement
disposition.
Violation 327,328/86-44-04; The SI-1 surveillance program was inadequately
implemented in that, Step I. A.9 of SI-1 Appendix F checklist, which
requires that all instructions referenced for performance under the SI
review program be reviewed using the SI review check' list, was not
l
adequately completed for SI-102E/SA, SI-7, and SI-6.
The licensee has
revised the SI-1 Appendix F forms and has conducted training on the
subject forms. The upgrade surveillance instruction review and revision
program dated March 6,1987, appear to be comprehensive and if followed
should provide adequate results.
The item, however, remains administra-
q
tively cpen pending final enforcement disposition.
l
J
10.
Licensee Corrective Actions
j
The inspector conducted a programmatic review of the licensee's SI Review
Program to determine what corrective action Sequoyah line management had
taken in response to third party evaluations and issues. The NRC review
included a determination of the issues identified by the following groups,
whether the issue appeared to be valid and affected the Surveillance
Instruction Review Program, and a review of the licensee corrective
actions.
The New Employee Concerns Program, Watts Bar Special Employee Concerns
Program, and the Sequoyah Quality Audit SQ-CAR-86-050 (including the post
revision lessons learned)
The licensee's corrective actions resulting from CAR -86-50 appeared not
to have been effective, based on the statistical data summarized and
presented by the licensee in weekly SI program updates.
However, upon
discussion with the audit participants and SI program managers, it was
determined that the data presented in statistical form was not entirely
i
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30
useful. The SI program corrective actions implemented by the lic.ensee as
a result of the lessons. learned portion of the CAR-086-50 also appeared to
not have been effective in three areas (electrical maintenance, power
systems. operations, and operations). Again, as a result of interviews, it
was' determined that the statistical data presentec by the licensee was not
entirely-accurate.
The corrective actions implemented by the licensee as a response to the
subject CAR appear to have effectively identified general problem areas in
the SI review program and adequate corrective actions are under
negotiation between the line and QA organizations. The corrective actions
appear to have been implemented by the licensee as a result of its own
1nternal audit capabilities, and not as a result of any NRC action. A
review of the most recent' transmittal from the QA organization to the SI
Review Program line management (Martin / Nobles) dated May 26,1987 (S08
870526 808), ' identified two issues that were also identified by the NRC
i
during the performance of this inspection.
.
'
a.
The adequacy of pump flow verifications was questioned with respect
to ensuring that the indicated flow was only from the pump tested,
b.
For those systems that address vendor's recommendations in the TS or
FSAR, a justification should be auditable for those recommendations
that were not included.
In addition, for those instructions that
reference a national standard in the test, those portions of the
standard that are not included should also be justified.
Independent Review Group (IRG) Reports
The IRG is a group of reviewers operating within the SI Review Program for
a manager responsible to the lead SI Review Program line manager. The IRG
is responsible for verifying that the review performed by the SI reviewers
is completed in accordance with the SI-1 Appendix F checklist as described
in the licensee's SI Review Program submittal.
The inspector reviewed a sample of the IRG reports to determine if the
licensee had taken appropriate corrective action. The IRG report comments
appeared to be specific to certain sis and did .not appear to expand
specific issues into programmatic questions. The criteria used by the IRG
has not been consistant throughout the SI Review Program and the criteria
used now appears to differ from both the QA criteria and the Nuclear
Performance Plan Site Restart Criteria.
The criteria used by the IRG is
also extremely conservative in nature. The inspector identified only one
issue from among all the IRG deficiencies reviewed, which might have
prevented a surveillance from performing its intended function.
Surveillance Instruction Verification and Validation (SIVV) Group Reports
The SIVV group is a group of reviewers operating within the SI Review
Program for a manager responsible to the lead SI Review Program line
manager. The SIVV is responsible for verifying that the review performed
!
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w
,
.-
.
1 % .;
)
1
31
I
by the SI reviewers is technically accurate- and can be successfully
completed in the field. The observations of the SIVV Group appear to be
SI specific. However, the SIVV group came to some general conclusions in
.a letter -(Denise/Gammage) . dated May 25, 1987, (555 870525 801).
The
general conclusions appear to have had adequate corrective actions
implemented by the licensee although the actions were not completed during
'this inspection period. In addition, the following SIVV group conclusions
were also reached independently by the NRC team,
a.
SI-1, allows an action to be performed in an instruction (or
supporting instruction) to be identified as a deficiency (or not
applicable)'without disposition prior to completing the test.
