ML20209E044

Insp Rept 50-424/87-01 on 870105-09 & 12-16.Violations Noted:Failure to Follow Procedure 00404 C by Signing Surveillance Task Sheets for Class 1E 18-month Battery Insp & Maint Indicating Acceptance Criteria Met

ML20209E044
Person / Time
Site:	Vogtle
Issue date:	04/11/1987
From:	Shymlock M, Linda Watson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20209E018	List: IR 05000424/1987001 ML20209E011 ML20209E024 ML20209E044
References
TASK-1.C.2, TASK-TM 50-424-87-01, 50-424-87-1, IEIN-86-061, IEIN-86-61, NUDOCS 8704290419
Download: ML20209E044 (39)

See also: IR 05000424/1987001

Text

.

p2 Ric UNITED STATES

oq'o NUCLEAR REGULATORY COMMISSION

2

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o REGloN il

5 $ 101 M ARIETTA STREET N.W., SUITE 2900

• 8

o ATLANTA, GEORGIA 30323

s,

.....

/

Report No.: 50-424/87-01

Licensee: Georgia Power Company

P. O. Box 4545

Atlanta, GA 30302

Docket No.: 50-424 License No.: NPF-61

Facility Name: Vogtle 1

Inspection Conducted: January 5 - 9 and January 12 - 16, 1987

Inspector: h OM

L. J./ Watson, Team Leader

'/!87

Dath Signed

Team Members: B. R. Bonser

M. S. Lesser

A. R. Long

P. B. Moore

G. Nejfelt

l T. J. O'Connor

'

W. K. Poertner

M. B. Shymlock

C. L. Vanderneit

Approved By: WO

M. B. ShymlocY, Chief

M8,887

Date Signed

Operational Programs Section

Division of Reactor Safety

SUMMARY

Scope: This routine, announced inspection was conducted in the areas of

surveillance program administrative controls and implementation, maintenance

program administrative controls and implementation, Technical Specifications

applicability to as-built systems, control room activities and plant

procedures. Corrective action for findings described in NRC Inspection

Reports 424/85-36, 424/86-60 and 424/86-117 were reviewed.

Results: One violation was identified involving four examples of failure to

follow procedures. No deviations were identified.

8704290419 870417

PDR

O ADOCK 05000424

PDR

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

#*P. D. Rice, Vice President, Project Engineering

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1. • G. B. Bockhold, Jr., General Manager, Nuclear Operations

1. • T. Greene, Plant Manager

1. • E. M. Dannemiller II, Technical Assistant to General Manager, Nuclear

Operations

1. • C. E. Belflower, QA Site Manager

1. • M. A. Griffis, Maintenance Superintendent

1. • J. F. D'Amico, Manager, Nuclear Safety and Compliance

1. • W. C. Gabbard, Senior Regulatory Specialist

• C. E. Felton, Vogtle Coordinator, Nuclear Operations

• L. F. Ray, Shift Supervisor

• P. D. Rushton, Plant Training and Emergency Planning Manager

1. • W. E. Burns, Nuclear Licensing Manager

1. • R. M. Bellamy, Plant Support Manager

• T. A. Seitz, Corporate Nuclear Office of Quality Assurance

• J. E. Swartzwelder, Deputy Manager, Operations

1. • H. A. Jaynes, Maintenance Engineering Supervisor

• A. L. Mosbaugh, Assistant Plant Support Manager

• M. L. Hobbs, Instrument and Controls Superintendent

,

• R. E. Conway, Senior Vice President and Project Director

'

• J. A. Edwards, Senior Regulatory Specialist

1. • W. F. Kitchens, Manager, Operations

1. L. Russell, Operations Procedure Coordinator

d*C. F. Meyer, Superintendent, Operations

fA. Caudill, Superintendent, Operations

,

1. H. Varnadoe, Plant Engineering Supervisor

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Other licensee employees contacted included engineers, technicians,

operators, mechanics, and of fice personnel.

! NRC Resident Inspectors

• J. F. Rogge

• R. J. Schepens

, +*H. Livermore

j * Attended exit interview on January 9, 1987

1. Attended exit interview on January 16, 1987

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2. Exit Interview

The inspection scope and findings were summarized on January 9 and 16,

1987 with those persons indicated in paragraph 1 above. The

inspectors described the areas inspected and discussed in detail the

inspection findings listed below. No dissenting comments were

received from the licensee.

IFI Number Status Description / Reference Paragraph

424/87-01-01 Open VIOLATION - Failure to follow procedure for

1) confirmation of test results for vital battery

surveillance (paragraph 7.a.1), 2) QA hold point

review and Shift Supervisor approval to work MWO

(paragraph 7.b.1), 3) verification by maintenance

technicians that drawings and vendor manuals were

current revisions (paragraph 8.a), 4) review and

initialing operations logs (paragraph 10.b)

424/87-01-02 Open IFI - Review of provisions for determining that

acceptance criteria are met (paragraphs 7.a.8

and 12.11)

424/87-01-03 Closed IFI - Followup on adequacy of functional tests

and work instructions for maintenance (paragraphs

8.c and 12.jj)

424/87-01-04 Open IFI - Completion of QA review of DR on mounting

of radiation monitors (paragraphs 7.b.1 and

12.kk)

424/87-01-05 Closed IFI - Determination if temporary modifications

negated surveillance tests completed after

preoperational tests (paragraphs 9 and 12.11)

424/87-01-06 Open IFI - Miscellaneous Findings on Surveillance and

Maintenance Program Review (paragraphs 7.b.3 and

12.mm)

424/87-01-07 Closed IFI - Use of Master Setpoint Document (paragraphs

12.nand12.nn)

424/86-117-01 Closed IFI - Administrative controls for independent

verification of the restoration and testing of

plant equipment did not conform to the guidance

of NRC IE Notice 84-51 (paragraph 12.c)

424/86-117-02 Closed IFI - Venting followup items including high point

vents on AFW and procedure revisions for system

venting (paragraph 12.d)

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3

424/86-117-03 Closed IFI - Procedure revisions to include adequate

subcooling margin requirements (paragraph 12.e)

-

424/86-117-04 Closed IFI - Correction of valve identification and

i system lineup discrepancies (paragraph 12.f)

424/86-117-05 Closed IFI - Correction of technical concerns in Unit

Operating Procedures (paragraph 12.g)

424/86-117-07 Open IFI - Correction of discrepancies on labeling

of valves and equipment (paragraph 12.h)

424/86-117-09 Open IFI - Correction of discrepancies in RVLIS

surveillance procedure and followup on vendor

recommendations (paragraph 12.1)

424/86-117-10 Closed IFI - Procedure revision to include check of

i equipment actuation on Control Room ventilation

start (paragraph 12.j)

424/86-117-11 Closed IFI - Procedure prerequisites are general and not

well understood by operators (paragraph 12.k)

424/86-117-12 Closed IFI -

Clarification of cleanliness levels

(paragraph 12.1)

424/86-117-13 Closed IFI - Review of events covered by Abnormal

Operating Procedures (paragraph 12.m)

IFI - Licensee to review annunciator response

424/86-117-14 Closed

j procedures for technical adequacy, walkdown

ARPs and revise ARPs involving annunciators

, on the main control board, as appropriate,

prior to fuel load. Remaining ARPs to be

reviewed within 90 days (paragraph 12.n)

!

424/86-117-15 Closed IFI - Resolution of ISI test data for CCW pump

(paragraph 12.0) ,

424/86-117-16 Closed IFI - Resolution of acceptance criteria for

RHR differential pressure on recirc flow

(paragraph 12.p)

424/86-117-17 Closed IFI - Resolution of water hammer in NSCW ESF

chillers (paragraph 12.q)

424/86-117-18 Closed IFI - Review of implementation of the surveil-

lance program administrative controls and

tracking system (paragraph 12.r)

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424/86-117-19 Closed IFI - Review of test control and configura-

tion control for surveillances performed

prior to release to the Operations Department

(paragraph 12.s)

424/86-117-20 Closed IFI - Revise procedures to clarify use of

Staggered Test Basis for determining frequency

of test (paragraph 12.t)

424/86-117-21 Closed IFI - Review of the justification for the use

of pre-operational tests to meet surveillance

test requirements (paragraph 12.u)

424/86-117-22 Closed IFI - Corrective action to assure control of

4 twelve hour surveillances (paragraph 12.v)

424/86-117-23 Open IFI - Resolution of various technical issues

in regard to surveillance procedure adequacy

(paragraph 12.w)

424/86-117-24 Closed IFI - Licensee to implement operational phase

corrective and preventive maintenance program

(paragraph 12.x)

424/86-117-25 Closed IFI - Resolution of Technical Specification

3/4.7.5 wording

the Ultimate Heat in regparagraph

Sink (ard to availability 12.y) of

424/86-117-26 Closed IFI - Corrective action for locking or system

lineup verification of boron injection flowpath

< valves (paragraph 12.z)

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424/86-117-27 Open IFI - Followup on surveillance procedures

which have not been identified as complete

, on the Technical Specification / procedure

i cross reference tracking list and review of

completed cross reference tracking list

-

(paragraph 12.aa)

424/86-117-28 Closed IFI - Procedure revision for consistent defini-

tion of surveillance test completion date and

time (paragraph 12.cc)

424/86-117-29 Closed IFI - Review of implementation of special

triggering mechanisms to assure completion of

special condition surveillances (paragraph

12.dd)

424/86-117-30 Closed IFI - Controls on location of BOP operator

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(paragraph 12.ee)

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424/86-117-31 Open IFI - Verification of key control and access

to plant equipment by operations staff (para-

graph 12.ff)

424/86-117-32 Closed IFI - Revise TS and procedure for 18 month check

of reactor trip breaker UV and shunt coil trip

(paragraph 12 99)

424/86-117-33 Open IFI - Resolution of miscellaneous technical

concerns on operating procedures (paragraph

12.hh)

424/86-60-10 Closed IFI - Adequacy of shift turnover procedures

(paragraphs 10.b and 12.00)

424/86-96-05 Closed IFI - Review of completed surveillance procedures

(paragraph 12.bb)

TMI It e T.C.2 Closed Shift Relief and Turnover (paragraphs 6 and 10.b)

Although proprietary material was reviewed during the inspection, no

proprietary material is contained in this report.

3. Licensee Action on Previous Enforcement Matters

This subject was not addressed in the inspection.

4. Unresolved Items

]

No unresolved items were identified during the inspection.

