IR 05000400/1986057

Insp Rept 50-400/86-57 on 860714-18.No Violations or Deviations Noted.Major Areas Inspected:Tech Spec Surveillance Requirements & Implementing Surveillance Test Procedures

ML20206S973
Person / Time
Site:	Harris
Issue date:	09/15/1986
From:	Mccay F, Wilson B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20206S963	List: IR 05000400/1986057 ML20206S959
References
50-400-86-57, NUDOCS 8609230061
Download: ML20206S973 (16)

Text

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UNITED STATES p*jp atQq'o NUCLEAR REGU.LATORY COMMISSION REGION 18

[' n 101 MARIETTA STREET, y j

• '* ATL ANTA, GEORGI A 30323 i g

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Report No.: 50-400/86-57 Licensee: Carolina Power and_ Light Company P. O. Box 1551 Raleigh, NC 27602 ,

Docket No.: 50-400 License No.: CPPR-158 Facility Name: Harri Inspection Conducted: July 14- 8, 1986 Inspector:  ?

F. R. McCoy, Tehm Lea (e V Uatt Signed Team Members: H. O. Christensen W. K. Poertner K. Sasser J. E. Tedrow Approved by: h ,

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B. Sflson, Acting Section Chief Uate Signed Operational Programs Section Division of Reactor Safety SUMMARY Scope: This routine, announced inspection was conducted in the areas of

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Technical Specification surveillance requirements and implementing surveillance l test procedure Results: No violations or deviations were identifie .

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REPORT DETAILS Persons Contacted Licensee Employees

• J. Willis, Plant General Manager

• J. L. Harness, Assistant Plant General Manager

• D. Tibbitts, Acting Director, Regulatory Compliance

• C. L. McKenzie, Acting Director, Quality Assurance / Quality Control

• G. Campbell, Director, Maintenance

• R. B. VanMeare, Manager, Technical Support

• J. R. Sipp, Manager, Effluent and Radiological Control

, *C. R. Gibson, Assistant to the General Manager

• C. S. Bohanan, Director, Special Programs

• T. F. Lentz, Engineering Supervisor

• D. A. Morrison, Project Engineer

• M. Blinde, Senior Specialist, Training

• D. A. Numy, Maintenance

• C. D. Gentile, Operations

• C. E. Rosener, Quality Assurance / Quality Control

• J. A. McAllister, Quality Assurance / Quality Control

• E. M. Steudel, Special Projects

*A. Howe, Regulatory Compliance r Other licensee employees contacted included engineers, technicians, l operators, mechanics, and office personne NRC Resident Inspectors

• S. Burris G. Maxwell

• Attended exit interview Exit Interview l The inspection scope and findings were summarized on July 18, 1986, with l those persons indicated in paragraph 1 above.- The inspector described the l areas inspected and discussed in detail the inspection findings.

l Proprietary information was reviewed during this inspection but is not included in this repor No dissenting comments were received from the license . Licensee Action on Previous Enforcement Matters l

This subject was not addressed in the inspection.

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4. Unresolved Items Unresolved items were not identified during'the inspectio . Surveillance Testing The inspectors reviewed the administrative control system for identifying and scheduling surveillance tests, the technical adequacy of selected surveillance test procedures,. performance of surveillance test procedures, and licensee evaluations in the area of surveillance testin Selected portions of the following procedures were used in accomplishing this review:

i PLP-103 Surveillance and Periodic Test Progra:n EST-710 Hot Channel Factor Tests

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EST-703 Moderator Temperature Coefficient Measurement BOL i EST-702 Moderator Temperature Coefficient Measurement E0L

MST-IO359 Radiation Monitoring System, Monitor RM-0KZ-3504A-3A, Control Room

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Normal Outside Air Intake Calibration i OST-1031 Control Room Emergency Filtration System Train "A" Operability EST-700 Core Reactivity Balance i EST-718 BOL Control Rod Withdrawal Limits EST-715 Quadrant Power Tilt Ratio with One Power Range Channel Inoperable L OST-1021 Daily Surveillance Requirements

! EST-720 Normalization of Boron Letdown Curve EST-701 Shutdown Margin Calculation GP-004 Reactor Startup from Hot Standby to Critical / Recovery from a l Reactor Trip l OST-1036 Shutdown Margin Calculation

