IR 05000255/1989028

Insp Rept 50-255/89-28 on 890901-1005.No Violations Noted. Major Areas Inspected:Actions on Previously Identified Items,Plant Operations,Maint,Surveillance,Reportable Events, Generic Ltrs & Enforcement Conference

ML18054B080
Person / Time
Site:	Palisades
Issue date:	10/26/1989
From:	Burgess B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML18054B079	List: IR 05000255/1989028 ML18054B078
References
50-255-89-28, GL-88-05, GL-88-5, NUDOCS 8911090027
Download: ML18054B080 (13)

Text

• * U. S. NUCLEAR REGULATORY.COMMISSION

REGION III

Report N ~255/89028(DRP)

Docket No. 50-255 Licensee:

Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201

. License No. DPR-20 Facility Name:

Palisades Nuclear Generating Plant Inspection At: *Palisades Site, Covert, MI Inspection Conducted:

September 1 through October 5, 1989 Inspectors:

E.. R. Swanson J. K. Heller B. L. Jorgensen Approved By:

2A Date~

Inspection Summary Inspection on September 1-through October 5, 1989 (Report No. 50-255/89028(DRP))

Areas-Inspected:

Routine unannounced inspection by the resident inspectors of: actions on previously identified items; plant operations; maintenance; surveillance'; reportable events; generic letters; enforcement conference; and, quarterly management meetin No Safety Issues Management System (SIMS) items were reviewe Results: Of the eight areas inspected, no violations or deviations were identifie New Open Items were identified to track Pressurizer Safety valve corrective actions (Paragraph 6.c) and resolution of a carbon steel/stainless steel bolt replacement issue (Paragraph 7).

The inspection disclosed weaknesses in the licensee 1s Augumented Test Program followup, and attention to detail in execution of some corrective action The inspection noted strengths in the licensee 1s remo~eling of the Auxilary Building Acces? Control; the innovative training video tape in the change area; the good review of issues by CARB; and the questioning, probing attitude of plant personne I I

• DETAILS Persons Contacted tonsumers ~ower Company

1. + ~. Hoffman, Vice President, Nuclear Operations

1. + G.. B. Slade, PlaAt General Manager

+ D. W.. Joos, Steam Generator Project Manager

1. + R. Rice~ Operations Manager

• J, G: Lewis, Technical Director W. L. Beckman, Radiological Services Manager

+*J. L. Hanson, Operations Superintendent

• H. M. Esch, I&C Superintendent (Acting)

• H. C. Tawney, Engi~eer~ng and Maint~nance Superintendent K. E. Osborne, System Engineering Superintendent

1. *R. M. Brzezinski, Engineering and Maintenance Manager (Acting)

L. J. Kenaga, Health Physics Superintendent*

• 1. + K. W. Berry, Director, Nuclear Licensing

+ J. J. Fremeau, Director, Nuclear Safety

• C. S. Kozup, Technical Engineer J. R. Brunet, Licensing Analyst

1. + D. J. Malone, Senior Licensing Analyst R. J. Frigo, Operations Staff Support Supervisor

' *R. McC~leb, Quality Assurance Director Nuclear Regulatory Commission (NRC)

1. + E. G. Greenman, Director, DRP

H. J. Miller, Director, DRS

1. + D. W. Cooper, Chief, Engineering Branch

1. + W. L. Axelson,Chief, Reactor Projects Branch 2

1. + B. L. Burgess, Chief, Projects Section 2A

1. + E. R. Schweibinz, Projec~ Engineer

1. +*E. R. Swanson, Senior Resident Inspector

1. + M. J. Farber, Project Engineer

• J. K. Heller,* Resident Inspector

+ I. S, Yin, Reactor Inspector

W. H. Schultz, Enforcement.Coordinator

1. +A. W. DeAgazio, Project Manag.er, NRR

1. + A. S. Masciantonio, Project Manager, NRR

+ C. F. Gill, Senior Radiation Specialist

+ M. A. Kunowski, Radiation Specialist

+ J. N. Jacobson, Reactor Inspector

1. Denotes some of those attending the Enforcement September 28, 198 +

D~notes some of those present at the Management September 28, 198 * Denotes some of those present at the Management OC:tober 5, 198 Conference on Meeting on Interview on Other members of the Plant ~taff, and several members of the Ccintract Security Force, were also contacted during the inspection perio **

2.