5. List of Abbreviations

i ACCW(S) Auxiliary Component Cooling Water System

AFW Auxiliary Feedwater System

A0P Abnormal Operating Procedure

ARP Annunciator Response Procedure

BIT Boron Injection Tank

B0P Balance of Plant

CBCS Containment Building Cooling System

CCP Centrifugal Charging Pump

CCW(S) Component Cooling Water System

CSS Containment Spray System

CVCS Chemical and Volume Control System

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DR Deficiency Report

ECCS Emergency Core Cooling System (s)

EDG Emergency Diesel Generators

E0P Emergency Operating Procedure

EQ Environmental Qualification

EQDP Environmental Qualification Data Package

ESF Engineered Safety Feature

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F Degrees Fahrenheit

FSAR Final Safety Analysis Report

HFAS High Flux at Shutdown

HVAC Heating, Ventilation and Air Conditioning

HX Heat Exchanger

IEN NRC Office of Inspection and Enforcement Notice

IFI Inspector Followup Item

IST Inservice Test

LP Lineup Procedure

MDAFW(P) Motor Driven Auxiliary Feedwater (Pump)

MLB Monitor Light Board

M0V Motor Operated Valve

MSIV Main Steam Isolation Valve

MWO Maintenance Work Order

MWPG Maintenance Work Planning Group

NLO Non-Licensed Operator

NPMIS Nuclear Plant Maintenance Information System

NRC Nuclear Regulatory Commission

NSAC Nuclear Safety and Compliance Section

NSCW Nuclear Service Cooling Water System

P&ID Piping and Instrumentation Diagram

PORV Power Operated Relief Valve

PRZR Reactor Coolant System Pressurizer

QA Quality Assurance

RCS Reactor Coolant System

RER Request for Engineering Evaluation

RHR Residual Heat Removal System

R0 Reactor Operator

RVLIS Reactor Vessel Level Indication System

RWST Refueling Water Storage Tank

SI Safety Injection

SIS Safety Injection System

SG Steam Generator

S0P System Operating Procedure

SS Shift Supervisor

SSMP System Status Monitoring Panel

STS Standard Technical. Specifications

TCP Temporary Change to Procedure

TDAFW(P) Turbine Driven Auxiliary Feedwater (Pump)

TS Technical Specification

UOP Unit Operating Procedure

VCT Volume Control Tank

6. Review of TMI Items (TI 2515/65)

(Closed) TMI Item I.C.2. Shift Relief and Turnover. The inspector ,

reviewed the implementation of the requirements of TMI Item I.C.2 and i

determined that the licensee had completed the actions necessary to meet I

these requirements. This review is documented fi paragraph 10.b of this i

report. TMI Item I.C.2 is closed.  ;

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7. Surveillance Program and Procedure Review (42450B)

During the inspection ending December 12, 1986, the inspectors had

determined that the licensee had not yet fully implemented the surveil-

lance program administrative controls except on a small number of systems

which had been accepted by the Operations Department. This item had been

identified as IFI 424/86-117-18. During this inspection, the inspectors

reviewed the implementation of the surveillance program and a number of

additional surveillance test packages. Although several concerns and

one example of a failure to follow procedure were identified; in general,

the results of this review indicated that the surveillance program was

adequately implemented. The review conducted is documented below. IFI

424/86-117-18 is closed,

a. Review of Completed Surveillance Packages

The inspectors reviewed completed active surveillance packages. The

surveillance reviews were performed to verify that specific controls

were established and the surveillance system was working in accord-

ance with procedure 00404-C, Surveillance Test Program. The

inspectors reviewed the following:

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System was readied by Operations before performance of the

surveillance.

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Prerequisites were completed and if not completed, adequate

justification was provided for prerequisites which were

marked not applicable.

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All procedural steps were completed or marked appropriately.

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Acceptance criteria were met and completed surveillances

were included in the surveillance tracking system.

- Data packages supported the acceptance criteria.

- Task sheets were attached and completed in accordance with

procedure 00404-C, Surveillance Test Program.

-

Appropriate reviews were completed as required.

The surveillance packages reviewed were:

SURV. TASK TITLE COMPLETED DATE

14225-101 Operations Weekly Surveillance Logs 1/14/87

14235-102 On Site Power Distribution Operability 1/10/87

Verification

14420-101 Solid State Protection System Train A 1/01/87

(B) Operability Test

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14420-102 Solid State Protection System Train A 1/10/87

(B) Operability Test

14423-106 Source Range NIS Analog Channel 1/14/87

Operational Test

14805-101 Residual Heat Removal Pump and Check 1/09/87

Valve Inservice Test

14811-101 Boric Acid Trant.fer Pumps and Discharge 1/08/87

Check Valves Ir. service Test

14850-102 Cold Shutdown Valve Inservice Test 1/08/87

14890-1 Diesel Generctor Operability Test Not recorded

14895-101 ECCS Check Valve Refueling Inservice 9/27/86

14896-101 ECCS Check Valve Cold Shutdown Inservice 9/22/86

14980-111 Diesel Generator Operability Test 1/09/87

14980-1 Diesel Generator Test Not recorded

(Fuel Oil Sampling for Water)

24342-1 Pressurizer Level Control F-121 Not recorded

Channel Calibration

24519-101 R. C. Pressure (Wide Range) Protection I 10/21/86

P-405 ACOT and Channel Calibration

24519-103 R. C. Pressure (Wide Range) Protection I 1/07/87

P-405 ACOT and Channel Calibration

24597-1 Containment Cooling Units 5, 6, Not recorded

7 & 8 - Condensate Detection L-17094

24626-101 Containment Vent Effluent Air Particulate 1/08/87

Monitor 1RE-2565A

24681-101 Meteorological Station 10M Wind Direction 10/30/86

Channel Calibration

24684-C Meteorological Station 60M Wind Speed Not recorded

Channel Calibration

24688-101 Meteorological Station 10M Ambient and 9/12/86

and 10-60M Delta Temperature Channel

Calibration

24737-101 Time History Accelerograph AXT-19903 12/04/86

24737-102 Time History Accelerograph AXT-19903 12/04/86

24739-101 Peak Acceleration AXR-19910 1/02/87

24806-101 Refueling Water Storage Tank Level L-990 1/15/86

ACOT and Channel Calibration

24840-101 Containment Pressure High Transmitters 1/02/87

RTT Sensors PT-934

28210-101 Main Steam Line Safety Valve Test 4/86

thru 120

28211-101 RHR Suction Relief Valve Test 2/20/86

28211-102 RHR Suction Relief Valve Test 1/09/86

28215-101 Safety Relief Valve IST 1 PSV-8010A 3/04/86

28215-102 Safety Relief Valve IST 1 PSV-80108 2/27/86

28215-103 Safety Relief Valve IST 1 PSV-8010C 3/05/86

28290-101 Containment Spray Nozzle Flow Test N/A

28711-101 Diesel Fuel Oil Storage Tank Cleaning 9/08/85

28711-102 Diesel Fuel Oil Storage Tank Cleaning 9/09/85

28712-101 Diesel Fuel Oil Piping Pressure Test 3/23/84

28820-C Battery Charger Load Test Not recorded

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28905-C Motor Operated Valve Thermal Overload Not recorded

and Bypass 18 Month Test

28910-102 Class 1E 18 Mo. Battery Inspection 12/08/86

and Maintenance

28912-102 Class IE Quarterly Battery Inspection 1/02/87

and Maintenance

54708-101 Containment Isolation and Containment 10/14/86

Ventilation Isolation - Manual

Initiation

54820-101 Train "A" SI Pump Response Time Test 9/28/86

54822-101 Train "B" SI Pump Response Time Test 9/28/86

54825-101 Train "B" CCWP Response Time Test 9/25/86

The following items were identified during the inspection:

(1) On procedures 28910-101,102,103, and 104, Class 1E 18-Month

Battery Inspection and Maintenance, the inspector noted that

the recorded data indicated that intercell resistance on

rack to rack and tier to tier jumpers exceeded the Technical

Specification requirement of 50 X 10-6 ohms. The Surveillance

Task Sheets (STS), which listed the TS requirement as part of

the acceptance criteria, had in each case been signed off as

meeting acceptance criteria. The licensee was questioned about

the signoffs. The licensee stated that the engineer had signed

off the step because the excess resistance was attributed to the

cable length between the rack to rack and tier to tier jumpers.

The inspector requested the evaluation of the cable resistance

value. The licensee stated that an evaluation had not been

performed. Since the cable resistance had not been determined

and subtracted from the total resistance, the value of the cell

to cell resistance was not known.

Procedure 00404-C, Surveillance Test Program, Step 4.5.4.1,

requires an independent reviewer to confirm that test results

satisfy acceptance criteria. The reviewer signed the STS

indicating that the acceptance criteria were met.

10 CFR 50, Appendix B, Criterion V, requires that activities

affecting quality be accomplished in accordance with documented

instructions, procedures, or drawings. This requirement is

implemented by Section 17.2, Operations Quality Assurance

Program, of the FSAR. The failure to follow procedure 00404-C

to confirm that test results met the acceptance criteria for

the rack to rack and tier to tier jumpers on the vital batteries

is identified as an example of violation 424/87-01-01.

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(2) On data sheet 2 of procedure 14423-106, Source Range NIS Analog

Channel Operational Test, performed on January 14, 1987, the

normal reading taken from the Neutron Level Drawer Meter

exceeded the upper limit values given on the data sheet. A

note on the data sheet directs the test performer to add the

pre-test indication on meter NI-101 to the upper limit values

for specific switch positions given on the data sheet. This

would raise the upper limit. Nowhere on the- data sheet,

however, is the reading on NI-101 documented. This makes the

true upper limit unclear and makes it appear the procedure is

unsatisfactory when in fact it is satisfactory. The licensee

agreed to change the procedure to include the reading on NI-101

on the data sheets.

No violations or deviations were identified.

(3) On procedure 14423-106, the High Flux at Shutdown (HFAS) set-

point was not checked. A note on the proceddre stated that the

i HFAS setpoint would be set after two fuel bundles were loaded

t

in the reactor vessel. The inspector questioned the licensee

on the triggering mechanism for establishirg the HFAS setpoint.

The licensee stated it was part of startup test procedure

1. 1-500-01, Initial Fuel Load Test Sequence. The inspector

verified this and had no further comments.

1 No violations or deviations were identified.

(4) On procedure 14895, ECCS Check Valve Refueling Inservice Test,

completed September 17, 1986, required flow rates which were

marked "LATER" had been changed to specific values without a

proper procedure revision. This item had also been identified

by the licensee's QA audits and was being followed by QA.

No violations or deviations were identified.

(5) Procedure 14811, Boric Acid Transfer Pumps and Discharge Check

Valves Inservice Test, had been identified as not acceptable by

the IST group but NSAC was showing the surveillance to be

acceptable. This item was also identified in a QA audit and

was being followed by QA.

No violations or deviations were identified.

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(6) The inspector questioned the absence of dates on a number of

Task Sheets attached to active surveillances. The licensee

provided verification that the problem was corrected and the

! surveillance tracking system was working as delineated in

procedure 00404-C, Surveillance Test Program. The inspector

had no further questions.

No violations or deviations were identified.

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(7) Surveillance procedure 14896-101, Revision 0, which was

completed and reviewed by the licensee on January 12, 1987,

was not revised in accordance with the outstanding TCP, No.

14896-187-1. The flow rate criterion on Data Sheet 1, for

the emergency core cooling system (ECCS) check valve cold

shutdown inservice test, was not changed from 3,000 gpm to

3,788 gpm, as required by this TCP nor was another TCP

written to change the flow rate criterion.

No violations or deviations were identified.

