IR 05000206/1990001
| ML20012A197 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 02/16/1990 |
| From: | Huey F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20012A195 | List: |
| References | |
| 50-206-90-01, 50-206-90-1, 50-361-90-01, 50-361-90-1, 50-362-90-01, 50-362-90-1, NUDOCS 9003080481 | |
| Download: ML20012A197 (24) | |
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O.S. NUCLEAR REGULATORY COMMISSION
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REGION V
l Report Nos.
50-206/90-01,50-361/90-01,50-362/90-01 Docket Nos.
50-206, 50-361, 50-362 k
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License Nos.
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Licensee:
Southern California Edison Company i
Irvine Operations Center u
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23 Parker Street Irvine, California 92718
Facility Name:
San Onofre Units 1, 2 and 3
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inspection at:
San Onofre, San Clemente California
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Inspection conducted: January 2 through January 19, 1990
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Inspectors:
C. W. Caldwell, Senior Resident Inspector l
M. p MM h y ea tor Inspector e
NI f,k 0
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Approved by:
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/ T"'T'FJey, chief, ty= r.;; G3Non FiTe'51gned
, Summary:
l Inspection on January i through January 19, 1900 (Report Nos, 30-206/90-01,
L 50-3f1/90-6T~TO-36GYO-01T
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Areas Inspected:
l Routine unannounced inspection by region based inspector of licensee action on
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' inspector identified items. NRC Inspection Procedures-37911, 38703, 64704,
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71707, 92701, and Temporary Instruction 2515/87 were used as guidance during L.
this inspection.
Results:
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General Conclusions and Specific Findings:
k; Continuing licensee attention is needed to implement programmatic improvements W
in the resolution of NRC open items.
For example, in 1985, the NRC raised
an issue concerning whether or not the inservice testing program for pumps is bounded by the safety analysis. The licensee has not yet resolved this issue.
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't 9003080481 900216
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Sumary of Violations and Deviations:
A deviation was identified concerning the failure of the licensee to resolve the above noted issue concerning inservice pump testing
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requirements.
Open Items Sumary:
During this report period, no new follow-up items were opened; eighteen items were reviewed, fifteen items were closed, three remain open.
Other Significant Safety Matters:
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None
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DETAILS 1.
Persons Contacted I
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Southern California Edison Company
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- H. Morgan Station Manager
- R. Plappert, Technical Support and Compliance Supervisor
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- P. Shipwash, Technical Support Supervising Engineer i
- D. Brevig, Onsite Nuclear Licensing Supervisor
- M. Speer, Onsite Nuclear Licensing
- R. Baker, Onsite Nuclear Licensing Engineer
- R. Krieger, Operations Manager
- L. Cash, Maintenance Manager
- J. Reilly, Station Technical Manager
- D. Peacor, Station Emergency Preparedness Manager
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- C. Brandt, Quality Assurance Engineer e
- L. Rice, Material Support Manager
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- T. Herring, Quality Assurance Supervisor
- D. Rosenblum, Nuclear Regulatory Affairs Manager
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W. Brush, Station Technical Coonizant Engineer A. Sistos. Mechanical Supervising Engineer M..lohnson, Stetion Emergency Preparedness Ent,lr.eer M. Merlo,. Nuclear Engineering Design Manager
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.1. Bognar. Compliance Engineer P. Croy, Technical Engineering Senior Engineer
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J. Davila, Compliance Engineer i
P. Blakesley, Power Generation Heat Removol Supervising Engineer D. Tuttle, Station Technical
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G. Stawnicry, Nuclear Design Project Engineer D. Ax11ne Quality Assurance
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San Diego Gas and Electric
- R. Erickson, Senior Engineer
- Denotes those attending the exit meeting on January 19, 1990.
The inspectors also contacted other licensee employees during the course of the inspection, including operations shift superintendents, control room supervisors, control room operators, QA and QC engineers, compliance engineers, maintenance craftsmen, and health physics engineers and technicians.
2.
Licensee action on previously identified items
A.
(0 pen) Unresolved Item 361/85-22-03 and (Closed) Open Item 206/
88-11-01, Inservice Testing (IST) of Pumps May Not Be Bounded by Design Bases.
In 1985, an NRC inspector noted that the licensee was unable to determine whether IST of safety related pumps was bounded by the safety analysis.
In particular, pumps may satisfactorily pass ASME Section XI IST and still be outside the safety analysis, i
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Schedule for Completion.
In 1985, an NRC inspector identified this issue for Units 2 and 3 pumps.
In 1986, an NRC inspector was concerned that Unit 1 IST of pumps also may not be bounded by the safety analysis. NRC inspection Report 87-05 stated that the licensee's methodology to assess the appropriateness of the IST pump acceptance criteria was not clear.
Inspection Report 50-361/89-21 dated August 15, 1989, documented this NRC concern and noted that this had been an issue since 1985.
In response, the licensee agreed to perform a final analysis to determine if the IST operability limits are bounded by the latest safety analysis for each unit. Also, the licensee made a firm commitment to issue a final licensee position document by November 15, 1989, identifying the analysis methodology and results.
As of January 19, 1990, the licensee had not issued a final analysis.
In a note-to-file dated January 18, 1990, the licensee i
stated that the evaluation would be completed in another 12 to 15 months for the pumps closett to the design riargin. The licensee did not notify the NRC that this comitment would not be met and had not initiated action to reassess needed effort until the concern was addressed by the NRC inspector during this inspection.
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This lack of control over the s'chedule to resolve this concern
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indicates a lack of proper management attention.
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The fact that the position document was net issued by the licensee's con'mitment date of November 10, 1989 is cor.sidered a deviation according to 10 CFR 2 Appendix C (.906/90-01-01).
Technicai Discussion. The safety analysis established performance critcr E o ensure safety related pumps perform their safety function. This performance criteric also assumes degradation of performance, for example, 5 percent. In accordance with the ASME Code, the licensee's IST program considers a pump operable with up
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to 10 percent degradation from the certified pump perfonnance curve L
obtained during original construction.
Depending on the conservatism
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of the pump design and procurement, the pump may be operable according to IST requirements but outside the safety analysis.
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In a note-to-file dated January 18, 1990, the licensee concluded
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that there is a reasonable degree of confidence that proper implementation of the IST program would detect pump degradation at a point where safety analysis flow requirements would be compromised.
