IR 05000261/1986026
| ML14175B443 | |
| Person / Time | |
|---|---|
| Site: | Robinson |
| Issue date: | 10/31/1986 |
| From: | Fredrickson P, Krug H, Latta R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14175B441 | List: |
| References | |
| 50-261-86-26, NUDOCS 8611110384 | |
| Preceding documents: |
|
| Download: ML14175B443 (13) | |
Text
dtpf R'u UNITED STATES
NUCLEAR REGULATORY COMMISSION A
REGION II
0101 MARIETTA STREET, ATLANTA,GEORGIA 30323 Report N /86-26 Licensee Carolina Power and Light Company P. 0. Box 1551 Raleigh, NC 27602 Docket N License No. : DPR-23 Facility Name : H. B. Robinson Inspection Conducted : September 11 - October 10, 1986 Inspector:
V H. E. P. Krug, Senior Resident Inspector 0a Sig ed Inspector:
_1_013-/0 7 /
R. M. Latta, Resident Inspector Da e Signed Approved by:__
__/3 P. E. Fredrickson, Section Chief D se Signed Division of Reactor Projects SUMMARY Scope: This routine, announced inspection was conducted in the areas of Technical Specification (TS) compliance, plant tour, operations performance, reportable occurrences, housekeeping, site security, surveillance activities, maintenance activities, quality assurance practices, radiation control activities, outstanding items review, IE Bulletin and IE Notice followup, organization and administration, independent inspection, Plant Status Report, Systematic Assessment of Licensee Performance (SALP)
and enforcement action followu Results: Violation 50-261/86-26-01,
"Failure to follow procedure:
AP-030",
paragraph Inspector Followup Item 50-261/86-26-02,
"PAP diesel overspeed trip," paragraph 8. Unresolved Item 50-261/86-26-03,
"Use of emergency boration
. to stabilize reactor power," paragraph 1,611110364 861031 PDR ADOCI 05000261 P DR
REPORT DETAILS Licensee Employees Contacted R. Barnett, Maintenance Supervisor, Electrical G. Beatty, Manager, Robinson Nuclear Project Department A. Beckman, Principal Specialist, Planning and Scheduling J. Benjamin, Supervisor, Operations R. Chambers, Engineering Supervisor, Performance D. Crocker, Principal Health Physics Specialist J. Curley, Director, Regulatory Compliance J. Eaddy, E&C Supervisor W. Flanagan, Manager, Design Engineering W. Gainey, Maintenance Supervisor, Mechanical E. Harris, Director, Onsite Nuclear Safety D. Knight, Shift Foreman, Operations E. Lee, Shift Foreman, Operations F. Lowery, Manager, Operations D. McCaskill, Shift Foreman, Operations A. McCauley, Principal Specialist, Onsite Nuclear Safety R. Moore, Shift Foreman, Operations P. Harding, Project Specialist (Acting), Radiation Control M. Marquick, Senior Specialist, Planning and Scheduling R. Morgan, Plant General Manager M. Morrow, Specialist, Emergency Preparedness D. Nelson, Operating Supervisor B. Murphy, Senior Instrumentation and Control Engineer M. Page, Engineering Supervisor, Plant Systems R. Powell, Principal Specialist, Maintenance D. Quick, Manager, Maintenance B. Rieck, Manager, Control and Administration W. Ritchie, Supervisor (Acting), Radiation Control D. Sayre, Senior Specialist, Regulatory Compliance D. Seagle, Shift Foreman, Operations R. Smith, Manager, Environmental and Radiation Control R. Steele, Shift Foreman, Operations R. Wallace, Manager, Technical Support L. Williams, Supervisor, Security H. Young, Director, Quality Assurance/Quality Control (QA/QC)
Other licensee employees contacted included technicians, operators, mechanics, construction personnel, security force members, and office personne.
Exit Interview (30702, 30703)
The inspection scope and findings were summarized on October 14, 1986, with the Plant General Manager and the Director of Regulatory Compliance, the Director of QA/QC, and the Director of Onsite Nuclear Safet Violations described in paragraphs 6 and 14 were discussed in detai The licensee acknowledged the findings without exceptio The licensee did not identify
as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio No written material was given to the licensee by the Resident Inspectors during this report perio.
