IR 05000315/1985029
| ML17321A950 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 10/25/1985 |
| From: | Hehl C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17321A949 | List: |
| References | |
| 50-315-85-29, 50-316-85-29, CAL, NUDOCS 8511130233 | |
| Download: ML17321A950 (18) | |
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION III
Repor ts No. 50-315/85029(DRP)
50-316/85029(DRP)
Docket Nos.
50-315; 50-316 Licenses No.
Licensee:
American Electric Power Service Corporation Indiana and Michigan Electric Company 1 Riverside Plaza Columbus, OH 43216 Facility Name:
Donald C.
Cook Nuclear Power Plant, Units 1 and
Inspection At:
Donald C.
Cook Site, Bridgman, MI Inspection Conducted:
September 3,
1985 through September 30, 1985 Inspectors:
B.
L. Jorgensen J.
K. Heller C.
L.
Wo1fs en Approved By:
C.
W. Hehl, Chief Projects Section 2A Ins ection Summar
/~/4 b/ +S Date Ins ection on Se tember
1985 throu h Se tember
1985 Re orts No.
50-315 85029 DRP
. 50-316 850
~A:
R d
p i
b h
e i
p of licensee actions on previous inspection findings; operational safety verification; surveillance; maintenance; Confirmatory Action Letter; regional requests; and licensee event reports.
The inspection involved a total of 224 inspector-hours by three NRC inspectors including 25 inspector-hours off"shift.
Resu1ts:
Of the seven areas inspectedno vi,olations or deviations were
>dent>fied in six areas, while two violations were identified in the remaining area (Unit startup and operation with required safety equipment not operable-Paragraph 4. a; inadequate containment air lock test - Paragraph 4.c).
System testing to demonstrate/maintain required operability status is an area of concern relating to both violations.
Until further evaluation can be done in the area of establishing and controlling special plant conditions or prerequisites, that area continues to be of concern as well.
This inspection found no additional problems in the areas of flammable'aterials control and test documentation processes, though continued indications of "casual" documentation practices were seen in another recent inspection and cannot yet be de-emphasized.
PDR.
ADOCL(, 05000315
L
DETAILS 1.
Persons Contacted
~ M.
G. Smith, Jr., Plant Manager
" B. Svensson, Assistant Plant Manager T. Kriesel, Technical Superintendent
- Physical Science
~ A. Blind, Assistant Plant Manager
~ K. Baker, Operation's Superintendent
~ J. Stietzel, gu'ality Control Superintendent T. Beilman, Planning Supervisor J. Allard, Maintenance Superintendent
~ L. Gibson, Technical Superintendent
- Performance E. Murphy, Production Supervisor G. Caple, Administrative Compliance Coordinator - equality Control Department
~ J.
Sampson, Production Supervisor The inspector also contacted a number of licensee and contract employees and informally interviewed operation, technical and maintenance personnel during this period.
~Denotes personnel attending exit interview on October 1, 1985.
2.
Licensee Actions on Previousl Identified Items (Closed) Violations (315/84-19-03; 316/84-21-03):
Acceptance criteria were not included in applicable procedures to perform certain instrument channel checks.
The licensee's letter (AEP:NRC:0915) dated January 11, 1985 committed to revision of the cited procedures.
These actions have been accomplished, verified and the verification documented in gC Surveillance Report gC0-85-0217.
b.
C.
d.
(Cl osed)
Open Items (315/84-19-02; 316/84-21-02):
Procedures for RHR surveillance testing needed revision to assure mini-flow valve circuitry is properly challenged.
The procedures have been revised in such a way as to eliminate this concern, the revision verified, and documentation filed as gC Surveillance Report gC0-85-0407.
(Closed)
Open Items (315/84-19-05; 316/84-21-,05):
Adequacy of shiftly checks of auxiliary feedwater trip and throttle valve position for assuring pump/turbine operability.
The problems in maintaining the valve "latched" which originated this concern have not recurred.
(Open) Confirmatory Action Letter (315/85022-03; 316/85022-03):
See Paragraph 6.a. for a discussion of this ite r aJ I fl J
e.
(Open) Confirmatory Action Letter (315/85022-04; 316/85022-04):
See Paragraph 6.b. for a discussion of this item.
(Open) Confirmatory Action Letter (315/85022-05; 316/85022-05):
See Paragraph G.c. for a discussion of this item.
No violations or deviations were identified.
3.
0 erational Safet Verification b.