This note-to-file states that the original design and selection of
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pumps for Units 1, 2 and 3 included considerable margin. Also, in discussion with the NRC, the licensee stated all pumps were operating close to the ASME pump curve, and no pumps were in an alert condition as defined by ASME Section XI. However, verification that the IST criteria are bounded by the safety analysis is appropriate since several changes to safety analysis and modifications of plant design have occurred since the original plant design.
At this time, the licensee is unable to determine if the IST program acceptance criteria for safety related pumps is bounded by the safety analysis. Of particular concern to the NRC is the performance requirements for Units 2 and 3 high pressure safety injection (HPSI) pumps in the event of a small break LOCA. This
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specific accident analysis provides the least margin in the plant design since HPSI pump pressure is significantly below the reactor coolant system nonnal operating pressure. The HPSI pump IST performance criteria as well as the perfonnance criteria for other j
safety related pumps will be compared with safety analysis
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requirements during future NRC inspections.
The licensee stated that Techtrical Specification limits for pumps are used when these limits are more restrictive than the ASME code
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limits. Use of Technical Spe'cifications limits in IST of pumps will be verified during future NRC inspections.
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For each pump important to safety, the licensee should determine the l
specific pressures and flow rates required to satisfy the plant safety
analyses for the required accident scenarios. Those pressures and flow rates should be compared to the acceptance criteria used in ASME Section XI testing.
In this comparison, the licensee should
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ensure that inservice test criteria do not allow pump performance
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cutside the safety analysis.
Because the licensee has not determined conclusively that IST limits
for safety related pumps are within the requirements of the safety analysis, follow-up of this issue iney result in identificethm of a violation in accordance with 70 CFR 2. Appendix C.
There 4re, this issue has beeri changed from an open item to an unresolved item.
Items 361/362/35-22-03 and 206/86-11-01 deal with the same issue for I
all three units. Therefore, this issue w'11 be tracked as a single item for all three units under the original item 301/Bb?2-03.
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B.
_(Closed)(!n_resolvedItem 50-361/88-22-01, Requirement to Provioe Cooling to Reactor Coolant Pump Seals.
For some conditions described in the safe shutdown analysis, the licensee does not plan i
to provide cooling to the RCP seals within 30 minutes. In some cases the RCP seals may be without cooling for as long as 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The NRC is concerned that the lack of cooling may cause seal failure, resulting in a unisolable loss of coolant and possible depressurization. This would be in violation of 10 CFR 50,
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Appendix R.
The licensee analysis maintains that the seal failure will not occur for 2 or 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, depending on the type of seal. This conclusion is based on test data for similar seals. After review of licensee submittals dated December 1,1988, and preliminary review of a I
December 27, 1989 submittal, the NRC maintains its position that, without cooling, seal integrity can not be expected for more than about an hour, even with the pumps shut down.
- Therefore, the NRC considers that the licensee is required to provide cooling to the seals within approximately 30 minutes after initiation of a fire. This item will be followed by NRR with Generic Issue 23.
Therefore, the open item is closed to preclude duplication.
Final resolution of this item is expected concurrent with resolution of Generic Issue 23.
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C.
(Closed) Follow-up Item 50-206/89-16-03 Licensee Program to Ensure Correct Assessment of Equipment Operability. An NRC inspection team noted that the licensee had failed to accurately assess equipment
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operability in several cases, and that enforcement had taken place l
concerning these 1ssues. The team planned to review licensee
efforts to improve assessment of equipment operability.
The inspector reviewed some of the efforts to improve operability
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assessment. The recently changed procedure 50123-0-9, " Operator
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Rounds and Inspections" was reviewed in detail.
It lists specific criteria to determine the operability of equipment inspected during operator rounds. Foms are included listing specific equipment with detailed limits for satisfactory operation. This detailed infomation appears to provide useful information in operability
assessment.
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The licensee solicited operations personnel input to determine the scope of the issue of operability assessment. Operators responded to many general and specific quektions ccncerning the operatar's perceptions and observations of plant equipment and its operability.
The operators responses to these questivnaires identified many
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instances where cperators were confused er uncertain regarding operability of safety related equipment.
For example, operators raised questions concerning specific
sightglasses without markinW gages which are difficult to read,
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lack of local level indication on rome equipment, gage indication
which changes.11Cnificantly between operating and stationary equipment conditions, and several other examplet of confusing or vague indication. The inspector reviewed the documentation of short tem and long tem corrective action for each of these items.
Completion of these corrective actions are being tracked by the
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licensee comitment tracking system.
Based on the licensee effort to date, the tracking of completion of these actions in the comitment-tracking system, and the fact that
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these areas are inspected as part of the routine resident inspector program, this item is closed.
D.
(Closed) Unresolved Item 50-206/89-16-02 Weak Implementation of the
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Work Authorization Process. An NRC inspection team noted improper implementation of work authorization and equipment clearance procedures. Although these procedures ure primarily to ensure industrial safety, nuclear safety can also be affected.
After the NRC inspection discussed above, the licensee implemented procedures 50123-I-1.2 " Work Authorization Process" and 50123-I-1.2.1 " Master Work Authorization." The inspector reviewed these procedures. They appear to provide more detailed guidelines
and personnel accountability for setting equipment clearances and establishing control of work than the previous work control procedures.
In addition to changing procedures, the licensee has formalized the position of " Work Authorization Coordinator", which
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requires completion of a training program and certification of those i
individualsauthorizedtoholdworkauthorizationrequests(WARS).
The licensee also stated that the maintenance manager has trained
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maintenance supervisors on the new procedures and the events
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associated with this violation, j
Also, the operations WAR form was revised to improve usability. The i
inspector reviewed this fonn.
It has explicit, detailed instructions.
It appears to address many of the concerns noted
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A computer database of standard tagouts is being developed, and
L training of operators and equipment control evaluators in this area is in progress. Continuinj training has been added to the Licensed
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Operator Requalification Program.
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The licensee is implementing these long term changes with the goal of improving day to day control of maintenance work. The effectiveness of these changes will be evaluated during the routine
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inspection effort of the resident inspectors. Tim.refore, this item
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is closed.
E.