Actions on Previously Identified Items (92701, 92702) (Closed) Op~n Item 255/87005-0G(DRP):

CPCo to prepare final report on resul_ts and status, of Augumented Test Program (ATP).

As

.

previously reported in Inspection Report No. 50-255/89015, CPCo had not prepared the subject report but had committed to complete the actio During subsequent reviews the inspector found that the individual assembling ATP data was only considering information predating mid-1987, although other aspects of the System Functional Evaluation. and Augmented Test P~ogram including Qngoing, complete and incrimplete testing requirements.* Further, QA Surveillance No. S-QP-89-25 had been performed, identifying: fifty eight questions and discrepancies for test requirements that had been identified by the program but never implemente This surveillance had been requested by the Technical Director and other line management to support their involvement in the progra During a meeting on September 7, 1989, the CPCo Technical Director, the Superintendent of Systems Engineering, and a cognizant supervisor met with the

_inspector and agreed that the ATP had been fully and properly implemented for both pre~ and_post-1987 ac~i~ities: 1) a report would be prepared for the pre-1987 items as originally committed; 2) the* QA Sur~eillance findings would ba closed (they were substantially complete at the time of this inspection); and, 3) the test requirements and status of the pre-and post-1987 programs would be compared for congruity, comp 1 eteness and lack of unne.cessary overla *At the close of this inspection the final report of item 1) wa~

• nearly complete and the licensee _was continuing w6rk on items 2). and

• 3).

Open Item number 255/89028-01 will track completion of these three commitment (Closed) Unresolved Item 255/87022-04(DRP): * CPCo to update LER *

255/85023 to document final corrective actions for inadequate Low Te~perature Over-pressure Protection (LTOP) Administrative Control LER 255/85023 was updated by submittal of LER 255/88001 on March 11, 198 Since identification of the original non-conservatism in the LTOP design in 1985, Technical Specification (TS) Amendment No. 117, for LTOP, was approved and the licen~ee has submitted a subsequent TS Change Request to update the pressure/temperature limit requirements-of 10 CFR 50, Appendix G. This latt~r submittal was under NRR review during this inspectio Further, the system was reviewed as~part of an engineering inspection (NRC Inspection 50-255/87009) which identified deficiencies in the calibration of the LTOP system instrumentation and control The intent -0f the original unresolved item has been met with CPC0 1s submittal of updated materia The continued acceptability of the system will be determined -separately by NRR review of the pending TS change request and NRC Region III review of the CPCo response to Inspection Report No. 50-255/8900 (Closed) Open Item 255/88010-07(DRP):

Update LER 255/88005 to address corrective actions for procedure deficiencie~. The LER reported performance of valve testing under TS prohibited plant conditions as a result of procedural deficiencie Revision 1 to the

LER was issued Febru~ry 7, 1989, _documenting final actions including revisions to administrative and surveillance procedure The inspec~or verified that all actions had been implemented as stated in the repor (Closed) Unres6lved Item 255/88027-02(DRP):

Updating and accuracy of control room drawing file Previous practices for maintaining control room drawings as up-to-date and as-built were, in some case~, limited to referring the user to other print files which included hand-drawn 11red-line 11 updates not included in the control room copie As a result of the prior inspection, the licensee had revised Administrative Procedure 10.. 44, 11 Design Document Control and D'istribution, 11 Revision 6, and Procedure 9.03, 11 Insfructions for Update of Drawings to Support Operability Authorization, 11 Revision 7, to provide for transcribing all drawing changes onto the control room print A sample of recent changes was verified for the control roo~ drawing files, operations department office drawing files, Emergency Operations Facility and the Technical Support Center drawing file The inspector noted that the coordination.of drawing updates between the site draftsperson 1 s and the Jackson Office drafting department appeared to be cumbersome and prone to error or omission, although n~ examples of missed or incorrect revisions were identifie '

.One open item and no violations, deyiations, or unresolved i-tems were identifie.