(8) The inspectors noted that items 1, 4, 5, and 7 raised questions

about the reviews required to assure that acceptance criteria

were met. The review of the licensee's procedures to assure

that adequate administrative controls exist for review of

acceptance criteria and determination that the acceptance

criteria are met is identified as inspector followup item

424/87-01-02.

No violations or deviations were identified.

b. Field Review of Surveillance Instructions

The inspectors performed a field review of surveillance procedures

by observation of surveillances in progress or by walkdown of

procedures in the field. The following concerns were identified:

(1) The inspector observed chemistry technicians dismantling a

radiation monitor identified as 1RE-12444C. When the inspector

asked to review the MWO under which the technicians were

performing the work, they replied that they were dismantling

the monitor via surveillance procedure 34223-C, Rev. 1, Channel

Calibration of the Gaseous Effluent Monitors. The inspector

reviewed the procedure and associated attachments to determine

if the procedure was being followed properly. The inspector

determined that the technicians had not obtained the signature

of the shift supervisor prior to performing work or the

signature for review of QC holdpoints.

The inspector noted that, step 5.1 of procedure 34223-C,

Prerequisites, states, " Ensure a Quality Control (QC) represent-

ative has signed the checklist indicating a QC review of the

procedure for hold points. If hold points are indicated, notify

QC prior to starting." Additionally, step 5.2 states, " Notify

the Operations Shift Supervisor, or his designee, of the work

to be performed and obtain his signature authorization."

Neither of these signatures had been obtained. When the lead

technician was questioned on these steps, the technician stated

that verbal approval had been obtained from the Shift Supervisor

to perform the work.

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10 CFR 50, Appendix B, Criterion V, requires, in part, that

activities affecting quality be accomplished in accordance with

documented procedures. VEGP FSAR, section 17.2, Operations

Quality Assurance Program, also requires that activities

affecting quality be accomplished in accordance with documented

procedures. The activities described above were not accom-

plished in accordance with procedure 34223-C in that the

signature of a QC representative had not been obtained for the

hold point review, indicating that the review was not accom-

plished, and the signature of the Shift Supervisor had not been

obtained to authorize performance of the work. The inspector

later verified that the Shift Supervisor had provided verbal

approval. The failure to follow procedure 34223-C is identified

as an example of violation 424/87-01-01.

During the review, the inspector questioned whether or not the

radiation monitor was seismically and/or environmentally quali-

fied equipment and if provisions existed in the procedure to

maintain these qualifications. The inspector determined that

Vogtle administrative procedure 00350-C, required that work

performed on seismically or environmentally qualified equipment

be done under the control of an MWO. The inspector questioned

the use of surveillance procedures to control removal and

restoration of seismic and/or environmentally qualified

equipment. Resolution of this issue was identified as

IFI 424/87-01-04.

During subsequent inspections, the inspector was informed by

the licensee that radiation monitor 1RE-12444C was seismically

qualified and the technicians were not taking any special

precautions to maintain the equipment qualification. The

licensee generated Deficiency Reports (DRs) 1-87-0203, on the

disassembly of monitor RE-12444-C; and,1-82-0204, on detector

removal and reinstallation for monitors RE-0020A and RE-00208.

A Request for Engineering Review (RER) was written for problem

resolution and MW0s were written to cover the remaining work.

Regarding the concern of whether or not the EQ of the monitors

was compromised by the routine disassembly and reassembly, the

inspector reviewed the system description 9002-DRMS-002 to

ascertain what is required to maintain EQ. The system descrip-

tion indicates that no specific removal or replacement proce-

dures are required. Nomal safety precautions and general shop

techniques were adequate for this task. The portion of the

monitor that could degrade the EQ of the monitor is never

opened for these routine calibrations. Since these calibration

activitics do not directly affect the seismically sensitive

areas of the equipment, the original procedure was not clearly

in violation of administrative procedure 00350-C, which requires

MW0s to be written for work performed on seismic or environ-

mentally qualified instrumentation. However, the licensee

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stated that all procedures that affect radiation monitors that

have seismic and/or environmental concerns are being reviewed

and revised as deemed appropriate.

Procedure 39350-C, Initial Calibration of Gaseous Process

Monitors, was written to require an MWO for the removal or

reinstallation of any components on radiation monitor RE-2562.

This system is seismically qualified per FSAR Table 11.5.2-1.

Other calibration procedures will be revised similarly in the

near future to cover all of the monitors in this table. The

inspector was concerned that simply placing this caution in the

calibration procedure would not guarantee that a technician

would not start with the procedure for the removal of the

detector; then use the procedure for the calibration and find

out that an MWO was required to implement precautions so as not

to jeopardize the EQ of the equipment.

The inspector then reviewed the licensees EQ program in order to

determine whether or not it provided adequate assurance that EQ

is maintained. The inspector interviewed personnel from the

Maintenance and Engineering departments as well as the Work

Planning Group. The EQ program is implemented under procedure

20009-C, Rev. 1. The inspector found the procedure to be

satisfactory. Any equipment that must be EQ had an associated

package of information called the Environmental Qualification

Data Package (EQDP). These EQDP's were numbered and controlled

'

documents. Each package was divided into nine parts. The parts

are:

(a) EQDP equipment identification list

(b) Environmental summary sheet

(c) NUREG 0588 Checklist

(d) Master listing - seismic

(e) Seismic qualification and recorder data sheets

(f) Calculations

(g) Maintenance / replacement information

(h) EQ design change signoff form

(1) Miscellaneous information

The inspector reviewed four EQDP's: Relief Valves; Radiation

Monitors; Limitorque Valves; and Rosemount Transmitters. The

inspector determined that the packages were comprehensive and

found the information easily accessible.

. .

_

14

The inspector reviewed three procedures to determine if the EQDP

information had been implemented into these procedures. These

procedures were: 22402-C, Rosemount Transmitter Removal and

' Reinstallation; 28211-C, Relief Valve Test Procedure; and

25240-C, General Bolted Flange Torquing Procedure. All of

these procedures compared favorably with their respective EQDP.

The inspector reviewed the licensee's Nuclear Plant Maintenance

Information System (NPMIS) to observe how EQ equipment was

flagged to prevent compromise of the EQ requirements. All

equipment had a safety classification that was reviewed whenever

an MWO was written against the equipment. In accordance with

Regulatory Guide 1.60, Design Response Spectra for Seismic

Design of Nuclear Power Plants, the licensee uses a project

classification matrix (Table C13-1 from the VEGP Project

Reference Manual) that delineates what safety classification

code is used to designate safety related equipment and whether

the equipment is EQ or not. All of the equipment with a safety

classification that indicates either seismic or environmental

qualification must be reviewed by QC. In addition, the Work

Planning Group engineer and the Environmental Qualification

Group engineer must both sign off on any EQ equipment that

all proper reviews have been performed, the EQDP had been

referenced, and the installation / replacement documents are

accepta,ble.

Finally, the inspector reviewed constructica documents to

determine if the equipment had been installed correctly. The

most important aspect of the seismic qualification of the

radiation monitors is the e, led upon which they are mounted

during normal operation. All seismic modeling of the equipment

was performed assuming that the sled was instaited the way that

it was designed. The inspu, tor found that probNms had occurred

with the installation of the sled. These are detailed in

Readiness Review finding M-13. Correspondence from F. B. Marsh

of Bechtel Western Power Division to J. A. Bailey of Southern

Company Services discussed the specifics and stated that the

deficiency was not reportable under the rules of 10CFR 50.55(e).

A Deviation Report (DR) CD-9158 was generated on December 19,

1987 to address and disposition the discrepant condition. The

DR, which details the evaluation that determined the condition

was ratisfactory, appeared adequate to the inspector. The DR

had not been sent to QC for approval.

Overall, the inspector found the licensee's EQ program to be

satisfactory and in some aspects, exemplary. IFI 424/87-01-03

will remain open pending review of the revisions of all radia-

tion monitor procedures that affect those monitors listed in

FSAR Table 11.5.2-1, and the closing out of CD-9158.

,

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(2) Sections of procedure 24519-1, Rev. 2, Reactor Coolant Pressure

(Wide Range) Protection I 1P-405 Analog Channel Operational

Test and Channel Calibration, which apply to the analog channel

operational test using the manual system, were observed. The

operational test failed. As-found readings fell outside the

expected band. Section 4.20, Summing Amplifier Card Field

Calibration, of procedure 23300-C, Rev.1, Field Calibration

Procedure, was performed and the appropriate sections of

procedure 24519-1 were repeated.

No violations or deviations were identified.

(3) An inspection of portions of the field performance of procedure

24634-1, CR Air Intake Process Radio Gas Monitor Analog Channel

Operational Test & Channel Calibration, and procedure 24623-1,

Containment Low Range Area Monitor Analog Channel Operation Test

and Channel Calibration, was performed. The inspector had no

comments.

The inspector reviewed procedure 24183-1, Rev.1 Fuel Handling

Building Effluent Radiogas Monitor, ARX-2533. The inspector

noted an inconsistency betwcen the procedure and panel in that

labeling for a connector was IAJ3 versus J3 on the panel. An

LED which was unmarked on the remote / control box, did not light

as indicated by the procedure. No LED was provided on unit

IRT-1005 as indicated in step 4.1.3.6.b.

The inspector reviewed procedure 24756-1, Rev. 2, Steam

Generator Level (Narrow Range) Protection Channel II, IL-553.

The inspector noted that the location of equipment was

determined using an out of date drawing due to the time required

to pull new drawings.

After this walkdown, the inspector encouraged the licensee to

evaluate the distribution of drawings from Document Control.

Requests for drawings by the inspector to the technicians, who

were performing work in the plant, typically resulted in a

50-minute wait in Document Control. The inspector was concerned

that the opportunity to use obsolete information would be more

likely if the people who needed the information consistently

found obtaining new drawings difficult. Prompt distribution can

greatly enhance compliance with drawing and document control

,

requirements. During two surveillances, which were witnessed by

I

the inspector, technicians spent approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> to find

equipment that was either erroneously listed in the procedure

(e.g., local indication for radiation area monitor) or moved in

a modification (e.g., a steam generator level transmitter). The

'

inspector asked the technicians in both instances, after a

twenty-minute search, if it would be more expedient to check

the drawings. In both cases, the technicians thought the

equipment would be located any moment and the time spent to

obtain a drawing was unnecessary.

16

.

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The inspector reviewed procedure 24634-1, Rer.1, Control Room

i

Air Intake (1RE-12116) Process Radio Gas Monitor. During the

surveillance, remote control test box was removed. This item

was identified to the licensee as part of IFI 424/87-01-06.

The equipment was later determined to be used only for testing

,1 and did not affect the operation of the safety related monitor;

'

however, the Readout Control Box (RCB) was removed and used to

perform calibrations on other monitors without any tracking,

i.e., no MWO was issued. Deficiency Report 1-87-161 was written

to document this occurrence and engineering report 87-0036

was generated to perform an evaluation of the incident. The

engineering report determined that the RCB is interchangeable on

the monitors and there is no problem with using them in this

manner. Still, the removal of the RCB does require a MW0 and

the licensee showed the inspector a procedure that cautioned

personnel performing this action with a RCB to generate a MW0.