C.
d.
Both units were maintained in NODE 5 (Cold Shutdown) throughout the course of this inspection.
Unit 1 is in the late stages of completion of a scheduled refueling/maintenance/modification and testing outage which has been extended to correct potentially adverse seismic qualification conditions inside the containment.
This is discussed further at Item f. below and will also apply to Unit 2 before restart of that plant.
Unit 2 continues in an outage involving investigation and repair of primary-to-secondary leakage of steam generator tubes.
The inspector observed control room operation including manning, shift turnover, approved procedures and LCO adherence; and reviewed applicable logs and conducted discussions with control room operators during the inspection period.
Observations of the control room monitors, indicators, and recorders were made to verify the operability of emergency systems, radiation monitoring systems, and nuclear and reactor protection systems, as applicable.
Reviews of surveillance, equipment condition, and tagout logs were conducted.
Proper return to service of selected components was verified.
Tours of the auxiliary building, Unit 1 containment, and screenhouse were made to observe accessible equipment conditions, including fluid leaks, potential fire hazards, and control of activities in progress.
The inspector independently surveyed accessible areas of the auxiliary building using a Xetex 305B.,digital exposure rate meter (Serial number NRC 013166)
and verified that the readings were in agreement with the licensee's readings and that areas were posted as required.
A specific cleanliness tour of the Unit 1 upper containment was conducted on September 18.
Numerous items remained to be removed, repaired or secured.
A list was provided to the licensee representative assigned final containment closeout responsibility.
The licensee had not yet performed his own final inspections.
The inspector was notified on September 3, 1985 of the discovery of Unit 2 auxiliary building safeguards ventilation system damage in the form of open weld seams, leaking charcoal, and localized corrosion or water damage.
This matter was referred to NRC Region III specialists who performed a review and discussed appropriate corrective actions for the specific component problems identified, and further investigations to ascertain the breadth of the problems, with licensee representative e.
Mutual understandings reached in this matter are documented in IE Inspection Reports No.
315/85024(DRSS)
and 316/85024(DRSS).
On September ll, 1985 the licensee reported that wide-range reactor coolant system pressure transmitters (which had been replaced in Unit 1 during the current outage)
were being relied upon for their inputs to the low temperature overpressure protection system despite the fact they had not yet been declared
"operable" after installation.
The subject instruments are to open the power operated relief valves on a pressure transient, and had been relied on for this protection since September 5, when reactor coolant vents were closed.
The licensee completed the necessary reviews to declare the system "operable" immediately upon identification of the problem.
The system had passed a surveillance test, so the deficiency was administrative, not physical.
The inspector verified the associated Technical Specification Action Statement time limit (7 days)
was not exceeded.
The, subject instruments were among many which were replaced due to electrical equipment environmental qualification questions.
Numerous other instruments in the main control room, were tagged on September 10, 1985 (as were the subject instruments)...
This was, well after the work had been started.
No other examples of reliance on'nstrumentation 'of indeterminate status were identified.
On September 20, 1985 the licensee reported discovery of steel plates of questionable, seismic qualification being used to support safety-related electrical components in 'both Unit 1 and Unit 2 containments.
The plates were used as concrete forms in original construction of.the steam generator and pressurizer enclosures.
As such, there appears to have been no adequate analysis performed relating to the seismic capabilities of the plates.
The licensee has decided to anchor the plates now in such a way the seismic capability will be adequately 'assured rather than attempting to determine the exact nature of the existing anchorage and analyzing that for adequacy.
Thes'e repairs are extending the duration of the current Unit 1 outage and may hereafter affect the Unit 2 outage schedule as well.
On September 26, 1985, the inspector met with members of the plant staff and by telephone with members of the corporate staff.
The inspector was previously informed that a sample of the base plate was removed to verify,material composition.
Because the base material may not have been known the inspector asked if the correct weld procedure/material and appropriate non-des'tructive testing was performed when the safety-related electrical component supports were previously attached to the base plate.
The licensee acknowledged the inspector's concerns and identified a program that should verify if the supports were adequately attached.
No violations or deviations were identifie.
Survei 1 1 ance
~
~
The inspecto r 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 personnel.
a 0
""12 THP 4030 STP.229
"Control Room Emergency Ventilation System Filter Efficiency Charcoal and HEPA Filter Leak Test" and ""1 THP 6040 PER. 094
"Unit 1 Control Room Ventilation Balancing."