Operational Safety Verification (71707, 71710, 42700, 40500)

Routine facility operating activities were observed as conducted in the plant and from the main control rooms.. Plant startup; steady power operation, plant shutdown, and system(s) lineup and operation were observed as applicabl The performance of licensed Reactor Operators and Senior Reactor Operators, of Shift Technical Advisors, and of auxiliary equipment operators was observed and evaluated including procedure use and adherence, records and logs, communications, shift/duty turnover, and the degree of professionalism of control room activitie Evaluation, corrective action, and response for off normal *conditions or events, if any, were examine This included compliance to any reporting requirements. -

Observations of the control room monitors, indicators, and recorders were made to verify the operability of emergency systems, radiation monitoring

• systems and nuclear reactor protection systems, as applicabl Reviews of surveillance, equipment condit1on, and tagout logs were conducte Proper return to service of selected components was verifie~.

It was observed that the plant Management and Supervisors were well informed on the overall status of the plant and that they made frequent visits to-the control room and regularly toured the plan Tours of the containment and turbine building were conducted to observe _plant *

equipm_ent conditions including: potential fire hazards, fluid leaks, and excessive vibrations, and to verify that maintenance requests had been initiated for equipment in need of maintenanc Radiation protection controls were inspected, including radiation work permits, calibration of radiation detectors, and proper posting and observance of radiation and/or contaminated area Access control has been remodeled to include a new larger change are A closed loop videotape, instructing workers in the proper Anti-C dressing procedure, is playing in the dressing roo This innovation reflects some good planning on the part of the plant staf The inspectors observed site security measures including access control of personnel and vehicles, pro.per display of identification badges for personnel within the protected area, 'and compensatory measures when security equipment had a failure or impairmen For one period of security equipment inoperability the licensee was noted to be using triple compensatory measure Steam Generator Leakage The Palisades plant had been operating for th~ last several months at a reduced power level of 80 percent, as a result of concerns for steam generator tube integrit Near the end of the operating cycle the-licensee decided, with NRC concurrence, to increase power under a controlled escalation plan to determine what effect power level had on the currently ~mall indicated tube lea It was also desirable that the leak be of a size that would be detectable and, therefore, repairable during the October outag On the evening of September 14, 1989, power level was increased from 80 percent to 82.5 percen The primary-to-secondary leak rate increased from the steady 0.017 gpm to about 0.03 gpm early on September 16, 198 Power was then reduced to 80 percent, with a reduction in leak rate to the prior valu The leakage phenomena is not understood at the present (ie, why does it get bigger and smaller with power level), although, several theories that relate temperature and pressu~e were offere The licensee did gain

_assurance that the leaking tubes would be identifiable during the October outag The Palisades Technical Specification limit for steam generator leakage is 0.3 gp Potential For Operation Outside The FSAR Design Basis The licensee's Licensee Event Report (LER) 255/89015, as discussed in NRC Inspection Report 255/89021(DRP), documented discovery of a single failure which could result in the post-accident overpressurization of the containmen In summary, the scenario results in a single containment spray pump supplying both containment spray headers with the reactor coolant pumps still running and adding hea In consequence, the calculated peak containment pressure is 57.4 psig, well above

• *

the 55 psig design value specified in the FSAR for a period of 19 second As described in the LER, the problem was resolved by electrical system realignment to avoid reliance on the breaker which could cause the scenari During the current inspection period, on September 13, 1989, another single failure was identified, this time involving the potential failure of a containment high pressure telay to energize, which-leads to the same post-accident reliance on a single spray pump supplying both headers with the reactor cooiant pumps still operatin The licensee made a telephone notification to NRC pursuant to 10 CFR 50.7 A safety evaluation was conducted which concluded that*

