IR 05000423/1985055

Insp Rept 50-423/85-55 on 850916-23.No Violation Noted.Major Areas Inspected:Plant,Operating & Emergency Procedures & Review of Licensee Actions on Previous Findings

ML20138G430
Person / Time
Site:	Millstone
Issue date:	10/17/1985
From:	Blumberg N, Chaudhary S, Dev M, Finkel A, Jerrica Johnson, Prell J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20138G402	List: IR 05000423/1985055 ML20138G398
References
50-423-85-55, NUDOCS 8510250475
Download: ML20138G430 (16)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-423/85-55 Docket No. 50-423 License No. CPPR-113 Licensee: Northeast Nuclear Energy Company P. O. Box 270 Hartford, Connecticut 06101 Facility Name: Millstone Nuclear Power Station, Unit 3 Inspection At: Waterford, Connecticut Inspection Conducted: September 16-23,-1985 Inspectors: LM/ /0 16-g J Prell, act r Engineer date

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_1D -IVAf Np B' umber,L"epReactorEngineer dite ~

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, 10-(6 85 Madan Dev, Reactor Engi 1eee date YtauNtM S. Thaudhary,~ Leaf Reactor Engineer ner (). I9W date A. Finkel, llead Reactor Engineer

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Approved by: [2-

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Jo'ff Johnson", Chief, date Operational Programs Section Operation Branch, DRS Inspection Summary: Routine, unannounced inspection conducted on September 16-23, 1985 (Report No. 50-423/85-55)

Areas Inspected: Plant Procedures, Operating Procedures,-Emergency Procedures and Review of Licensee Actions on Previous Findings. The inspection involved 176 hours0.00204 days <br />0.0489 hours <br />2.910053e-4 weeks <br />6.6968e-5 months <br /> on-site by 5 region-based inspector Results: No violations were identifie .

8510250475 851022 PDR ADOCK 05000423 G PDR l

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l DETAILS 1.0 Persons Contacted K. Burton, Operational Supervisor

• J. Crockett, MP-3 Unit Superintendent, NNECo E. Fries, Startup Engineer

• R. Gray, Staff Assistant, QA, NUSCo

• Hess, Plant Engineer, NNECo

• J. Krechting, Assistant Project Engineer, SWEC

"J. LaMarca, Electrical Engineer, SWEC J. Lawcre, QA Engineer, NUSCo

• M. Matthews, Assistant Superintendent, FQC, SWEC

• R. McGuinness, Licensing Supervisor, NUSCo

• L. Nadeau, Assistant Project Engineer, NUSCo

• V. Papadapoli, Supervisor, CQA, NUSCo M. Pearson, Operations Assistant, NNECo

• Vos, Senior FQC Engineer, SWEC U.S. Nuclear Regulatory Commission

• T. Rebelowski. Senior Resident Inspector

• Denotes those present at the exit meeting on September 20, 1985.

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2.0 -Licensees Actions on Previous Inspection Findings (Modified) Open Item (423/85-37-04): Technical Specifications, Surveil-lance Procedures, and Operating Procedures are not in conformance with each other and the SAR as to setpoint During a review of the licensee Abnormal Operating Procedures (A0Ps) and Emergency Operating Procedures (EOPs) it was noted that most setpoints were not yet established. This was also true of the alarm procedures which were incorporated into the Operating Procedures (0P). Therefore this open item is modified to also include AOPs and E0Ps for inclusion of setpoint (Closed) Inspector Follow-up Item (423/84-09-01): Procedure No. NEIM-55, Rev. O for piping walk downs has been issued. The inspector reviewed the procedure for adequacy and details. The procedure appears to contain sufficient procedural control and detail This item is close (0 pen) Construction Deficiency Report (423/85-00-10): This significant '

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deficiency with regards to the Anchor Darling Tilting Disc Check Valve (License SDR #SD77), described a ' problem of cracks in the bushing to the disc tack weld. Bushing to disc tack welds were used to prevent the hinge