These were the activities conducted August 16 and 29 respectively, during which the problem with the Unit 2 con'trol room emergency ventilation system (discussed below) was created and later found.
The inspector's review focused on causative factors relating to the procedures and to corrective action approaches relating to these factors.
On August 29, 1985 the inspector was notified that in-progress testing of the Unit 1 control room emergency ventilation system had determined both the Unit 1 and Unit 2 emergency ventilation systems were incapable of performing as designed.
Upon investigation the Unit 2 fresh air intake damper was found fully closed, such that neither system could maintain adequate positive pressure.
The licensee's investigation indicated an error was made in adjustment of the Unit 2 fresh air intake damper following testing on that unit on August 16, 1985.
The subject damper is a two-position design, intended to be full-open in the pressurization mode and throttled to a pre-determined makeup setting in the cleanup mode.
Following testing on August 16, the actuator arm on the fresh air intake damper was erroneously set to the makeup setting for pressurization, and full-closed for cleanup.
The error remained undiscovered until August 29 in part because no functional check followed the final actuator arm connection adjustments.
Unit 1 remained in Mode 5 throughout the time period August 16-29, 1985.
Unit 2, however, entered Mode 4 at 0023 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> on August 19, 1985 and proceeded to Mode 1 by 1401 hours0.0162 days <br />0.389 hours <br />0.00232 weeks <br />5.330805e-4 months <br /> on August 21, 1985.
Power operation at up to about 30 percent full power then occurred until August 24, when the unit was shutdown due to primary-to-secondary leakage problems.
Node 5 was reached on August 25, at 0708 hours0.00819 days <br />0.197 hours <br />0.00117 weeks <br />2.69394e-4 months <br />, and continued through the remainder of this inspection period.
Pursuant to Technical Specification 3.7.5. 1 (both units) the control room emergency ventilation system is required OPERABLE in MODEs 1, 2, 3 and 4.
Because of system design, sufficient interaction exists between the two control rooms that the ability to maintain the specified positive pressure (per Technical
P I
I
Specification 4.7.5.1.e.3)
in one control room depends on correct conditions in the ventilation systems for both control rooms.
In the case described above, though neither system was OPERABLE, requirements to have an OPERABLE system applied to Unit 2 only.
Further, since the problem in system alignment was unrecognized, separate requirements of Technical Specifications involving not entering an operational Mode unless applicable system conditions are met (Technical Specification 3.0.4)
and requiring action to place the unit in a Mode where the Specification does not apply (Technical Specification 3.0.3) were both violated.
The licensee is performing an evaluation of safety significance for the Licensee Event Report being prepared on this matter.
NRC considers the described circumstances to be a Violation of Technical Specifications 3.0.3 and 3.0.4 for Unit 2. (Violation 316l85029-01).
""2 THP 4030 STP. 146
"Containment Pressure Protection Set I Surveillance (Monthly)."
""12 THP 4030 STP.204
"Personnel Air Lock Leakage and Interlock Surveillance Test" and ""12 THP 4030 STP.227
"Multiple Entry Personnel Air-Lock Leakage Surveillance."
These procedures were reviewed pursuant to a review of Unit 2 Control Room Logs, during which the inspector identified an apparent failure to comply with the requirements of 10 CFR 50, Appendix J.
The problem involved the means used to verify proper restoration (by test) of containment airlock integrity, following a period for which such integrity was neither required nor maintained.
According to the logs, Unit 2 was in Node 5 from July 16 through 30, 1985.
During this time (July 18 through 28) the licensee defeated the upper containment airlock interlocks to permit opening of the airlock (e.g.
both airlock doors open at the same time) and improve containment accessibility for a number of ongoing activities.
On July 27, the licensee resumed testing of the door seals on each airlock door via Procedure STP.227.
This testing, which is required for each entry (or each three days when there are numerous entnes)
is only required when containment integrity is required.
The seal testing was initially performed to demonstrate restoration of the airlock itself prior to returning the plant to Mode 4, where containment (and therefore, airlock) integrity is required.
When the airlock interlock was restored on July 28, the licensee considered containment integrity (at least insofar as affected by the airlock) to be re-established.
Procedure STP.204 was not performed.
Title 10, Code of Federal Regulation, Part 50 (10 CFR 50) Appendix J, concerning periodic retest scheduling, requires at III.D.2(b)(ii)
that "airlocks opened during periods when containment integrity is not required...shall be tested at the end of such periods at not less that P(a)."
