IR 05000344/1989019

Insp Rept 50-344/89-19 on 890712-0808.Violations Noted.Major Areas Inspected:Licensee Actions Following Identification of Debris in Containment Recirculation Sump Prior to & Subsequent to Establishing Containment Integrity

ML20246H977
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	08/11/1989
From:	Mendonca M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20246H962	List: IR 05000344/1989019 ML20246H956
References
50-344-89-19, EA-89-162, GL-85-22, NUDOCS 8909050006
Download: ML20246H977 (11)

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.- U. S. NUCLEAR REGULATORY COMMISSION ')

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-1 g REGION V .j i

Report N /89-19 EA 89-162 q Docket N License N NPF-1 ,

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Licensee: Portland General Electric Company ,

121 S.W. Salmon Street, TB-17 l Portland, OR 97204 t Facility Name: Trojan j Inspection at: Rainier, Oregon Inspection conducted: July 12, 1989 - August 8, 1989 j

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Inspectors: R. C. Barr Senior Resident Inspector J. F. Melfi Resident Inspector Approved By: %- '

M. M. Mendonca, Chief Date Signed i Reactor Projects Section 1 ,

Summary:

Inspection on July 12 - August 8, 1989 (Report 50-344/89-19)

Areat Inspected: A special inspection of the Trojan Nuclear Power Plant. The inspection focused on licensee actions following the identification of debris in the containment recirculation sump, prior to and subsecuent to establishing containment integrity. Inspection procedures 30703, 37702, 71707, 71710, 92700, and 93702 were used as guidance during the conduct of the inspectio )

Results This inspection identified five apparent violations of regulatory requirements with respect to the containment recirculation sump. Weaknesses identified ;

included : (1) failure to assure appropriate management oversight of i significant plant activities; (2) failure to learn from previous plant l problems of a similar nature; (3) failure to assure design basis implementation through engineering and surveillance activities; and (4)

inadequate cleanliness controls for tne sum ' '

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DETAILS

1. Persons Contacted I

• D. W. Cockfield, Vice President, Nuclear C. Pm Yundt, Plant General Manager T. D. Walt, General Manager, Technical Functions -;

• D. L. Nordstrom, Acting Manager, Nuclear Ouality Assurance -

• R. P. Schmitt, Manager, Operations and Maintenance  :

• R. M. Nelson, Manager, Nuclear Safety and Regulation Department

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• A. N. Roller, Manager, Nuclear Plant Engineering

• D. W. Swan, Manager, Technical Services

• J. Singh, Manager, Plant Modifications l

• J. D. Reid, Manager, Quality support Services

• J. W. Lentsch, Manager, Personnel Protection  ;

• A. R. Ankrum, Manager, Nuclear Security

• R. E. Susee, Manager, Planning and Scheduling

• J. M. Anderson, Manager, Trojan Materials E. B. James, Outage Manager l

• P. A. Morton, Branch Manager, Plant Systems Engineering R. L. Russell, Branch Manager, Operations i T. O. Meek, Branch Manager, Radiation Protection l D. L. Bennett, Branch Manager, Maintenance '

S. A. Bauer, Branch Manager, Nuclear Regulation R. N. Prewitt, Supervisor, Quality Systems

• J. A. Benjamin, Supervisor, Quality Audit W. J. Williams, Regulatory Corrpliance Engineer

• J. D. Guberski, Nuclear Safety and Regulation Department Engineer

• R. K, Buckles, Regulatory Compliance Engineer D. O. Leslie, Quality Operations Engineer D. E. Kivi, Quality Operations Specialist ,

R. 5. Adams, Maintenance Engineer  !

J. B. Kramer, Work, Planning, and Refueling Coordinator L. D. Larson, Radioacti'e Waste Supervisor M. R. Morris, Plant System Engineer