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pin bushing from moving out of the disc. Af ter reviewing the problem, Anchor Darling provided a new design for hinge pin bushings that prevented the bushing from coming out of the disc. The licensee has replaced the defective bushing (documented on EE-DCR#TP-05637). This item however, remains open pending completion of pressure testin (Closed) Construction Deficiency R y ort (423/85-00-01): The license was informed that certain lots of Parker Hannifin stainless steel fittings could experience cracking. Of three hundred and forty-one (341) potenti-ally deficient fittings, three hundred and twenty-four (324) were located and returned to the supplier. The site A-E, Stone & Webster Engineering Corporation, verified that the remaining seventeen fittings were not in-stalled in any safety-related system. The code numbers of these fittings were supplied to Field QC and other site organizations to prevent receipt and installation of these fittings in safety-rated, QA Category I applica-tion This item is close (Closed) Inspector Follow-up Item (423/84-14-06): The licensee has devel-oped and issued procedure No. SP-CE-223, Revision 0, for the structural movement monitoring program. The procedure contains criterion for engi-neering review of the settlement program and the limiting settlement value triggering such review. The procedure appears to provide sufficient con-trol and detailed instructions for an adequate monitoring progra This item is close (Closed) Inspector Follow-up Item (423/84-20-05): The inspector assessed the adequacy of the licensee's QC inspection program for HVAC ductwork and connections. By review of QCIR's and discussions with the cognizant engi-neer, the inspector determined that the inspection program in this area was adequate and effective. The documentation indicated that the Field QC had identified similar problems before the NRC inspection. As a part of the regular QC inspection, a check of bolts / screws and bolt hole sizes was conducte This item is close (Closed) Unresolved Item, (423/82-13-03): The inspector reviewed the test report, held discussion with cognizant engineers, and determined that the substitution of a cable tray clip with a PS-619-h" square strut washer was acceptable. The washer equalled or exceeded the specification require-ment for cable tray application and the seismic analysis of the cable tray conformed to the requirements of IEEE-344,197 This item is closed.

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(0 pen) Inspector Follow-up Item, (423/85-05-10): The inspector reviewed the Safety Injection Accumulator (SIL) Test package and observed that the results of the blow-down test did not meet the acceptance criteria. The as-tested accumulator piping length-to piping diameter ratio (L/0) values were significantly lower than those listed in the acceptance criteri The results were forwarded to Westinghouse Electric Corporation for evaluation. Westinghouse informed the licensee that a new Safeguard Analysis was performed with CD=0.6 to evaluate the ef fect of this condition (limiting large break LOCA for the site.)

The results of this analysis indicated that the blow-down occurred earlier than anticipated. This resulted in a lower calculated peak cladding temperature than provided in the FSAR, and therefore, the as tested accumulator L/0 values were acceptable from the LOCA analysis standpoin The inspector also observed the following: Sections 7.3.27, 7.4.27, 7.5.27, and 7.6.27 required that the test recorder be run at approximately 50mm/sec, but the data were recorded at approximately 25 mm/sec. Although, the data strip was run at half the specified speed, it appeared to be adequate for data accurac . Page 11 ef Appendix C of test procedure T3307AP003 (data sheets for accumulator 3SIL*TK1C) contains an obvious error. The value of H B S recorded as -4.77, whereas the correct value should be in the vicinity of -11.77. Although this data sheet has been reviewed and accepted by the responsible test engineer as part of the test package, this obvious error had not been noticed and correcte . The values of the hydrostatic head (HB-HC) as used in L/D equation are in feet (elevation), but the data is recorded, as the level of water in accumulator, in inches. The procedure does not directly provide the reference datum for converting the recorded relative data to absolute elevation for use in the calculations. This omission makes the comparison of calculations with the recorded raw data somewhat confusing and cumbersome, although it does not affect the validity of the calculation The inspector described the above concerns to the licensee. The respon-sible test engineer informed the inspector that the test had not been reviewed or finally accepted, but during the test package review and acceptance the above concerns would be examined. This item remains open pending the final review and acceptance of the test package and result (Closed) Construction Deficiency Report (423/85-00-05): Category 1 Foxboro Transmitters do not have conduit drain holes. Foxboro installa-tion instructions require that if a junction box is installed on the transmitter, the conduit connection on the box must face downward to