Licensee Action on Previously Identified Inspection Items (92701)
(Closed) Inspector Followup Item 50-261/83-18-03:
The licensee issued Engineering Surveillance Test Procedure EST-067, titled "Intermediate Range Detector Setpoint Determination" to require the documentation and verification of the intermediate range trip (current equivalent to 25%)
and rod stop (current equivalent to 20%).
This item is close (Closed)
Inspector Followup Item 50-261/83-24-01:
The inspectors reviewed the licensee's completed documentation for Temporary Repair Procedure (TRP)
84/5 and Engineering Evaluation 85-075 and performed inspections on selected fire damper The inspectors determined that the licensee's action, to install springs to assist the gravity closure of affected fire dampers, appeared adequate. This item is close (Closed)
Inspector Followup Item 50-261/83-26-02:
Most of the sub-items associated with this item were closed prior to, or during, the Post Accident Sampling System inspection reported in Inspection Report 50-261/86-1 The remaining sub-items have been absorbed in Inspector Followup Item 50-261/85-15-0 This item is close (Closed)
Inspector Followup Item 50-261/83-36-01:
Maintenance Instruction MI-306 "Emergency Lighting System - Unit Load Test" was promulgated by the licensee to provide for an eight hour load test of emergency lightin This item is close (Closed) Inspector Followup Item 50-261/84-36-05: The licensee modified the following maintenance surveillance test procedure (MST) to include procedural steps to check both the undervoltage and shunt trips on the reactor trip breakers:
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Reactor Protection Logic Train "A" and
"B" at Power, Safeguards Relay Rack Train "A" and "B",
Revision MST-011
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Reactor Protection Logic Train "A" and "B" at "0" Power, Safeguards Relay Rack Train "A" and "B",
Revision MST-012 -
Inspection and Testing of Reactor Trip and Bypass Breakers, Revision The licensee also revised MST-017 (Revision 3) titled "Manual Reactor Trip Pushbutton Test,.Refueling Interval" to include functional testing of both trip pushbuttons on the RTGB. This item is close (Closed) Inspector Followup Item 50-261/84-37-01:
This item concerning the overpressurization of the condensate storage tank was converted into
I
violation 50-261/84-44-04 which was closed in inspection report 50-261/86-15. This item is close (Closed)
Inspector Followup Item 50-261/84-53-03:
This item on administrative controls and partial test acceptance associated with the execution of surveillance tests was encompassed by the review of inspector followup item 50-261/84-44-05, which was closed in inspection report 50-261/86-1 This item is close.
Plant Tour (71707, 62703, 71710)
The inspectors conducted plant tours periodically during the inspection interval to verify that monitoring equipment was recording as required, equipment was properly tagged, operations personnel were aware of plant conditions and maintenance activities, and plant housekeeping efforts were adequate. The inspectors determined that appropriate radiation controls were properly established, excess equipment or material was stored properly, and combustible material was disposed of expeditiousl During tours the inspector looked for the existence of unusual fluid leaks, piping vibrations, pipe hanger and seismic restraint abnormal settings, various valve and breaker positions, equipment clearance tags and component status, adequacy of fire fighting equipment, and instrument calibration dates. Some tours were conducted on backshift Plant housekeeping and contamination control were observed to be outstandin The inspectors performed system status checks on the following systems:
a. Safety Injection System b. Component Cooling Water System c. Auxiliary Feedwater System d. Vital Station Batteries e. Electrical Switchgear f. Chemical and Volume Control System g. Emergency Diesel Generators h. Security Power Systems No violations or deviations were identified within the areas inspecte.
Technical Specification Compliance (71707, 62703, 61726)
During this reporting interval, the inspectors verified compliance with selected limiting conditions for operation and reviewed results of certain administrative surveillance and maintenance activities. These verifications were accomplished by direct observation of monitoring instrumentation, valve positions, switch positions, and review of completed logs and record Specifically, the inspectors reviewed licensee records of changes to the facility as documented in annual reports to Region I This examination revealed that the 1986 report which provides a summary list of changes to the facility, as described in the FSAR pursuant to 10 CFR 50.59, was not submitted to the Regional Administrator as required in Administrative
- Procedure AP-030 (Revision 3) titled "NRC Reporting Requirements".
AP-030, paragraph 5.7, stipulates in part that "Regulatory Compliance will submit an annual report in July in conjunction with the Updated FSAR...
and that this summary report shall be submitted to the NRC Region II office..."