• J. Westfold, Quality Operations Engineer

• P. Nelson, NBRD Engineer

• R. C. Snyder, Administrative Services Manager

• J. P. Fischer, PM/EA Branch Manager NP,C Region V Personnel

• A. D. Johnson, Enforcement Officer

• J. L. Crews, Senior Reactor Engineer l Bonneville Power Administration

" C. Milbrot

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LF The inspectors also interviewed and talked with other' licensee employeet

!- during the course of the inspection. These included shift supervisors, L reactor and auxiliary operators, maintenance personnel, plant technicians L;- and engineers, and quality assurance personne * Denotes those attending the exit intervie I Plant Status s On July 12; 1989, the facility wat in Mode 5 preparing to resume power j

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operation following the 1989 Refueling 0utage. At 1:13 pm.. July 12, 1989, via .the Emergency Notification System (ENS), the licensee, as )

. courtesy, notified the NRC that debris had bean found in the containment 1 recirculation sump (sump) on July 8, 1939, and an operability issue was j l being evaluated. On July 143 1986, n 6:10 am, the plant shiftedito Mode , j 4. On July. 14,1989,. at M25 pm, the licensee, via ?he ENS, notified .

the NRC that additional debris was found in tne sump. At M 55 am, the plant was returned to Mode 5 to' conduct equipment reptics. At 4:40 pm on July 17, 1989, the . licensee reported to the NRC Via the ENS that a j sump design deficiency hed been identified in that the sump top screen )

was not instelled. At 6:16 ata, on July 23, 1989, the plant shifted to 1 Mode 4 followed by 3 shift tc Mode 3.at 5:48 pm. At 1:35 ar, en Augu.,t 2, 1989,.the plant entered Mode 1 after shifting between Node 4, 3. and 2 {

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to evaluate equipment problems. At the conclu11on of this special inspection, the facility was' ascending to 100%. powe . Containment Recirculation Su g Description i

'j Trojan, a foursump recirculation loop described (Westinghouse reactor, in section utilites aofcontainment 6.E.2.2. the FSAR), a )

large collecting reservoir, to. provide an adequate supply of water with a j minimum of particulate matter to Emergency Core Cooiing Syst. ems (ECCS) i (Containment 5 pray, Residual Heat Removal, Safety.Imjection (SI), and High j Head'Injectiori Systems) daring the decign basis Loss of Coalant Acciden The sump provides water to de ECCX via two separate 18' suction lines :l that subdivide into 14" lines that provide the Containment Spray (CS) and Reu dual 41 eat &cmoval (RHR) System pumps. The Containment Spray p Wpc and the hesidual Heat Removal pumpt are single stage centrifugal pumps )

with rattd flow cf 2800 gpm and 3000 gpm, and horsepower of .500 )

horsepower and 400 ncesepower, respectively. When -in the recirculation 1

, mode, the ECCS may have the RHR pumps provfde water to the 51 and '

high head injection (centrifugal charging) pumps. These are multistsge pumps with a rated flow of 425 gpm and 150 gpm, and horsepower of 400 i horsepower and 699 horsepower, respectively. The sump's design includes  !

an enclosure consisting of trash racks, large mash screen and fine raesh 1 screen to ain si7e particulate matter that could enter and potentially damage the systems' components. Additionally, the design includes a screen j on the top of the enclosure to prevent debris from entering We sum '

l Containment Recirculation Sump Event Chronology i

On July 8,1989, while cunducting contaiuiaent cleaning as part of the j recovery from the 1989 Refueling Outage, the Radioactive Waste Supervisor  !

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found debris in the easily accessed areas of the containment recirculation )

l + sump and identified that debris was also located in a difficult to access i

" pipe ' chase" area, of thf sump. Prior to exiting containment, he directed j

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that the debris in the " pipe chase" be removed and contacted Quality Inspections to request r. heir involvement. Prior tc leaving the facility, he notified the Manager, Radiation Protection and_the.Mcnager, Operations {

and Maintenance that debris had been found in the sump and that it

. appeared that the debris-had been in'the sump for sometime. Subsequently, .i the debris was romoved and retained. A contract Qual $ty Control inspector 7 provided limited coverage (approximately 10 minutes) during removal of i the' D bris from the pipe chase. He concluded the debris had been in the j sump only since the 1989 Refueling Outage. Later. that 'aftcrnoon, a .i Quality Operations Inspector examined the debris romoved from the sum '