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prevent any accumulation of condensate. Attached flexible or rigid conduit should also have provisions (drain holes) for preventing any accumulation of condensat Foxboro Transmitters 3RCS*PT405 and 3RCS*PT405A were iden-tified by the licensee as being installed incorrectly during a plant walk-down in March, 198 Engineering and Design Coordination Report (E&DCR) TE-03827 identified the problem and a corrective action was issued on March 19, 1985 and implemente Quality control inspection verified and closed the item on August 2, 198 This item is close (Closed) Unresolved Item (423/85-05-07): Solenoid valves 3SIL*SV8875A-H provide isolation in only one directio The Target Rock solenoid operated valve provides isolation in one direction and essentially octs as a check valve. The valve spring force maintains the valve in the closed position up to 5-10 PSID. The valve is designed to open whenever the nitrogen head-er pressure is 5-10 PSI above the tank pressure. Injection of nitrogen into the common header by design, will cause the solenoid valve to open if the corresponding accumulator tank pressure is 5-10 PSI lower than header pressur Millstone Unit-3 design is such that all four accumulator tanks will be maintained at approximately the same pressure. One tank can be vented while the others are pressurized. The nitrogen header will become pressur-ized upon manual opening of a solenoid valve. It is possible for valves at the other tanks to momentarily lift due to the resulting pressure spik However, with vent valve 3SIL*HCV9438 fully open, the header will lose pressure rapidly so that other valves will quickly close. All tanks can remain pressurized by administratively closing the tank isolation valve, 3SIL*MU8808 X, of the corresponding loo This item is close (Closed) Construction Deficieny Report (423/83-00-18): ITE type K-6005 Cir-cuit Breaker Trip Device. The magnetic latch leads were being cut by the closing spring of the breaker. The cause of the problem was determined to be too much slack in the leads when the breaker" wiring was harnesse Nonconformance and Disposition Report No. 2948 identified the breakers that had cut magnetic trip leads. The damaged wires were spliced and insulated with Raychem Heat Shrink Tubing (WCSF-N) in accordance with manufacture instructions. Out of 130 breakers inspected, 5 had the wire proble The inspection has been documented on N&DR No. 2948 and closed by the licensee j on Completion Report, System Number 3344A-1 on March 26, 1985.

This item is enclose e

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3.0 Plant Procedures 3.1 References / Requirements CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants, Criteria V, VI, XIV, XVII and XVII . ANSI N18.7 (Regulatory Guide 1.33-1978), Administrative Control and Quality Assurance Program Requirements (Operation). ANSI N45.2 Quality Assurance Program Requirements for Nuclear Power Plant . Northeast Utilities Quality Assurance Program Topical Report, Rev. . Final Safety Analysis Report Sections 6,9,10 and 1 . Technical Specification, Sections 3 and 6 (Draft)

3.2 frogram Review The following licensee's administrative control procedures were reviewed to verify the adequacy and scope of plant procedures and management controls used in implementing and maintaining them.

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ACP-QA-1.01, Millstone Administration, Rev. 4,

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ACP-QA-1.02, Organization and Responsibilities, Rev. 16,

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ACP-1.18, Unit Duty Officer Responsibilities, Rev. 1,

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ACP-QA-3.01, ACP's and Station Forms, Rev. 15, i

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ACP-QA-3.02, Station Procedures and Forms, Rev. 33,

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ACP-QA-3.03, Document Control, Rev. 27,

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APC-6.01, Control Room Procedure, Rev. 14,

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ACP-6.12, Shift Relief Procedures, Rev. 2,

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ACP-QA-9.03, Inservice Plant Testing, Rev. 5,

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ACP-10.02, Routine Reporting Requirements, Rev. 4,

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ACP-QA-10.04, Nuclear Poner Plant Records, Rev. 25, l

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ACP-10.05, Log Book Requirements (Control Room), Rev. 2,  ;

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OP 3207, Reactor Shutdown, Rev. O,

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OP 3301A, Pressurizer Relief Tank and Reactor Vessel Flange Leakoff Operations, Rev. O,

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OP 33010, Reactor Coolant Pump Operation, Rev. O,

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OP 3304A, Charging and Letdown, Rev. O, j --

OP 3308, High Pressure Safety Injection, Rev 0,

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OP 3316A, Main Steam, Rev. O,

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OP 3316C, Steam Generator Blowdown, Rev. 1, 1 ---

OP 33418, Fire Protection Hatch System, Rev. 1,

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GPIC 5.1, Foxboro Model 2 AP+SSX Hi/Lo Selector, Rev. O,

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CP 3801F, Total Organic Analyzer, Rev. O,

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SP 31105, Containment Quench Spray Header Nozzle Flow Test, Rev. 1,  ;

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GPE 03AM, Relay Procedure Type PVD21, Differential Voltage,  !