(Closed) Open Item 50-361/88-1$01, Verification of Surveillance, Calibration anc Testing of Post Accident Monitoring Instrumentation.
During an inspection of instrumentation required by Regulatory Guioe
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1.97, the surveillence, calibration and testing for pressurizer heater current, core exit thermocouples e.nd status of standby power were not verified.
1he inspector reviewed the applicable Technical Specifications, procedures and surveillance, calibration, and testing records for
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this instrumentation.
(1) Pressurizer Heater current. The inspector reviewed procedure
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507.3-11-11.165, Class 1-E Pressurizer Heaters Capacity / Operability Verification which tests the operability and capacity of the pressurizer heaters. This 18 month surveillance required by Technical Specifications verifies voltage and current of the heaters. The most recent record of surveillance for Unit 2 was implemented by maintenance order (MO)No.89103491000 on December 12, 1989, and for Unit 3, M0 No. 89111144000 on December 7, 1989. The inspector verified l
that the data recorded during these surveillances appeared to meet the acceptance criteria of the procedure and the
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h associated Technical Specifications.
(2) Status of Standby Power. The inspector reviewed the procedures 502-11-11.1, " Surveillance Requirement Unit 2 Loss of Voltage and Sequencing Relay and Circuit Test" and S03-11-11.1, the similar procedure for Unit 3.
The inspector reviewed the most recent Units 2 and 3 surveillances performed according to these procedures; M0 Nos. 81009007001, 81009007002, 71110010000, and 71110010001 for trains A and B of Units 2 and 3.
The inspector noted that the surveillances had last been performed in May and
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July of 1988. Although these are 18 month surveillances, at the time of the inspection, more than 18 months had past. The licensee stated they were using the 25% extension allowed by Technical Specification 4.0.2.
Therefore, these surveillances are not overdue. The inspector verified that the calibration
and test data obtained appeared to be within the acceptance
criteria of procedural and Technical Specification j
requirements.
.j For M0 No. 81009007001, 'which implemented procedure 503-11-11.1, two relays and two breakers were specified by r
incorrect numbers on the procedure data sheets, pages 46 and 63. Although technicians noted the procedure errors on the
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work order data sheets on May 16, 1988, there were no comments discussing these apparent procedure errors on the notation section of the maintenance order, and the procedure was not
corrected as January 19, 1990. After discussion with the
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inspector, the licensee agreed to review the procedure and to chaege the procedure to correctly specify the breakers and n hys.
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(3) Core Exit ThermocoLples. The inspector reviewed r,rocedures i
1023-V-12.10.10 Qualified Safety Parmneter Display System (QSPDS) Core Exit Thermocouples Verification and Heated Junction 'Inermocouples Yerifications. Channels A and B;
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S023-V-3.2.5, Refueling Interval Temperature Sensor Calibration; and 5023-V-12.10.2, Surveillance Requirement QSPDS Channel A Calibration. The most recent surveillances, tests
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and calibration M0s were also reviewed. These are documented
by M0 Nos. 88012102000, 89121639000, 89121842000, 8801209800, and 890222280001. The data recorded during these tests and surveillances appeared to meet the acceptance criteria of applicable procedures and Technical Specifications.
Based on the inspector's verification discussed above, this item is closed.
F.
(0 pen) Unresolved Item 50-361/88-10-02 Failure to Consider a Single Failure in the Component Cooling Water (CCW) System During a Safe i
Shutdown Earthquake. An NRC inspection team determined that the single failure during a Safe Shutdown Earthquake (SSE)y experience a licensee had failed to consider that the CCW system ma
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k The licensee maintained that, in spite of this error, the CCW system P
would have fulfilled its safety function during an SSE. The team l
questioned whether the licensee's procedures and training were adequate in the past to address this single failure.
The inspector reviewed the CCW system to determine the system configuration as it was several years ago, and to determine if it would have fulfilled its safety function during an SSE. To date the licensee has not addressed this item in sufficient detail to determine the issue.
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With regard to this issue, the licensee should address at least the following interrelated areas; (1) the estimated length of time after an SSE to provide makeup water to the CCW system, currently assumed to be four hours.
(2) the expected failures caused by the SSE, and (3)
the CCW system operating characteristics after these failures occur.
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In addition, the inspector considers that the licensee should address the specific concerns discussed below with regard to these three areas.
CCW Pump Net Positive Suction Head (NPSH) The licensee calculation RZ7.12, "CCW Pump NP5H" which evaluated the loss of CCW surge tank nitrogen (N2) overpresture during an SSE, concluded that the CCW system wocid remain functional even after an isolation of N2 supply pressure. The inspector reviewed the calculation.
Initial assumptions of minimam N2 volume, nn air in-ledage after the surge tank pressere dropped below atmospheric pressure, a pipe break allowing loss of inventory, and continuous system leakage of 6 GPM for four hours after the break were used. This four hours is based on the estimated time to provide makeup water to the CCW 3ystem, a concern addressed above.
Calculation M27.12 showed that voiding would be expected in the return lines from the containment emergency air coolers. However, the calculations also show that voiding would not occur in the heat exchange portion of those coolers because an outlet throttle valve would provide flow restriction and, therefore, backpressure to prevent voiding in the coolers.
The calculation concluded that, after 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, the CCW pump net positive suction head (NPSH) would be 33.6 feet, which is above the minimum NPSH of 27.1 feet. The inspector considers the concern for ensuring sufficient NPSH to be resolved with the exception of the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> estimate to provide makeup water to the CCW system. The licensee should slow that, based on the plant configuration and personnel response expected before 1988, the makeup water would have been provided before the NPSH was reduced below 27.1 feet.
CCW Surge Tank N2 Pressure.
In the event of an SSE, calculation M27.12 h
assumes an initial N2 pressure of 27.4 psig. After the SSE, the surge tank level drops, resulting in a N2 pressure of 11.6 psia.
Using the NPSH values noted above, assuming ideal gas behavior, and using the methods of calculation M27.12; the minimum N2 pressure required at the beginning of the SSE to provide minimum NPSH after 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> appears to be about 19.2 psig. Therefore, if the CCW surge tank pressure is below about 19.2 psig at the initiation of an SSE, it appears that the required NPSH for the CCW pumps may not be available for the entire 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> before makeup water is provided.