the new scenario, though not within the FSAR design limits, was within the limits previously accepted by NRC for the low-probability event of simultaneous blowdown of both st~am generators into containmen Furthei, the current scenario was also less probable than the two-generator blowdow Thus, overall plant safety was not significantly affected and shutdown of the plant, which was at 80 percent power, was not require The safety evaluation also focused on containment spray-valve stroke time, upon which both the current scenario and that of the previous LER were highly dependen The calculations had assumed a seventeen second stroke time, consistent'with the valve performance criterion established in routine testing. A review of actual test data, however, showed both valves had consistently stroked in less than ten seconds for the last several year The technical analysis determined that with valve stroke times less than twelve seconds, even the one pump/two header scenarios would not exceed the FSAR containm~nt pressure of 55 psig. This means actual historical plant operating conditions were such that the FSAR criteria could always have been me The licensee withdrew the 50.72 phone notification, of September 13, later that same da An update on the original LER is anticipate For the longer term, it may not be desirable to rely on the (perhaps infrequently verified) speed of a pair of active components (the spray valves) to maintain design basi~ condition The licensee is evaluating design change option Corrective Action Review During routine attendance at Corrective Action Review Board (CARB)~

the inspector verified that the reviews and assignment of corrective actions were generally comprehensive and reflected a safety perspectiv Events identified during this period reflect an exceptional probing, questioning attitude by a wide range of plant employee For example, an SRO reviewing and revising procedures identified six potential single failure susceptibilities in various system actuation logics, and a hot license class walkdown of the Control Room HVAC system identified several relay failures that

• could cause the system not to actuate as assumed in the current analysis~ The former issue was being evaluated at the close of the inspection and the latter will result in an LE No violations, deviations, unresolved or open items were identified:

4. -

Maintenance (62703, 42700)

Maintenance activities in the plant were routinely inspected, including both corrective (repairs) and preventive maintenanc Mechanical, electrical, and instrument and control group maintenance activities were included as availabl The focus -of the inspection was to assure the maintenance activities reviewed were conducted in accordance with approved procedures, regulatory guides and industry codes or standards and in conformance with Technical Specification The following items were considered during this review: the Limiting Conditions for Operation were met while components or systems were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures; and post maintenance testing was performed as applicabl The following activities were inspected: Power cross-ties for P-S5A and P-558 (FC-839, W0-24903905, RWP 890399). Service Water pump P-7A rebuild (W0-24904386) Replacement of Feed Pump P-lA lube oil purifier pump (W0-24900788). Calibration of instrumentation in the Boric Acid System (W0-24903497).

e. -

Removal of Containment Spray Pump (P-54C) motor for rebuild (W0-24_901667). Removal of H1gh Pressure Safety Injection Pump (P-668) for motor rebuild (W0-24901671).

• No violations, deviations, unresolved or open items were identifie.

Surveillance (61726, 42700)

The inspector reviewed.Technical Specifications required surveillance testing as described below and verified that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that Limiting Conditions for Operation were met, that removal and restoration of the affected components were properly accomplished, that test results conformed with Technical Specifications and procedure requirements and were reviewed by personnel other than the individual directing the test, and that deficiencies identified during the testing were properly reviewed and resolved by appropriate management personne Th~ following activities were inspected: Q0-16 DW0-13 S0-4A SC-5 DW0-1 SH0-1 Inservice Test Procedure - Containment Spray Pumps, Rev. 2, dated December 29, 198 The test performed on September.11, 1989 was performed according to the procedure, Limiting Conditions of Operation (LCOs) were entered_and exited as required, and the results of the test were satisfactor The Operations personnel involved in the test encountered a few difficulties which they _

annotated on the Test Improvement Sheet, so that the next revision of the procedure might be improve Local Leak Rate Test for inner & outer personnel Air Lock Door Seal Personnel Air Lock Penetration Leak tes Iodine removal system tank concentration tes Daily Control Room Surveillanc Operators Shift Surveillanc No violations, deviations, unresolved or open items were identifie.