! OST-1811 Safety Injection: ESF Response Time MST-10106 Chlorine Detection System. Train A Channel Calibration MST-10107 Chlorine Detection System Train B Channel Calibration MST-IO361 Radiation Monitoring System, Monitor RM-01CZ-3504-38, Control Room Normal Outside Air Intake Calibration OST-1028 Containment Isolation Valve Operability Post Maintenance Interval OST-1079 Contaiment Isolation Valves Inservice Inspection Test OST-1029 Containment Penetration Outside Isolation Valve Verification OST-1808 Main Steam Isolation: ESF Response Time AP-010 Implementing Changes to the Operating License / Technical Specifications AP-009 Processing Proposed Changes to Operating License / Technical Specifications OST-1807 Containment Spray System: ESF Response Time MST-E0015 Electrical Hydrogen Recombiner MST-10235 Thermal Recombiner Temperature Channel Calibration: T-7701A and l T-77018

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OST-1030 Electric Recombiner Functional Test MST-10211 Electric Hydrogen Recombiner Kilowatt Indication Channel Calibration RST-004 Air Filtration Testing Requirements

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OST-1052 RAB Emergency Exhaust System Operability i

OST-1032 RAB Emergency Exhaust System Train "A" Operability OST-1049 RAB Emergency Exhaust System Train "B" Operability

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OST-1231. Control Room Emergency Filtration System Operability i OST-1053 Control Room Emergency Filtration System Train "B'.' Operability MST-E0022 Emergency HVAC Heater Maintenance and KW Verification

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EST-212 -Type C Local Leak Rate Tests EST-206 ECCS Flow Balance EST-207 Containment Spray System Nozzle Flow Test

[ EST-205 RHR System Flow Test

OST-1007 CVCS/SI System Operability Quarterly Interval Modes-1-2-3-4 ( OST-1008'.RHR Pump Operability Quarterly Interval Modes 1-2-3 l

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OST-1106 CVCS/SI System Operability Quarterly Interval Mode 4-5-6 .

OST-1107 ECCS Flow Path and Piping Filled Verification Monthly Interval, l Modes 1-2-3-4 ,

OST-1011 Auxiliary Feedwater Pump 1A-SA Operability Test Monthly Interval, Modes 1-2-3-4 '

l OST-1021 Daily Surveillance Requirements, Daily Interval Modes 1 and 2

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OST-1022 Daily Surveillance Requirements, Daily Interval Modes 3 and 4

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OST-1033 Daily Surveillance Requirements, Daily Interval Modes 5 and 6 '

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OST-1111 Auxiliary Feedwater Pump 1X-SAB Operability Test Monthly Interval

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Modes 1-2-3 OST-1076 Auxiliary Feedwater Pump 18-SB, Operability Test Quarterly ,

i Interval, Modes 1-2-3-4 l OST-1078 Auxiliary Feedwater Pump 1B-SB Operability Test Monthly Interval, Modes 1-2-3-4 OST-1119 Containment Spray Operability Quarterly Interval Modes 1-2-3-4

OST-1116 Administrative Controls to Prevent Dilution During Refueling

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Monthly Interval, Mode 6

OST-1006 Boration System Operability Monthly Interval Modes. 1-2-3-4-5-6 l- OST-1211 Auxiliary Feedwater Pump 1A-SA Operability Test Quarterly l Interval, Modes 1-2-3-4 OST-1411 Auxiliary Feedwater Pump IX-SAB Operability Test Quarterly Interval, Modes'1-2-3 OST-1803 Containment Sump Visual Inspection 18-Month Interval, Mode 5 RST-205 Reactor Coolant System Accumulator Boron Concentration Surveillance OST-1074 Motor Operated Valves Thermal Overload and Torque Switch Protection Bypass Test OST-1013 Emergency Diesel Generator Operability Test Monthly Interval OST-1123 Offsite Power Availability Verification Weekly Interval, Modes 5 and 6 OST-1023 Offsite Power Availability Verification Weekly Interval,

Modes 1-2-3-4

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OST-1024 Onsite Power Distribution Weekly Interval Verification, i- Modes 1-2-3-4-5-6 l- OST-1085 Diesel Generator Operability Test Semiannually, Modes 1-2-3-4-5-6 OST-1073 18-SB Emergency Diesel Generator Operability Test Monthly Interval

! Modes 1-2-3-4-5-6

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GP-006 Normal Plant Shutdown from Power Operation to Hot Standby MST-E0005 Molded Case Circuit Breaker Instantaneous Trip l

MST-E0008 480V AC Power Circuit Breaker Functional Test MST-E0051 Reactor Coolant Pump Breaker 1A-SN Integrated Functional Test