'He concluded tSe debris (a 2'x 3' flat iron bar metal frame, fiberglass and chalk insulation, metal banding and clips,. pens, a cpool of stain 1&ss steel wire, a bundle of stainless steel wire, a roli of duct t, ape, Masslin cloths, IB". wire tie wraps, weld rod stubs, and a section of i scaffolding) had been in the sump prior to the 1989 Refueling o utage and' .j considered that a reportobility issue existed. He shared his 6 observations- i and concerns with his supervisor on July 10, 198 On July 10, 1989, as part of a containment cleanliness inspection additional debris (1 roll of duct tape, 1 Masslin wipe cloth) was found and removed from the sump. On the morning of July 10, 1989, other members of Plant Management including the Vice President Nuclear were appraised of the debris found in the containment recirculation sum On the afternoon of July 11, 1989, 0;ality Operations discussed their i concerns about the debris found in the sump with ths. Compliance Engirge i The Compliarxe Engineer tietermined an internal event report was require On July 11, 1089, the Containmer.t Pre-Integrity Inspect 1on (a Mods 4 surveillance requirement that verifiec c9mplipoce of Trojan Technical Specification (T.T.S.) 3.5.3.1. "Each ECCS subsystem shall h'a oem0nstrated ,

operable") wo signed off as beirg completed per Administrative Orders (AO) 3-11, " Containment Access, Integrity, Evacuation, and Inspections " ]

Revision 2 At 10:00 am, Juh 12, 1989, a meeting was conducted to compile '

l information on the debris found in the sump and to determina how long it had been in the sump. At 1:13 pm, July 12, 1989, the licensee r6 ported to the NRC, as a courtesy via the Emergency Notification System (ENS), that debris had been found in the sump and that the need for an operability determination of Emergency Core Cooling Systems was being evaluated, On July 12, 1989, the Resident Inspectors visually evaluated the debris I found in the sump on July 8, 1989 for volume, size anp stape. The .)

observation generated operability and cleanliness inspection followup concerns. On July 13, 1989, at 3:45 am, the licensee established Containment Integrity in preparation for shifting to Mode Fcliowing a Read) for Startup Review implemented per A0-3-23, " Ready for Startup," Revision 7, and Management approval, the clant was shif ted to Mde 4, H6t Shutocwn, at 6: Vu an , July ,14,198 !

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.At 8:15 am, the Resident Inspectors requested, from the Plant Manager, authorization for containment entry to inspect the recirculation sum While reluctant to authorize the request because many previous licensee inspections had been conducted as part of the closecut process, he cooperated with the entry and inspection. At 9:30 am, on July 14, 1989, with the plant in Mode 4 the Resident Inspector, who was accompanied by a licensee Quality Operations inspector, a management representative, and a Radiation Projection Technician, evaluated the cleanliness in a portion of the sump (Inspection of the pipe chase was not conducted at this time).

The inspection identified debris (an unopened 50 count bag of 30" long nylon tie wraps, an 1/8" screw, 3-1/4" washers, 2-pop rivets, a weld rod stub, 2-loose nylon tie wraps, an insulation covering sheet metal band, and a 6" paper label). The licensee, when apprised of the additional debris found in the sump, initiated an event report, made a courtesy NRC Emergency l