The procedure was a draft copy. Until the procedure is revised,

this part of IFI 424/87-01-06 will remain open.

The inspector also noted during plant walkdowns that an ambient

temperature difference of 8 to 10 existed between the Control

Building normal air conditioning room temperature gauge and the

ESF air conditioning room temperature gauge,1-1539-TIC-13150

and 1-TSH-13151. The inspector requested the licensee to

investigate if the instruments were operable. In a letter dated

January 12, 1987, the licensee stated that an investigation had

revealed that the instruments served separate functions, i.e.,

monitored different rooms. However, as a result of this

finding, the inspector later determined that the licensee had

written maintenance work order (MW0) 18700997 to correct the

discrepancy between these instruments, since both instruments

measured the same ambient room temperature. This is considered

acceptable; however, the action did not correspond to the

January 12, 1987 response. No followup is considered necessary

for this item.

Other concerns involving emergency lighting which was out in

a stairwell, the failure of personnel to close fire doors

and a question on the wire bend radius of cable at location

A-1813-M3-027 were promptly answered or corrected by the

licensee. The wire bend radius was determined to be within

specification. These concerns had also been identified as

part of IFI 424/87-01-06. These concerns are considered closed.

No violaticns or deviations were identified.

!

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17

8. Maintenance Program and Procedure Review (42451B, 357438)

During previous inspections, reviews had been conducted of the administra-

tive controls for plant maintenance, the technical adequacy of maintenance

procedures and the implementation of the maintenance program. The review

included an assessment of the corrective maintenance program; an assess-

ment of the preventative maintenance program; a review of equipment

control including the removal and restoration of equipment, equipment

status tracking and functional testing requirements; verification of

control of special processes, housekeeping and system cleanliness; and,

document review and field verification of the implementation of the

maintenance program. The program had not been fully implemented under

the operational quality assurance program at that time. Followup on the

implementation of the program was identified as IFI 424/86-117-24.

During this inspection, the inspectors reviewed procedure 00350-C,

Maintenance Program, Rev. 5, dated December 3,1986. This procedure

was the administrative procedure which governed maintenance activities

during operation. Additionally, the inspectors witnessed several

maintenance activities in progress including the processing of mainte-

nance work orders (MWO) in accordance with the requirements of 00350-C.

The inspectors also reviewed completed work packages that were accom-

plished under the operational QA program. The inspectors verified that

the licensee had implemented its planned maintenance program. Based on

the review, IFI 424/86-117-24 is closed.

The field review consisted of observing 14 MW0s which addressed various

aspects of plant maintenance. The inspector noted that MW0's, with one

exception, were appropriately filled out and all MW0s reviewed addressed

such areas as QC hold points and proper initial review by other depart-

ments. The inspector noted a number of cross outs which detracted from

legibility. The inspector identified the following items:

a. The inspector determined that maintenance personnel had not verified

that approved drawings, procedures and vendor manuals included in

MW0s in use in the field were the current revision. Procedures

00103-C, Document Distribution and Control, and 00101-C, Drawing

Control, required that drawings, procedures and vendor manuals be

verified as current every seven days. These procedures also required

that any documents which affected the revision to be noted on the

affected working copy. In addition, procedure 20050-C, MWPG Work

Order Processing, requires that working copy documents be verified

current prior to their issuance to the field; and, procedure 20407-C,

Maintenance Conduct of Operations, states that it is the responsi-

bility of the user to ensure that only current, approved working copy

documents are used. The maintenance personnel observed by the

inspector had failed to perform the seven day review for drawings on

MW0s 18700429,18700453 and 18624440 and for vendor manuals on MW0

18624165.

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10 CFR 50, Appendix B, Criterion V, requires that activities

affecting quality be accomplished in accordance with documented

instructions, procedures or drawings. The failure to follow

procedures 00101-C, 00103-C and 20407-C is identified as an

example of violation 424/87-01-01.

During the week of January 12, 1987, the inspector determined that

the drawings and vendor manuals included in the MW0s reviewed were

the latest revisions. The Maintenance Department issued a memorandum

to all maintenance department supervisors and foremen requiring them

to review all work packages in their possession to assure that all

working copy documents are the latest revision.

Deficiency Report (DR) 1-87-0185 was written by the licensee to

document the finding. The licensee stated that the Quality Assurance

Department will perform random audits of the maintenance program.

Additionally, the licensee will consider incorporating into the

, appropriate Maintenance Department procedure the requirement that

foremen and supervisors verify weekly that working copy documents are

'

the latest revision.

b. Paragraphs 4.1.2.c through e of 00350-C, stated that MW0s were not

required for certain activities which do not involve safety-related,

seismic or environmentally qualified equipment. The inspector

interviewed members of the Maintenance Work Planning Group concerning

the process used in making this determination and documentation of

the review. The MWPG stated that equipment addressed by paragraphs

c, d, and e of 00350-C was contained in the Nuclear Plant Management

Information System (NPMIS) which delineates all of the pertinent

information on the safety-related, seismic and environmental qualifi-

cation classifications of equipment. If the foreman is in doubt, an

MWO is submitted which will be reviewed for procedural applicability.

Additionally, paragraph d, which addresses labeling, was being

performed under operations procedure 10016-C, Equipment Labeling

Guidelines.

No violations or deviations were identified.

c. The inspector noted that MW0 18624097 did not have a functional

test assigned in block 32 as required by procedure 00350-C. During

review of other maintenance work orders the inspectors noted that

MW0s appeared weak in the area of functional testing. This item is

of particular concern in light of the number of findings identified

by the Quality Assurance Department related to the failure to assign

functional testing to MW0s. These findings are documented in audit

reports No. OP15/TP02-86/20, #045-II, July 12 thru August 5,1986;

No. OP15-86/45, November 17 thru December 5, 1986; and No. OP15-87/03,

January 6 thru 11,1987. The inspectors identified this item as IFI

424/87-01-03.

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_ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _

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19

The inspector reviewed the corrective action for this item during

the week of January 12, 1987. In response to the item, the licensee

had issued procedure 20051-C, Maintenance Work Order Functional

Tests, to provide guidelines for proper functional test assignments.

The licensee also plans to revise the MWO processing procedure to

assign the functional testing requirements after the work has been

accomplished. In addition, the licensee established a review team

assigned the task of assessing the quality of the MW0s being issued

by the Maintenance Work Planning Group and returning to the MWPG

those MW0s lacking sufficient direction or adequate functional

testing. The work conducted under MWO 18624097 was complete and

awaiting the assignment of the appropriate functional testing. The

inspector determined that the licensee had implemented procedures

which provided adequate direction and review to ensure that MWO

instructions are sufficiently detailed and are assigned the appropri-

ate functional testing. IFI 424/87-01-03 is closed. The IFI number

will remain assigned to the item to allow tracking of the finding.

No violations or deviations were identified.

9. Review of Aaministrative Controls for Temporary Modifications (424518)

During the inspection, the inspector noted that there were numerous

temporary modifications installed in the plant. The inspectors determined

that the licensee had a mechanism to review temporary modifications and

their effect on system operability once the system was formally turned

over to operations. However, the licensee was performing surveillances on

systems that had temporary modifications installed. Therefore, the

validity of the surveillance could be affected for surveillance tests

completed after preoperational testing and prior to establishing configu-

ration control by Operations. This concern was identified as Inspector

Followup Item 424/87-01-05.

During the week of January 12, 1987, the inspection team conducted a

review of the licensee's procedures. Procedure 00350-C, Maintenance

Program, addressed the removal of temporary modifications to ensure

that proper documentation was provided and that the functional testing,

including assessment of its impact on surveillances, was performed.

Procedure 00307-C, Temporary Modifications, addressed the methods utilized

to ensure that temporary modifications are properly identified, docu-

,

mented, controlled and evaluated.

While under the jurisdiction of the Start Up Manual, Procedures SUM-10,

Temporary Modification Control, and SUM-22, Maintenance Work Orders,

,

adequately addressed the subject of temporary modifications including the

'

assessment of its impact on surveillance tests.

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20

The aforementioned maintenance and temporary modification procedures

ensure that work / temporary modifications performed on a system will verify

that surveillances are active and document that components / systems are

functioning properly and capable of performing their intended safety

function. Temporary modifications which were in place during pre-

operational testing which was utilized to satisfy surveillance require-

ments were adequately addressed by the constraints imposed by Section 4.4

of procedure 00404-C, Surveillance Test Program. Under the pre-

operational test program, the test supervisor was responsible for

reviewing the temporary modification log for items which may preclude

completion of the test or invalidate the test results upon completion.

Specifically, paragraph 4.4.6.1 required that " documentation for the

completed procedure or work activity shall be carefully reviewed to ensure

that satisfaction of the surveillance requirements is clearly documented

and that the conditions during the period of the test are the same as

would be experienced during the operational phase surveillance test

procedure. Discrepancies shall be noted in the comments section of the

documentation check list."

As a further area of discussion, it should be noted that test / surveil-

lance procedures contain steps which require the introduction of

modifications which place the system / component into a configuration such

that the test / surveillance procedure attains the required objective. The

introduction of such modifications is reviewed with the development of the

procedure. The inspector feels that all concerns regarding temporary

modifications have been addressed and therefore inspector followup item

424/87-01-05 is closed. The inspector followup item number will remain

assigned to the item to allow tracking of the item.

No violations or deviations were identified.

10. Control Room Activities Review (424508)

a. The inspector reviewed control room administrative procedures and

verified documentation maintained in the control room to assure

the documentation was being maintained in accordance with procedures.

Documents reviewed were:

Reactor Operator & Shift Supervisor Logs

LC0 Log i

!

Standing Orders

Jumper & Lifted Wire Clearance Log

Operations Reading Book

Disabled Aanunciator Log

The inspector also checked 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Technical Specification valve

position verification requirements applicable to the ECCS subsystems. ,

These verifications were being performed properly. The inspector had l

no comments.

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It was noted previously that numerous administrative controls

established for the management of those plant and control room

activities conducted under the direction of licensed operatcrs

were not implemented. These findings were documented in NRC

Inspection Report 424/86-117. However, during this inspection

the inspectors noted a marked improvement in this area. The

administrative controls were implemented and review of record,

logs and checklists indicated thorough input and current status.

The inspector had no further comments in this area.

No violations or deviations were identified.

b. (Closed) Inspector Followup Item 424/86-60-10 (TMI Action Item

I.C.2). Shift Relief and Turnover. The inspector reviewed procedure

10004-C, Shift Relief, Rev. 3, and the shift turnover process to

ensure adequate controls were in place to provide for a complete

shift turncver and the meeting of TMI action item I.C.2 requirements.

The inspector's review included observation of control room activity,

review of logkeeping and log review, and a review of all procedures

governing shift turnover.

The inspector noted that adequate controls appeared to be in place

to maintain access to the control room in an orderly manner. The

operators also appeared to display a professional manner and surveil-

lance of the control boards appeared to be adequate.