Licensee site personnel stated that AP-030 was not followed because site personnel erroneously assumed that the summary would be submitted by corporate staff personne After identification by the NRC, the licensee submitted the required summary on September 24, 198 Failure of the licensee to submit the annual report of changes to the facility to Region II within the required time frame as required by Administrative Procedure AP-030 is an example of failure to follow procedures and is identified as violation 50-261/86-26-0.
Plant Operations Review (71707, 62703, 61726, 61707, 61711)
Periodically during the inspection interval, the inspectors reviewed shift logs and operations records, including data sheets, instrument traces, and records of equipment malfunctions. This review included control room logs, maintenance work requests, auxiliary logs, operating orders, standing orders, jumper logs, and equipment tagout records. The inspectors routinely observed operator alertness and demeanor during shift changes and plant tour The inspectors conducted random off-hours inspections during the reporting interval to assure that operations and security were maintained in accordance with plant procedure The inspectors periodically verified the reactor shutdown margi The inspectors also periodically observed the reactor axial flux difference and compared the observed valves with those required by the T While the inspectors were in the control room at 6:06 on September 12, 1986, they witnessed the response of the fire brigade to an unannounced fire dril The simulated fire was located at the "A" Main Feedwater Pump. The inspectors witnessed the response of the fire brigade team leader (senior reactor operator on duty) as well as the actions of other operations personnel who were utilizing Fire Protection Procedure FP-001 (Revision 10)
titled "Fire Emergency".
The inspectors observed the starting of the motor driven fire pump from the control room and the donning of full turn-out apparel by all fire brigade member No violations or deviations were identified within the areas inspecte.
Physical Protection (71707)
In the course of the monthly activities, the Resident Inspectors included a review of the licensee's physical security progra The inspectors verified by general observation, perimeter walkdowns and interviews that measures taken to assure the physical protection of the facility met current
requirements. The inspectors routinely observed the alertness and demeanor of security force personnel during plant tour The performance of various shifts of the security force was observed in the conduct of daily activities to include; protected and vital areas access controls, searching of personnel, packages and vehicles, badge issuance and retrieval, escorting of visitors, patrols and compensatory post In addition, the Resident Inspectors observed protected area lighting, protected and vital areas barrier integrity and verified an interface between the security organization and operations or maintenanc During the inspection period, the inspectors continued to monitor the progress and activities of the HBR Security System Upgrade Projec The inspectors attended the September 17, 1986 meeting of the Security Project Implementation Task Force and determined that the licensee was pursuing corrective measures to previously identified followup items and facility improvements in the area of physical securit No violations or deviations were identified within the areas inspecte.
Monthly Surveillance Observation (61726, 61700, 71710)
The inspectors observed certain surveillance related activities of safety-related systems and components to ascertain that these activities were conducted in accordance with license requirement The inspectors observed portions of selected surveillance tests including all aspects of one major surveillance test involving safety-related system On September 18, 1986, the inspectors witnessed the conduct of OST-406 (Revision 1) titled "TSC/EOF/PAP Diesel Generator".
The purpose of this operational surveillance test is to assess the mechanical readiness of TSC/EOF/PAP Diesel Generato The inspectors determined that the operations personnel conducting this test used approved procedures, that all precautions and limitations were observed, that administrative approvals and tagouts were obtained prior to initiating the test, that testing was accomplished by qualified operations personnel, and that test data was accurate and complet The inspectors verified that the system was returned to servic During the conduct of this surveillance the inspectors observed that while the operator was attempting to raise and lower the engine speed, in accordance with step 7.1.10 of OST-406, the diesel tripped off on an overspeed conditio Prior to restarting, the operator verified all prerequisite conditions and contacted the shift forema Subsequent to this occurrence, the diesel was restarted and the test was completed without inciden The inspectors noted that the operator documented the abnormality on a work request to investigate the sensitivity of the governor raise/lower contro Until the licensee has definitively identified and corrected the cause of this overspeed trip, this item is
identified as an Inspector Followup item, 50-261/86-06-02;
"PAP Diesel Overspeed Trip".
The inspectors witnessed the conduct of MST-006 (Revision 1) titled "Reactor Coolant Flow Protection Channel Testing".