Rev. O,

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MP 3720CG, PM Procedure Adding Lube Oil to Diesel Generator,

Rev. O, r

3.3 Program Implementation i

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! The inspector reviewed the licensee's procedures and departmental j instructions listed in paragraph 3.2 and determined that:

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The licensee has established administrative controls for review, approval and periodic updating of administrative, general plant

operations, startup, operation and shutdown of safety-related

' systems, and night order or standing order procedures in accordance with ACP-QA-1.0 Responsibilities for review, update and approval of plant pro-cedures, including incorporation of changes per 10 CFR 50.59  ;

and temporary changes have been established in accordance with '

ACP-QA-1.02 and ACP-QA-1.18.

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Preparation of station procedures including format and contents are controlled in accordance with ACP-QA-3.01 and ACP-QA-3,02,

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Issuance of new and revised procedures and disposition of outdated procedures are controlled,

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Plant procedures, including night orders, are periodically reviewed by cognizant individuals, ,

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Preparation and correction of operations logs are controlled in accordance with Operations Instructions 3-0PS-10.01 and 3-0PS-10.02,

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Shift turnover activities and review of the operating logs are

conducted in accordance with ACP-6.12, a

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Working copy of the procedures is consistent with the master i file cop l 3.4 QA/QC Interface The inspector verified that all quality related administrative control procedures were reviewed for adequacy, accuracy and completeness and approved by QA/QC staff. The inspector reviewed QA Monitoring Reports 384-01, 384-05 and 384-08 for " Unit 3 Daily surveillance and Shift Turnover Activities" and verified that the intent of the Operations Instruction 3-0PS-10.02 was implemented along with the requirements of ACP-QA-9.0 .5 Findings The procedures reviewed indicated incorporation of scope, references, prerequisites, precautions, limitations, actions and sequence of operations.

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The licensee has clearly identified -in ACP-QA-1.02, the responsib-ilities of the plant operational staff. At any given time two senior operators and one shift supervisor are available in the control room j to conduct safe operation of the plant. The operators have the authority and responsibility for shutting the reactor down based on a safety concern, as well as for not returning the reactor to power following an unanticipated scram. This authority and responsibility has been delineated in the startup station procedure OP 3202. As indicated in ACP-QA-1.02, the senior licensed operators determine and

, analyze the circumstance and cause of fault conditions and correct the condition before returning the reactor to power following an unanticipated scram. As discussed with the operations assistant the operators are trained and indoctrinated in pursuing their respons-ibility to follow plant procedures and to adhere to the Technical

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4 Specifications. ACP-10.05 delineates log book requirements (Control Room) and entries thereto of operating information. The new and revised procedures, prior to approval for implementation, are reviewed by PORC and evaluated for any unreviewed safety concerns,

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environmental impact and integrated safety system response, as

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applicable. Plant procedures are approved by an appropriate member of facility management, namely the Station, Service or Unit Super-intendent. The procedure ccver sheet includes the approval signature and effective date of implementation. ACP-QA-10.04 identifies source, applicability, and responsibility for retention of these plant procedures used to perform significant operations. The approved procedures are distributed in accordance with the current distribution lis Five controlled copies of operating procedures, one with Operation  !

Supervisors, one with Shift Supervisors, and three working copies are available in the control Room. These procedures are periodically  :

reviewed and updated. Administrative procedures ACP-1.18, ACP-QA-3.02 and EPIP 4112 provide for personnel conduct and control, and "on-call"

availability of professional and supervisory personnel. The different departments maintain an "on-call" log book for individuals assigned to emergency duties. Their availability and responsiveness is considered critical for implementation of the plant emergency and administrative procedures.