The Reactor Operator (RO), Balance Of Plant (80P), and Non-Licensed

Operators (NLO) utilize rounds sheets to log and record plant

parameters. The inspector reviewed the rounds sheets of the R0, B0P,

and the NL0s. These sheets appeared to be properly completed and to

adequately meet the part of TMI action item I.C.2 which requires that

the licensee provide assurance that plant parameters were within

allowable limits. The rounds sheets of the NL0s are reviewed by the

R0, B0P, and Shift Supervisor (SS) to ensure knowledge of plant

parameters not indicated in the control room. The rounds sheets of

the R0 and the B0P are also reviewed by the SS. The inspector

determined that these reviews appeared to be taking place and that

the operators in the control room were cognizant of the status of the

plant.

While reviewing the narrative logs, the inspector noted on

January 15, 1987, that the SS log had no initialed review by

the day shift SS for the previous night's log entries. When

questioned as to the apparent lack of a review, the SS told the

inspector that he did not review the previous night's logs and that

he was not required to review his own logs by procedure because

the verbal turnover from the off-going SS was adequate. The

inspector showed the SS where procedure 10004-C, Revision 3, Shift

Relief, required the on-coming operator to review and initial the

._. -. - - . ,

22

narrative logs completed since the last shift worked by that operator

or for the preceding 5 days, whichever is less. The SS stated that

he was referring to direction received from procedure 10001-C,

Revision 3, Logkeeping, however, when he showed the procedure to

the inspector he noted that he was incorrect and that he was also

required to review his narrative logs by this procedure.

The failure to review and initial the Shif t Supervisor narrative

logs is a failure to follow approved plant procedures in accordance

with 10 CFR 50, Appendix B, Criterion V. This item is identified as

an example of violation 424/87-01-01.

During the review of procedure 10004-C the inspector identified a

discrepancy between the procedure and the On Shift Operations

Supervisor (0505), R0, and B0P checklists. These checklists are

provided in procedures 11870-C,11872-C, and 11869-C, respectively.

The procedures require each on-coming OSOS, R0, and 80P to review the

following logs in addition to the rounds sheets and narrative logs:

Special Conditions Surveillance Log, Clearance Log, Lif ted Wire Log,

and Temporary Modifications Log. The OSOS, R0, and 80P checklists

were missing the appropriate check blocks for each of the above logs.

This was brought to the attention of the licensee and the checkshetts

were modified to reflect the intent of the procedure.

The TMI action item also required implementation of a system to

evaluate the effectiveness of the shift relief turnover procedure.

Step 3.12 of procedure 10004-C states that the 050S shall make an

evaluation of shift relief and turnover at least semiannually. The

results of this evaluation were to be forwarded to the Operations

Manager for disposition. Although the statement contained in the

licensee's procedure directed the Operations Superintendent to

perform an evaluation, the procedure provided no instructions on how

the evaluation was to be performed. The inspector discussed this

item with the licensee and the licensee issued a revision to the

Non-Technical Specification Activities sheet. Prior to the revision

the sheet merely restated the step in the procedure and provided no

further direction. The revision provides direction to the OSOS by

listing several specific items to be addressed during the evaluation.

This revision appeared to satisfy the final requirement of the TMI

action item. TMI Action Item I.C.2 and IFI 424/86-60-10 are closed.

11. Inspection and Enforcement Notice Review (92701)

The inspector reviewed the licensee's response to IE Notice 86-61,

Failure of Auxiliary Feedwater Manual Isolation Valve. The inspector l

discussed the notice with the licensee and determined that the preventive

maintenance requirements for manual isolation valves were determined on a

case-by-case basis during the formulation of the PM program. Based or

this review this item is closed.

_ . - _ _ - _ - _ _ - _ _ _ _ _ _

23

12. Inspector Followup Items (92701)

a. (Closed) Inspector Followup Item 424/85-36-02. Evaluation of

Operational Event Reports. The IFI involved a concern that the

licensee tended to address items programmatically rather than

technically. The applicant had committed to reopen and reevaluate IE

Information Notice 85-23 and reevaluate preoperational testing

associated with differential pressure transmitters. The inspector

reviewed a March 14, 1986 memorandum from Ron Bone, GPC to Bob Lide,

GPC which provided the technical evaluation of the preoperational and

startup testing of the differential pressure transmitters and an

evaluation of IE Information Notice 85-23. The inspector did not

identify any concerns with the licensee's disposition of the evalua-

tion findings. In addition, the inspector reviewed five additional

IE Information Notice evaluations and identified no concerns. This

item is considered closed.

b. (Closed) Inspector Followup Item 424/85-36-03. Performance of Safety

Evaluations and Duties and Responsibilities of Plant Review Board.

The IFI concerned the lack of procedural requirements to submit

safety evaluations for unreviewed safety questions and Technical

Specification changec to the Plant Review Board for review. The

inspector reviewed a revised copy of 00051-C, Review and Approval of

Procedures, which added this requirement. This item is closed.

c. (Closed) Inspector Followup Item 424/86-117-01. Independent

Verification. The inspector reviewed procedure 00308-C and deter-

mined that the licensee had met the NRC g'aidance in regard to

independent verification. The inspector verified that independent

verification was being performed in accordance with procedure

00308-6, Independent Verification Policy. The inspector observed the

performance of a Boric Acid Transfer Pump tag-out and checked a

co.'pleted RHR system lineup. This item is considered closed.

d. (Closed) Inspector Followup Item 424/86-117-02. Lack of Vents on

AFW Piping at Apparent System High Points. The inspectors had noted

in a system walkdown of the Auxiliary Feedwater System that there

were no high point vents on the AFW side of the first check valve

between the AFW system and the main feedwater bypass line for stecm

generators 1 and 4. The inspectors were concerned that any back-

leakage and subsequent steam formation of main feedwater through

those check valves would become trapped in the highpoints and could

result in water hammer upon AFW initiation. There were no provisions

within the procedure, 13610-1, to monitor these highpoints for l

1eakage and steam formation, nor to take action, upon detection of ,

steam formation, to resolve water hanner concerns. The inspector  !

reviewed the analysis performed by the licensee for backleakage into )

the AFW system and determined that the present design and monitoring

procedures provide adequate assurance that backleakage will not occur l

or result in waterhammer in the AFW system. This item is closed. -

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e. (Closed) Inspector Followup Item 424/86-117-03. Precautions on

Maintaining Subcooling Margin. Item a was closed in Inspection

Report 424/86-117. In regard to Item b, which concerned A0P 18009-1,

Steam Generator Tube Leak, the inspector had determined that Step 5,

" Response Not Obtained", required the reduction of RCS temperature

from 557 F to 500 F prior to isolation of the faulted SG if the

faulted S/G was not immediately identified. The procedure then

required the subsequent identification and isolation of the faulted

S/G and RCS depressurization to 25-50 psig greater than the faulted

S/G pressure. Under these conditions, RCS subcooling margin would be

approximately 5 F, which is substantially less than the 28 F sub-

cooling margin parameter delineated in procedure 19200-1, F-0,

Critical Safety Function Status Trees, for assuring adequate core

cooling in the Emergency Operating Procedure Network. In addition,

no instructions were given to isolate the cold leg accumulators at

950 psig.

The inspector reviewed the revision of the procedure that had been

reviewed and approved by the Plant Review Board. (The revision was

handwritten at the time of the review.) Prior to the steps that

depressurized the RCS to 25-50 psig of the faulted S/G, the licensee

i

had inserted the following steps: "If pressurizer pressure lowers to

less than 1000 psi, accumulators should be isolated." and, "During

cooldown, maintain at least 50 F RCS subcooling." These changes

adequately addressed the problems described above and Item b of IFI

424/86-117-03 is closed.

f. (Closed) Inspector Followup Item 424/86-117-04. Correction of Valve

Identification and Lineup Discrepancies. Each item identified in IFI

424/86-117-04 is addressed separately below.

Item a. NSCW valve 1-1202-X4-205, shown to be on the return line

l of the train "A" reactor cavity cooling coil, was listed on the

alignment checklist of procedure 11150-1, Rev.1, but was not on

the P&ID, nor was it found in the system during a system walkdown.

The licensee provided the inspector a Temporary Change to Procedure

(TCP) form number 11150-1-87-2, generated and approved on January 8,

1987, which corrected the checklist. The TCP required final approval

by the Plant Review Board by January 22, 1987. Item a of IFI

424/86-117-04 is closed.

Item b. A vent valve on the NSCW system on the outlet from the

lube oil cooler for the centrifugal charging pumps on train A was

not on the valve lineup verification list of procedure 11150-1,

Rev. O. This discrepancy had been corrected on Rev.1 of this

procedure. Item b of IFI 424/86-117-04 is closed. l

l

ltem c. This item was closed in Inspection Report 424/86-117. .

1

! Item d. This item was closed in Inspection Report 424/86-117. I

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Item e. The CS system alignment procedure, 11115-1, and the CS

system P&ID, drawing 1X4DB131, did not agree. The CS drawing

contained two valves, X-40 and X-127, on a flushing line downstream

of the B train CS pump that were not included in the alignment

procedure. The valves were verified to exist during the CS system

walkdown. The drawing indicated that the valves were both normally

closed. Also, in the same flushing connection, the CS alignment

procedure showed valve U4-012 closed. The CS P&ID showed the valve

locked open. The inspector reviewed procedure 11115-1 and determined

that the licensee had corrected the discrepancies. Item e of IFI

424/86-117-04 is closed.

Iten f. The IFI concerned the removal of a reference to a obsolete

controller from a procedure. No followup review was considered

necessary.

Item g. The inspector noted that CTB Cooling Unit Outlet Dampers

were required to be locked open per Containment Heat Removal System

drawing 1X4DB212. Procedure 13120-1 did not include the locking

requirement and the locking method. The inspector determined that

the licensee had corrected the discrepancy. Item g of 424/86-117-04

is closed.

g. (Closed) Inspector Followup Item 424/86-117-05. Discrepancies in

Unit Operating Procedures. Each item identified in IFI 424/86-117-05

is addressed separately below.

Item a. Item a was closed in Inspection Report 424/86-117.

Item b. Item b was closed in Inspection Report 424/86-117.

Item c. Procedure 12006-1, step 2.2.5, paraphrased a Technical

Specification requirement. The paraphrase was incorrect. The step

should have read "... and at least one loop in operation with the

reactor trip breakers open." The inspectors verified that 12006-1

had been corrected. Item c of IFI 424/86-117-05 is closed.

Item d. Procedure 12006-1, Section C4.1, Preparation for Continuing

Unit Cooldown, required action be taken to accivate protection

against cold overpressurization. Only one method of cold over-

pressure protection was addressed, the use of PORVs. The procedure

also should have addressed the two other mear of cold overpressure

protection and a mechanism to declare which method was providing

protection. The procedure should have addressed the implementation

of the TS :urveillance requirement on the RHR relief valves which

must be completed prior to taking credit for the RHR reliefs. The

inspector verified that procedure 12006-1 had been changed. Item d

of IFI 424/86-117-05 is closed.

l

.

-

g -

. -. . .

26

Item e. Procedure 12005-1 did not include a requirement in the

i

Limitations section to refer to TS 3.4.1.2. The inspector verified

that procedure 12005-1 had been changed. Item e of IFI 424/86-117-05

is closed.