Reportable Events(92700, 92720)

The inspector reviewed.the following Licensee Event Reports (LERs) by means of direct observation, discussions with licensee personnel, and review of r~cords. fhe review addressed compliance to reporting requirements and, as applicable, that immediate corrective action and appropriate action to pr~vent recurrence-had been accomplished. * (Closed) LER 255/86032-01:

Issue updated report for Component Cooling Water Flows Less Than Specified in FSA The licensee had committ~d to submit a revision to this LER in its original report of September, 198 The subject report documented the final cause determinations and the corrective actions taken and planne This matter has been reviewed separately by the resident inspectors and NR (Closed) LER 255/86036-01:

Issue updated report-for Service Water Capability Less Than Specified in FSAR:

The licensee had committed to submit a revision to this LER in its original report of October 30, 198 The subject report documented the final cause, determinations and the corrective actions taken and planne This matter has been reviewed separately by the resident inspectors and NR The NRC expressed concern for the lack of plans to restore the intended operating margin to the syste (Closed) LER 255/88020:

Pressurizer safety valve RV-1039 failed to meet its Technical Specification lift setpoint acceptance ban This item was previously reviewed during Inspection 255/88-26 at which time the licensee had not yet identified a root cause and

• corrective actio Subsequent to the test *fa i 1 ure of RV-1039, RV-1040 and RV-1041 were tested, failed, repaired, successfully*

retested, and returned to service as documented in deviation reports 0-PAL-88-197,.-191, and -04 Development of corrective action plans was still in progress during this inspection with tentative plans including: 1) submittal of a technical specification change request to broaden the setpoint tolerance band from 1% to 3%; 2)

establishing administrative controls for an 11 as found 11 acceptance criteria of 3~~ and an 11as-left 11 retest criteria of 1%; and 3)

routine vendor overhaul of each valve after every 11 as-found 11 test, even if acceptabl The next test was scheduled and budgeted for the 1990 refueling outage; budget and Five Year Plan provisions had not yet been. established for the other corrective action plan Long term licensee action will be reviewed as Open Item 255/89028-02(DRP)..

(Closed) LER 255/88022:

Foreign Material on Valve Seat Results *in Inoperable Isolation Valv The valve, serving a liquid waste tank pump, had a plastic foreign object fouling the valve plu The valve was repaired and retested. Associated with the retest, the resident inspectors identified a concern about compliance with TS during the valve test, Q0-11, 11 Containment Isolation Valve Check Valve Test, 11 which rendered the containment penetration inoperable during the tes This definition of operability was clarified by Technical Specification Amendement No. 12 The inspector confirmed the licensee's corrective actions to revise the Q0-11 procedure and to upgrade cleanliness controls which were completed as stated and appeared responsive to the prior event and concern * (Closed) LER 255/89001:

In-progress Plant Derate Results In Failure to Perform Required Surveillance. The primary coolant leak rate determination was not performed when required by Technical Specification (TS) 4. The leak rate surveillance requires stable plant conditions for performanc Power was being reduced as a result of primary to secondary coolant leakage exceeding procedural limits and stable plant conditions were not available without undesirably terminating the power reductio The resident inspectors followed this event as it occurred and the inspector verified that corrective actions were satisfactorily implemented as stated in the LE This violation of TS meets the conditions of 10 CFR 2, Appendix C, Section V.G.l, for not issuing a Notice of Violation. As such, a Notice of Violation was not issue A number was assigned for tracking purposes only (255/89028-03(DRP)). (Closed) LER 255/89002:

Pressurizer Power Operated Relief Valve (PORV) Opens Due to Primary Coolant System Pressure Spik With the plant at 210 degrees F. and with no bubble in the pressurizer, a pressure spike occurred when shutdown cooling flow was stopped and the low temperature Over-pressure protection system (LTOP) actuated the POR The licensee's analysis of the event concluded that air trapped in large bore connected pipinR caused the approximately 50-60 psig pressure surg Procedure changes were made to isolate the suspect piping prior to securing shutdown cooling, utilized, and

appeared effective in preventing recurrenc The licensee also planned to complete an evaluation of the need for additional system vent paths and procedures prior to the 1990 refueling outag Other licensee 1 s typically use a pressurizer steam bubble to control pres-sure in conditions similar to those encountered during this even However, the licensee considers the c~rrent limitation~ on minimum pressure for reactor coolant pump operation, the ~aximum pressure for reactor vessel neutron embrittlement considerations, and the maximum permissible pressurizer spray delta-T to provide too narrow an operating envelope to permit formation of a pressurizer bubble at low temperature No plans exist to use a pressurizer nitrogen bubble as an alternativ (Closed) LER 255/89003:

