IR 05000219/1989010

Insp Rept 50-219/89-10 on 890402-29.No Violations Noted. Major Areas Inspected:Action of Plant Deficiencies Discovered During Startup,Instrument Air Sys Problems, Surveillance Testing & Control Rod Scram Timing Testing

ML20244B005
Person / Time
Site:	Oyster Creek
Issue date:	05/24/1989
From:	Cowgill C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20244A995	List: IR 05000219/1989010 ML20244A991
References
50-219-89-10, NUDOCS 8906120223
Download: ML20244B005 (14)

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U.S. NUCLEAR REGULATORY COMMISSION REGION:I' Report N /89-10 Docket N License N DPR-16 -Priority -- Category C Licensee: Gpu Nuclear Corporation i

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Parsippany, New Jersey 07054 Facility Name: Dyster Creek Nuclear Generating Station-Inspection Conducted: April 2-29, 1989-Participating Inspectorsi E.' Collins D. Lew Approved By: b <dd E- 5 97 C.J.Cosgill,gef,ReactorProjectsSection1A Date Inspection Summary: Inspection April 2-29, 1989 (Report No. 50-219/89-10)

Areas Inspected: Routine inspections by resident inspectors (120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />) were conducted on activities in progress, including: licensee corrective action on plant deficiencies discovered during startup, instrument air system problems,-

surveillance testing, plant startup activities, loss of condenser vacuum event,.

core spray intergranular stress ' corrosion cracking, licensee housekeeping ac-tivities, standby gas treatment system accumulator testing and control' rod scram time testing. One previously opened inspection finding was. reviewe Results: Inspectors concluded that licensee corrective action in. response to the loss of condenser vacuum event should be effective to prevent recurrence (paragraph 7.0). Inspectors observed that plant operators had. difficulty im-piementing a surveillance test (paragraph 5.0). These two events taken to-gether, (paragraphs 5.0 and 7.0), indicate 'that there. is a . lack of. effective-ness in implementing. station policy that all activities be conducted in accord-ance with approved station procedures. Licensee repair efforts on the "D" reactor recirculation pump were well coordinated and implemented (paragraph 2.0). The licensee conducted a controlled, safe plant startup (paragraph 6.0).

This startup was terminated due to a leak on a core spray system weld (para-graph 8.0). Increased management attention was noted in the area of plant cleanliness (paragraph 9.0). Continued' attention in this' area is warranted.' A

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plant drawing error caused maintenance workers to repair the wrong piece of I equipment (paragraph 3.0). The licensee has implemented long. term corrective actions to upgrade the accuracy of plant as-built drawings. Licensee correc- 4 tive actions in response to possible desiccant in the instrument air system were adequate (paragraph 4.0). One previously opened inspection item was closed. No violations or unresolved items were identifie )

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TABLE OF CONTENTS PAGE 1.0 Licensee Action on Plant Deficiencies Discovered During Startup. . . . .. I "D" Reactor Reci rcul ati on Pump Repai rs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 3.0 Vacuum Relief Valve V-26-16.......................................... 3'

4.0 Instrument Air System................................................ 4 5.0 Monthly Surveillance Observation....m ..... ........................ E 6.0 Plant Operations.............................................. ....... 7'

7.0 Manual Scram Due to Lowering Condenser Vacuum..... .... ............. 7 8.0 Core Spray Intergranular Stress Corrosion Cracking. . . . . . . . . . . . . . . . . . . 9 9.0 Plant Cleanliness... ................................................ 9 10.0 Standby Gas Treatment System Accumulator. Testing...................... 10 11.0 Scram Time Testing................................................... 10 12.0 Quality Assurance Annual Revie .................................... 11 13.0 Unresolved Item 88-38-04 (Closed).................................... '11 14.0 Radiation Protection.................................................. 11 15.0 Review of Periodic and Special Reports............................... 11 16.0 Inspection Hours Summary............................................. 12 17.0 Exit Meeting............. ............................................ 12 i