Item f. Procedure 12006-1 did not include a precaution to assure

that when the reactor is in the source range, positive reactivity

additions will only be made by one controlled method at a time.

The inspector verified that 12006-1 had been changed. Item f of

IFI 424/86-117-05 is closed.

j h. (0 pen) Inspector Followup Item 424/86-117-07. Discrepancies in

Equipment Labeling. Each item identified in IFI 424/86-117-07 is

addressed separately below.

i Item a. Name tags were missing from RHR valves HV-8701B and

1205-027. The licensee stated that one of these tags had been

replaced and the other had been ordered. These valves will be

examined during a subsequent inspection to assure that these actions

l are taken. Item a of IFI 424/86-117-07 is open.

l Item b. The inspector determined that the B train controller at

the remote shutdown panel was still labeled as 4. Item b of IFI

424/86-117-07 remains open.

Item c. The TDAFW panel SG level gauge was not labeled wide range or

narrow range. The procedure did not indicate the range. An AFW to

SG bypass flow gauge was not labeled with engineering units. The

inspector verified that the SG level gauge had been labeled. The

bypass flow gauge had not been labeled. Item c of IFI 424/86-117-07

remains open.

Item d. Item d was closed in Inspection Report 424/86-117.

Item e. Item e was closed in Inspection Report 424/86-117.

Item f. The inspector had noted that engineering units were not

displayed on strip chart recorder scales for main steam temperature

and other recorders. The inspector subsequently reviewed labeling

of main control board strip chart recorders for engineering units.

'

Although the main steam temperature had been correctly labeled by

the licensee, other recorders still had no units. Item f of IFI

1 424/86-117-07 remains open.

Item g. The inspector noted that remote handwheels in the CVCS

system including BIT valves and charging crossover were not labeled.

The applicant stated that handwheels had been installed recently and

labeling was planned but had not been completed. The inspector

,

conducted a tour of the auxiliary building levels containing the CVCS

.

system and noted a greatly improved level of labeling for the remote

i

manual valve operators, however, the inspector noted several remote

<

<-,--,.-----.,,,--m- ,- ----.-w.,, ,-p.m, w w -.----w.,-n..-,.m-- . - , ,- -,,-,..,,--,n ,,-y . ,,--,.--m-e-,- yme --

27

manual valve operators in the waste gas disposal area which lacked

tags. The licensee stated that final efforts were being completed in

assuring the adequacy of valve labeling. No additional followup is

considered necessary. Item g of IFI 424/86-117-07 is closed.

Item h. The CS alignment procedure, 11115-1, lists two sets of

120V AC CS MOV space heater breakers. A check of the 120V AC breaker

<

panels (IAYD1 and 18YD1) identified the breakers as being labeled

" spares." The applicant is determining if these breakers are

utilized for the M0V space breakers. Item h of IFI 424/86-117-07

remains open.

i. (0 pen) Inspector Followup Item 424/86-117-09. Review of Reactor

Vessel Level Indication System. Four concerns were identified during

the review of RVLIS involving procedure nomenclature, instrumentation

references in procedure 14228-1, a vendor recommendation for a

control room annunciator that had not been provided, and a vendor

recommendation for periodic checks of locally indicating null meters.

The inspector was provided a Daily Schedule Control Sheet which

indicated that the null meters would be checked by Operations

quarterly. It is noted that the RVLIS will be tested when the

reactor coolant system is at system operating pressure during startup

testing. The inspector will review the reuining items and the

results of the RVLIS testing after startup. IFI 424/86-117-09

remains open.

j. (Closed) Inspector Followup Item 424/86-117-10. Procedure Revision

to Include Check of Equipment Actuation on Control Room Ventilation

Start. The inspector reviewed procedure 13301-1, which had been

revised in Rev.1 to include steps that verify that the outside air

supply dampers close on manual actuation of Control Room Toxic Gas

Isolation. IFI 424/86-117-10 is closed.

k. (Closed) Inspector Followup Item 424/86-117-11. Adequacy of

Procedure Prerequisites. The inspectors had identified that scme

of the prerequisites in S0Ps and surveillance procedures were too

general. Interviews with licensee personnel indicated that it was

not clear to them what was required to be verified to satisfy

selected prerequisites. By letter dated January 14, 1987, the

licensee committed to implement additional controls of prerequisites

until the procedures were reviewed and modified to clarify prerequi-

sites. The licensee stated that standing order 1-87-04 had been

issued to Operations to require that prior to initial use of any

procedure being used in the control room the Shift Supervisor and

operator will review the prerequisites / initial conditions section

to ensure clarity and understanding of the required conditions. The

order contains provisions to upgrade prerequisites by submitting

comments / changes via an attachment to the letter. Based on this

commitment, IFI 424/86-117-11 is closed.

. . _ -. ._. _ _ _ _ _

28

,

f

1. (Closed) Inspector Followup Item 424/86-117-12. Clarification of

Cleanliness Levels. The IFI involved clarification of the cleanli-

'

ness zone designations in Section 4.1.d of procedure 00254-C, Plant

Housekeeping and Cleanliness Control, to ensure that all open RCS

components, as well as the refueling cavity, would be classified as

Level II. The licensee revised the Level II cleanliness requirements

in 00254-C, Section 5.4, to specifically include any system that

could allow contaminates to reach the RCS. This revision meets the

intent of the IFI and IFI 424/86-117-12 is closed,

i

! m. (Closed) Inspector Followup Item 424/86-117-13. General Review

i of Abnormal Operating Procedures. Topics from Regulatory Guide

1.33, Revision 2, February 1978, were verified to have procedures

established. The following contingencies were implemented by the

procedures listed below:

l Procedure Revision

Event Number Number

Loss of Condenser Vacuum - 18011-1 1

18023-1 1

Loss of Containment Integrity - 17005-1 2

Loss of Feedwater - 17009-1 0

18016-1 1

>

Conditions Requiring Emerg. Boration - 17010-1 3

18007-1 1

Fuel Cladding Failure - 17005-1 2

18006-1 1

High Activity in Coolant or Offgas - 17100-1 2

, 17213-1 0

18009-1 2

Pressure Control Malfunction - 18011-1 1

Plant Fires - 17103-C 0

, 18038-1 2

i Abnormal Releases of Radioactivity - 18009-1 2

j Based on this review, procedural implementation of Regulatory

'

Guide 1.33 is adequate and IFI 424/86-117-13 is closed.

n. (Closed) Inspector Followup Item 424/86-117-14. Annunciator Response

Procedure (ARP) Discrepancies. The inspector reviewed the licensee's

commitment to conduct a review of ARP's to determine the adequacy of

initial operator actions, the accuracy of window labelling, and the

overall adequacy of each procedure. The inspector reviewed Main

Control Board (MCB) ARP's (panels 1 through 20) and concluded that a

thorough review had been performed on these procedures and the

procedures accurately reflected the annunciator windows and provided

sufficient initial operator action. The inspector also reviewed

,

several of the review packagos for the annunciator panels, particu-

'

larly those on the MCB. All of the reviews appeared to be comprehen-

sive and competent. Although the ARP's for the annunciators that are

(

.-

29

!

not on the MCB have not all been revised as yet; the reviews that

were completed were adequate and the licensee program for completion

of the reviews was determined to be adequate. Therefore, IFI

424/86-117-14 is closed.

During the review of the corrective action for IFI 424/86-117-14,

the inspector detennined that the ARPs referenced a Master Setpoint

Document in lieu of giving an actual setpoint for certain annunciator

alarms. Interviews with several operators indicated that they did

not know where to find this document. In addition, personnel in the

Operations Department were not sure as to the exact form or location

of this document. Followup on the licensee's actions to establish

the document or to replace the references to the document in the

ARP's with the actual setpoint was identified as IFI 424/87-01-07.

This IFI was subsequently reviewed during this inspection and the

inspector determined that the licensee had taken corrective action

for the IFI. This review is documented under paragraph 12.nn for IFI

424/87-01-07 in this report.

o. (Closed) Inspector Followup Item 424/86-117-15. Acceptability of

Baseline IST Data for Section XI ASME Pump Testing. This item

concerned baseline data obtained on four of six Component Cooling

Water (CCW) pumps which was below the data obtained during preopera-

tional testing. The inspector requested engineering justification

for the operability of these pumps prior to fuel load. The inspector

discussed with the licensee the ASME Section XI code, the licensee's

ISI program, the inherent error in the measuring equipment, and the

configuration of the preoperational test versus that of the ISI test.

Pump curves from the manufacturer were compared with the preopera-

tional data and the baseline data. The licensee provided adequate

justification as to the operability of the CCW pumps in question.

, IFI 424/86-117-15 is closed.

p. (Closed) Inspector Followup Item 424/86-117-16. Technical Specifica-

tion on the Discharge Flow of the RHR Pump. The inspector had

determined that the discharge pressure on the recirculation flow of

RHR pump B was equal to 180 psid. TS 4.2.5.f required the discharge

,

pressure to be 1180 psid. The licensee had stated that a TS revision

had been requested to change the value to be 1165 psid. The inspec-

tor subsequently reviewed the TS revision whIch incorporated the

-

change. IFI 424/86-117-16 is closed,

q. (Closed) Inspector Followup Item 424/86-117-17. Resolution of Water

Hanner in NSCW. The item concerned the waterhammer that had occurred

on the NSCW system during the Loss of Offsite Power test. The

licensee's analysis, which concluded that the waterhammer did not

impair the operability of the system, was reviewed and found to be

acceptable. IFI 424/86-117-17 is closed.

-

.- -

.-_- - -. - -- - - - . . . - - --

_

.

- .