This maintenance surveillance test is conducted monthly to demonstrate the operability of the Reactor Coolant Flow Protection Channel Set I, II, and II As noted in the subject procedure, the successful completion of this surveillance test satisfies the requirements of TS Table 4.1-1, Item Additionally, the inspectors observed major portions of MST-013 (Revision 4)
titled "Steam Generator Water Level Protection Channel Testing".
The instructions contained in this procedure are designed to determine the operability of Steam Generator Water Level Protection Channel Sets I, II, and III and satisfy the requirements contained in TS Table 4.1-1, Item 1 During the performance of these surveillance tests, the inspectors determined that the test procedures conformed to TS requirements, that all precautions and limitations were met and that the surveillance tests were completed at the required frequency. The inspectors also verified that the required administrative approvals were obtained prior to initiating the tests, that the testing was accomplished by qualified personnel in accordance with approved test procedures and that the required test instrumentation was properly calibrate For those portions of the surveillance tests observed, the inspectors confirmed that the annunciators gave the proper status, that the associated alarms responded as required, and that the specified test voltages were within the required tolerance Upon completion of the testing, the inspectors observed that the recorded test data was accurate, complete and met procedural requirements; that there were? no test discrepancies; and independently verified that the system was properly returned to servic The inspectors also witnessed the execution of the weekly operability test of the emergency diesel, as it was performed on the "A" emergency diesel generator. This test was conducted using Operations Surveillance Test Procedure OST-401 (Revision 8) titled "Emergency Diesels - Weekly."
The test technician used the correct and current procedures and was qualified to perform the tes OST-401 is designed to verify the mechanical performance and operational readiness of the emergency diesels; and that the requirements of TS 4.6. and 4.6.1.4 are satisfied. With respect to tests and surveillances which are to be performed as stated, TS 4.6.1.1 requires a:.
"Manually-initiated start of the diesel generator, followed by manual synchronization with other power sources and assumption of load by the diesel generator up to the nameplate ratin Normal plant operation will not be affected."
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TS 4.6.1.4 requires that:
"Diesel generator electric loads will not be increased beyond the long term rating of 2500 kw."
The inspectors observed that the proper administrative approvals were obtained and that the required precautions were observe The inspectors noted that although the TS requires that this test be performed on a monthly basis, the licensee performs the test weekly in accordance with vendor recommendations. As part of the test, the operator verified the operation of the redundant solenoid valves on the "A" diesel prior to the engine star The
"A" diesel generator successfully completed the test requi rement Upon completion of the testing, the inspectors observed that the recorded test data was accurate and complete, and independently verified that the systems were properly returned to servic No violations or deviations were identified within the areas inspecte.
Monthly Maintenance Observation (62703)
The inspectors observed several maintenance related activities of safety-related systems and components to ascertain that these activities were conducted in accordance with approved procedures, TS and appropriate industry codes and standards. The inspectors determined that these activities were not violating Limiting Conditions for Operations (LCO's) and that redundant components were operable. The inspectors also determined (1)
that the procedures used were adequate to control the activity, (2) that required administrative approvals and tagouts were obtained prior to work initiation, (3) that proper radiological, and appropriate ignition and fire prevention controls were implemented, and (4) that replacement parts and materials used were properly certified. The inspectors verified that these activities were accomplished by qualified personnel using approved procedures. The inspectors independently verified that equipment was properly tested before being returned to servic The inspection emphasized the witnessing of the safety related maintenance activities associated with the disassembly, inspection, repair, and reassembly of the "A" diesel generator Lub Oil Heat Exchanger and the After Coolant Heat Exchanger. This activity was administratively controlled by a work request which delineated the scope of the job, tools required, and Q listed replacement materia The inspectors noted that the work progressed in an orderly manner, that the maintenance personnel involved appeared knowledgeable, that removed and replacement parts were segregated and controlled, and that when not required for maintenance, the standing ends of the heat exchanger flanges were covered to preclude the entry of foreign materia The inspectors independently verified that the equipment was adequately tested before being returned to servic *
Additionally, the inspectors reviewed several outstanding job orders to determine that the licensee was giving priority to safety-related maintenance and that a backlog which might affect its performance was not developing on a given syste No violations or deviations were identified within the areas inspecte.