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DETAILS s I

1.0 Licensee Action on Plant Deficiencies Discovered' During Startup -l (71707,93702)

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During the plant startup and heatup conducted on 3/26/89 the licensee dis-covered several equipment problems. The most significant of these equip- ;

ment problemsiwas the high vibration on the "D" reactor recirculation pump 1 which resulted in a plant shutdown. Inspectors followed and reviewed lic-ensee repair activities on equipment problem Flange leaks were identified on both "A" and "B" reactor feed pump discharge check valves. The licensee disassembled these valves and replaced the gaskets to repair these leaks. Because of the problems experienced previously with the "A" feed pump discharge check valv being pinched in the closed position (50-219/89-07), tne licensee used a piece of ice to hold the disk open while the check valve bon-net was bolted to the valve body to ensure that the check valve-hinge-pin and disk are properly positione During filling and venting of the system following reassembly, the licensee identified that the "A" check valve was pinched in its closed position. Subsequent licensee investigation identified some anomalous hinge pin runout readings, but could not identify the root cause for the valve's failure to open. The hinge pin was replace The licensee postulated that the valve disk was pinched in a closed position during reassembly. The probable cause was that the block of ice melted or shifted during the torqufng sequence. The licensee reassembled the valve, and confirmed that the check valve operated properly. The inspector had no further questions regarding this matte The licensee repaired steam leaks on the turbine step valve and also a through wall steam leak on drain line to the flash tank. The lic- !

ensee performed pipe wall thickness measurements to ensure other por-tions of the pipe had not eroded below minimum wall thickness. No concerns were identifie The licen:ee identified that the "A" electromatic relief valve (EMRV)

was leaking past its seat. During the startup (3/26/89) with the reactor at power the licensee cycled this valve several times in an attempt to seat the valve. These attempts were unsuccessful, and the licensee shut down with a leaky EMRV.. This valve was replaced with a !

new valve (see paragraph 6.0).

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During post maintenance testing of the "B" reactor water cleanup re-circulation pump, the licensee identified a leak at one pump casing flange bolt. Proposed licensee repair on this flange bolt was to i

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install a copper gasket and retorque the pump flange bolts (see para-graph 6.0). {

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Previously the licensee had replaced the motor on the "A" condensate pump. During post repair testing the licensee experienced high bear-ing temperatures. As a result, the licensee replaced the pump motor (

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During plant operation the licensee identified anomalous pump dis-charge pressure and pump motor running current conditions on the "A" condensate pump. Licensee analysis concluded that these conditions were a result of the "B" condensate pump discharge check valve not closing. The licensee disassembled this valve and identified foreign material in the valve which was preventing it from fully closin This material was removed, and the valve was reassembled and tested satisfactoril .0 "D" Reactor Recirculation Pump Repairs (71707)

During this inspection period, inspectors followed the activities associ-ated with the repair of a high vibration condition on "D" reactor recir-culation pump. Extensive repairs were required in that.the pump rotating assembly, the pump cover and the pump motor were replaced. The identifi--

cation of the root cause for the high vibration on the pump and the com-pletion of these repairs received significant licensee attention. A pro-ject manager was assigned to cover these activitie The pump disassembly and repairs were implemented on or ahead of schedul Also, a high level of attention was directed to the radiological aspects of this job. A review was conducted to ensure that radiological conditions were anticipated, planned, and that measures were taken to minimize per-sonnel radiation exposure. The inspectors concluded that radiological control measures were effectively implemente The licensee conducted an indepth analysis to identify the root cause for the high vibration. During pump disassembly, it was discovered that the pump bearing had failed. Licensee examination of the pump impeller showed no evidence of imbalance. The licensee examined the pump shaft; there were no indications of radial cracks. Based on this analysis, the licen-see concluded that the probable cause of failure was the pump bearin The licer.see further analyzed the bearing to determine the cause of the bearing failure. Probsble internal causes for bearing failure could be an assembly problem or a deficient material condition within the bearin Possible external causes for bearing failure could be foreign material entering the bearing excessive out of plane loading nr loss of cooling water to the bearing. The licensee elfininated loss of' cooling water as a cause for the failure because there was proper cooling water flow during pump operation. Licensee review of bearing assembly instructions did not identify any problems, the licensee also eliminated this as a probable cause. To evaluate bearing fai'.ure from foreign material introduction or material deficiency the licensee sent available bearing fragments.off site I