Door seal testing may be substituted for a test of
d.
e.
the entire airlock only as specified in III.D.2(b)(iii),e.g., to demonstrate continuing integrity "... during periods when containment integrity is (emphasis added) required."
Thus, use of the door seal test in lieu of a test of the entire air lock for purposes of re-establishing integrity at the end of a period when the locks were open and integrity was not required, is contrary to the referenced
CFR 50 Appendix J, and is considered a violation.
(Violation 316/85029"02).
The violation reflects what had been standard licensee practice.
Immediately upon identification of the. licensee's apparent misunderstanding of these requirements, the inspector met with licensee representatives to assure the violation was not repeated in restoring Unit 1 to service.
The licensee had intended to rely on a test of the door seals, but agreed to change the applicable procedures, thus preventing a repeat violation.
~"1 OHP 4030.STP.034
"Local Valve Position Verification."
This procedure was reviewed in conjunction with Condition Report 1-09-85-1824, which identified interaction among the Target Rock pressurizer and reactor vessel head vent valves during performance of the test, such that a control signal was given to one valve to open and two valves opened in one case and three valves in another.
The inspector discussed this matter with selected licensee management as a known phenomenon involving valves of this manufacture if opened with a significant differential pressure across the valve.
Some licensee personnel were aware of the phenomenon, and in fact the procedure STP.034 states the testing should be performed with th'e RCS pressure below 80 psig.
This was d>scussed at the Management interview.
~"12 THP 4030 STP.228 "Engineered Safety Features Ventilation Performance Test."
This matter was reviewed in conjunction with identification to the inspector by licensee mariagement that the ventilation systems as designed are not capable of maintaining a
uniformity of airflow within 20%%u',
as specified by Technical Specification 4. 7. 6. 1. d. 2.
This was referred to the Office of Nuclear Reactor Regulation via the Licensing Project Manager, who consulted with the technical staff.
Their conclusion was that the intent of the Technical Specification would be met by introducing a
calculational
"penalty" into the determination of filter efficiency based on the degree of departure from the plus/minus 20K criteria.
The licensee had done this with satisfactory results.
Thus, a
technically adequate test has been performed, but the "letter" of the Technical Specifications (involving ANSI N510-1975 criteria) is inconsistent with the system design.
The.licensee needs to address this incompatibility to permit a condition of compliance to the
"letter" of Specifications.
Action to resolve this matter is considered an Open Item.
(Open Item 315/85029-01; 316/85029-03)
k Two violations and no deviations were identified in this are K fl I
Maintenance Station maintenance activities of safety-related systems and components listed below were observed and/or reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides and industry codes or standards and in conformance with Technical Specifications.
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; and activities were accomplished using approved procedures.
The following maintenance activities were observed:
Electrical equipment painting, Unit 1 Auxiliary Building 633 foot level
""12 MHP 5021. 019. 001 Maintenance Repair Procedure for Essential Service Mater Pump.
""12 MHP 5021.017.001 Rev 1 Maintenance Repair Procedure for Residual Heat Removal Pump.
Mhile observing maintenance work related to the two procedures stated above, the inspector noted that the cleanliness inspection hold point sign-offs were being omitted.
When questioned on this matter, licensee personnel pointed out that per Procedure PMI-2220, a new stamp on the job or der itself was replacing the sign-off in the actual procedure.
The inspector questioned the validity of removing the hold points from the procedure where they flag areas to be inspected before system closure, as opposed to having a single sign-off (though verified for Rating I, II systems) for cleanliness inspection on the job order.
This practice relies on thorough knowledge of PMI-2220 as the basis for system inspection, and results in documentation which is non-specific with respect to when (which step in the procedure)
the inspection was conducted.
This was discussed at the Management Interview.
The licensee expressed confidence in the level of training and qualification provided to those employees certified to perform the subject cleanliness inspections.
No violations or deviations were identified.
Confirmator Action Letter During this inspection, the inspector reviewed the licensee s activities and findings relating to a Confirmatory Action Letter (CAL) issued on August 30, 1985 to address licensee actions in response to several findings of an IE Headquarters Team Inspection conducted August 19-28.
The CAL addressed three specific items relating to surveillance activities, which were to be completed prior to placing the plant in a Mode in which specific Technical Specification surveillances were applicable.
On September 17, 1985, the inspector met with members of the licensee's Corporate and Plant staffs for the purpose of a briefing and
summary.
