IR 05000416/1989019

Insp Rept 50-416/89-19 on 890715-0825.Violations Noted.Major Areas Inspected:Operational Safety Verification,Surveillance Observation,Maint Observation,Instrument Air Sys Walkdown, Action on Previous Insp Findings & ROs

ML20247G698
Person / Time
Site:	Grand Gulf
Issue date:	09/11/1989
From:	Cantrell F, Christensen H, Mathis J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20247G675	List: IR 05000416/1989019 ML20247G668 ML20247G679
References
50-416-89-19, NUDOCS 8909190125
Download: ML20247G698 (15)

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NUCLEAR REGULATORY COMMISSION REGION 11

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Report No.: 50-416/89-19 Licensee: System Energy Resources, In Jackson, MS 39205 Docket No.: 50-416 License No.: NPF-29 Facility Name: Grand Gulf Nuclear Station Inspection Conducted: July 15 through August 25, 1989 Inspectors:

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o ff) M e' r H.'0. Christensen, Tenio'r Resident Inspector

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J.'t. Mathis, Residpt ltrspsctor Date Signed Approved by: Ydg+f-[uf[ d

.F. S.'Cantrell, Sectio'n f

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9[/ [f9 Da'te Signed Division of Reactor Pro cts SUMMARY Scope:

The resident inspectors conuucted a routine inspection in the following areas:

operational safety verification, maintenance observation, surveillance observation, instrument air system walkdown, action on previous inspection findings, and reportable occurrences. The inspectors conducted backshift inspections on August 19, 20 and 22, 198 Results:

During the inspection period the plant had two reactor scrams one caused by a lightning strike and the other caused by a turbine trip on loss of condenser vacuum. During the turbine trip scram, one control rod failed to fully insert, a MSIV failed to close and the scram discharge volume did not vent and drai The corrective actions for the above problems were thorough and timely, (paragraph 3).

Within the areas inspected one violation with four e. samples for failure to follow procedure was identified. The first example was failure to install an iodine activity filter in the fuel handling area vent sample holder (paragraph 5), the second example is failure to perform the required engineering evaluations on instrument air samples (paragraph 6), the third example is failure to

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perform the semi-annual instrument air sample for 1989 (paragraph 6), and the final example is failure to transmit completed instrument air semple data to

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records management (paragraph 6).

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The above violation examples along with the post accident sample system violation (NRC inspection report 89-16) are an indication of lack of attention to detail by the Chemistry Departmen The licensee has committed to developing and implementing a diesel generator air start system sampling program, which will include air quality acceptance criteria. The licensee has implemented or plans to implement system improvements to instrument air; however, the deficiencies noted during the system walkdown indicates inadequate attention to a system important to safety.

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REPORT DETAILS Persons Contacted Licensee Employees J. Buckalew, Mechanical Superintendent, Acting J. G. Cesare, Director, Nuclear Licensing W. T. Cottle, Vice President of Nuclear Operations

• M. L. Crawford, Manager, Nuclear Licensing D. G. Cupstid, Superintendent, Technical Support L. F. Daughtery, Compliance Supervisor J. P. Dimmette, Manager, Plant Maintenance S. M. Feith, Director, Quality Programs

> *C, R. Hutchinson, General Manager GGNS F. K. Mangan, Director, Plant Projects and Support R. H. McAnuity, Electrical Superintendent A. S. McCurdy, Technical Asst., Plant Operations Manager L. B. Moulder, Operations Superintendent

- W. R. Patterson, Technical Asst., General Manager

• J. C. Roberts, Manager, Plant and System Engineering

• G. Smith, Superintendent, Chemistry S. F. Tanner, Manager, Quality Services L. G. Temple, I&C Superintendent .i F. W. Titus, Director, Nuclear Plant Engineering M. J. Wright, Manager, Plant Support J. W. Yelverton, Manager, Plant Operations

• G. A. Zinke, Superintendent, Plant Licensing Other licensee employees' contacted included technicians, operators, security force members, and office personne * Attended exit interview NRC Personnel Providing Inspection Assistance

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R. P. Carrion, Reactor Inspector, Division of Reactor Safety

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J. Menning, Senior Resident Inspector, Plant Hatch F. S. Cantrell, Section Chief, Division of Reactor Projects S. D. Ebneter, Region II Administrator, and F. S. Cantrell, Section Chief, Division of Reactor Projects, were on site August 22, 1989, to conduct a plant tour and to hold discussions with the resident inspectors and plant managemen . Plant Status At the beginning of the inspection period, the plant was operating at l 100 percent power. On July 22, 1989, the plant scrammed due to a lightning strike. The unit returned to operation on July 23, 1989. On August 14, L

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2 1989, the plant scrammed on a turbine . trip signal caused by a loss of-condenser vacuum. The loss of condenser. vacuum- caused by a failure of the condenser expansion seal. The unit retu, .sd to operation on August 23, 198 . Operational Safety (71707)