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3-for material analysis. The final results from this analysis were not available at the conclusion of the inspection period. The licensee's preliminary conclusion concerning the bearing failure is that it did originate from within the bearing and the cause'for this was either a material deficiency or introduction of foreign material. If the bearing failure was due to introduction of foreign material, the licensee indi-cated that identification of the cause and the source may not be possibl To more effectively monitor reactor recirculation pump performance, the licensee installed vibration instrumentation on the D and E. recirculation

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pumps. The basis for this decision was that the bearings-on "A", "B", and

"C" recirculation pumps were original bearings and the "D" and "E" recir-culation pumps bearings were replaced in 1986 and the licensee found no problems with the pump shaf After pump assembly the pump was operated and tested. Vibration readings on the pump were well within normal expected tolerances, and the' licensee concluded that pump operation was satisfactory. Overall, the licensee effort to overhaul the recirculation pump was well planned and conducte .0 Vacuum Relief Valve V-26-16 (62703)

During surveillance testing on 4/11/89, the reactor building to torus vacuum relief valve V-26-16 did not open. The inspectors followed and reviewed the licensee's troubleshooting and corrective actions associated with this failur This valve is a solenoid activated air operated valve. As a result of the troubleshooting efforts, the licensee concluded that'it was necessary to replace the valve solenoi A Work Request was generated to replace the operating solenoid on. valve V-26-16. The Operations Department initiated the necessary tagouts to electrically deenergize the solenoid. In this configuration, the parallel train valve (V-16-18) solenoid is powered from the same power scurce as V-26-16. The Operations Department tagout deenergized both solenoid Electricians replacing the solenoid on V-26-16 consulted electrical prints and replaced the solenoid using this information. The print was wrong and the electricians replaced the solenoid for V-26-18 instead of V-26-16 as

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The plant engineer observing the maintenance noted that the wrong valve l was being replaced. He verified the system configuration through use of I the process and instrumentation diagram (P&lD) and compared this to the i

electrical drawing. He determined that there was a conflict between the P&ID and the electrical drawing and informed the electricians performing the maintenanc _ _ _ _ _ _ _ - _ - _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ .

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The electricians then replaced'the solenoid on vacuum relief valve V-26#

16. .The plant engineer initiated a' Field Change Request (FCR) to resolve the conflict between the-P&ID and_ electrical drawing. It was concluded-that the electrical drawing was in erro Because of this drawing error, electricians were directed to replace the

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solenoid on the' opposite train vacuum relief valve. The potential safety significance of this: error is that had;the valves been required to be

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operable, the disabling of the opposite train valve could have-disabled the vacuum relief functio Licensee examination of the solenoid which was removed from V-26-16 iden-tified the presence of a powdery substance and moisture. The licensee.has sent the solenoid to the laboratory for analysis to -determine the failure mechanism. At tS conclusion of the~ inspection period this analysis ~had;

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not been complet :. The licensee has documented the failure of this valve in a Licensee Event Repor The replacement of the solenoid on the opposite train valve because of(a drawing error is considered to be a condition adverse to _ quality. The effectiveness of the licensee's corrective action systems to identify this

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condition and initiate corrective actior to prevent reoccurrence'had not been reviewed at the conclusion of the inspection perio .0 Instrument Air System (71707)

On April 2,1989, desiccant beads from the' instrument air dryers entered the Instrument Air System. The introduction of desiccant beads resulted from a failure of the retention screen. in the air dryer ' towers. This failure caused both sets of instrument air post filters to clog and pre-vented the closure of the inlet isolation' valves.to the post filters. ' To prevent a loss of instrument air, the operators cracked open the post filter bypass valve but left the air dryers in service for about 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.

) The licensee later bypassed the air dryers when covert .were raised re-t garding potential detrimental effects on the Instr een~ Air System.-

A Plant Engineering Work Request was generated by Operations to address the effects of desiccant beads in the instrument air lines. The inspector followed the Plant Engineering investigation. The actions taken by Plant Engineering. included the examination of ten different locations-in the In-strument Air System for desiccant beads. Two cups of Desiccant were found at one location, a low point in the system,:Just before a bend and 10 foot vertical rise in the system. The licensee concluded that any desiccant beads _which were introduced into the Instrument Air System would collect-in this' portion of piping, because of the relatively low air velocity in the system, the long vertical rise, and that no evidence of any desiccant beads existed in the rest of the system.