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MST-E0048 RCP 1A-SN Current Relay (s) Calibration MST-E0002 480V AC Power Circuit Breaker Inspection and Maintenance MST-E0001 6.9KV (Reactor Coolant Pump) Circuit Breaker Inspection and Maintenance MST-E00101E Battery Weekly Test MST-E0011 1E Battery Quarterly Test MST-E0012 1E Battery 18-Month Test MST-E0013 1E Battery Performance Test MST-E0014 IE Battery Charger Capacity Test MST-10163 NI-41 Operational Test MST-10164 NI-42 Operational Test MST-10165 NI-43 Operational Test MST-I0l66 NI-44 Operational Test MST-10045 Calibration of Power Range NI-42 MST-10647 Train A Undervoltage Relay to Reactor Trip Breaker Response Time Test MST-10120 Pressurizer Pressure (P-0456) Protection Set II MST-IO142 DT/Tavg Protection Set 3 Operational Test MST-10039 DT/Tavg Loop Calibration (T-0432)

EST-300 (Draft) Reactor Trip Response Time MST-10645 Group 2 of 3 Channel Reactor Trip System and Engineered Safety Features Actuation System Response Time Test MST-10029 Steam Generator 3C Narrow Range Level (L-0494) Protection Set I Calibration MST-I0143 Steam Generator 1A Narrow Range Level (L-0474) Protection Set I Operational Test

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MST-E0038 Reactor Coolant Pump Undervoltage Relay Channel Calibration t

OST-1125 Reactor Coolant Pump Undervoltage and Underfrequency Trip l Actuating Device Operational Test EST-302 (Draft) ESF Response Time Evaluation, Feedwater Isolation MST-10237 Containment Pressure (P-0951) Protection Set II Operational Test MST-10004 Containment Pressure (P-0951) Protection Set II Calibration MST-10001 Train A Solid State Protection System Actuation Logic and Master Relay Test l

MST-10122 Pressurizer Pressure Protection Set I Operational Test l MST-IO607 Containment Pressure Response Time Test for Protection Set I l Sensor (PT-0950)

Additionally, selected portions of the licensee's surveillance test tracking system cross reference list were reviewed. This cross reference list is designed to index each Technical Specification (TS) surveillance requirement to a procedur During the course of this inspection, the inspectors noted examples where major procedures had not yet been prepared or approved, examples where the

surveillance test tracking system cross reference list did not require accomplishment of some TS surveillance requirements, examples where the cross reference list stated that surveillance requirements were implemented by certain procedures when in fact they were not, and examples of procedures acceptance criteria and scaling and setpoint data being at variance with TS values. Additionally, the inspectors noted that very few surveillance test

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. procedures had been accomplished in the field, that programs - for

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accomplishing conditional and mode related surveillance requirements had not yet been developed, and that no formal mechanism was in' place to ensure that changes to preliminary and = final draft TS were properly implemented into surveillance test procedures and the surveillance test tracking system. The-inspectors consider that the status of preparations with respect to~

surveillance testing was not sufficiently advanced to warrant an operational

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readiness inspection in this area at this tim Data supporting this

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assessment is as follows.

!' Surveillance Test Tracking System Inadequacies l .TS 4.3.1.17 requires an operational test of the turbine trip inputs to

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the reactor ~ protection system prior to startup. This surveillance was i not included in the cross reference list. -The licensee stated that

! procedure GP-05 did, in fact, implement the surveillance requirement l and that the problem was an error in the cross reference list. This is i~ still of concern since such an error could preclude scheduling and

! tracking of the surveillance resulting in nonperformance.

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L TS 4.3.2.1.2.a requires an operational test of manual initiation of containment spray each refueling. This surveillance was not included in the cross ref6rence list. The licensee stated that procedure OST-1807 did, in fact, implement the surveillance requirement and that i- the problem was an error in the cross reference lis .

TS 4.3.2.1.3.a.1 requires an operational test . of nanual phase A l

' isolation initiation e.ach refuelin The cross reference list did not i include this surveillance. Additionally, the licensee was not able to l demonstrate that the surveillance requirement was implemented by 'any procedur TS 4.3.2.1.3.b(3) requires a shiftly channel check of containment pressure instrumentation. This surveillance was not included in the '

cross reference list. The licensee stated that procedures OST-1021 and OST-1022 did, in fact, implement the surveillance requirement and that the problem was an error in the cross reference lis TS 4.3.2.1.3.c(1) requires an operational test of containment ventilation isolation initiated from manual containment spray initiation each refuelin The surveillance was not included in the cross reference lis The licensee was not able to demonstrate that this surveillance requirement was implemented by any procedur TS 4.3.2.1.6.f requires an operational test of auxiliary feedwater system initiation from trip of the main feedwater pumps each refuelin The surveillance was not included in the cross reference list. The licensee was not able to demonstrate that this surveillance requirement was implemented by any procedur .

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1-l ~ TS 4.3.2.1.7.b requires a quarterly slave relay test for safety injection switchover to the containment sump on low low RWST level.