The licensee's representatives provided an overview of the program developed to implement CAL provisions, and then summarized the activities and findings of each involved Department for each of the below line items.
The inspector concluded the scope of the licensee's reviews exceeded that mandated by the CAL.
Findings may be summarized as follows:
a 4 b.
(Open) Confirmatory Action Letter (315/85022-03; 316/85022-03):
Conduct a review by both corporate equality Assurance and Plant organizations of all surveillances which are contained in tabular form in the Technical Specifications to ensure that the surveillance scheduling meets the Technical Specification requirements.
This item focused on timeliness of testing as to frequency or other scheduling requirements.
The licensee found some examples where test scheduling had potential omissions due to considerations beyond the scope of the CAL, but no additional cases of scheduling lapses within the area directly covered by the CAL were found.
The findings appearing to require some licensee action to correct or clarify the situation have been documented on Condition Reports.
This will also assure a review for reportability and safety significance.
(Open) Confirmatory Action Letter (315/85022-04',
316/85022-04):
Conduct a review by all departments of the surveillances which are contained in tabular form in the Technical Specifications to determine, for tests which are not the sole responsibility of a single department, that no omissions of test requirements exist and to determine which documents show how that responsibility is established.
C.
This item focused on completeness of testing, particularly where more thanone Department might be involved in accomplishing the various parts of the overall testing of a given system to show satisfactory system performance.
The licensee did not,find any examples of testing requirements being overlooked and therefore not performed.
Some examples of aspects of overall testing being accomplished "unintentionally", rather than by design, were identified.
Corrective actions will be accomplished for those items which fell in this category, where appropriate, to assure the intended Department is performing and documenting the activity, and to clarify inter-departmental interfaces and documentation/
recordkeeping responsibilities.
(Open) Confirmatory Action Letter (315/85022-05; 316/85022-05):
Conduct a review of Technical specification surveillances which involve calibration and time response testing of process sensors, and take actions to ensure that Technical Specification surveillance requirements are satisfied.
This item addresses potential deficiencies in the licensee's interpretation as to the meaning of process
"sensors",
and the possible exclusion of certain devices from the calibration and
L'
I
time response testing programs on the basis of the interpretation.
Discrepancies or questionable items are being addressed considering the individual technical and design considerations of the components in question.
Few remain to be resolved.
The major findings in this area involved calibration activities for the'reactor coolant system hot and cold leg thermocouples.
These were just replaced in Unit 1, during the current outage, with new factory calibrated sensors.
A means for performing "in situ" calibration of the Unit 2 sensors is being developed.
Pending completion of the few identified items already known to the licensee as requiring resolut'ion prior to MODE change, the licensee s
actions in performing to the stipulations of the Confirmatory Action Letter were considered satisfactory.
No violations or deviations were identified.
7.
~ll i 1R The inspector was asked to determine whether the licensee was using controlled drawings that depict correctly the actual location of the manual trip circuit, and to confirm that the manual trip circuits are located downstream of the output transistors in the undervoltage (UV)
output circuit.
a.
Background Information Notice No. 85-18 highlighted the effects of short-circuit failures of the output transistors in the UV output circuit of the Westinghouse Solid State Protective System (SSPS).
A short-circuit failure of the type described in the Notice would prevent the automatic tripping of the associated reactor trip breaker (RTB) on a valid reactor trip demand.
During the review of this matter, another potential deficiency involving the SSPS was discovered.
Namely, the use of erroneous controlled schematic diagrams of the SSPS at an operating facility.
Except for the drawings being used by the I&C technicians, the controlled schematic diagrams of the SSPS being used at that facility erroneously depicted the manual trip circuit for the RTBs as being upstream of the output transistors.
If such were the case, and if output transistors were shorted as described in Information Notice 85-18, then the manual trip action associated with the UV portion of the trip circuit would also be ineffective.
However, manual trip action would be provided by separate contacts on the manual trip switch that are wired directly to the shunt trip coils of the RTBs.
Westinghouse had informed the NRC that all domestic plants with SSPS were designed with the manual trip downstream of the output breakers.
II
I b.
Inspection Through discussion with the licensee and reviews of prints OP-1 and 2-98369-0,
"Solid State Reactor Protection and Safeguard System-Train A" and OP-1 and 2-98389-0,
"Solid State Reactor Protective and Safeguard System Tra'in B" the inspector verified that the manual trip circuits are located downstream of the output transistors.
No violations or deviations were identified.
8.