Plant shutdown due to Primary Coolant Drain Valve Leakag An unusual event was declared on February 18, 1989 when reactor coolant cold leg drain valves leaked due to repeated torquing and galling of the seats and conductive heating induced overpressurization of the piping between the series drain valve Corrective actions included interim operation with the leaking drain valve lines capped (this activity was inspected in progress by the resident inspectors), -planning of a permanent modification for the 1990 refueling outage to replace these and like valves with a design less susceptible to damag Replacement of two of these loop drain valves is in the scope of the current maintenance outage.. (Closed) LER 255/89010:

Breaker Failure Results in Two Coinci-dentally Inoperable Safety Injection Component Safety injection tank T82A was inoperable due to low water level after routine sampling (expected condition) when the P66A high pressure safety injection pump failed to start due to a loose plunger assembly bolt in its circuit breake Review of breaker maintenance his~ory by the licensee and the breaker vendor concluded that the loose bolt was an isolated failure not previously experience The breaker was replaced with a spare and returned to the vendor for repai The CPCo Permanent Maintenance Procedure SPS-E-4, "Breaker Inspection Procedure For 4160/2400 Volt Switchgear, 11 Revision 5, was revised by MRN-M89-015 to include a specific step, 5.1.6, for checking the tightness of the "plunger assembly bolL

However, the step refers the performer to procedure Attachment 10, "Figure 5, Typical Operator Assembly, 11 which portrays a cutaway view of the solenoid assembly but does not ioentify the plunger assembly bol This represents a human engineering deficiency in the procedure that can result in the performer incorrectly performing the ste Similarly, Attachment 2, 11 Breaker Inspection Checklist, 11 includes as-found-and as-left inspection characteristics including general checks for 11 Loose nuts, bolts or screws, loose parts" but does not specifically identify the bol The responsible system engineer stated that correction of the procedure deficiency would be made at the next routine revision of the procedur (Closed) LER 255/89012:

Failed Yoke Nut Threads Result in Inoperable Containment Isolation Valv The inboard safety injection tank sample and drain isolation valve yoke nut threads were found stripped, apparently from excessive disc/stem loading

• cause by poor stem packin The licensee's immediate corrective actions which included temporary modification of the valve yoke had been followed in progress by the resident inspectors; replacement of the yoke and yoke nut is planned for the current maintenance outag The 1 i censee reviewed the maintenance hi story for about 720 va.l ves with like yoke/stem configurations identifying only two additional valv~s subject to potential failur These valves will be repacked and lubricated during the next outag (Closed) LER 255/89018:

Coincident Equipment Inoperability for Auxiliary Feedwater flow indicating control FIC-0727 and Emergency Diesel Generator (EOG) 1-The Auxiliary Feedwater flow indication had been rendered inoperable for routine maintenance when the EOG experienced low lube oil pressure during a maintenance ru Correcti~e action for the flow indicator involved completion of repairs and restoration to servic With regard to the EOG low oil pressure, the CPCo internal event report (E-PAL-89-035) documents extensive troubleshooting and repair activities which included replacement of a suspect pressure control valve, inspections and cleaning of filters, et The condition has persisted with lower, but acceptable, oil pressures and the licensee is evaluating replacement of the oil pump during the 1990 outage and is closely trending operating dat The engine vendor advtsed that the engine may be run indefinitely with oil pressures as low as the 40 psig

• engine trip oil pressure; observed oil pressures are in the range of 58-70+ psi (Closed) LER 255/89019:

Analyzed Boron Dilution Incident Not Bounding for Newly Identified Potential Single Failur The licensee found that a previously unanalyzed potential boro~ dilution path exists via idled charging pumps during plant shutdown condition Corrective actions are being tracked by event report E-PAL-89-021, include revision of operating procedures, and are scheduled for completion prior to restart from the Fall 1989 maintenance outag The licensee identified the cause.of the analysis oversight to be lack of personnel awareness of charging pump-design features and inadequate internal communication No corrective or preventive actions were specified in the LER to address these causal factor The CPCo reactor engineering superintendent stated that no specific corrective actions were taken for this event but that ongoing department-level actions were responsive to preventing recurrenc These actions include basic systems training and on the job training for the accident and tran-sient analysis group staff, addition of staff members and first line supervision with substantially more plant and analysis experience, relocation of the group from the general offices in Jackson, MI to the plant, and increased involvement with vendor performed analysis, including technical audits of nearly all vendor analyse (Closed) LER 255/89020:

Reactor Trip Due to Blown Fuse and Subse-quent Auxiliary Feedwater Pump Star The inspector reviewed corrective actions specified by the LER and by CPCo event reports E-PAL-89-036 and -037 for procedure improvements, fuse control program evaluations, operator training, and equipment improvement

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evaluations finding them responsive to the event factor The licensee's schedule for completing the actions also appeared adequat One non-cited violation, one open item, and no deviations or unresolved items were identifie.

NRC Generic Letters (92703)

The inspector reviewed the NRC communications listed below and verif1ed that: the licensee has received-the correspondence; the correspondence was reviewed by appropriate management representatives; a written response was submitted if required; and, plant-specific actions were taken as described in the licensee's response, (Closed) Generic Letter (GL) 88-05:

Boric Acid Corrosion of Carbon Steel Reactor Pressure Boundary Components in PWR Plants. The licensee proposed (CPCo letter of June 3, 1988) to:* 1) develop a plant procedure for control of engineering activities involving the identification, evaluation, correction and monitoring of boric acid leakage; 2) revise work order procedures to ensure that boric acid leakage is identified by work order initiators arid planners; and 3) develop work order planning guide to contain specific maintenance related measures for identification, evaluation and correction of leakag The inspector reviewed the content and implementation of Procedure EM-26, "Boric Acid Leak Inspection," Revision O; Maintenance Administrative Memo 89-010,

"Mechanical Maintenance Boric Acid Guide," Revision l; Mechanical Maintenance Planning Guideline, dated July 27, 1988; Administrative Procedure 5.01, "Processing Work Requests/Work Orders," Revision 9; and various status report~ and data bases associated with the implementation of these document Considering the above program documents in conjunction with plant walkdown results, the licensee appears to have effectively implemented the commitments made in response to GL 88-05 with one exceptio The licensee's response notes that a Specification Change (SC) No.87-031 was issued to provide generic authority for replacement of boric acid degraded bolts, studs, and nut The licensee had suspended use of the SC about two months ago based on CPCo concerns about control of the replacement process including the lack of tracking and of drawing updates for prior change The NSSS Systems Engineering group is currently researching work order and stores issue records attempting to determine the total number of changes made and their application for a retrosp~ctive evaluatio Further, the SC does not include specific provisions to ensure that the replacement materials are compatible with system base metals when non-austenitic or non-ferritic alloys are encountere The cognizant system engineering supervisor stated that the administrative controls and material compatibility issues would be resolved prior to further use of generic material replacemen In the interim, individual SC's would be issued for each case in which fastener replacement was warrante This item will remain open pending review of the licensee's actions (255/89028-04(DRP)).

No violations, deviations, unresolved or open items were identifie *

("\\ Enforcement Conference An enforcement conference, attended as indicated in Paragraph 1 above, was held in the NRC Region lII office on September 28, 198 The purpose *

of' the conference was to discuss the potential violations documented in Inspection Report 50-255/89027(DRP) regarding the failure to maintain containment integrity, conduct containment boundary testing, and issues related to inadequate control of activitie The results will be discussed in future correspondenc.

Quarterly Management Meeting A quarterly management meeting was held in the Region III office o September 28, with the personnel indicated in Paragraph 1 above, in attendanc The topics discussed were: Stearn Generator replacement update; Cbnfi~uration Control Project update; upcoming Maintenance outage; August 4 reactor trip; safety margin; and other items of interes.

Open Items Open Items are matters which have been discussed with the licensee, whi_ch will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or bot Open Items disclosed during the inspection are discussed in Paragraphs 2.a and 6.c.

1 Management -Interview (30703)

The inspectors met with licensee representatiyes (denoted in Paragraph 1)

on October 5, 1989 to discuss the scope and findings of the inspection.*

In addition, the inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspectio The licensee did not identify any such documents/processes as proprietar