30

r. (Closed) Inspector Followup Item 424/86-117-18. Implementation of

Surveillance Program. During the inspection ending December 12,

1986, the inspectors had determined that the licensee had not yet

fully implemented the surveillance program administrative controls

except on a small number of systems which had been accepted by the

Operations Department. During this inspection, the inspectors

reviewed the implementation of the surveillance program and a number

of additional surveillance test packages. Although several concerns

were identified and one example of a failure to follow procedure was

identified; in general, the results of this review indicated that the

surveillance program was adequately implemented. The review is

documented in paragraph 7 of this report. IFI 424/86-117-18 is

closed.

s. (Closed) Inspector Followup Item 424/86-117-19. Review of Test

Control and Implementation of Configuration Control during

Performance of Surveillance Testing. The inspectors had determined

that in some surveillances performed during the preoperational

testing, the prerequisites were not always satisfied prior to

beginning the test. It was not clear in the cases reviewed whether

or not credit would be taken for the test. The inspectors reviewed a

number of completed surveillance packages and observed additional

performances of surveillance testing. No additional instances of

failure to satisfy prerequisites or establish system configuration

were noted. The inspector rereviewed the performance of the MDAFW

surveillance procedure,14807, and determined that the system had

been retested. Additional information on the review of the surveil-

lance program is provided in paragraph 7. IFI 424/86-117-19 is

closed,

t. (Closed) Inspector Followup Item 424/86-117-20. Revise Procedures to

Clarify Use of Staggered Test Basis for Determining Frequency of

Test. The inspector had determined that although the Surveillance

Test Coordinator was correctly tracking surveillances required on a

staggered test basis, the test frequencies specified in certain

surveillance procedures did not mention the requirement for stagger-

ing the tests. The inspector determined that procedure 00404-C,

Surveillance Test Program, has been revised to include the TS

definition of staggered test basis. The inspector reviewed the

deficient procedures identified and determined that the surveillance

procedures had been revised to specify that the tests are to be

performed on a staggered test basis where appropriate. IFI

424/86-117-20 is closed.

u. (Closed) Inspector Followup Item 424/86-117-21. Review of

Justifications for Use of Preoperational Tests to Meet TS

Surveillance Requirements. The inspectors reviewed the

preoperational test data used to take credit for the 18 month

surveillance tests of the emergency diesel generators (EDG) and

the battery chargers. The inspectors reviewed the pre-op tests

with the engineers responsible for the EDGs and the battery

- _ _ . ._ _ _ _ _ , . _

. __

31

chargers. The review included a step by step table-top walkthrough

uf the effected surveillances with a comparison of the pre-op data

used to take credit for required data in the surveillances. In both

cases the inspectors determined that the pre-op data appeared to be a

valid substitute for the data required for the surveillance and that

the licensee did an adequate job in the justification of the use of

the pre-op data. The inspector discussed the controls with the

licensee which will be utilized for assuring that startup tests are

appropriately evaluated if the tests are to be used in lieu of

surveillance tests. The inspector determined that the licensee made

significant improvements in the evaluation of the use of other tests

in lieu of surveillance tests and took steps to assure that surveil-

lance tests were performed in those cases where other tests did not

satisfy the surveillance test requirements. The inspector had no

additional questions. IFI 424/86-117-21 is closed.

v. (Closed) Inspector Followup Item 424/86-117-22. Corrective Action to

Assure Control of Twelve Hour Surveillances. The inspector reviewed

procedure 14000-1, Rev. 3, Operations Shift and Daily Surveillance

Logs, which now specify that surveillances be performed within

two hours of each shift. Procedure 10000-C, Rev. 3, Conduct of

Operations, had been revised to require that the On Shift Operations

Supervisor or the Shift Supervi::or ensure that procedure 14000-1

be performed within the first two hours of each shift. IFI

424/86-117-22 is closed.

w. (0 pen) Inspector Followup Item 424/86-117-23. Miscellaneous

Technical Issues Identified in Review of Surveillance Program.

This IFI included examples of various technical concerns identified

during the review of surveillance procedures and/or surveillance

program implementation. Each concern is identified separately below

by the paragraph number in Inspection Report 424/86-117.

Paragraph 7.c. Procedure 14721-1 required SI pumps to be operated

during the test; however, there was no provision to open and rack out

the motor supply breakers upon test completion. TS 4.5.3.2 requires

the motor supply breakers to be open while in Modes 4, 5 and 6. The

inspector was shown a draft revision to the procedure which included

adequate steps. The procedure additionally specified that maximum

allowed flow was 650 gpm although TS 4.5.2.h.2.b allows up to 660

gpm. Although the requirement was conservative, it was inconsistent

with other requirements in the procedure. The same draft revision

also corrected the allowable flew to 660 gpm. Procedure 14460-1 did

not require venting through valve 1-1204-X4-827, SI Pump Miniflow I

Vent Valve. TS 4.5.2.b.1 requires the venting of ECCS pump discharge  !

piping high points at least once per 31 days. The applicant stated

that a Temporary Change Procedure (TCP) would be initiated. The

procedure additionally referred to the A SI pump as 1. The inspector I

verified that the procedure was corrected. Procedure 14000-1 did not l

specify that the surveillances on page 17 were to be performed in  !

modes 1 or 2 only. The inspector verified that the procedure was

v

.vr

_ _ _ _ _ ___ _____ _ ____ _ . _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

32

corrected. The correction of minor comments on procedures 54821-1,

which referenced a deleted TS table, and 55016-1, which contained a

typographical error in a TS reference, was verified. The comments on

the surveillance procedures for the safety injection system in IFI

424/86-117-23 are considered closed.

Paragraph 7.e. A review of procedure 00404-C, Surveillance Test

Program, Rev. 2, dated December 3, 1986; 00405-C, Commitment

Identification, Tracking, and Implementation, Rev. 3, dated

October 22, 1986; and 00051-C, Procedures Review and Approval,

Rev. 5, dated December 1,1986 indicated that the mechanisms to

govern changes to procedures which implement technical specification

commitments and changes to technical specification commitments which

are implemented in procedures were in place. The aforementioned

procedures will ensure that if changes occur, the changes will be

reflected in the surveillance task cross reference report and the

master surveillance report. It should be noted that procedure

14935-1, Rev. I draft, which prompted this concern, was approved. A

review of the associated paper work revealed that the individual

responsible for the commitment review failed to identify the deletion

of a commitment. The appropriate corrections were made when the

error was identified to the reviewer. This part of IFI 424/85-117-23

is closed.

A review of procedure 14721-1, ECCS Subsystem Flow Balance Test,

Rev.1, dated January 2,1987, discloses a revision which changes

the applicability of the procedure to modes 1, 2, 3 and 4. This

is consistent with TS 4.5.2 and 4.5.3.1. This part of IFI

424/86-117-23 is closed.

Paragraph 7.f. Section 6.0, Acceptance Criteria, in both revisions

of procedure 14806-1 did not include observation of proper lubricant

level or check of calibration due dates. Section 8.0 of draft Rev.1

did not include the date of the applicable edition of ASME B&PV code,

Section XI. The inspector verified that these items had been

corrected. These comments are considered closed. Procedure 54701-1:

(1) did not meet the requirements of TS 4.8.4.2.b, (2) failed to

require the opening and locking of valve 1-1206-U6-029 after comple-

tion of the test, (3) did not include a step to unlock and close

valve 1-1204-U6-018, and (4) did not include independent verification

of the position of 1-1206-U6-018. The inspector verified that

the licensee had corrected these items. This portion of IFI

424/86-117-23 is closed.

Paragraph 7.g. The valve numbers in TS 3/4.6.1.7 were incorrect.

Valves HV-2624 A and B, 4 inch isolation valves in the Containment

Building Post LOCA Exhaust system; and, HV-2627 A and B and HV-2629 A

and B, containment purge and exhaust isolation valves, were not

included in the statement of the LCO. The valve numbers in surveil-

lance requirement 4.6.1.7.1 were not all 24-inch containment purge

33

and exhaust isolation valves as indicated. HV-2624 A and 8 were 4

inch Containment Building Post LOCA Exhaust isolation valves.

HV-26268 and HV-26-288 were 14-inch Containment Building mini-purge

supply and exhaust isolation valves. The inspector verified that the

numbers in the TS were corrected. This portion of IFI 424/86-117-23

is closed.

Paragraph 7.h. The reference to paragraph 7.h in Inspection

Report 424/86-117 was a typographical error. Coments in this

section were evaluated and no followup was considered necessary.

Paragraph 7.i. While witnessing the MDAFWP testing, the inspector

noted in procedure 14807 that no step was included in the system

restoration to place handswitch HS5131A back into automatic. The

system restoration section of procedure 14807, Rev.1, now includes a

step to place handswitch HS5131A back into automatic at the conclu-

sion of the MDAFW surveillance test, and to independently verify this

step. This portion of IFI 424/86-117-23 is closed.

Paragraph 7.J. The inspector noted that the physics curve book

had not been completed. During a subsequent inspection, the

inspector determined that the physics curve book was near completion.

The majority of the reactivity data, which had been extracted from

WCAP-11338 and reformatted, had been provided to Reactor Engineering

for review. This portion of IFI 424/86-117-23 will remain open until

completion of the curve book is reviewed.

x. (Closed) Inspector Followup Item 424/86-117-24. Implementation

of the Operational Phase Corrective and Preventive Maintenance

Program. This item is closed as discussed in paragraph 8 of this

report,

y. (Closed) Inspector Followup Item 424/86-117-25. Ultimate Heat Sink

Technical Specification Clarification. A revision was to be made to

the ultimate heat sink TS to clarify the wording, remove ambiguities,

and modify a surveillance so that it could be realistically met. The

inspector determined that the changes had been approved and would be

included in the TS. IFI 424/86-117-25 is closed.

z. (Closed) Inspector Followup Item 424/86-117-26. Verification of

Position of BIT Isolation Valves. A review of procedure 11006-1,

Chemical and Volume Control System Alignment for Start-up and Normal

Operation, Rev. 3, dated December 29, 1986, contains a revision which

calls for the verification of BIT isolation valves 1-HV 9803 A & B

in the open position with the Limitorque handwheel lon ed. This

revision satisfies TS requirement 4.5.2.b.2 by designating these

valves, which are in the ECCS flow path, as locked valves, thereby

excluding them from the 31 day correct position verification. The

inspector field verified that the appropriate locks were installed.

IFI 424/86-117-26 is closed.

34

aa. (0 pen) Inspector Followup Items 424/86-117-27. TS / Surveillance

Procedure Cross Reference List and Surveillance Procedure Completion.

Some procedures referenced in the TS / surveillance procedure cross

reference list had not been written and/or had not been identified in

the cross reference list. Procedure 53002-C was shown in the cross

reference list for BOL moderator temperature coefficient surveillance

(TS 4.1.1.3.a) but the licensee did not plan to use the procedure for

the initial startup test and it had not been written. This procedure

will be an integrated low power physics testing procedure to be used

for reloads. The inspectors confirmed that the procedure to be used

was adequate to meet the surveillance requirements. The TS cross

reference list did not show which startup tests are used to satisfy

surveillance requirements. Startup testing will be observed in

future inspections.

The inspectors reviewed a portion of the cross reference list to

confirm that procedures required for Mode 6 had been identified

and completed. The inspectors provided several minor comments to

the licensee for resolution, but determined that the cross reference

list was adequate for startup. IFI 424/86-117-27 will remain open

pending further review of the status of procedures required for power

operation. IFI 424/86-96-05, which involved the review of the

completion of procedures required to meet TS surveillances, is

closely related to IFI 424/86-117-27. Based on the review of the

surveillance program documented in paragraph 7 and the followup to be

conducted to close IFI 424/86-117-27, IFI 424/86-96-05 is closed.

bb. (Closed) Inspector Followup Item 424/86-96-05. Review of Surveil-

lance Procedure Completion. This item is closed as documented in

paragraph 12.aa.

cc. (Closed) Inspector Followup Item 424/86-117-28. Procedure Revision

for Consistent Definition of Surveillance Test Completion Date and

Time. Administrative surveillance tracking procedure 00404-C, was

revised by Revision 4 to correct a discrepancy between Section 2.5

and its surveillance task sheet completion instructions, note 20,

concerning the surveillance official completion date and time. A

surveillance test is now consistently considered complete only after

the test results have been reviewed. Therefore, IFI 424/86-117-28 is

closed.

dd. (Closed) Inspector Followup Item 424/86-117-29. Review of Special

Condition Surveillance Test Triggering Mechanisms. The inspector

reviewed documentation to determine whether or not the applicant has

adequate triggering mechanisms to ensure certain special condition

surveillances are performed. A computer printout listing all special

condition surveillances for mode 6 and all modes was reviewed. The

list contained approximately 112 surveillance requirements, the

department responsible for triggering, the department responsible for

.