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LThe licensee repaired the failed retention ' screen in the air' dryer towe Additionally, the licensee installed a second screen. downstream of. the air -

dryer towers as an extra measure of protection. The inspector had no fur-ther questions on the licensee's repair of the air. dryer retention screen and evaluation of the impact of the desiccant beads in the Instrumer;t Air Syste Although the corrective action tolfix the mt.terial problem and alleviate the' concern of. desiccant-in the air system was performed, no formal pro-cess was implemented to identify and address the root causes of this'

event. In this particular event,.the post filters were bypassed with the air dryers still in . servic In,a' conversation with a Group Shift ~ Super-visor, he stated that he did not'know what was more detrimental,ubypassing

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the post filters, and potentially allowing desiccant or. foreign material into the Instrument Air System; or, bypassing both. the ' dryers and the; post =

filters,- and potentially allowing moisture into the In'strument' Air Syste The inspector reviewed existing procedures and concluded there was in-

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adequate guidance to the operator to address this event. -This concern was

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brought to the attention of the licensee management. -The. licensee state that Plant Engineering was in the process of developing a new abnormal procedure for the Instrument Air System.and that'better guidance will be provided for the operators. The in'spector had no further questions.re--

garding this even .0 Monthly Surveillance Observation (61726)

On April 17 and 19, 1989, the inspector observed the licensee perform pro-cedure 604.4.016 Torus to Drywell Vacuum Breaker.0perability. and Inser-vice Test. The inspector observed that the operators'in the' torus room and on the 23' elevation of the reactor building did not have a. procedure in hand during the performance of the evolution. Although the procedure was maintained in the control room, operators in the' torus room _were directing the surveillance. Additionally, the' operators did not consult the procedure until a problem was encountere Errors were observed during the performance of this' surveillance. During the testing of valve V-26-10, a closed indication ~was not-received when the valve was allowed to fall freely from one inch. The= operators in the torus room intended to apply a closing force to the valve'to obtain'the i closed indication. The inspector questioned this action relative to the 1 procedure. After' consulting with the control room operators, who had the procedure available for review,.it was determined that a closing force can only be. applied if the valve had' rebounded. This valve,'however,.had not rebounded. After several attempts to obtain a closed * indication,. operator j discovered that they had missed a step requiring the removal of a threaded rod from the vacuum breaker arms. Upon removal of the threaded rod, valve:

V-26-10 indicated closed as required.

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While observing the surveillance, the inspector noted that several steps could not be performed. These steps included the inability to 'use the threaded rod on some valves, as specified by the procedure due. to inter-ference. Additionally, the procedure identified the use,of bolts onctwo valves because interference prevented the use of the threaded rod. lAl-'

though these bolts were missing, the inspector noted that the threaded rod could in fact be used. ' As .a result of these discrepancies, the operators had to improvis ~

The~ inspector observed that the operators had initially used 'a 1/2- inch'-

threaded rod. The procedure, however . specified the use of a 7/I6. inch ..

threaded rod. The 1/2 inch threaded rod could not fit through the arms.of. .

some valves.- The operators subsequently located a 7/16 inch threeded rodi to complete the-surveillance. This rod was located lying on top of the t toru During the timing of valve motion, the inspector' asked about the method by-which the operators measured the times. The operators started. timing whe force was. initially applied to the valve.instead of when valve movement'

began. The method by which the operators timed the valve, however, was:

conservative and did not affect the results of the test. The inspector discussed this point with Operations Management. They ' stated that Plant Engineering would resolve the discrepancy. The apparent'causes.for con -

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fusion were the length, complexity, and ambiguity of the procedural' step The ability to obtain. repeatable results.during this surveillance con-tinues to be a problem. This is evidenced by the high number-of failures encountered during this surveillance. Problems; appear to' lie with exces-sive tolerances in valve position indication. The licensee is cognizant of the problems and has initiated review activities to effectively address the issue Although the inspector identified the potential for an : unauthorized pro- ,,

cedure change to licensee personnel before steps were performed and the 1 deficiencies identified during this surveillance were of a minor ~ nature,-

it reflects a lack of rigorous procedural compliance' and implementatio .0 Plant Operations (71707)