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This would be a concern both before 1988 and at the time of this inspection. The inspector notes that the licensee does not appear to require monitoring of the surge tank N2 pressure.
The licensee considers that, currently, there is no significant safety concern because the following actions ensure that the N2 pressure remains above the minimum required.
(1) The CCW surge tank pressure is controlled by N2 regulators to a minimum of 33 psig, which the licensee is raising administrative 1y to 38 psig. This provides significant margin above the minimum required 19.2 psig.
(2) The CCW surge tank is checked for gas leaks every outage.
(3) The N2 regulators are calibrated every 5 years, which the licensee is increasing to a frequency of every outage.
(4) The cognizant engineer has noted occasional drift in regulator pressure, but it has not been observed to be greater than about a pound over several months.
(5) A large air leak in the surge tank gas volume would not impair CCW system response during an SSE because atmospheric pressure would provide adequate pressure over the surge tank liquid volume to maintain minimum NPSH for the CCW pumps.
(6)
If the inlet N2 regulator failed shut and allowed a very small leak of N2 to atmosphere, the N2 pressure would gradually drop to atmospheric pressure. During the SSE, the liquid level could drop at a rate that reduces N2 pressure faster than air in-leakage could make up.
In case (6), NPSH requirements would not be met. However, the l
licensee considers that, in the event of significant drift, or failure of the inlet regulator accompanied by a pinhole leak, the t
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quarterly IST surveillance of the CCW pumps would show a significant change due to the change in NPSH. This would alert the licensee to a large change in surge tank pressure.
l The licensee stated that they will evaluate the need to monitor CCW surge tank N2 pressure, and will determine the required monitoring frequency. This evaluation will be reviewed as followup of this item.
The inspector noted that the cognizant system engineer had not been provided calculation M27.12, dated December 14, 1988. Also, this calculation did not appear to be retrievable from the licensee document storage system (CDH).
In addition, although calculation
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overpressure, the concern to maintain a minimum N2 pressure to ensure l
CCW system operability did not appear to have been addressed and
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comunicated to the site technical or operations departments. Since i
the design basis reconstruction efforts may identify other operability i
concerns, the investigation and comunication of this type of infonnation is particularly important. The licensee should i
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(1) determine why the effect of minimum N2 pressure on CCW system
o)erability was not identified and promptly communicated to tie site;
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(2) ensure other operability concerns identified by design basis
calculations are reliably comunicated to the site; and (3) ensure the instance of lack of availability of calculation M27.12 to site engineering and to COM is investigated and
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corrected, both for this specific calculation and for the
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l generic concern applicable to other calculations.
This item was also tracked by 361/88-10-20, which is now closed to i
preclude duplicate tracking.
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CCW Surse Tank isolhtion Valves. The original CCW system had motor
operatec isolation vsives on the outlets of the surge tanks. These l
valves were locked open as a result of the finoing of the NRC team i
documented in report 88-10. The breakers associated with these
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motor operators were not qu6 ified for an SSE. Therefore, the t
breakers may have ch6ttered during an SSE causing the valves to
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close inadvertently. The licensee stated that there may be test data available which shows the breakers would have performed satisfactorily during an SSE, and stated that if this data was i
found, they would )rovide it to the NRC. Otherwise, the analysis must assume that tie breakers would cause the isolation valves to shut during an SSE. This would result in the CCW system not being able to fulfill its safety function. The licensee should address the qualification of these breakers regarding an SSE.
Capability to Supply the CCW System with Makeup Water from Fire
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Hoses. The original CCW configuration did not have quick disconnect i
fittings for fire hoses to provide makeup inventory to the CCW surge tank. However, it had a 4 inch flange connection for flushing purposes with which the licensee may have been able to provide makeup. The inspector notes that connection to this flange could have taken significant time since it is not compatible with fire hose connections.
Preparations for connection to this flange would i
have to start very soon after the SSE in order to provide CCW makeup
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within the required 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The licensee should show if this l
connection could be made up before the CCW system NPSH dropped below L
27.1 ft.
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Containment Heat Exchanger Throttle Valve. The licensee submittal of January 4,1990 stated that the expected voiding in CCW system return lines under low surge tank pressures will be minimized
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because surge tank levels will be optimized and containment L
emergency air cooler throttle valves will be relocated further
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downstream during Cycle 6 refueling outage to provide higher pressure in areas in which voiding may occur. The licensee is
tracking completion of these modifications in the commitment i
tracking system. Since water hamer would be expected prior to
1988, future NRC inspection will review licensee evaluation of water
hamer effects on CCW operation during an SSE with respect to its operability. Also, inspection will verify completion of these modifications to minimize CCW system water hamer.
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Critical Crack versus Break in CCW Piping. The NRC is reviewing the licensee assumption of a critical ccW system crack, and the calculation of leakage based on a critical crack versus a pipe break. This review is expected to be completed in March 1990. At
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that time, the licensee's assumptions concerning CCW system leakage will be compared to the hRC Safety Evaluation Report with respect to this issue and with respect to the current operability of the CCW
sy3 tem.
TrainingandProceduresforFire_irigade. Durirg an SSE, it is
assumed that a fire will start, rewiring fire brigade response.
After fighting this fire, the fire brigade would be imediately required to refill the truck and bring it to a pusittor, to provide CCW makeup. Currently, the fire brigade is trained to provide makeup and Appendix 9 of procedure 5023-2-17. " Component Cooling
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System Operation", is provided to ensure makeup is available to the CCW. However, before 1988, the fire brigade was not provided procedures or training to provide CCW makeup.
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SSE, the lack of these procedures and training could have significantly delayed providing makeup water to the CCW system. The
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licensee should address this lack of procedures and training in the
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analysis of the CCW system's ability to sustain an SSE.
Training and Procedures for Operations Personnel.
In the same manner as applies to the fire brigade discussed above, the
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Operations' personnel are trained to ensure sufficient makeup water is provided to the CCW. However, operator procedures and training
for CCW makeup were not provided before 1988. The licensee should show how operator response would affect the CCW system's ability to
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fulfill its safety function during an SSE.
In addition to the above specific concerns, the licensee should be i
able to show in an analysis whether or not the CCW system would have been able to sustain a safe shutdown earthquake assuming single failures, failure and leakage of the non-vital CCW loop, and loss of offsite power for the CCW system configuration as installed before
1988.