This surveillance was not included in the cross- reference list. The licensee stated that procedures OST-1083 and 1084 did, in fact, implement the surveillance requirement and the problem was an error in the cross reference lis TS 4.6.3.2.e requires a surveillance to verify main st' eam isolation valve actuation upon a main steam isolation test signal at least every 18 months. This surveillance was not included in the cross reference

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lis The licensee stated that procedure OST-1808 did, in fact,-

implement the surveillance requirement and that the problem was an error in the cross reference.

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TS 4.8.1.1.2.g requires that the diesel generators be proven operable j

at least once per ten years or after any modifications which could

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affect diesel generator interdependence by starting both diesel generators simultaneously, during shutdown, and verifying that both i

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diesel generators accelerate to at least 450 rpm in less _than or equal to ten seconds. At the time of this inspection, the licensee had no procedure identified within the surveillance tracking system to

, accomplish this surveillance requirement. It is noted that the l licensee had also identified this item prior to the NRC inspection.

! TS 4.8.1.1.2.h(2) requires that the diesel generators be proven i operable at least once per ten years by performing a pressure test of

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those portions of the diesel fuel oil system designed to Section III, i subsection ND of the ASME Code, at a test pressure equal to 110% of the j system design pressure. At the time of this inspection, the licensee I had no procedures identified within the surveillance test tracking system to accomplish this surveillance requiremen .

OST-1078, Auxiliary Feedwater Pump 18-SB operability test, was not listed in the surveillance cross-reference list as a procedure fulfilling the corresponding TS requiremen Weaknesses in Procedure Adequacy TS 4.8.4.2 requires that the thermal overload protection for certain required valves be verified to be bypassed only under accident conditions by an operable integral bypass device by the performance of a trip actuation device operational test of the bypass circuitry at

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l i least once per 92 days for those thermal overloads which are normally in force during plant operation and are bypassed only under accident conditions and following maintenance on the motor starter. Review of the surveillance procedure identified as meeting this surveillance requirement revealed that the procedure was inadequate in that it did not meet the requirements of a trip actuation ':vice operational tes Specifically, the test performed by the licensee merely tested the primary relays and did not test the initiation circuitry or the contacts which actually place the bypasses inservice. When identified

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to the licensee, they concurred but stated that performance of a trip

actuation device operational test at-least once per 92 days was not '

feasible. The licensee agreed to-review this issue and resolve it with NR This item will be identified as an inspector followup item

pending resolution with NRR (400/86-57-01).

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Maintenance procedures MST-IO644, 0645, and 0646 perform the response time- testing of the- Overtemperature Delta Temperature (OTDT) trip function as required by TS 4.3. A review of these procedures indicated that a complete response time test of this safety function

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i may not be performed by the test method. Specifically, the OTDT trip

, function has five channel sensors: nuclear flux upper ion chamber (la), nuclear flux lower ion chamber (Ib), pressurizer pressure (P), ,

cold leg temperature (Tc), and hot leg temperature (Th). The response i

time test method of MST-IO645 varied 'Th', while. holding the other four

! inputs constant, until actuation of the OTDT trip. The procedure is repeated for 'P' and then 'Ia' while holding the other four parameters

, constant in each case. Response times are not obtained when 'Tc' or

'Ib' channel sensors exceed the trip setpoin TS definition 1.29 i states that reactor trip system response time shall be the time inter-val from when the monitored parameter exceeds its trip setpoint at the-

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channel sensor until loss o_f stationary gripper coil voltage. The

licensee's response time test method did not time the interval from

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when all monitored parameters of OTDT exceed their trip setpoint at the l channel sensor as required by TS 1.29 definition. As a result, the

longest channel response time may not be compared to the TS acceptance i criteri The licensee stated that action would be taken to correct l this situatio The inspectors consider that response time tests of

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all reactor trip and engineered safety features should be reviewed by the licensee to ensure that all monitored parameters are tested in compliance with TS requirement Procedures MST-10359 and MST-10361 activate components which auto-matically reposition valves to isolate the control roam ventilation system and place this system in the recirculation mode of operatio At the completion of this test, the restoration section of the procedure did not return the ventilation system to the normal operating lineu TS 4.1.2.1.a requires that the boric acid tank and the charging / safety injection pump suction header temperature be greater than or equal to 65 F when used. This requirement is applicable for modes 4, 5, and OST-1033, Daily Surveillance Requirement for modes 5 and 6, failed to address this TS. Additionally, OST-1022, Daily Surveillance Require-ments for Modes 3 and 4 addressed the same requirement for TS 4.1.2. but the procedure did not state that it met the requirement for TS 4.1.2.1.a. Mode 4. The licensee was informed, and corrective action to revise these two procedures was initiate TS 4.1.2.6.a.3 requires that the boric acid tank solution temperature be equal to or greater than 65 F in modes 1, 2, 3, and 4 when it is the