'
b.
Administrative Instruction AI-13, requires the operator to place a
label on instruments affected by a specific procedure or work
request.
The issue identified by the SIVV group involved the
placement of orange instrument tags. The NRC issue was more general
and involved the control of diesel generator air start supply valves,
the placement of hold orders, and test control,
c.
The SIVV group identified that there does not appear to be a require-
ment to' double verify calculations.
The NRC identified that double
verification is apparently not completed on control drawings in the
control room (Inspection Report 327,328/87-24) and that Instrument
Maintenance calculations are not double verified (Inspection Report
327,328/87-18),
d.
The SIVV group identified that AI-9, did not clearly define what "out
of service" was. The issue involves both attendent equipment and the
use of equipment with orange instrument tags. The NRC identified the
issue as an aspect of post maintenance testing and troubleshooting
and how these activities relate to LCD compliance.
Because of the planned corrective actions and the fact that items b
and d were arrived at by the licensee prior to the NRC, no violation
will be issued.
For the issues identifed under item a above, credit
for licensee implemented corrective action will be allowed for only
the orange instrument tag issue and not for the issues of test
control and hold order use.
These issues are currently the subject of
potential escalated enforcement.
For the issues identified under item c
above, credit will not be given for licensee corrective action because the
issue was initially identified by the NRC and adequate corrective action
has not yet been implemented by the licensee.
This issue is currently
identified as an unresolved item in report 327,328/87-24.
11. Diesel Generator Surveillance Procedures
The inspector reviewed the scheduled maintenance program recommended in
the vendor manuals which included:
Instruction and Parts Manual for 400 KW Tandem Diesel Generator
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l
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_
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__
a
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e.
32
Plant, Bruce GM Diesel Inc., Cont. 92652, Rev 7.
GM-EMD Maintenance
Instruction (MI)-17.2,
Rev.
E,
Scheduled
-
Maintenance Program 999 System Generating Plants.
MI-17.2 contains the manf acturer's recoinmendation that were used by the
licensee to prepare their surveillance instructions for the diesel
generator-units.
These requirements were identified in a letter from R. V. Pierce to B. M.
Patterson dated March 25, 1987 (553 87.0325.800).
This letter has an
attached copy of MI-17.2 in which the licensee has cross referenced each
requirement listed in the MI to the corresponding licensee procedure to
ensure they contained the recommendations of the MI:
a.
SI-102 M/M, Diesel Generator Monthly Mechanical Inspections
b.
SI-102 M/A, Diesel Generator Annual Mechanical Inspections
c.51-102 M, Diesel Generator Annual Mechanical Inspections
d.51-102 E/M, Diesel Generator Monthly Electrical Inspections
e.
SI-7, Electrical Power Systems; DG
f.51-166.36, Diesel Starting Air Valve Test
g.51-102 E/A, Diesel Generator Annual Electrical Inspection
h.
SI-102 E/SA, Diesel Generator Seim-Annual Electrical Inspections
System Operating
1.
50I-82.1 through 8E.4, Diesel Generator
-
Instructions
1
MI-4.2.3 (DRAFT), Monthly Preventive Maintenance of Diesel
Engines
k.
MI-4.2.4 (DRAFT), Annual Preventive Maintenance of Diesel
Engines
1.
MI-4.2.6 (DRAFT), Two year Preventive Maintenance of Diesel
Engines
m.
MI-10.1 E/A, Diesel Generator Annual Electrical Inspections
The inspector considered the licensee's diesel generator procedures
mentioned above to be technically adequate with regard to specifying the
vendor recommendations and the requirements of TS 4.8.1.1.2.d.1.
12.
Independent Inspection of Specific Technical Issues Related to the
Surveillance Instruction and Review Program
a.
Response Time Testing of Radiation Monitors
A review of the response time testing of radiation monitors was
conducted in order to determine if the response time testing of the
radiation monitors included the log integrator circuit.
The log
integrator circuit is a contributor to the total time delay of the
instrument channel.
This issue involved a total of 12 radiation
monitor channels and their associated instrument maintenance
instructions (IMIs).
The licensee identified this issue in LER
327-87-007. It was determined that the response time testing of the
radiation monitors does not include the log integrator circuit. This
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33
issue will be followed through the resolution of LER 327-87-007.
b.
Upper Containment Pressure Transmitter Calibration
A review of the calibration of the upper containment pressure
transmitter to determine if the. test instrument and associated input
error calculations were adequate.