G.
(Closed) Deviation 50-361/88-10-16 CCW Mode of Operation is not Consistent with FSAR and Standard Review Plan Description. An NRC inspection team determined that the CCW system alignment.and i
radiation monitoring were not consistent with the descriptions in the FSAR and Standard Review Plan (SRP).
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(1) CCW System Alignment. The FSAR description states that one CCW loop is in wet standby while the other supplies cooling to the noncritical loop and the letdown heat exchanger. However, the
team found that the CCW operating procedure required both loops to be operating, one cooling the letdown heat exchanger, the other cooling the none.ritical loop. The licensee changed
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procedure 5023-2-17. * Component Cooling Water System i
Operation." to require the letdown heat exchanger to be aligned
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to the same CCW loop as the noncritical loop. This alignment
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is required for radiation monitoring purposes discussed below.
l The FSAR statement that one CCW loop was left in wet standby
was changed to allow the standby loop to be in operation. The licensee considers that operation of both CCW loops provides a
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slight increase in reliability since the operability of a running system is readily gaged by system operating parameters.
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Also, the licensee states that the redundant loop interfaces
with conponents are at about ambier.t pressure, precluding an
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unmonitored ralease path. The insper, tor reviewed the safety
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evaluation associated wii.h this change to operate both CCW
loops.
It appects adeqJate.
(2) CCW System Radiation Monitoring. The CCW system radiation monitor samples flow from the noncritical 1o03. The team pointed out that cooling the letdown heat excianger with the loop which is not aligned to the noncritical loop resulted in
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no radiation monitoring of a potential leakage path from the letdown heat exchanger.
In addition, this mode contradicted I
the FSAR which stated that the CCW system was continuously L
monitored for radioactivity during nonaccident conditions.
The licensee changed the CCW system alignment as discussed in
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(1)abovetocorrectthisdeficiency.
(3) Lack of Flow Indication on the Radiation Monitoring Sample Line. The team noted there was no positive indication of flow on the sample line which monitored CCW system radiation levels.
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In addition, it was noted that this
> articular instrument model had previously experienced flow bloccage problems on the containment sump system, rendering the sump system monitor l
inoperable for an extended period of time.
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The licensee stated that a repetitive maintenance order (RMO)
would be established which verifies flow through the radiation monitoring line. This verification would take place whenever
the monitor is calibrated.
The licensee is tracking establishment of this RM0 in the licensee commitment tracking system. This action appears acceptable to preclude long term flow blockage since the CCW system is a comparatively clean system and flow blockage has not been experienced.
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(4) Direction of Flow Through CCW Radiation Monitorins Sample Line.
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The F5AR stated that the radiation monitor sample ( the CCW noncritical loop return header.
In fact, the flow in the i
moni.ored line passes from the noncritical loop supply header.
and flows sast the monitor to the noncritical loop re" urn header. Tie flow is driven by the CCW pump differential pressure.
The licensee stated that the existing radiation monitoring flow path is capable of detecting a leak of contaminated fluid into.
the CCW system, and that no changes to the plant are necessary.
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Therefore, the licensee changed the FSAR to indicate that the
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radiation monitor samples the noncritical loop supply header.
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In this way the actual configuration was represented. This l
appears to be adequate.
i (5) CCW SS tem, Monitoring During Accident Conditions. The team noted that, upon an E5FAS signal, the CCW noncritical loop
would be isolated, resulting in the isolation of the CCW system radiattor, monitor. The team questioned if isolation of CCW snten radiction rcattoring capaoility was apprcpriate.
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The inspector discussed this issue with NRC and licensee
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persennel. During an accident, CCW system radiation levels
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would not be directly monitored because operstors would be monitoring raotetion levels of higher priority systems. The
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CCW system radietion leveli wNid be available when the noncritical loop was returned to service, idec11y within an i
hour or two.
In the meantime, any significant system t
contamination would be contained within the system. This is
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considered acceptable because of the low leakage rates imposed on the CCW system of 4 GPM. The inspector verified that, in the event of leakage of contamination from the CCW system Auxiliary Salt Water heat exchangers, the release path
would be monitored at the outfall to indicate the condition of
CCW system contamination and leakage.
Based on the verification discussed above, and licensee
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tracking of the associated commitment to establish an RM0 to
verify flow through the radiation monitoring sample line, this item is closed.
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H.
(Closed) Violation 50-361/88-10-13 CCW System and Components not Designed to Withstand Earthquakes An NRC inspection team noted a
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violation of NRC requirement in that. (1) the design of the motor operator control circuits for the CCW surge tank outlet valve did not include effects of an earthquake; and (2) the design basis of the CCW system did not reflect the combination of the effects of these outlet valves spuriously closing in conjunction with an SSE.
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In a letter dated September 2, 1988, the licensee has disconnected the power supplies from these valves by removing thennal overloads i
from the breakers. The licensee states that this will prevent automatic, manual, and inadvertent valve operation. Also, the l
licensee states that additional evaluation has taken place in the I
CCW system operability assessment to ensure the operasility of the CCW system is broadly evaluated. NRR is not reviewing this j
assessment.
i Based on the licensee's corrective action, and tracking of this issue in open item 361/88-10-02, this item is closed.
I.
(Closed) Open Item 50-361/88-10-20 CCW Surge Tank Nitrogen Pressure This item noted that the CCW surge tank is not periodically checked
for leakage of the nitrogn (N2) nyerpressure blanket. Also, the
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significance of maintaining a required minimum level of N2 pressure was not determined.
j The inspector reviewed the licensee calculation M27.2, which j
evaluates the consequence of loosing the N2 overpressbre in the CCW
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surge tanks. The calculation assumos the inttial N2 pressure of 42.1 psia, which, according to system description SD-5023-400, "CCW System," is below the low setpoint for the surge tank overpressure.
j The calculation concludes that during an SSE, the minimum available NPSH for the CCW pumps will be 33.0 feet, which is above the NPSH
requirement of 27.1 feet.
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According to the licensee calculation M27.12, air in-leakage to the tanks during accident conditions would be a conservative assumption, since the minimum required NPSH is 27.1 feet, which is below I
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atmosphere.