Operational Safety Verification (71707)
The inspectors observed licensee activities to ascertain that the facility was being operated safely and in conformance with regulatory requirements, and that the licensee management control system was effectively discharging its responsibilities for continued safe operation by direct observation of activities, tours of the facility, interviews and discussions with licensee management and personnel, independent verification of safety system status and limiting conditions for operation, and reviewing facility record The inspectors observed licensee activities associated with an emergency exercise on September 16, 1986. This exercise scenario was based on a fire in a vital area, failure of the reactor to trip on demand, fuel damage and a subsequent loss of coolant accident. The inspectors witnessed the assembly of response personnel, the establishment of communications, the assessment of the simulated plant conditions, and the activation of the Technical Support Center (TSC)
and subsequently the Emergency Operating Facility (EOF).
No violations or deviations were identified within the areas inspecte.
ESF System Walkdown and Monthly Surveillance Observation (71710, 61726, 56700)
The inspectors verified the operability of the engineered safety features system by performing a walkdown of the accessible portions of the safety injection, residual heat removal and containment spray systems as prescribed by Operations Surveillance Test Procedure OST-158 (Revision 3) titled
"Safety Injection and Containment Spray Systems Flowpath Verification Monthly Interval (At Power)."
The inspectors confirmed that the licensee's system lineup procedures matched plant drawings and the as-built configuratio The inspectors looked for equipment conditions, maintenance status and items that might degrade performance (that hangers and supports were operable, acceptable housekeeping, etc.).
The inspectors verified that valves were in proper position, power was available, and valves were locked as appropriat The inspectors compared both local and remote position indication The inspectors noted that the current revision of the subject procedure was used by qualified operations personnel and that the monthly performance of this surveillance test satisfied the requirements of Section 4.5.2.2 of the TS which states:
"At monthly intervals during power operations each valve (manual, power operated, or automatic) in the safety injection (low and high pressure) and containment spray systeem flow paths that is not locked, sealed or otherwise secured in position shall be verified as correctly positioned."
The inspectors determined that the prerequisites for the performance of this surveillance test were performed and that all specified precautions and limitations were observe No violations or deviations were identified within the areas inspecte.
Onsite Followup of Events and Subsequent Written Reports of Nonroutine Events at Power Reactor Facilities (92700, 90714, 93702)
For onsite followup of nonroutine events, the inspectors determined that the licensee had taken corrective actions as stated in written reports of the events and that these responses to the events were appropriate and met regulatory requirements, license conditions, and commitment During this reporting period, the inspectors reviewed the following LERs to verify that the report details met license requirements, identified the cause of the event, described appropriate corrective actions, adequately assessed the event, and addressed any generic implication When licensee identified violations were noted, they were reviewed in accordance with enforcement Spolic The inspectors had no further comment LER EVENT 84-05 Safety Injection Circuit Testing 86-12 Low Pressure Reactor Trip No violations or deviations were identified within the areas inspecte.
Onsite Followup of Events at Operating Power Reactors (93702)
As documented in Inspection Report 50-261/86-07, the licensee received a violation associated with procedures and their execution concerning two reactor trips which occurred on January 15, 1986 and January 22, 1986. In a letter to the Regional Administrator dated June 2, 1986, the licensee acknowledged the violation and delineated corrective actions which the licensee implemente Among other actions, the licensee stated that it promulgated a program for reactor trip analysis which emphasized prevention of reactor trips. Key features of this program are included in Inspection Report 50-261/86-0 Subsequently, on August 25, 1986, Unit 2 experienced a reactor trip which was reported in Licensee Event Report LER-12. Briefly, the control operator opened, and inadvertently left open, the emergency boration valve in an attempt to stabilize reactor power at a lower level to match reduced feedwater flow caused by tripping of both heater drain pump The operators elected to avoid the use of control rods in order to avoid the accumulation
of axial offset penalty point For a period of about twelve minutes, the operators successfully restarted the drain pumps which would run briefly, then trip again. During this period, the emergency boration valve was left open causing an excessive boration of the reactor coolant system resulting in a rapid decrease in reactor powe Associated with the power reduction was a rapid primary system cooldown with a concurrent reduction in pressurizer pressure which was the direct cause of the reactor tri The inspectors continue to evaluate this use of emergency boration to stabilize reactor powe This is identified as unresolved item 50-261/86-26-03, use of emergency boration to stabilize reactor powe.