The upper containment pressure
transmitter'is an absolute pressure transmitter with a scale of -5 to
+60 psig.
A rs view of the setpoint methodology determined that
_
inputed errors to an aneroid type transmitter as a result of the test-
instruments was accounted for
The setpoint methodology included
barometric pressure variations in the total error calculations which
will account for' inaccuracies in the lower portion of the span,
c.
Vendor Technical Manual Validation Process
A review of the adequacy of the licensee's vendor validation process
was conducted to determine if valid vendor manual information was
being used as source documents to prepare sis.
This issue was
identified in inspection report 327,328/86-42 and in' inspectior;
report 327,328/86-01. TVA has an ongoing activity to validate vendor
manuals and to convert from an interim program of vendor ' manual
control;
d.
Operability of the Chlorine Detection System
A review of the operability of the Chlorine Detection Systef was
conducted to determine compliance with TS requirements. Three issues
involving the Chlorine Detection System (CDS) were addressed during
this review.
-
The purpose of the CDS is to isolate the control room on high
chlorine levels. The licensee performs a test using a known
concentration of sodium hypochlorite to confirm that the trip
setpoint of the detector is less than 5 ppm.
Based on the
purpose of the CDS the inspector found no evidence that response
time testing had been performed.
A response time test is
necessary to correlate the administered sample applied to the
detector, the detector trip setpoint, and the maximum allowable
chlorine concentrations in the control room (setpoint at which
the ventilation isolation is complete). With no control over
the response time of the instrument, the functional validity of
the circuit is not assured.
-
The detector setpoint test employs the use of a rotometer to
determine the flow rate of the applied chlorine test source.
The inspector reviewed the licensee's calibration process for
the subject rotometers.
No licensee calibration data could be
located.
Upon conversations with licensee management it was
determined that off-the-shelf accuracies supplied by the
rotameter vendor are used in the error calculation assumptions
i
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34
and that no licensee validation or calibration is performed by
the licensee's test instrument calibration facility.
As a
result, no verifications of flow rates used in the setpoint
calculations have been completed by the licensee.
-
Functional testing of the CDS was reviewed by the inspector.
This issue was identified in URI 327,328/86-32-07.
Functional
testing of a channel requires that the. alarm / trip function be
tested as part of the functional test. The URI identified the
control room isolation signal is not functionally tested using
the chlorine detector signal as an initiation signal. Since the
control room isolation is the trip function, functional testing
of the CDS is not fully implemented.
TS 3.3.3.6 states that two independent chlorine detection systems,
with their alarm / trip setpoints adjusted to actuate at a chlorine
concentration of less than or equal to 5 ppm, shall be OPERABLE.
Surveillance Requirement 4.3.3.6 states that each chlorine detection
system shall be demonstrated OPERABLE by performance of a CHANNEL
FUNCTIONAL TEST at least once per 31 days and a CHANNEL CALIBRATION
at least once per 18 months.
Contrary to the above, neither the CHANNEL CALIBRATION nor the
CHANNEL FUNCTIONAL TEST have been adeqately performed for the period
of January 1,
1982 (since the preoperational test phase) to the
present.
(Note:
one special test was performed at the request of
the NRC in 1987.) Both channels of the chlorine detection system are
considered to be inoperable at the present time, and to have been
inoperable for the period that these tests were not adequately
performed.
This is a vioiation 327,328/87-36-01.
e.51-125, Channel Calibration of Seismic Monitoring Instrumentation
The above procedure was reviewed to resolve questions over the
technical adequacy. This procedure was independently reviewed by two
NRC inspectors (see paragraph 5.b of this report). One review was
conducted to resolve concern RII-86-A-0258, and one review was
conducted during the SI Review inspection. The inspector found that
the current revision (8) did not contain a section for acceptance
criteria nor did it address common mode failure criteria.
The data
sheets for each measured variable do provide the appropriate accept-
ance criteria in the form of desired values or acceptable ranges.
The inspector sampled the values listed on the data sheets
and found them to be conservative with respect to the values listed
in the vendor technical manuals.
The licensee has identified the
lack of a designated section of an instruction for acceptance
criteria as an administrative requirement in the SI-1, Appendix F,
Part II.
The licensee has also identified corrective actions to
address the resolution of SI-1, Appendix F,
Part II items. This
procedure has not completed the SI-l review process and is currently
in
revision.
Pending
licensee
corrective
action
on
the
administrative review section this item is closed.
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