.

35

completion, and the applicable procedures. The inspector audited 20

surveillance requirements to determine that adequate steps or

'

precautions had been inserted into the appropriate procedure to

trigger the required surveillance test.

In all but one case either an adequate procedure existed, a Temporary

Change Procedure (TCP) had been generated, or a revision was in the

approval process which the inspector reviewed. The inspector noted

one case where inadequate triggering mechanisms existed. Procedure

17034-1 did not contain a requirement to verify 125V battery opera-

bility after battery discharge or overcharge within 7 days as

required by TS 4.8.2.2. Although procedure 17034-1 had been desig-

nated to have the triggering mechanisms for the maintenance

department to perform the surveillance, the revision had not been

done. This was pointed out to the licensee. A TCP was immediately

processed. The inspector reviewed the TCP and found that the change

incorporated the appropriate triggering mechanisms.

! The inspector reviewed methods and procedures for departments to

keep track of special condition surveillances. Draft procedure

50045-C, Engineering Special Condition Surveillances, was reviewed.

The procedure included a log for keeping track of active surveil-

,

lances. Discussions with responsible personnel indicated that the

draft copy reviewed by the inspector was not finalized for approval

and that additional EFPD sensitive surveillances, which were not

requirements for fuel load, were to be incorporated into the

procedure. The inspector reviewed chemistry procedures 31045-C, Rev.

4

4, Chemistry Logkeeping, Filing, and Record Storage; and, 30040-C,

Rev. 1, Reporting Chemistry Data to Operations Department. The

procedures were adequate to track surveillances in the Laboratory

Logbook. Special condition surveillances for the Instrumentation and

i Control Section were primarily associated with instrument calibra-

tions after a seismic event and one associated with RCS pressure

calibration after refueling. The following procedures were reviewed:

18036-C, Rev.0, Seismic Event; 50022-C, Rev. 3, Seismic Event Plan;

55039-C, Rev. O, Seismic Monitoring Instrument System; 12000-1,

Rev.1, Refueling Recovery. Items will be tracked through Operations

as equipment is placed inoperable. The Maintenance Department

triggered all of their special condition surveillances through the

,

planning and work order programs and did not have a log to keep

track of active surveillances; however, procedure 20051-C, Rev. O,

Maintenance Work Order Functional Tests, itemized surveillances to

be triggered after certain maintenance items. This was deemed

adequate. IFI 424/86-117-29 is closed.

ee. (Closed) Inspector Followup Item 424/86-117-30. Control on the

Location of the B0P Operator. The inspector reviewed procedure

10000-C, Rev. 3, which had been revised to state that the balance

of plant operator normally remains in the control room. IFI

424/86-117-30 is closed.

4

l

l

l

!

36

ff. (0 pen) Inspector Followup Item 424/86-117-31. Key Control . On

December 11, 1986, during the walk through of the reactor coolant

pump loop 1F-416 procedure, 24790-1, the inspector had observed

that the technician needed to go to the shif t clerk's office three

times to obtain the keys needed to open the reactor solid state

protection system (SSPS) cabinets to perform the surveillance

procedure. In a letter dated January 13, 1987, which referenced a

memorandum dated January 8, 1987, the licensee stated that the

,

control of keys to all panels and cabinets which require operator

access would be reviewed and validated. The memorandum stated that a

new key control cabinet had been added, that an up-to-date list of

keys had been completed and that the cabinet keys would be validated

by February 6, 1987. By memorandum dated January 15, 1987, a copy of

which was provided to the inspectors, the licensee stated that the

cabinet key controls would be in place by February 21, 1987. The

inspectors agreed that this date was acceptable. The memorandum also

,

stated in regard to locked doors inside the power block, that these

doors would routinely be left unlocked, except vital area doors,

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remote shutdown panel doors, essential 4160V AC switchgear room

doors and high radiation area doors. Due to the types of locks

on some of the interior doors, the licensee stated that certain

locks would have to replaced to allow the doors to be left unlocked.

.

The licensee stated that the locks would be replaced by April 1,

l 1987. IFI 424/86-117-31 will remain open until these actions are

verified.

gg. (Closed) Inspector Followup Item 424/86-117-32. Technical Specifica-

tion Change to Reflect 18 Month Surveillance of Under Voltage and

Shunt Trip Coils on Reactor Trip Breaker. The final TS draft did not

specify testing of the reactor trip breaker undervoltage (UV) and

shunt coils. Generic letter 83-28 required this testing to be

performed with an 18 month frequency, as a minimum. The inspector

verified that procedure 14701-1, Rev. 3, had been changed tn

incorporate these items to test the reactor trip breakers unde -

voltage and shunt trip. IFI 424/86-117-32 is closed.

hh. (0 pen) Inspector Followup Item 424/86-117-33. Miscellaneous

Technical Issues Identified in Review of Operations Procedures.

This IFI included examples of various technical concerns identified

, during the review of operations procedures. Each concern is identi-

fied separately below by the paragraph number in Inspection Report

424/86-117.

i Paragraph 6.b.6. Two alarm panels were not displayed above the

CCW operating switches in the control room as required by 18020-1

and ARP 17002-1. The inspector verified that the licensee had

taken action to correct these discrepancies. This portion of IFI

424/86-117-33 is closed.

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Paragraph 6.b.7. In procedure 18003-1 the following coments were

made. In step 4.1.2.9, which repeats a reactor coolant pump start

sequence, no reference was made to the reactor coolant pump restart

limitations identified by precautions 2.2.11.2 and 2.2.11.3. The

seal injection flow shown on Figure 1 showed six to eight gpm,

whereas item 2.2.6 specified 8 to 13 gpm. The flow logic in the

decision tree depicted in Figure 1 failed at both the " check No. 2

seal leakoff flow" block and at the " check injection and bearing

temperature" block since neither block provided a logical exit from

the block. The inspector verified that procedure 18004-1, Rev. 2,

corrected the:e items. This portion of IFI 424/86-117-33 is closed.

Paragraph 6.b.9. The inspector had identified concerns in that

procedure 13610-1 did not contain provisions for monitoring and

responding to adverse bearing oil temperatures for all three AFW

pumps and did not implement provisions for positioning and aligning

the turbine driven AFW pump overspeed test switch (HS-15130) and

speed control potentiometer. During a walkdown of the AFW system,

the inspectors noted that the turbine driven pump gland seal leakage

was approximately 3 to 5 times greater than that of the motor driven

pumps and appeared to be excessive. The licensee acknowledged the

concern. Procedure 11882-1, Outside Areas Round Sheets, did not

provide for a general inspection of the north Main Steam and

Feedwater valve room, the motor driven pump A pump room or the

turbine driven pump pump room. Also there are no items to check for

adequate pump gland seal leakage and adequate gland seal leakage

drainage from the gland seal leakage reservoir. The inspector

verified that all of the issues had been satisfactorily addressed by

the licensee except one. Gland seal leakage from the turbine driven

AFW purrp has not been dispositioned yet. IFI 424/86-117-33 remains

open to follow the corrective action on the gland seal leakage.

Paragraph 6.b.10. Steps 2.2.1 and 2.2.2 in CS system procedure

13115-1 which addresses TS limits did not include Mode 4 in the

applicable modes as required by TSs. The inspector verified that

the procedure had been revised. This portion of IFI

424/86-117-33 is closed.

Paragraph 6.b.11. Steps 2.2.1 and 2.2.2 in procedure 13120-1 did

not list the applicable TS modes. The inspector verified that the

procedure was revised. This portion of IFI 424/86-117-33 is closed.

Paragraph 6.c. The concern involved limiting excessive overtime

for personnel performing safety related functions. Limiting exces-

sive overtime is addressed by TMI Action Item I.A.1.3. Procedure l

00005-C, Rev. 2, Overtime Authorization, now includes the requirement I

of TS 6.2.2.e that overtime should not be routinely scheduled for l

personnel responsible for performing safety-related functions.

Procedure 10000-C, which applies to Operations personnel, also

had been revised to state that overtime should not be routinely

scheduled. This portion of IFI 424/86-117-33 is closed. l

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ii. (0 pen) Inspector Followup Item 424/87-01-02. Acceptance Criteria

Reviews. The IFI involved the review of the licensee's procedures

to assure that adequate administrative controls exist for review of

acceptance criteria and determination that the acceptance criteria

are met. This item is discussed in paragraph 7.a.8 of this report.

jj. (Closed) Inspector Followup Item 424/87-01-03. Implementation of

Controls to Assure Adequate MW0s and Assignment of Appropriate

Functional Testing. The inspector had determined that a MWO did

not designate the functional testing to be performed. In addition,

the inspector noted that QA audits indicated recurring problems in

the adequacy of MWO instructions and designation of functional tests.

The inspector reviewed the corrective action taken by the licensee.

This review is described in paragraph 8.c. of this report. IFI

424/87-01-03 is closed.

kk. (0 pen) Inspector Followup Item 424/87-01-04. Resolution of Concerns

on the Seismic and Environmental Qualification (EQ) of Radiation

Monitors. This IFI is discussed in paragraph 7.b.1 of this report.

11. (Closed) Inspector Followup Item 424/87-01-05. Review of Temporary

Modifications. This IFI is closed as discussed in paragraph 9. The

IFI number will remain assigned to allow tracking of the item.

mm. (0 pen) Inspector Followup Item 424/87-01-06. Miscellaneous Findings

on Surveillance and Maintenance Procedure Implementation. The

concerns, which are discussed in paragraph 7.b.3 of this report

included equipment mislabeling and an inadequate lighting safety

concern. The items were determined to be isolated cases and have

been corrected by the licensee. After obtaining additional informa-

tion from the licensee, the fire doors and a wire radius bend concern

were determined not to be issues. Therefore, with the exception of

one item, discussed in paragraph 7.b.3, IFI 424/87-01-06 is closed,

nn. (Closed) Inspector Followup Item 424/87-01-07. Reference of

Nonexistent Setpoint Document in Control Room ARP's. Control Room

ARP's were found to reference a Master Setpoint Document that was

used in lieu of giving the actual setpoint. No one in either the

Control Room or the operations department could produce or describe

the document. The licensee provided revised procedures for the

following ARPs that had previously been noted as deficient. The

procedures no longer referenced the Master Setpoint Document. The

procedures reviewed were 17001-1, Rev. 5; 17013-1, Rev. 3; 17014-1,

Rev. 3; 17015-1, Rev. 2; 17016-1, Rev. 2; 17017-1, Rev.1; and,

17020-1, Rev. 3. The inspector found that the revised procedures

were incorporated into the control room copies. The inspector

determined that the ARP's in the control room no longer referenced

the document. IFI 424/87-01-07 is considered closed.

oo. (Closed) Inspector Followup Item 424/86-60-10. Shift Relief and

Turnover. The item is discussed in paragraph 10.b.