Organization and Administration (36700)
The inspectors reviewed the on-site licensee organization to ascertain whether changes made to the licensee's onsite organization are in conformance with the requirements of the TS by verifying that (1) the established organization is functioning as described in the TS is functioning effectively, (2) personnel qualification levels are in conformance with applicable codes and standards, and (3)
the lines of authority and responsibility are in conformance with TS and applicable
codes and standard Comprehensive discussions of current safety-related activities were conducted with plant management and technical personnel during this reporting period including, and in particular, Operations, Environmental and Radiation Controls, Quality Assurance, Requlatory Compliance and Onsite Nuclear Safety organizations. Topics discussed included licensee activities associated with plant operations activities; plant modifications, including the security system upgrade; the fire protection system; ongoing construction activities; emergency drills; and communications interface No violations or deviations were identified within the areas inspecte.
Onsite Review Committee (40700)
The inspectors reviewed certain activities of the plant nuclear safety committee (PNSC)
to ascertain whether the onsite review functions were conducted in accordance with TS and other regulatory requirement The inspectors (1) attended the regular monthly PNSC meeting held on September 17, 1986 and observed the conduct of the meeting, (2) ascertained that provisions of the TS dealing with membership, review process, frequency, qualifications, etc.,
were satisfied, and (3)
followed up on previously identified PNSC activities to independently confirm that corrective actions were progressing satisfactoril The inspection emphasized the review of revision 14 of the Emergency Plan, decontamination activities in progress, and a review of reactor trip No violations or deviations were identified within the areas inspecte.
Followup on Headquarters Requests (92704, TI 0110/3, TI 0110/4)
The inspectors reviewed the construction of the Independent Spent Fuel Storage Installation on September 12, 1986, by witnessing the placement of the Ram Mounting Slab which required about 12 yards of concret The inspectors noted that all required testing was performe No violations or deviations were identified within the areas inspecte.
TMI Action Items (TI 2515/65)
a.)
II.B.1.2 Reactor Coolant System (RCS)
Vent Installatio The inspectors reviewed the following licensee documentation to verify completion of work and operational status of equipment:
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NUREG-0737, Clarification of TMI Action Plan Requirements, November 198 Letter From:
Mr. S.A. Varga (NRR), To:
Mr. J.A. Jones (CP&L),
dated March 8, 1982; RSC Vents (Item II.B.1)
Request for Additional Informatio )-
Robinson TS Section 3.1. Safety Evaluation Report (SER)
From:
Mr. S.A Varga (NRR),
To:
M Utley (CP&L),
dated September 23, 1983; NUREG-0737, Item II.B.1 RSC Vents, H. B. Robinso CP&L Letter, File NPERO-168, From:
M R.L. Sanders, To:
M R. E. Morgan, dated January 4, 1984; RSC Venting (Mod 520)
Information to NR Letter From:
Mr. A. B. Cutter (CP&L), to: Mr. S. A. Varga (NRR),
Serial NLS 85-028, dated May 12, 1985; Request for TS changes associated with Generic Letter 83-3 SER From: G. Requa (NRR),
To: M E. E. Utley, dated August 29, 1985; Amendment (94) to Operating Licens Reactor Coolant System, Flow Diagram 5379-1971, Revision 2 CP&L Modification Package 520, RSC High Point Ventin The inspectors verified the operability of the RSC Vent Path by performing a walk down of the accessible portions of the syste The inspectors confirmed that the licensee's system line-up procedures matched plant drawings and as-built configuration, that the valves were in the proper position and that equipment changes were properly approved and controlle The inspectors also verified that preoperational testing had been performed and that the installation/modification of the RSC Vent Path System appeared
to meet the licensee commitments and applicable NRC requirements. This item is close b.)
II.B.1.3 RCS Vent Procedure The inspectors reviewed the following licensee procedures to verify program/procedure development and implementatio FRP-Response to Voids in Reactor Coolant System GP-001 Fill and Vent of the Reactor Coolant System OP-101 Reactor Coolant System and Reactor Coolant Pump Startup and Operation SD-001 Reactor Coolant System OST-703 ISI Primary Side Valve Test GP-002 Cold Solid to Hot Subcritical at No Load T-Aug OMM-0OS Minimum Equipment List TMM-004 Inservice Inspection Testing The inspectors determined that procedural changes were made, that necessary personnel training had been accomplished, and that operational procedures were being use It is noted that the licensee has receiveci approval on their proposed utilization of the RCS Vent Path System as described in paragraph 3.1.1.4., Amendment 94 of the T This item is closed.