Re ortable Events Through direct observation, discussions with licensee personnel, and review of records, the following Licensee Event Reports were reviewed to determine reportability requirements were met, and corrective and preventive actions were accomplished in accordance with Technical Specifications.
The following LERs are considered closed:
Unit 1 RO 315/84004-0 RO 315/85016"0 Unit 2 The AFW pump turbine failed a surveillance test due to internal steam erosion and consequent pressure loss on steam needed to close the throttle trip valve.
A leak-off line was capped to retain adequate operating pressure as an interim measure.
~ Repairs to the eroded bushing and bonnet have been completed and a functional test will be performed prior to return to service during unit startup from the current outage.
Strict control of containment integrity was not maintained when, following a hydrostatic test of the RHR system, drain valves were opened concurrently both inside and outside the containment with the unit still in Mode 4.
The applicable Technical Specification Action Statement was not exceeded, in that Mode 5 was (coincidentally) achieved only 45 minutes later.
The test procedure was revised to include appropriate guidance and precautions.
RO 316/83100-03L The gauge protector on the east motor-driven auxiliary feedwater pump suction pressure trip switch became mechanically bound and rendered the pump inoperable.
The applicable Action Statement requirements were met, the gauge protector replaced, and the switch calibrated and verified to operate correctly.
The problem has not recurred since.
RO 316/83103-03L RO 316/83115-03L The CVCS letdown isolation valve gCR-301 failed a stroke timing test due to boric acid solidification in the stuffing box from a small leak.
The packing was cleaned, adjusted and the valve stroked satisfactorily.
Pressurizer pressure 'fell below 2205 psig just prior to a reactor trip from about 30K power due to over-feeding the steam generators.
Poor control room communications contributed, and were addressed in operator requalification training.
Limited pressurizer heater capacity due to undersized heater breakers (which have since been replaced)
may also have contributed.
RO 316/85004-0 One reactor coolant system cold-leg temperature RTD was discovered to be non-qualified environmentally pursuant to 10 CFR 50.49, because of a lack of qualification information on the RTD connection used in the installation about two months earlier.
The plant was operating at the time the discrepancy was identified, but tripped off line the following day due to unrelated causes.
The questionable RTD was replaced with a qualified device before plant restart.
A number of other non-qualified devices remain in service, but these have been evaluated and are covered under NRC-granted temporary exemptions to
CFR 50.49, as provided for in that regulation.
These will all require replacement before plant operation beyond November 30, 1985 unless an additional extension is granted by the Commission.
Operation with the non-qualified RTD not evaluated and approved by NRC was in violation of 10 CFR 50.49.
Since this matter was identified, reported, and corrected by the licensee and had minimal safety significance, no Notice of Violation is being issued.
One violation (for which no Notice of Violation is being issued - see above)
and no deviations were identified in this area.
9.
~0en Items U
Open Items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part, of the'RC or licensee or both.
An open'item disclosed during the inspection is discussed in Paragraph 4.e.
10.
Mana ement Inter view The inspector met with licensee representatives (denoted in Paragraph
above) following completion of the inspection on October.l, 1985.
The inspector summarized the scope and findings of the inspection as described in these Details.
The following were specifically addressed:
a.
The inspector stated the apparent Violations identified during the inspection for which a Notice of Violation would be issued (Paragraphs 4.a and 4.c).
b.
The potential for problems in performing and documenting appropriate post-maintenance cleanliness inspections, due to transition conditions while applicable procedures are revised, was discussed (Paragraph 5).
Licensee representatives remained confident their training and procedure use practices will minimize the potential for error.
C.
The inspector expressed satisfaction with the activities conducted by the licensee in implementing a Confirmatory Action Letter concerning review of surveillance activities, indicating the review process appeared to satisfy (or exceed)
the scope and depth specified.
Corrective actions and/or resolution of questions remain in a few cases (Paragraph 6) and may be reviewed further at a later date.
d.
The inspector indicated the licensee would be expected to take action to resolve an identified discrepancy in "testability" of ESF ventilation systems (Paragraph 4.e).
e.
The degree of control of pressure conditions for testing the reactor head and pressurizer vent systems was discussed, in light of the known sensitivity of these valves to differential pressure.
The licensee is continuing to investigate the cause of the unexpected valve behavior during the September 8,
1985 test.
The inspector also discussed the likely informational content of the report with respect to documents or processes reviewed.
The licensee was afforded the opportunity to identify any such documents/processes which might be proprietary, and none were so designated.
I 13