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1 source of borated water. The surveillance cross-reference list stated

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.that procedures OST-1021 and OST-1022, the daily surveillance require-ments for modes 1 and 2 and modes 3 and 4 addressed the TS. A review

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addressed. The' licensee was infomed and corrective action to revise these two procedures was initiate TS 4.5.2.b.2 requires all valves (manual, power-operated, or automatic)

in the flow path, of the emergency core cooling system . (ECCS)

l subsystems, that are not locked, sealed, or otherwise secured in

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position be verified in the correct position. OST-1107, ECCS Flow Path

. and Piping Filled Verification for modes 1-2-3 and 4 contains a. valve

! checklist which lacked valves 1ST-340 (Low Head Safety Injection to l . Reactor Coolant. System Cold Legs) and IST-341 (Low Head Safety j Injection to Reactor Coolant System Cold Legs). The inspectors noted

that these valves .do get position checked daily under TS 4.5.2.a -but were not checked pursuant to TS 4.5.2.b.2. The licensee informed the-L inspectors that the valves would be added to the monthly checklist.

(L . TS 4.5.3.1 requires ECCS subsystems in mode 4 be demonstrated operable l per the applicable requirements of specification 4.5.2. A review of f the surveillance cross-reference list and the procedures used to meet

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TS 4.5.2 indicated that not all the TS requirements of TS 4.5.2 were

addressed for TS 4.5. For example, OST-1008, RHR Pump Operability l Quarterly Interval, addressed TS 4.5.2.f.2 but did not state in the

' purpose section of the procedure that it also applied to TS 4.5. .0ST-1007 CVCS/SI System Operability, Quarterly interval addressed TS 4.5.2.f.1 but.did not state it is applicable for TS 4.5. The

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licensee informed the inspectors that all TS requirements of TS 4.5.2 l

applied to TS 4.5.3.1 and that they would review all items of TS 4. :

to ensure that TS 4.5.3.1 was adequately addresse "

l TS 4.5.2.h.1 requires a flow balance test during shutdown or following completion of' modifications to the ECCS subsystems that alter the  ;

subsystem flow characteristics and requires verifying that for charging / safety injection pump lines, with a single pump running the sum of the injection line flow rates, excluding the highest flow rate,

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is greater than or equal to 379 gpm and the total pump flow rate is

! less than or equal to 650 gpm. EST-206, ECCS flow balance test is the

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procedure used to meet this requirement. A review of the procedure indicated that only one charging pump is used to determine flow balance l characteristics. The inspector expressed a concern that the other two l

charging pumps may have different pump characteristics and not meet the

! flow balance acceptance criteria. The licensee stated they would L revise the surveillance procedure to test the other two charging pumps

and reword the procedure to ensure that all affected flow paths are teste ,

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TS 4.5.2.h.2 requires a flow test of the Residual Heat Removal (RHR)

system injection lines after a system modification. EST-205, RHR j system flow test is the surveillance used to meet the TS requirement.

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This procedure did not test the hot leg injection paths for low head safety injectio The licensee informed the inspectors that the procedure would be revised to include the hot leg injection path Acceptance Criteria and Scaling and Setpoint Data Inadequacies The acceptance criteria of several surveillance test procedures differed from the requirements specified in the applicable TS surveiliances. These differences appear to be caused by recent revisions to the facility's TS and these revisions not being fully incorporated into the facility's surveillance test procedures. The following examples were noted:

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TS 4.6.3.1 requires phase A containment isolation valves SP-948, SP-949 (RCS sample isolation valves) and SP-941, SP-949 (H, analyzer isolation valves) to be determined operable following maintenance or repai These valves had been recently relabeled for identification purpose The revised TS had the current correct valve identification numbers, however, procedure OST-1811

, had not been revised to reflect the new valve identification.

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TS 4.7.7.d.1 requires that the pressure drop across the combined HEPA filters and charcoal absorber bank in the reactor auxiliary building (RAB) emergency exhaust system be less than 4.1 inches water gauge (wg) while operating the system at a flow rate of 6800 cfm. The acceptance criteria of procedure OST-1052 requires this pressure drop to be less than 9.22 inches w TS 4.7.6.d.1 requires that the pressure. drop across the combined HEPA filters and charcoal absorber bank in the control room emergency filtration system be less than 5.1 inches wg while operating the system at a flow rate of 4000 cfm. The acceptance criteria of procedure OST-1231 requires this pressure drop to be less than 8.49 inches wg. TS 4.7.6.d.3 further requires that the system maintain the control room at a positive pressure of greater than or equal to one eighth inch wg when the system is operated at a pressurization flow of less than or equal to 315 cfm. The acceptance criteria of procedure OST-1231 requires that this pressurization flow be less than or equal to 400 cfm.