The inspector interviewed an Operations Assistant and determined that he was aware of and understood the system established for temporary changes to procedures. He indicated that an Operations Department i generated Standing Order pertaining to " Control Room Rounds (SP-3670.1)" was in the process of PORC review for approva No violations were identifie .0 Emergency Procedures 4.1 References / Requirements

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Regulatory Guide 1.33, February 1978, Quality Assurance Program Requirements,

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ANSI N 18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants,

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Millstone Nuclear Power Station Unit 3, Final Safety Analysis

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Report (FSAR) Section 13.5, Plant Procedures,

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NUREG-1031, Safety Evaluation Report (SER) Related to the Operation of Millstone Nuclear Power Station Unit number 3, ,

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4.2 Program Review The following emergency procedures were reviewed to determine if they were consistent with the requirements and references identified in Section Administrative Control Procedure (ACP)-QA-3.02, Attachment C, Revision 33, Millstone Unit 3 Emergency Operating Procedures

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Writers Guide,

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Emergency Operating Procedure (EOP) 35E-0, Revision 0, Reactor Reactor Trip or Safety Injection,

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E0P 35 ES-0.0, Revision 0, Re-diagnosis,

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E0P 35 E-1, Revision 0, Loss of Reactor or Secondary Cooling,

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E0P 35 ES-1.3, Revision 0, Transfer to Cold Leg Recirculation,

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ECP 35 E-2, Revision 0, Faulted Steam Generator Isolation, l

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E0P 35 ECA-0.0, Revision 0, Loss of All AC Power,

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E0P 35 ECA-0.2, Revision 0, Loss of All AC Power Recovery with SI Required,

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E0P 35, FR-P.1, Revision 0, Response to Imminent Pressurized

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Thermal Shock Condition,

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Abnormal Operating Procedure (AOP) 3550, Draft B, Turbine / Generator Trips,

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AOP 3552, Draft B, Malfunction of the Rod Drive System,

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A0P 3564, Revision 0, Loss of One Protective System Channel, Based upon this review it was determined that:

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the procedure format followed by the licensee was similar to that used in the WOG Emergency Response Guidelines. ACP-QA-3.02

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Appendix C sets forth a format to be used for all E0Ps which is i consistent with the WOG Emergency Response Guidelines, ,

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abnormal operating procedures had been identified and drafted, 4 --

.an Emergency Response Guideline Transition Flow Chart existed which was used as the basis for the WOG Emergency Response

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Guidelines, i

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the procedure which provides for reset of the Safety Injection System (SIS) signal following a LOCA, provides for actions

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alarm procedures have been prepared and approve These  !'

procedures are incorporated into Section 8 of the operating procedures. A Control Room Alarm Book (CRAB) is used as a cross reference index to reference a control room panel alarm to the particular operating procedures paragrap .3 Program Implementation

' A review of the following P& ids was made to verify proper valve lineup for " Cold Leg Recirculation - ECCS Valve Lineup" wh;n

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required by the appropriate operating emergency procedure,

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Low Pressure Safety Injection, Drawing No. 25I12-26912, Revision 2 I --

High Pressure Safety Injection, Drawing No. 2i212-29913, Revision 1A.

4.4 Findings i

, Although twenty-two (22) of the twenty three (23) identified A0Ps

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have been drafted only six of these 123 have been approved. Prior to fuel load, the licensee shall, as a minimum, identify and approve those AOPs required for fuel load and low power testing. This is an unresolved item (50-423/85-55-01).

The Control Room Alarm Book (CRAB) is not being controlled and does i not accurately reflect the status of the alarm boards. Control of

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this book is needed to assure that the control room operators have an accurate and up-to-date cross reference to the alarm procedures when needed. This is an unresolved item (50-423/85-55-02). ,

Certain alarms in the control room monitor more than one parameter  ;

or sensor. When one of these sensors gives an alarm, the operator may take that sensor out of operation and then reset the alarm to

monitor the remaining sensors. The licensee has not established any administrative controls for monitoring the status of the sensor taken out of service. This is an unresolved item (50-423/85-55-03).