In that case, incoming air would increase NPSH for the CCW pumps. Therefore, over the short tenn accident condition, loss of the non-seismic N2 supply in a manner which allows air in-leakage would not directly cause the CCW system to be inoperable.
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l The inspector was concerned that the surge tank pressure did not appear to be indicated or alarmed in the control room. Also, after
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a review of procedure 50123-0-9, " Operator Rounds and Inspections "
the inspector noted that CCW surge tank N2 pressure was not required
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to be monitored.
Since a minimum N2 overpressure of 27.4 psig is assumed for the
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system not being able to fulfill its safety function, the inspector g
considers that this parameter important to system operability
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j may need to be monitored more frequently.
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In addition, the inspector noted that the system description listed l~
the CCW surge tank outlet isolation valves as being controlled by l
the low level switch. This control was removed when the valves were taken out of service for seismic concerns discussed earlier. The l
licensee agreed to correct the system description.
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l Another open item tracks the concern for maintaining and monitoring a minimum N2 pressure in the CCW surge tanks. Therefore, this
issue will be followed in 361/88-10-2, which is discussed in Section 2.F of this report.
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Based on the discussion above, and the fact that the licensee agreed to track implementation of the procedure changes in the licensee comitment tracking system, this item is closed.
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LClosed) Violation 50-361/88-10-01 Late Reportino of CCW System
M nope ra bil i t.y.
An NRC inspection team noted that the licensee had failed to report CCW system inoperability within the allotted time for the following issues:
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(1) the CCW system High Energy Line Break (HELB) event was not
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properly analyzed; J
(2) the combination of CCW 1eakage and erroneously high allowable noncritical loop valve closure time; and (3) the late reporting of t.ER 88-003, which reported CCW system leakage in excess of design le6Lage and a leck of seismically
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qualified CCW r,ystem mektup water.
The licensee identified that the issues regarding CCW system operability were addressed in LER 88-008 01, a revision to
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LER 88-08. These will be discussed in K. Miow.
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The licensee stated that these inoperability issues were not
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reported because offsite engineering personnel were not thoroughly
trained in the NCR process, and that training had been given to the
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offsite engineering in response to this violation. The inspector
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reviewed the training records.
l Also, when excessive CCW system leakage was identified, a Site /Startu) Problem Report (SPR) was issued which was not reviewed j
for reporta)ility as an NCR would be.
The insp' etor reviewed the Procedure. 50123-V-5.13. " Site Problem Reports, which requires that the SPR be evaluated by a cognizant l
supervisor to determine if an NCR should be issued for the problem identified in the SPR. Also, the SPR fonn lists an option to issue
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an NCR for the problem. This appears to address the situation where an SPR is issued but there is no review to issue an NCR thus precluding a review for reportability.
Based on the licensee's corrective action, this item is closed, i
K.
(Closed) LER 50-361/88-08-01 CCW System Outside Design Basis. The licensee issued a revision to an LER, 88-08-01, which discussed operability and accident analysis of the CCW system. The licensee's i
I design basis reconstruction program appears to cover most of the areas of concern. Additional actions involve removing power to the
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CCW surge tank outlet isolation valves, revisions of test procedures, and evaluation of alternatives for providing seismic Category I makeup to the CCW system.
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The action not completed to date is as follows:
j To reduce effects of short term CCW system voiding, the licensee ~
J plans to
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(1) relocate emergency air cooler throttle valves oownstream,
(2) maintain a seismically qualified source of N2 pressure on the CCW surge tanks, and
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(3) raise the CCW surge tank low low level setpoint two to three feet.
The licensee plans to implement these changes during Cycle 6 I
refueling outages, and is tracking completion of these items'in the
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commitment tracking system.
Also, a review by NRR of the licensee's CCW system operability assessment is expected to be completed in March,1990. The other licensee corrective actions reorganization with responsibility for
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the design functions and design basis focused in one department.
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establishment of a design basit documentation program, and augmentation of in-house engineering functions are completed or well
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underway.
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Based on the corrective action to date and continuing NRC fo11cw of
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the licensee's CCW system design issues ard the design basis efforts
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in other open items, this item is closed.
L.
(0 pen? Unresolved item 50-361/89-16-11 Insufficient Emergency Light' ng for Station Blackout. The licensee has submitted to the NRC its evaluation of Units 2 and 3 actions and systems required to sustain a station blackout. An NRC inspection team considered that t
the emergency lighting provided was insufficient to support safe shutdown as described in the licensee evaluation.
NRR plans to complete the review of the licensee evaluation after October, 1990. Based on the NRR assessment, the adequacy of the
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licensee's emergency lighting will be evaluated by Region V.
Therefore, this item remains open.
I M.
(Closed) Violation 50-206/89-16-01, Failure to Record Calibration of Containment Spray Valve Actuator A violation identified that a containment spray header isolation valve actuator was not calibrated and tested according to procedures and maintenance order requirements.
The licensee response states that the actuator was correctly calibrated, but the calibration was not correctly documented due to personnel error by maintenance supervision.
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Technicians from another department were not adequately trained to document the calibration, and were supervised only during the
calibration portion of the work order, j
The licensee states that maintenance supervisory personnel have been
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appropriately instructed in training craft personnel, supervising new activities, and ensuring completion of calibration
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documentation. Also, the Unit 1 Boiler and Condenser Mechanics
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required to perform these actuator calibrations will obtain formal J
1aboratory and classroom training on documentation of calibrations i
by March 31, 1990.
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The licensee states that full compliance will be achieved when the
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next surveillance of the affected actuator is performed. This will be after the Unit 1 outage scheduled to end in December, 1990. This
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item is closed, since its follow-up is part of the routin9 efforts of i
the NRC resident inspector staff.
N.
(Closed) 0)en Item 50-206/89-16-09 Receipt Inspection for i
Emergency ighting Batteries A licensee root cause investigation i
resulted fn a recommendation to perfom a receipt inspection of
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emergency lighting batteries which tested 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge capability. This item follows-up to ensure the receipt inspection is <mplemented.
