ML20235W921

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Insp Repts 50-327/87-36 & 50-328/87-36 on 870526-0605. Violations Noted.Major Areas Inspected:Surveillance Program Review,Surveillance Observation,Sys Lineups,Followup of Events & Licensee Identified Items.Unresolved Item Noted
ML20235W921
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
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

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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

,

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

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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:

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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

PDR

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

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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

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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

Penetration

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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in RHR lube oil site glass.

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.,

l

4

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . _

.

.

12

The procedure does not address common mode failure.

-

SI-85.2 does not address redundant loops or equipment in

-

.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.

RT-605A;

Response Time Testing Engineered Safety Feature

Actuation Slave Relay K605

SI is adequate and is not required 'for Unit 2 startup.

RT-699A;

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

  1. 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

inoperable

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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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

'

TS 3.7.4.

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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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.

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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

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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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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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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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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

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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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