5.0 Operating Procedures

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Millstone 3 Draft Technical Specification, August 16, 1985

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Millstone 3 Final Safety and Analysis Report, Sections 5.2, 5.4.1, 7.2, 6.3, 10. Regulatory Guide 1.33 - 1978, Quality Assurance Program Requirements (0peration)

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ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plant ,

5.2 Program Review The inspecto" reviewed the Millstone Point (MP) -3 program for preparation of plant operating procedures to verify compliance with the requirements referenced in paragraph 5.1 and to determine that MP-3 has established administrative controls for:

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Procedure preparation and approvals

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Procedure formats

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Procedure distribution and status control

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Checklist preparation and contro The follcwing site administrative control procedures and Operations Department instructions were reviewed:

Site Administrative Control Procedures

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ACP-QA-1.02, Organization and Responsibilities, Revision 16, April 17,1985,

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ACP-QA 1.04, Plant Operations Review Committee, Revision 19, June 13, 1984,

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ACP-QA-2.06A, Station Tagging, Revision 9, June 24, 1985,

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ACP-QA-2.12, System Valve Alignment Control, Revision 7, August 27, 1985,

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ACP-QA-3.01, Administrative Control Procedures and Station

, Forms, Revision 15, July 23,1985

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ACP-QA-3.02, Station Procedures and Forms, Revision 33, August 20, 1985 l --

ACP-6.01, Control Room Procedure, Revision 14, June 20, 1985

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ACP-QA-9.02, Station Surveillance Program, Revision 13, July 26, 1985

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ACP-QA-9.03, Inservice Plant Testing, Revision 5, November 7, 1982

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ACP-QA-9.06, Inservice Inspection Program, Revision 8, February 1, 1985

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ACP-QA-10.06, NRC Commitment Follow Program, Revision 5, March 2, 1984 Operations Department Instructions

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3-0PS-3.01, Station Procedure Development and Control Prior to PORC Approval, Revision 3, January 6, 1985

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3-0PS-3.03, Procedure Preparation Guidance, Revision 1, March 5, 1982

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3-0PS-3.04, Pump Surveillance Procedure Preparation Guidance, Revision 1, July 22,1982

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3-0PS-3.05, General Operating Procedure Preparation, Revision 1,

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March 22, 1984

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3-0PS-3.06, Valve Surveillance Procedure Preparation, Revision 0, April 6, 1984 5.3 Implementation Review Randomly selected, recently issued plant procedures were reviewed to determine compliance to the requirements referenced in paragraph and the administrative controls detailed in paragraph Procedures were reviewed for the following:

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Proper review and approval

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Correct format

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Conformance to Technical Specifications

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Inclusion of checkoff lists where applicable

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Stepwise instructions and provision of necessary detail to

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} Procedures Reviewed were:

I General Operating Procedures j

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OP 3202, Reactor Startup Revision 0, August 28, 1985

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OP 3203, Plant Startup, Revision 0, February 11, 1985

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OP 3204, At Power Operation, Revision 0, July 17,1985

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OP 3250, Removing Equipment From Service For Maintenance,

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Revision 1, January 30, 1984 i

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OP 3252, " Operator Aids," Revision 1, June 22,1984 System Operating Procedures

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OP 33010, Reactor Coolant Pump Operation, Revision 0, ,

November 30, 1984 i

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OP 3301G, Pressurizer Pressure Control, Revision 0, July 8,1985 f --

OP 3302A, Control Rod Drive, Revision 0, August 5, 1985 i  :

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OP 3308, High Pressure Safety Injection, Revision 0, 1 J April 8, 1985 I

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OP33108, Accumulator Low Pressure Safety Injection, Revision 0, '

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OP 3322, Auxiliary Feedwater System, Revision 0, August 28, 1985 l

l 5.4 Findings

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The inspector noted that the licensee had issued most operating i procedures (19 of 29 identified general operating procedures j (GOP's), and 109 of 127 identified system operating procedures have been issued). However, many procedures are incomplete as i the checkoff lists (OPFORMS) associated with the procedures have 1 not yet been issued, and system parameters and setpoints are not i yet included in the procedures. The applicant stated that the i

failure to reach agreement on certain aspects of the T.S. had prevented these numbers from being incorporated into the  :

procedure The applicant further stated that a system has been developed l

to ensure that system parameters and OPFORMS are added to

i procedures. The applicant also stated that system operating

! procedures would be used and checked out during the performance  !

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of hot functional testin !

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Revision of operational procedures to include OPFORMS is an

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open item subject to NRC-RI review (50-423/85-55-04). t

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Regulatory Guide 1.33, Appendix A, paragraph 3 states that system operating procedures should include " Instructions for energizing,

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{ filling, venting, draining, startup, shutdown, and changing modes of  :

operation...as appropriate...". Procedures OP 3322, " Auxiliary Feedwater" and OP 3308, "High Pressure Safety Injection" do not

! include procedures for filling, venting and or draining the systems.