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TS 4.5.2.f.1 requires that the charging and safety injection pumps develop the required differential pressure when tested pursuant to specification 4.0.5 (ASME Code Section XI testing). OST-1007, CVCS/SI system operability quarterly interval is the procedure used to meet this requirement. A review of this procedure indicated that the acceptance criteria, equipment alert values, and required action range values had not been incorporated into the procedur The procedure had a note which stated, "Any pump and valve acceptance criteria and alert values not listed on data sheets will be determined subsequent to the first performance of the OST by the Inservice Inspection Group". The inspector

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i reviewed additional procedures which required ASME Section XI test

. . data and all of them lacked acceptance criteri The inspectors were concerned that running the procedure to determine equipment acceptance criteria would not be adequate. The licensee informed the inspectors that the data taken from the first run of the procedure .would receive an engineering evaluation against the systems design basis and the preoperational test data to determine

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adequate acceptance criteria values. The inspectors informed the licensee that subsequent NRC review of the engineering evaluations to determine ~ adequate acceptance criteria for surveillance

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procedures would be an inspector followup item (400/86-57-02).

i Additionally, the inspectors informed the licensee that the first run of the surveillance to determine acceptance criteria data should not be used as credit toward successful completion of the surveillance requirement. The inspectors noted that a surveil-lance- test procedure should be completely established and l determined to be acceptable prior to performing the surveillance test procedure to satisfy the initial TS surveillance requirement.

r TS 4.5.2.f.2 requires that each RHR pump develop the required differential pressure when tested pursuant to specification 4. OST-1008, RHR pump operability, quarterly interval is used to meet this requiremen This procedure is another example where acceptance criteria would be added after the first run.

TS 4. 7.1.2.1.a .1, requires that each motor-driven auxiliary feedwater pump develop a discharge pressure of greater than or equal to 1510 psig at a recirculation flow of greater than or equal to 50 gp A review of OST-1011, Auxiliary Feedwater Pump L

1A-SA operability test, indicated that the acceptance criteria for

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pump suction pressure had not been determined yet. This is another example of acceptance criteria being provided after the procedure is first ru The inspectors noted the following with respect to scaling and setpoints associated with the reactor trip system. TS table 2.2-1 provides instrumentation trip setpoints. The setpoints for Overtemperature Delta Temperature (0 TDT) and Overpower Delta Temperature (0PDT) were recently revised based on Westinghouse supplied information. The inspectors found that the revised setpoints had not been incorporated into the instrument scaling documents and implementing procedure It was also noted that additional revisions to these documents were necessary to incorporate results of preoperational tests (e.g., RTD cross -

calibration data). Approximately six to eight weeks was estimated by the licensee to be required for incorporation of TS .

and test data revisions into the plant procedure +

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Procedure Preparation Status Concerns Technical Services procedures (designated as EST) for response time testing of the Reactor Trip System (RTS) and Engineered Safety Features Actuation System (ESFAS) are the controlling procedures to ensure compliance with TS 4.3.1.2 and 4.3. The ESTs will schedule and coordinate response time test procedures conducted by Maintenance and Operations in MSTs and OSTs. The inspectors found that, of the 18 EST ,

, procedures planned for RPS and ESFAS response time testing, none had been approved and issued in final form, two were in final draft, and

, the remaining 16 were in various stages of preparation. The licensee estimated approximately, six to eight weeks to be required to complete

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the technical review and final approval. The two procedures in final draft were reviewed. The inspectors reviewed the final draft of l EST-300, Reactor Trip System Response Time Evaluatio The procedure i contained no provisions for scheduling train and channel tests to

< ensure compliance with the alternating frequencies specified by TS 4.3.1.2. When questioned by the inspectors, the licensee responded i with a later draft revision which addressed this concern. This problem had previously been identified by the licensee but was not brought to the inspector's attention until questioned. The revised procedure

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contained a workable method for ensuring that system train and channel

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tests are conducted on the required schedule. The inspectors reviewed

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the two draft- procedures, EST-300 and EST-302, against maintenance

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procedure MST-IO645 to determine if data could be extracted from the

MST procedure data sheet As written at the time of the review, much

! of the data required to be recorded in the EST procedures was not readily identifiable in the MST data sheets. The inspectors considered that each EST procedure and its corresponding satellite MST procedure

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should be reviewed by the licensee to ensure proper identification and i

tracking of required data.