Notification System report and conducted a critique to compile facts regarding the debris found in the sum Subjects mentioned during the critique were previous sump and ECCS cleanliness and foreign material exclusion concerns: 1) an RHR pump dambged by a piece of weld rod found between the impeller and the casing; 2) debris (a respirator, plastic protective clothing shoe covers, etc.) found in the sump during the 1988 Refueling Outage inspection; and-3) debris found in the sump during a November 1988 forced outag The Inspectors subsequently determined the debris believed to be found in the sump in November was actually found in the containment building drain sump in July 1988, as part of the 1988 Refueling Outage Closeout. The critique also considered the current 1989 Refueling Outage cleanliness inspections conducted prior to shifting Modes to Hot Shutdown. The critique also raised the question of what work had been conducted in the containment recirculation sump during the Outage. While the answer was not specifically known, it was thought that limited 151 inspections had been performed. The 11censee's immediate actions from the critique were to clean the sump, conduct a sump inspection with a " fresh set" of eyes, conduct an independent cleanliness verification, establish cleanliness criteria for containment and develop a Plan of Actio On July 15 and 16, 1959, the licensee formulated the " Refueling Outage Containment Closecut Action Plar,, AP 89-037." Procedures were also revised to provide more detailed guidance on performance of cleanliness inspection .

On July 17, 1989, the licensee conducted multi-discipline cleanliness walkdowns of containment. During the course of the walkdown and a review of the Final Safety . Analysis Report (FSAE), the licensee identified that a design requirement for fine mesh screening on the top of the recirculation sump had not been implemented. The licensee made an immediate NRC-ENS report and generated Nonconformance Report (NCR)89-355. Also, on July 17, 1989, due to a concern that a timely, detailed operability assessment of the sump was required, the Resident inspectors contacted the Mar,ager, Nuclear Plant Engineering to ascertain if the lf ctnsee was characterizing the material f ound in the sump by size, shape ,

6nd location. He indicated that a detailed characterization was in j progres j l

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.: On July 19, 1989, the Resident Inspectors conducted a cleanliness / design evaluation of the containment sump after having reviewed the FSAR, drawings and the Design Basis Documents (DBD's). The Inspectors found'

additional debris (3-weld rod stubs, miscellaneous stainless steel wire,

. 3-3/4" pipe fittings und tie wraps, and an approximately 1/2" to 1" thick o layer of boric acid crystals) in the pipe chase area, 2-approximately 4" diameter unscreened holes in the sump-Bioshield wall, tears .in. the fine mesh: screen, and large gaps between the pipes penetrating the trash racks,

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,, large mesh and fine mesh screens. The Inspectors shared their' findings on July 19, 1989, at 9:3D am with the the Nuclear Department Mechanical Branch Manager and requested a copy of the data being used to perform.the ECCS operability determination. The data provided the NRC Resident ,

. Inspectors did not have specific locations assignec nor was it a complete l and accurate' listing of the material found to date. That efternoon, the i

licensee performed a design walkdown of the sump and found additional debri On July 22, 1989, after extensive licensee efforts' to clean the sump and verify design features, the Inspectors again examined the sump for cleanliness and design feature compliance. No discrepancies were identified. The licensee established containment integrity per their procedure On July 25, 1989, the licensee contacted the Residents to obtain exact locations of the material fcund in the sump by the Inspectors. In this discussion the Inspectors learned that the licensee had not segregated the material found in the sump by each inspection but, were at that time, attempting to charecterire the material foun . Design and Design Inspection Requirements The containment' recirculation sump design includes the subcomponents of trash racks, course mesh screen, find mesh screen, and a top screen to i prevent debris from entering the sump. The oefinition of OPERABLE J requires auxiliary equipment that are required for the system, subsystem, I train, component, or device to perform its safety-related function (s) l to be capable of performing their rated support function (s). T. l 3.5.2. requires the two ECCS subsystems, which includes the sump, be j OPERABLE in Moce 1, 2, and During this inspection period, it was .

identified that the sump top screen screens around pipes penetrating -

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the sump, and the southern most fine mesh screen were missing or damaged l since startup from the 1988 Refueling Outage. This is an apparent j violation of T.T.S. 3.5.2.(50-344/89-19-01).