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P The inspector reviewed the receint inspection procedure applicable to 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> emergency lighting batteries. The procedure stated it met
the requirements of Class V procurement, which, according to f
Procedure SO 123-XI-1.4, meets the 10 CFR'50, Appendix S criteria l
for commercial grade procurement. The inspector noted that the receipt inspection procedure listed an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge as a
critical characteristic, but did not require this characteristic to
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be tested unless there was no model number listed on the battery.
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l The licensee stated that the batteries were each given an eight hour
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discharge test upon installation in the emergency lighting system, i
and additional 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge tests during surveillance tests.
To verify these statements, the inspector reviewed SCE procedure L
Nos. S023-XIII-22, S01-XIII-22, $023-XIII-52 and S01-XIII-52, the L
emergency lighting surveillance procedures. All procedures require a
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8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge test for installed fixtures. However, if a lighting fixture fails this surveillance and must be replaced, the
retest requirement for the replacement battery does not explicitly
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require an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge test before releasing the battery as L
The inspector reviewed maintenance orders which required individual
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battery replacement. The retest requirement for the new battery
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referenced procedure 501/23-XIII-22; however, several other tests
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i are listed in this procedure which are not eight hour discharge
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' After discussing the lack of an explicit 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge test a
requirement for each battery upon receipt or installation, the
licensee agreed to place emergency lighting batteries in the Pre / post Installation Test (PIT) program. This program, described in SCE procedure No. QAP N10.02, Rev. 15, requires that, upon receipt, a tag be attached to the item which lists'the acceptance tests to be performed before the item can be released for service.
The inpector verified that the licensee has implemented the PIT-program for the batteries which require 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge tests upon-installation-in accordance with site procedures. Based on the licensee's PIT program requirement for emergency batteries, this item is closed.
O.
(Closed) Deviation 50-362/89-16-07 LPSI PumrSeal Leakoff not Piped Directly to Drain. The FSAR stated t1e LPSI pump seal leakoff was piped to the E5F pump room floor drain. However, an NRC
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inspection team noted that the leakoff was piped to the floor directly under the pumps, and not to the drain. The team noted that discharge to the floor could increase the radiological consequences of LPSI pump operation following a LOCA.
The inspector verified that both the Unit 3 LPSI pump seal leakoff lines had been corrected to direct the seal leakoff directly to the i
floor drain. Based on th% e observations, this item is closed.
P.
(Closed) Unresolved I:
-362/87-02-01, Changes to the Fire
'n iitensee changed a number of items in the Protection Program.
i fire protection plan. Specific changes include fire doors for the Unit 2/3 laundry and combustible storage in Unit 3.
Evaluations pursuant to 10 CFR 50.59 were performed prior to installation of the changes. However, license conditions required that a license
amendment be approved before the change could be implemented.
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After these changes were installed in the plant, the license was amended to allow plant modifications after completion of a satisfactory' safety evaluation pursuant to 10 CFR 50.59.
Therefore, the modifications performed by the licensee, although not in compliance with the license at the time, would be considered
acceptable under the current license conditions. This item is closed.
Q.
(Closed 1 Unresolved Item 50-361/89-16-05, Temporary Procedure Change Enconsistent with Proposed Technical Specification Amendment.
I A team inspection noted that a temporary change to a procedure specified that emergency lighting units had a 28 day limitation for i
equipment out of service. However, at that time, an amendment to Technical Specifications was being drafted which stated that, if a lighting unit could not be made operable, provisions would be made for alternate lighting within seven days. The teams concern was that procedure changes and draft Technical Specification amendments were not coordinated properly.
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During discussions with the inspector, the licensee stated that.-
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-it was determined that the Technical Specification amendment should not be submitted. The licensee stated that this decision was-in l
accordance with the guidelines of the Technical Specification
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Improvement Program.
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The licensee stated that typically, group leader and discipline
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supervisor comments were obtained to ensure consistency between
plant documents. The license'e stated that the team review had taken
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place before the responsible group leaders and discipline i
supervisors for the systems had returned comments on the proposed draft.
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To determine if appropriate coordination was occurring to ensure
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consistency between licensing documents and plant procedures, the inspector reviewed procedure E&C 40-9-13 " Department QA Procedure",
which controls SONGS licensing document changes. This procedure o
states that the responsible licensing engineer will forward the draft document to appropriate group leaders and discipline supervisors for review and comment. When the reviewers comments are received, the connents are resolved and concurrence is obtained from the reviewers. The licensee states that these requirements ensure consistency between documents.
In the case of this specific issue-identified by the NRC team, the licensee stated that the review process was not complete.
The inspector reviewed the concurrence files for the last two l
L proposed changes to technical specifications and verified that comments and concurrences had been obtained from appropriate
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technical and administrative groups such as operations, station technical, health physics and others; to document comment resolution.
l The inspector verified that the steps required by procedure to L
ensure that amendments to Technical Specifications are consistent p
with plant procedures appear to have been implemented. However, at the time the team raised this issue, the licensee did not appear to
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have completed the review process.
Incomplete review would be expected at this stage of the process. Therefore, this item is closed.
3.
Verification of the Units 2 and 3 Auxiliu/ Feedwater (AFW) Pumps and MotorsAbilitytoWithstandSteamLineRudure(37911)
L The Units 2 and 3 AFW systems are in a concrete enclosure. The licensee has calculated that, in the event of a break in the steam line to the steam powered AFW pump, the temperature would rapidly rise to over 300*F.
The inspector reviewed the licensee's assessment of the equipment qualification for the pumps and motors in the enclosure.
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A.
Electrically Powered AFW Motors The inspector reviewed calculation M37632, the equipment qualification package for Units 2 and 3 AFW pump motors. The calculation and assumptions appeared conservative.
The inspector reviewed =the motor drawings and in pected the motors-to determine if the rapid rise may cause operatit^al problems due to uneven thermal expansion. Based on inspector review and discussion with the licensee, the concern was resolved since there are no apparent close operating tolerances which may be subject to uneven
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thennal expansion.
B.
AFW Pumps The_ inspector reviewed calculation N-0240-004, a calculation to determine the effects of a steam line break on AFW pump bearing heatup. The assumptions.and calculations appeared conservative. The accident analysis assumes the steam line can be isolated after 30 minutes, which limits bearing heatup. The calculation shows-that the bearing may reach up to 275'F, which is below the manufacturers-limit of 300'F. A significant amount of heat is removed by AFW, which cools the pump shaft.