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TS 4.8.1.1.2 requires various surveillance tests for diesel generators

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which are to be performed on an 18 month frequency. Presently, the licensee has no approved procedure to accomplish a substantial portion

! of these surveillance requirement The licensee stated that procedures to accomplish these surveillances were presently in the i review process and would be issued shortly.

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TS 4.8.4.1 requires that all containment penetration conductor

' overcurrent protective devices given in Table 3.9-1 of the TS shall be demonstrated OPERABLE at least once per 18 months by verifying that the 6900-volt circuit breakers are OPERABLE by selecting, on a rotating basis, at least 10% of the circuit breakes, and performing the i following:

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• A channel calibration of the associate protective relays.

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• An intergrated system functional test which includes simulated automatic actuation of the system and verifying that each relay

• and associated circuit breakers, and control circuits function as

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designe For each circuit breaker found' inoperable during these functional

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r tests, an additional representative sample of at least 10% of all j- the circuit breakers of the inoperable type shall also be

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functionally tested until no more failures are found or all circuit breakers of that type have been functionally tested.

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. Additionally, they shall be demonstrated operable at least once per i 18 months by selecting and functionally testing a representative sample of at least 10% of each type of lower voltage circuit breakers.

l Circuit breakers selected for functional testing shall be selected on a

, rotating basis. Testing of these circuit breakers shall consist of

injecting a current with a value equal to 300% of the pickup of the

long-time delay trip element and 150% of the pickup of the short-time i delay trip element, and verifying that the circuit breaker operates within the time delay band width. for that current specified by the manufacturer. The instantaneous element shall be tested by injecting a i, current equal to 20% of the pickup value of the element and verifying

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that the circuit breaker trips instantaneously with no intentional time delay. Molded case circuit breaker testing shall also follow this procedure except that generally no more than two trip elements, ti , delay and instantaneous, will be involved. Circuit breakers found i inoperable during functional testing shall be. restored to OPERABLE status prior to resuming operation. For each circuit breaker found inoperable during these functional tests, an additional representative sample of at least 10% of all the circuit breakers of the inoperable

type shall also be functionally tested until no more failures are found or all circuit breakers of that type have been functionally tested; and at least once per 60 months, they shall be demonstrated operable by subjecting each circuit breaker to an inspection and preventive maintenance in accordance with procedures prepared in conjunction with its manufacturer's recommendation The inspectors determined that the requirements of 4.8.4.1.a.1.c were not fully incorporated into the surveillance procedures identified in the cross reference list. The inspectors also determined that all of the procedures identified to implement the requirements of 4.8.4.1 had not been fully developed at this poin Of specific concern was the fact that only 13 of approximately 300 breakers were covered by currently issued procedures and that provisions for additional testing upon breaker inoperability during testing were not adequately addresse The inspectors recognize that the surveillance referenced in this paragraph are 18 month surveillances; however, the inspectors are unaware of any vehicle, other than the referenced surveillance test procedures, that will be used to initially credit accomplishment of the surveillance requirement prior to operation. Consequently, it is considered that these surveillance tests procedures are required prior to licensin *

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13 Program Preparation Status The inspectors reviewed the licensee's program for implementing changes to the facility's T Discussions with licensee personnel revealed that the licensee presently does not have a formal program to ensure that changes to TS required surveillances are properly incorporated ,

into plant procedure The scheduling and implementation of event related surveillances were reviewed to determine if these surveillances have a mechanism to ensure accomplishment. Surveillances reviewed included those required to be performed prior to exceeding specified power levels, those required to be periodically performed as measured by Effective Full Power Days

.(EFPD), and those required when specified system parameters are reached. The review of plant procedures and discussions with licensee personnel indicated that no mechanism is currently established to formally track and to ensure completion of these types of surveil-lance A review of the surveil',ance test tracking system data base reflected that of app:oximately 800 surveillance test procedures, the licensee was only Ale to demonstrate that 11 calibration procedures had been field run and documented in the tracking syste The inspectors consider that actual satisfactory performance of a surveillance test procedure is mandatory to demonstrate operational readiness for that procedur A review of the licensee's progress in preoperational testing and system turnover was conducted to assess readiness for establishing acceptance criteria for ASME Code Section XI testing to satisfy surveillance requirements. This review was restricted to only safety related and non-safety related but TS required systems and reflected that preoperational testing of these systems was approximately 65%

complete with 106 of 162 systems tested and of these 61 were approved by the Joint Test Group. Only two systems in these categories had been operationally turned over; the diesel generator fuel oil transfer system and the condenser vacuum system. The status of these activities has a direct bearing on the licensee's ability to establish satis-factory acceptance criteria within surveillance test procedures and affects the licensee's ability to demonstrate operational readiness. Miscellaneous Observations TS 4.7.1.3.1 requires the condensate storage tank (CST) be demonstrated operable at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying the contained water volume is within its limits when the tank is the supply source for the auxiliary feedwater pumps. OST-1021 and OST-1022, the daily surveil-lance requirement procedures, implement this requiremen The l inspectors attempted to review the licensee curve book to determine if the instrumentation for the CST was setup to have 270,000 gallons of water equal to 62% indicated level as listed in the procedure signoff i