Regulatory Guide (RG) 1.82, " Sumps for Emergency Core Cooling and Containment Spray Systems," describes methods acceptable to the Regulatory staff for implementing requirements with regard to design, fabrication, cnd testing of sump or suction inlet conditions for pumps in the ECCS and CS system. For the most part, the sump design features ,

are in agreement with the Regulatory Guide even though Trojan did not I commit to RC 1.82, either in the FSAR or the Ouality Assurance Progra l To document the exceptions to the RG, PGE developed an "In-House" l position. The PGE "In-House" position for RG 1,82 takes exception to  !

sections C.1, C.2, C.4, C.7 and C.b; however, the licensee justified j these exceptions by alternative approache I

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, Section C.8. of the Regulatory Guide recommends a solid. top over the j PGE took exception to this design feature but justified the

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- sum exception by designing the top of the sump with 1/2"-trash rack bars and a 3/16" wire mesh scree In follow-up of'this event, the licensee j identified that the 3/16" screen probably had not been in-place since  :

197 It appears that when PGE developed their "In-House" position to RG  :

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1.82, no verification was performed to assure the screen was installe Section C.14. of the Regulatory Guide recommends " inspection for coolant sump components (trash racks, screens, etc.); and pump suction inlets' to 3 include coolant sump components inspection every refueling, and that' the j inspection be a visual examination of the components for evidence of  ;

structural distress or corros' ion." Because the sump is critical to .

safety duYing a design base loss of Coolant Accident, the requirement to j periodically verify the sumps operability as reconnended by RG 1.82 was l incorporated into Tecimical Specification i Trojan Technical Specification 4.5.2.d.2. requires- a verification of .

certain design features of the containment recirculation sump by stating

"Each ECCS subsystem shall be demonstrated OPERABLE at least once per 18 ],

months by a visual inspection of the containment sump and verifying that j the subsystem suction inlet lines are not restricted by debris and that sump components (trash racks, screens, etc.) show no' evidence of structural distre:,s ano corrosion."' To comply with T.T.S. 4.5.2.d.2., the licensee conducts closecut inspection of the containment sump per AD 3-11

" Containment Access, Integrity, Evaluation, and Inspections."

Since the Inspectors Tound additional debris subsequent to the completion of A0 3-11; Inspector follow-up included interviews with personnel assigned to perforn the sump closecut inspections for the 1989 Refueling Outag l The Inspectors concluded from these interviews that no licensee individual had accessed the recirculation sump as part of the closecut inspection effort. Due to a conmurication error, the inspection required -)

by A0 3-11 w3s not performed. This is an apparent violction of T. i 4.5.2.d.2. (50-341,/89-19-02). Additionally, due to a poorly human i factored sign-off sheet, the A0 3-11 form that documented the inspection I was incorrectly initialled as having been completed on July 11, 198 .)

This document was provided to the NRC inspectors on July 17, 1989. This is an apparent violation of 10 CFR 50.9 (50-344/89-19-03).

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The sump inspection required by A0 3-25, " Ready for Startup", was conducted

'by shining a flashlight through the screen into the sump vice entering the i sum In this instance the group conducting the cleanliness walkdown was j referred to as a " Management Walkdown Team" even though no PGE Managers were in the inspection group. The Inspectors also noted that subsequent i

to identifying the debris in the containment sump on July 8, 1989, and i

establishing containment integrity on July 12, 1989, that only one j supervisor and no managers accessed containmen [

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As previously stated, the Inspector en July 14,1989 found debris and gaps in the sump screens where piping per,etrated the sump trash rac'ks ano the fine and course mesh screens. Tne concern was shared with licensee on that da ,

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,. As discussed in section 4, the licensee determined that the containment recirculation sump deviated from its initial design in that the top of I the sump was not covered with 3/16" n>esh screening as stated in the Final Safety Analysis Report (FSAR) Section 6.5.2.2.2,5. In the review of this ,

event the inspectors noted that the Design Basis Document (DBD) for the j Containment Spray System also identified the top screens as sump design i feature but that the DSD effort to verify design feature did not identify the screens were not installed. The absence of a screened top section would allow debris to fall from above the sump through the the trash ]

racks into the sum J l

Also, as discussed in section 4, on July 19, 1989, the inspectors found additional design concerns in the pipe chase area. The inspectors noted that no System or Design engineers had accessed the sump area as part of l the Containment Pre-Integrity or Closeout inspection. The Inspectors i noted on July 22, 1909, that a 3/16" mesh screen had been placed on the top of the sump, the tear in the fine mesh screen had been repaired, the