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The inspector also reviewed the pump drawings and inspected the pumps to determine if the rapid temperature rise may cause i
operational problems due to uneven thermal expansion. During discussion with the licensee, the only thermal expansion effect identified would be loosening of a bearing cover which closes the opening between the shaft and the bearing housing. This is unlikely, and in any event, should not interfere with pump operation over the short term in which AFW is required. Otherwise, no
o)erability concerns were identified which were associated with tiermal expansion, j
The inspector reviewed the possibility of thermal shock in the event i
the pumps are heated in a steam line break accident and then used to l
pump comparatively cold AFW. Based on discussions with the licensee and review of material properties, relatively cold AFW will not'
introduce stresses of significance to cause an operational conccrn.
4.
Commercial Grade Procurement-(38703)
The inspector reviewed a portion of the licensee's commercial grade procurement program as follows.
A.
Procurement Program: The inspector reviewed procurement procedures 50123-XI-1.4 and MSSONGS-P-307 for commercial grade procurement.
The procedures require that the item's critical characteristics be determined.
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B.
Receipt Inspection Program: The inspector reviewed procedure QA N10.02 for receiving inspection.
It requires training of receipt
' inspection personnel and use of applicable detailed receipt inspection procedures.
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C.
' Procurement of Mobil Brand Lubricating 011: The inspector reviewed i
the receipt. inspection procedure AC21-AE for lubricating oil used in
safety related applications. The procedure describes the lubricants i
critical characteristics as " Wax free synthesized hydrocarbon base stock with additives to increase load carrying ability, reduce friction and operating temperatures, and provide high temperature oxidation stability." Six varieties of Mobil brand oil are listed in this procedure, with varying flash points and viscosities. The inspection requires a "special inspection" to verify that the container seal is not broken to preclude contamination. The receipt inspection form states that "The items critical characteristics are sufficiently controlled by industry to assure adequate quality to meet Safety-Related applications." The inspector notes that proper lubrication of safety-related equipment is essential to equipment -
operability, and that the lubricant properties are not verified by the licensee.
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The issue of whether or not a receipt inspection is required to validate lubricant properties will be followed as a routine part of a future inspection of commercial grade procurement.
D.
Procurement of Emergency Lighting Batteries: Emergency lighting is
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required by 10 CFR 50. However, the batteries for emergency lights are non-safety-related.
Eight hour batteries apply to safe shutdown requirements and ninety minute lights in the control room apply to station blackout requirements.
The licensee procurement system tracks two types of eight hour batteries with the material code No. 023-01430, the Halophane model 92829, and the Lightalarms model CEl-5BD. However, failure analysis associated with NCR S01-P-6631 report for one of the batteries states that the battery evaluated was a Lightalarms Model CEl-5AG.
The licensee material code for emergency lighting batteries No.
023-01430, does not list the model CEl-5AG; however, in a letter dated January 19, 1990, the Lightalarms Electronic Corporation stated that the battery model CEl-5BD equals or exceeds
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L specifications of battery model CEl-5AG. Since incorrect battery l
float voltage settings had occurred in the past, the inspector asked if these batteries had identical float voltages, which the licensee confirmed.
The receipt inspection Package Level V No. Y406 for the eight hour batteries now requires an eight hour discharge test as a result of significant failures documented in NCR No. S01-P-6631. This eight hour discharge is listed as a critical characteristic.
The receipt inspection package for 90 minute batteries does not
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require a discharge test, although the 90 minute discharge is listed as a critical characteristic. The inspector's concern is similar to l
that for lubricants discussed above, and will be resolved as in C.
above.
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Procurement of Diesel Fuel Oil: The inspector reviewed procedure 50123-III-6.6, " Diesel Fuel.OTl Specifications and Testing
Requirements."
It appears to meet applicable Technical Specifications requirements. All fuel oil parameters except for
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microbial growth must be verified at the offsite storage facility on L
a quarterly basis, before delivery to the site. The procedure appears-to be detailed, with specific instructions. This procedure appears to adequately fulfill the Technical Specification requirements for diesel fuel oil procurement.
.The inspector assessed the likelihood that a delivery of contaminated
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fuel to the offsite storage could eventually contaminate the onsite diesel fuel oil. The licensee stated that newly delivered fuel was placed in a tank which is not available to be delivered to the site until chemistry analysis verifies it is free of contamination and meets Technical Specification requirements for onsite diesel fuel oil.- After satisfactory chemistry is verified, the oil is purchased and then
released for transportation to the site as necessary. This appears l -
.to adequately preclude contamination of onsite fuel oil by a l
L contaminated delivery to the offsite storage facility, 5.
Follow-up of Open Items (92701).
L Recent NRC inspection _ reports documented untimely and sometimes
inadequate actions to address concerns identified by the NRC.
The licensee started efforts to improve the commitment tracking system in i
November, 1989.
Interim' corrective actions which have been implemented
include increased management oversight of the resolution of NRC open items, dedication of additional manpower,_ emphasis on timely and complete open item resolution by executive management and improved status l
reporting.
i Long term corrective actions which are being implemented include 1-l-
centralization of the tracking system, improvement of the audit trail, l:
higher management visibility, and designation of the tracking system as
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" Quality Affecting", requiring Nuclear Oversight Division review.
l The inspector reviewed the open item and commitment tracking system g
l1 memoranda and status reports which the licensee has issued to date to l
L improve performance. The memoranda and reports appear to incorporate many of the corrective actions such as the requirements for management review
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and accountability. Based on the inspectors observations at the time of this inspection, the licensee's resolution of open items had improved
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resolution for about half the open items reviewed during this inspection.
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The remaining items, although considered closed by the licensee, required i
l significant additional effort by the inspector to satisfactorily L
determine whether or not the NRC concern had been addressed.
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The inspector considers that the licensee's continuing efforts to improve I
this program are warranted. The proposed corrective actions appear to address the problems observed by the -inspector.
Implementation of these corrective actions by the licensee will be addressed in future inspections as part of. routine engineering and resident-inspector efforts.
6.
Exit Meeting
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An exit meeting was held with the licensee staff on January 19, 1990.
The specific concerns addressed in this report were discussed with the licensee during this meeting and were acknowledged by the licensee.
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