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ste This data along with the curve data for the volume equivalents

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for the boric acid tank and refueling water storage tank were not

' available. The licensee informed the inspectors that these curves were

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_under review and the procedure governing the control of the curve book was under revisio *

TS 4.8.1.1.2.a.1 requires a minimum of 92.5% indicated level in the

diesel fuel oil day tank, which is equivalent to 2,670 gallons. The-surveillance procedures only required an indicated level of 85% in the

, day tank. Discussions with the licensee determined that the correct j value for 2,670 gallons is 85% indicated level. The licensee plans to

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have this error in the TS corrected in the next revision.

f-l The - inspectors reviewed the - licensee's quality assurance department

involvement in assessing the surveillance test program. The quality

assurance representatives responsible for this area stated that an j assessment had been performed in' March 1986, and had indicated major

, weaknesses in the area of surveillance testing. Although no report was

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published, actions were undertaken by the licensee to correct these weaknesse In July 1986, a second assessment was performed as

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documented in QA surveillance report SR'86-191. This assessment compared the surveillance requirements credited by each procedure

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within the scope statements of the procedures to the surveillance test

< tracking system cross reference list. A significant number of

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discrepancies were noted; however, this type of review could not discern whether.the discrepancies were administrative problems with the cross reference list or procedure scope statements, or whether the discrepancies were actual technical inadequacies representing failure

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to properly implement TS surveillance requirements. The licensee

! informed the inspectors that a new quality assurance surveillance was ,

i initiated on July 10, 1986, which would review surveillance . test .

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procedures to verify that the procedures actually implemented the

surveillance requirements that the procedure scope ' statements i

indicated. The licensee stated that this surveillance would be

! documented and a response to the findings would be required. The

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inspectors consider that completion of the licensee's assessment 'is j necessary to assure operational readiness-in this are t

It was the general consensus of the inspection team that the licensee's

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procedure format and clarity of instruction was adequate and conducive j to utilizatio Additionally, for those procedures reviewed, implementation of independent verification and supervisory and quality l assurance reviews appeared to be adequate.

I General Conclusions

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! As previously stated, the inspectors consider that the licensee's

! status of preparations in the area of surveillance testing was not

! sufficiently advanced to demonstrate operational readiness in that t are Consequently, NRC reinspection of surveillance testing will be

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required prior to licensing. Prior to the reinspection, the inspectors i

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consider that the licensee's surveillance test procedure program should be adequately implemented to assure operational readiness. To this end, the following actions should be completed by the licensee prior to NRC reinspectio (1) All procedures which implement surveillance requirements that are

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required to support operations encompassed by the license should be approved and ready for use.

. (2) Proper acceptance criteria and scaling and setpoint data should be

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prescribed within surveillance test' procedures encompassed by paragraph g.(1). Additionally, instrumentation should be set to the proper setpoint parameter .

{ (3) Surveillance test procedures encompassed by paragraph g.(1) should be satisfactorily completed in the field at least once without

! problem and following establishment of acceptance criteria. Where

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plant conditions prohibit this, the procedure should be walked down satisfactorily without proble (4) The surveillance test tracking system data base should be verified

, by the licensee to ensure that it is complete with respect to capturing all surveillance requirements for all required frequencies.

I (5) The licensee should adequately establish programs for condition l

dependent and mode dependent surveillance (6) The licensee should implement a formal mechanism to ensure control of changes to preliminary and . final draft TS. This is to ensure that the surveillance test tracking system will be up to date at the time of licensin (7) The licensee's QA surveillance of surveillance testing, which was (- in progress at the time of this inspection, should be completed

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and documented, with all concerns satisfactorily resolve The inspectors noted that the licensee was addressing and taking action

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to resolve the specific concerns generated by this inspection.

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Additionally, at the exit interview, the licensee stated that those

' types of concerns which could be programmatic in nature would be reviewed on a generic basis to ensure program adequacy. Since complete reinspection in this area is necessary, specific findings were not addressed as inspector followup items unless additional engineering

evaluation and resolution was required to resolve the issue.

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