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I openings in the screens where pipes penetrated were returned to design i condition and the two unscreened holes in the wall of the sump were j screene . Containment Sump Cleanliness and Cleanliness Inspection Requirements To ensure ECCS operability the cleanliness of containment, which includes i the containment recirculation sump, is periodically verifie The requirement to perform containment and recirculation sump inspection is implemented by T.T.S. 4.5.2.c. that states, "Each ECCS subsystem shall be demonstrated OPERABLE by a visual inspection which verifies that no loose {

debris (rags, trash, clothing, etc.) is present in the containment which '

could be transported to the containment sump and cause restrictions of the pump suctions during LOCA conditions. This visual inspection shall ;

be performed: 1) for all accessible areas of the containment prior to establishing containm'nt integrity; and 2) of the areas affected within 1 containment at the completion of each containment entry when containment l integrity is established."

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As pretiously discussed in section 4, the licensee generated an internal 1 event report on July 11, 1989, and informed the NRC on July 12, 1989, j that an operability concern was being evaluated as a result of having i found debris in the sump during a cleanliness inspection condscted on July 8, 1989. Also, as previously discussed, after the licensee had ]

j established containment integrity the Inspectors on July 14, 1989 identified

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loose debris in the sump and on the containment 45 foot level and again on July 19, the Inspectors performed an inspection on the sump which 4 ident1fied debris in the sump. To implement the surveillance requirement I of T.T.S. 4.5.2.c. the licensee conducts cleanliness inspections per A0 3-11, " Containment Access, Integrity, Evacuation, and Inspections."

As previously discussed in section 5, the inspection was not conducted ;

due to a communication error. This is an apparent violation of T. .5.2.c. (50-344/89-19-04). After the licensee's efforts to clean the sump and restore the original surrp design, the Inspectors performed another inspection on July 22, 1989, of the sump and pipe chast are fic further aebris was identified in the sump or pipe chase area, but a tie wrap anc some tape were identified by the Inspectors on the 45 ioot

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l.y L , 4 level of-containment under the "C" Safety Injection Accumulator. On .

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July 27, the. Resident Inspector and Regional Inspectors toured outside of the. containment sump area anu identified two pieces of tie wire and l:, a piece of heat shrinkable tubing on top of the sump encloswe screen.

! Finding the debris on July 27 on the top screen of the sump after the r

licensee had closed out containment emphasized the importance of having the top screen installed.

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Through followup inspection, the' Inspectors determined that there was no

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work done in the pipe chase area of the sump this outage that would account for. the debris found in the pipe chase area. Further, during the inspection of the pipe chase area on July 19 by the Inspectors, it was determined that the debris found was encrusted in the dried boric acid'

crystals in the pipe cha:;e. The Inspectors determined that the pipe chase area was flooded with borated water twice since the initial criticality of the plant, and that each instance was prior to the current plant outag . Design and Cleanliness Inspection Procedure Adequacy The specific guidance (criteria) given by A0 3-11 for the conduct of th'eseinspectionsiscontainedinSection4.4.5.,substepsa.1),a.6),

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b, and c, and states in part, "The inspection team shall perform the inspection '

as follows: Inspect for the following:

1) Any material that could potentially cause damage to equipment

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or cause flow obstruction in the ECC ) General areas for any boric acid on structures, components, or floor Visually verify that the recirculation sump suction inlets are not restricted by debri Visually verify that the recirculation sump components show no evidence of structural distress or corrosion."