The ins,.ector informed the applicant that operating procedures for i systems which contain reactor coolant or perform key safety functions i

should contain fill, vent and drain procedure This item is open i

pending revision to OP 3322, 3308 and other procedures where appropriate (50-423/85-55-05).

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Regulatcry Guide 1.33, Appendix A, Paragraph 3.U, specifies that an

! operatin'j procedure be established for the Reactor Protection Syste No such procedure had been established by the Operations Departmen The applicant stated that an Instrument and Control (I&C) surveillance

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procedure also constituted an operating procedure for this syste However, this procedure was not presented to the inspector for q review. This item remains open pending NRC verification that an

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operating procedure has been established for the reactor protection j system (50-423/85-55-06).

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OP 3301 D, Reactor Coolant Pump Operation, specified conditions for three loop operations. Draft Technical Specification 3.4.1.1 does a

not authorize three loop operations. Discussions with plant i representatives indicate that they expect the final T.S. to authorize -

three loop operations. If such operations are not approved then  !

! three loop operations must be deleted from OP 3301 0 and any other procedure which may authorize three loop operations (50-423/85-55-07).

l In addition, OP 3301 D requires one reactor coolant pump (RCP) remain operational for Reactor Mode 3 operations. However, draft T.S. 3.4. states that 2 RCP's and 2 loops must be in operation if reactor trip breakers are closed. Discussions with plant operations personnel indicated that there are possible operations in Mode 3 during which reactor trip breakers are close The inspector informed the applicant that OP 3301 D should be revised to accurately reflect the requirements of T.S. 3.4.1.2 concerning RCP operation in Mode 3 l (50-423/85-55-08).

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FSAR Section 10.4 provides a list of annuciator:rfor the Auxiliary

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Feedwater System. Two annunciators on this list:

i j (1) Vibration Monitor Alarm, and

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l (2) Auxiliary Feed pump turbine speed in local control s i were not incorporated in Section 8 of OP 3322. The-applicant stated .

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that annuniiator (2) above was not incorporated into the procedure l through an oversight, but would have been picked up during fidal ,

i review and updating of the Control Room Alarm Book (CRAB). Alarm (1)

l was part of a common vibration alarm system which had been deleted 1 l by a design change. This item is open pending inclusion of the "AFP, turbine speed in local control" annunicator into OP 3322 and r t i verification that a change to the FSAR deleting the vibration alarin

l is in progress (50-423/85-55-09 ). ,

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Valve lineup Checkoff Lists (COL's) in operatir.g procedures provide for a separate verification of each valve portion. However, the <

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l inspector noted that breaker and fuse COL's in procedures OP 3322, OP 1 3310 B, and OP 3301 G did not provide for an individual signoff for j each fuse or breaker aligned on each panel or mater control center ,

j (MCC). A single signoff is provided for each panel or MCC which .

i; contains as many as eight or nine fuses or breakers. In contrast, procedure OP 3301 D electrical COL provides for a signoff for each breaker aligne The prerequisites in procedure OP 3308 provide for checking the status of numerous safety bus breakers. In this case no signoff

, verification is provided at all.

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The inspector expressed a concern to the applicant about the lack of individual signoffs for breaker and fuse alignments, and the i

inconsistencies among procedures. The applicant acknowledged the

inspectors comments but made no commitment to provide individual signoff for electrical checks in COL's or procedure prerequisite !

l 6.0 Unresolved Items i ,

j Unresolved items are matters about which more information is required in

order to ascertain whether they are acceptable, deviation or violation Nine unresolved items are discussed in Paragraphs 4.4 and [

.

! 7.0 Management Meetings

e

Licensee management was informed of the scope and purpose of the inspec-  !

tion at an entrance meeting conducted on September 16, 1985. The findings , ,

a of the inspection were discussed with licensee representatives during the l course of the inspection. Exit meetings were conducted on September 20,

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and 23, 1985 at the conclusion of the inspection (see paragraph I for attendees) at which time the findings were presented to the licensee l managemen '

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! At no time during this inspection _was written material provided to the i j license !

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