The inspectors observed-the. April 21, 1989 reactor startup. -During the'

startup the inspector noted that problems continued with'the intermediate range neutron monitors (IRM). During- the startup. three half reactor' .)

i scrams were received, one from IRM range 16 and two from IRM range 1 j The first of these half scrams from IRM range 17 occurred whenithe reactor d operator ranged _the IRM from 6 to 7. Normally, during the. course'of the startup, the control room operators would perform a correlation between

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range 6 and range 7 on each intermediate range monitor before placing IRM range 7 into service. In this instance, reactor power was increasing at a 1 j

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rate as such the reactor operator was required to move the.IRMtinto. range 7 before doing the correlation. 'At this-time control rods were inserte to reduce. reactor period, and reactor powe'r drifted downward while the control room' operators performed the IRM range' correlations. IRM 17 could not be correlated and was declared inoperable. .The inspector observed th'e presence"of Operations Department management.in the control room. Over--

all, the inspector concluded that'the licensee reactor startup was con-

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trolle . During the startup and heatup, the inspector witnessed two,sh'ift turnovers w- and two preshift briefings. The inspector concluded that the 'controle room operators' turnovers effectively transferred information and plant; con-ditions from one shift to'the next. The inspector also noted that the preshift briefings were informative'and provided a detailed summary of-plant conditions and planned plant evolutions for the upcoming. shif After the' reactor plant had been heated to normal operating. pressure and temperature, some. equipment problems were noted. The first;of these'was-that the "D" reactor recirculation. pump inner. seal: showed signs'that the

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seal had failed. Another problem which had been. encountered previously was the "A" electromatic' relief valve. .The thermocouple downstream of this relief valve was reading above 200 degrees,: indicating that:the ne relief valve installed was leaking. Finally,. post maintenance. testing'o the "B'? RWCU pump showed that the casing leak had not been stoppe Or 4/22/89, at normal operating pressure, the licensee performed a drywell.-

inspection. The results of this inspection indicated'several. plant prob-lems. The most significant problem identified was a through wall leak on a core spray system weld. This weld is located in the core: spray dis-charge piping between the manual isolation valve and the reactor vesse This hole was characterized as a pinhole leak emitting a 1-2 inch pl'ume of steam. One "C" reactor recirculation-loop spring can had:been left' pinned and another spring can was at its extreme range of travel. Because of the leak in the core spray discharge piping,~ the licensee' shut down the reac-tor for repairs. Because of the decis.on to promptly perform a plant shutdown, the licensee was unable to~ test the "A" EMR xl During the reactor shutdown, the licensee experienced a loss of main' con-denser vacuum, which required the operators to manually scram the reactor to prevent an automatic scram. The loss' of vacuum event is' reviewed in paragraph 7.0 of this repor !

7.0 - Manual Scram due to Lowering Condenser Vacuum (93702, 71707)

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y On April 22, during a reactor shutdown, a manual' scram.was inserted as a' '

result of lowering condenser vacuum. The loss of vacuum occurred when seal water was lost to the mechanical vacuum pum __ _ _ _ - _ - _ _ _ _ _ _ _ _ _ __

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The inspector observed the licensee's critique of the event. The critique

' identified that the Equipment Operator failed to open the inlet isolation valve to the seal tank float valve. As a result of not opening this valve, makeup water was lost to tFe seal water tank. Subsequently, seal water was lost to the mechanical vacuum pump causing the loss of condenser vacuum. The critique further identified that the Equipment Operator did not have the procedure in hand nor had he reviewed the procedure prior to performing the evolution. It was also identified that the last time the evolution was performed by the Equipment Operator was approximately two years ag .