Specific inspection criteria were not stated, to ensure that all areas of

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the sump were inspected or to ensure an acceptable level of cleanlines For example, the design of the sump screens preclude the entrance of foreign ;

matter greater than will pass through the 3/16" screen mesh, however, the cleanliness criteria does not incorporate that design requiremen Technical Specification 4.5.2.d.2 specifically identifies trash racks, screens, etc. be inspected. Because A0 3-11 did not identify specific components to be inspected, thorough consistent inspection of these components had not been performed as evidenced by the finding of damagea, torn, and missing screens. This is an apparent violation of 10 j CFR 50 Appendix B, Criterion V, that requires, in part, procedures to A have appropriate quantitative and qualitative acceptance criteria for determining that imoortant activities have been satisfactorily 6 accomplished (50-344/89-19-05).  !

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, 8. Previous Missed Opportunities To Identify Sump Deficiencies

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The Inspectors recogni?ed there had been previous opportunities that if fully researched and evaluated may have aided the licensee in determining ,

that deficiencies existed in assuring that technical specification, {

requirements associated with the containment recirculation sump were J being satisfactorily implemente !

l Facility records indicate that on May 29, 1980, the "B" Residual Heat Removal Pump was rendered inoperable by a piece of weld rod that was found between the pump casing ring and the impeller ring area. In i reviewing the Nonconformance Report (NCR) associated with the RHR pump ;

damage, the Inspectors were unable to determine if the source of the weld l rod was identified. 1he licensee is now attempting to determine if previous work on or adjacent to the pump may have introduced foreign meterial in the RHR system. If an exhaustive effort had been performed at the time of the pump failure to determine the source of the weld rod, an evaluation of the sump's cleanliness and design may have been considere l NRC Generic Letter 85-22, " Potential for Loss of Post-LOCA Recirculation l Capability due to Insulation Debris Blockage," notified the licensee of the concern insulation. Theoflicensee sump operability performed due to foreign Operational material, Review Assessment specifica'lly (0AR) i 86-18, dated May 30, 1986. The OAR concluded that fibrous insulation I breakup which could result in floating debris being potentially i tr6nsported to the sump was not a source of concern because at Trojan j reflective metal insulation was used on the primary coolant systems l piping and components. The OAR assessment did not include an evalustion i of the piping that penetrated the recirculation sump and was covered with !

fibrous insulation, nor was an inspection of the sump performed as a j result of the concer l l

In December 1987, the ' licensee performed a Design Basis Document )

reconstruction effort that included an evaluation by licensee engineers to ensure tests and inspection were being performed to ensure ECCS design I'

features were being verified. The review was not sufficiently detailed to identify sunp design deficiencie Licensee Quality Assurance Surveillance Report P182 conducted on July 8, ,

1988, identified that debris was removed from the containment i recirculation sump during the closecut inspection of the sump following !

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the 1988 Refueling Outage. The surveillance report noted that one l of the tools found in the sump had been checked out during the 1987 Refueling Outag In response, an NCR (88-126M) was generated. The NCR was closed out on January 1,198 The licensee identified th? root l causes of finding debris in the sump as: an accountability problem with workers and supervisors, a foreign material exclusion concern and an i adequacy of inspection concern. One of the recommendations by the Quality Assurance Organization was to revise procedures to include reference to T.T.S. 4.5.2.c. and to clarify inspection criteria. This recommendation was not incorporated into the corrective action Accitionally, the licensee, as a result of findin, the debris, did not reinspect the sump eith redefined inspection criteria.

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Also as previously mentioned, during the closeout of the containment from the 1988 refueling outage, the licensee also discovered debris in the containment drain sump that provided another opportunity to reconsider containment cleanliness and sump condition .

i 9. Exit Interview (30703)

The Inspectors met with the' licensee representatives denoted in paragraph 1 on July 28, 1989, and with licensee management throughout the i inspection period. In these meetings the Inspectors suranarized the scope l and findings of the inspection activities. The licensee stated that the {

identified deficiencies were a result of unacceptable personnel i performance of the system engineer and his supervisor by failing to l identify the deficiencies during the Design Basis Document effort. The licensee committed to reexamining the entire DBD effort. The licensee '

also noted that extensive and intense effort had been undertaken to ensure the sump n>et its desig j

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