The corrective actions identified in the critique included resolving a tagging issue which was contributed to causing Equipment Operator con-fusion. Additionally, the critique members intended to add a caution to the procedure to alert the operator to the potential for losing seal tank level. The critique concluded that this event was a single isolated case of personnel erro The inspector discussed the critique and conclusions reached with licensee management and noted that there appeared to be broader implications re-garding use of procedures in the underlying issues of the' event in that infrequent events were performed without reference to the procedur Operations Management representatives agreed that additional corrective actions were require In response, Operation Management is developing a policy to require opera-tors to perform all procedures with the procedure in hand, a photocopy of the procedure in hand, or the procedure read from the control room. Ex-ceptions to this requirement are procedures which are considered fre-quently used and simple in nature. A list of these exceptions is being i compiled by a team formulated by operations. Additionally, Operations {

Management stated that prior to this event, plans were already in progress 'j to make controlled procedures available outside the control roo This is not being cited as a violation because the equipment involved was ,

not a safety related piece of equipment and control room operators took l appropriate action to insert a manual scram, and the event was reported as l require Nonetheless, this event is of concern to the NRC. The failure to follow station procedures in this case required operators to insert a manual scram in order to prevent the automatic actuation of the reactor

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protection syste Further, initial conclusions reached by those conduc-ting a critique of the event had not included one major root cause of the event. Paragraph 5. of this report also describes a situation where tech-nicians conducting a safety related surveillance did not follow procedure In both of these cases, the required procedure was not available to personnel y in the field and in the case of the mechanical vacuum pump the individual had not reviewed the procedure prior to performing the evolution. These cases indicate a weakness in the licensee's control of activities and demonstrate that the licensee's policy regarding procedural adherence is not being uniformly applie !

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9 8.0. Core Spray Intergranular Stress Corrosion Cracking-(71707)'

Licensee examination of- the hole _ in core spray weld NZ-3-38 indicated that '

the flaw was due to _intergranular stress corrosion cracking. _ Ultrasonic-testing indicated that two axial indications and one circumferential in-

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dication exised in the core spray weld. Currently eight core spray weld had been classified as Category G in accordance with NUREG 0313 and.had '

never been inspected. After discussion with NRC Region I'and Headquarters personnel, the_ licensee agreed to inspect a total of eight welds in the system. including five of the welds that had not previously been inspecte .

The.other three welds were located behind the biological shield wall lsur-rounding the reactor and would have required significant _ radiation expo-sure to perform the inspection Licensee inspection on the eight additional core spray welds showed,no evidence of ~intergranular-stress corrosion cracking from ultrasonic ex .

aminations. One surface indication was identified on weld NZ-3-39. The licensee reviewed this indication and dispositioned it-to "use as is".

At the end of the' inspection period the licensee was in.the process of making the repairs to core spray weld NZ-3-3 .0 Plant Cleanliness (71707)

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During plant tours, the inspectors focused on identifying deficient condi-tions and assessing plant cleanliness. Areas toured included'the reactor building, turbine building, diesel generator building, and plant intake-structure It was evident as a result of the' outage nearing completion, that an increased amount of site resources was being applied to the area of plant cleanlines The inspector concluded from these tours that during this extended outage, plant cleanliness had degraded significantly and that an' increased toler-ance for deficient and temporary conditions existed. .The inspector ob-served many temporary hoses, electrical cords, plastic tubings and tem-porary valves being left in the plant. The inspector also concluded, be-cause of the amount of miscellaneous equipment, that workers do not gene-rally clean up their work area after job completio h The licensee has implemented a specific effort to clean up the plant at- l L the completion of the outage. The licensee has conducted tours of plant i buildings and plant areas and has identified those conditions which need '

to be corrected. Inspector tours noted that some improvement had been made, but many items previously identified as needing correction persis Effort by the licensee is needed to alter personnel attitudes, increase-their sensitivity, and increase personal-~ accountability to achieve and maintain a high standard of plant cleanliness. The licensee stated that it was their policy that workers were personally accountable for their-

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10-10.0 Standby Gas Treatment System Accumulator Testing (71707)'

Inspection Report 50-219/88-38 described the licensee's testing on Standby Gas' Treatment System (SGTS) accumulators. The results of the testing'had shown that the accumulators,.which operated the outlet valves of-the'SGTS trains, did not meet their acceptance criteria. ..The inspector noted that the licensee had not written a Licensee Event- Report (LER) on ,this even m The-inspector' requested the basis for.the_ licensee's decision. In re-sponse, the licensee provided the minutes- from a Plant Review Group (PRG)-

meeting on this event which was-held on January- 12, 1989. The PRG deter.-

mined that this event was not reportable'for the'following reasons:- The Technical Specifications do not require the accumulator nor that air pressure be maintained for any given length of tim The concern exists only for 'an' extended loss of instrument air when-SGTS is required to be operating. (The inspector noted that instru-ment air system is a non safety related system.)' The most limiting valve would maintain its position long'enough.(1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />) for corrective action to restore instrument air pressure.or_

block the valves in the nece'ssary positio The ' data used in the' PRG's evaluation was in error in that _the limiting time of 12.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> was not the "as found" condition of the~ accumulators,-

but the condition after the check valves were replaced on the accumulator When this was-identified to the licensee, thez licensee confirmed the information and reconvened the PR The PRG. determined that the most ;

limiting time was actually 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. The licensee stated.-that the differ-- i ence in the times did not alter'the PRG's conclusion, however, the PRG .i intends to issue a revision to LER 89-008 (Loss of Air Event Will Prevent 3

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Containment Isolation due to Inadequate Surveillance. Testing of,the Air Support System) to include a description of-the SGTS accumulator testing- El The inspector identified no other concern .0 Scram Time Testing (71707)

Inspection Report 50-219/89-07 documented that the licensee' incorrectly l

interpreted their test results,-from scram time testing; performed in re-

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fueling outage 11R. The_ licensee has completed a_ review of test _infor--

mation taken during refueling outage 11R and has' concluded that all. con-trol rods met their acceptance criteria for insertion times. The inspec-tor identified no other concerns.

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12.0 Quality Assurance Annual' Review (71707)

On 4/12/89, the NRC inspectors attended the site Quality Assurance Annual Review. This presentation consisted of QA assessment of ten previously identified deficient areas. In each area, the concern and the corrective actions were presented with the status of completion. After each item, a question and answer period was made available to establish a flow of com-munication between QA and site personnel. Overall, the presentation indi-cated the issues that QA personnel considered significant, and it updated-

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the status of the corrective action and site response to these issue .0 (Closed) Unresolved Item 88-38-04 This item pertains to the accumulator testing on secondary containment valves during the 12R refueling outage. The licensee had tested sixteen primary containment and Standby Gas Treatment System accumulators and dis-covered a 50 percent failure rate. At the conclusion of Inspection 88-38, the inspector had questioned the licensee if they intend to test the rest of the accumulators based on the high failure rate encountered. The lic-ensee at the time stated that they had not yet decided. The licensee has since tested the balance of twenty four secondary containment related ac-cumulators. All accumulators failed to meet their acceptance criteri The licensee issued Licensee Event Report 89-008 and committed to estab-lish a surveillance program to periodically test these accumulator Based on the completion of the accumulator testing and the commitment to establish a surveillance program, this item is close .0 Radiation Protection (71707)

During entry to and exit from the RCA, the inspectors verified that proper warning signs were posted, personnel entering were wearing proper dosime-try, personnel and materials leaving were properly monitored for radio-active contamination, and monitoring instruments were functional and in calibration. Posted, extended Radiation Work permits (RWps) and survey status boards were reviewed to verify that they were current and accurat The inspector observed activities in the RCA to verify that personnel com-plied with the requirements of applicable RWPs and that workers were aware of the radiological conditions in the are .0 Review of Periodic and Special Reports (71707)

Upon receipt, periodic and special reports submitted by the licensee were examined by the inspectors. The inspectors also reviewed weekly reports 1 l when received. These reviews included the following considerations: that l the report includes the required information; that planned corrective ac-tions are adequate for resolution of identified problems; and that the reported information is valid, f

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16.0 Inspection Hours Summary Inspection consisted of 120 direct inspection hours'out of a total of 258 ,

inspector hours on sit of these direct inspection hours were per-formed during backshift periods, and 10 of these hours were deep backshift inspection (April 16, 21, 22 and 23).

17.0 Exit Interview (30703)

A summary of the results of the inspection activities performed during this report period were made at meetings with senior licensee management at the'end of this inspectio The licensee stated that, of the subjects

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discussed at the exit interview, no proprietary information was include l l

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