The inspectors kept cognizant of the overall plant status, and of any significant safety matters related to plant operation Daily discussions were held with plant management and various members of the plant operating staf The inspectors made frequent visits to the control room. Observations included the verification of instrument readings, setpoints and recordings, status of operating systems, tags and clearances on. equipment controls and switches, annunciator alarms, adherence to limiting conditions for operation, temporary alterations in effrt, daily journals and data sheet entries, control room manning. .and aceos controls. This inspection activity included numerous informal dis.:ussions with operators and their supervisor On.a weekly basis selected engineered safety feature (ESF) systems were confirmed operabl The confirmation was made by verifying that accessib'c valve flow path alignment was correct, power supply breaker and fuse status was correct, and instrumentation was operational. The following systems were verified operable: RCIC, HPCS, LPCI A, B and General plant tours were conducted on a weekly basi Portions of the control building, turbine building, auxiliary building and outside areas were visited. The observations included ' safety related tagout verifica-tions, shift turnovers, sampling programs, housekeeping and general plant conditions, the status of fire protection equipment, control of activities in progress, problem identification systems, containment isolation, and the readiness of the onsite emergency response facilitie The inspectors observed health physics management involvement and awareness of significant plant activities, and observed plant radiation controls. Periodically the inspectors verified the adequacy of physical security control The inspectors reviewed safety related tagout 893408 (CRD Suction Filter B) to ensure that the taglut was properly prepared, and perfortne Additionally, the inspectors verified that the tagged components were in the required position.

l The inspectors have noted that senior plant managers make routine tours of the plant and the control roo The inspectors reviewed the activities associated with the events listed belo _ - _

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On July 22, 1989, at 5:23 p.m. with unit 1 at 100 percent power, all eight APRM channels spiked high causing a reactor protection system actuation and a reactor scram. The most probable cause of the APRM spike was a lightning strike. A severe thunderstorm was occurring at the time of the scram. In addition to the APRM spikes, wide range reactor vessel level instruments spiked downward, a suppression pool water level low-low trip signal was generated and suppression pool hi/lo annunciator. alarmed. RCIC

' initiated on the water level instrument spike. The plant was stabilized and all. systems operated as designed. The plant was returned tn operations J on July 23, 198 On July 26, 1989, during the performance of the quarterly pump IST, the RHR ~ 'C' pump failed to develop the required differential pressure for rated flow. The plant aggressively pursued the problem and determined that the pump's flow element had been installed incorrectly during the last refueling outage. The flow element was installed correctly and the pump returned to service on July 29, 198 On August '4,1989., at 9:29 p.m., the Division III diesel generator tripped during the performance of the monthly functional test, P-1P81-M-0002-01.: The cause of the trip was due to a failure of the motor operated potentiometer in the governor control circuit. The potentiometer was replaced and the diesel generator was returned to L operation.

l l On August 14, 1989, at approximately 8:16 a.m., the control room received L an alarm for " Condenser Turbine A Expansion Joint Seal Level Low" and an l "Off Gas Panel Trouble" alarm. The control room operator responding to the alarm noted both narrow and wide range off gas flow recorders were upscale. ;The low pressure condenser vacuum was noted to be decreasing rapidly. The operator began reducing - power rapidly by closing the recirculation flow control valve. During the power reduction the turbine tripped from approximately 93 percent power thus resulting in a reactor p tri The turbine tripped on low condenser vacuum as a result of a pd ruptured seal (rubber boot) between the condenser and turbine. All control o rods inserted fully except rod 32-45, which inserted from full out to position'08. This rod was driven in manually without additional problems.

y Both recirculation pumps tripped as a result of the high pressure ATWS signal (pressure spike) generated when the turbine stop/ control valves fast closed to initiate the turbine trip. The main steam isolation valves were closed manually uefore the condenser vacuum decreased to the automatic closure setpoints. MSIV F022B failed to close manually and did not close until about- 10-15 minutes after the isolation signal was received as a result of low condenser vacuum. Safety relief valves were used to control reactor pressure until a mechanical vacuum pump was started. MSIV's were reopened and the condenser was used to bring the plant to cold shutdown. RCIC was manually initiated and secured without reactor level decreasing to the initiation poin The vent / drain valves t___________

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on the scram discharge volume failed to open to permit draining the SDV after the scram. Initially the scram signal could not be reset because the SDV could not be drained. The licensee investigated the failures L mentioned above and NRC Region 11 dispatched 'a Project Section Chief l

to assist the residents in monitoring the licensee action The licensee performed a series of tests to determine why the control rod L at location 32-45 apparently stopped at position 08 during the automatic scram on August 14. The associated CRD was initially stroked over its full range of travel, notched. and then stall flow tested. No anomalous performance was observed during this initial testing. A special instruction was developed to verify the scram outlet flow path of CRD 32-45. The intent of the instruction was to determine if the scram outlet flow path was clear of obstructions, if the disc and stem of HCU valves 102 and 112 were . attached and operable. On August 17, the inspector observed the performance of this special instruction; however, CRD internal seal leakage was high enough to preclude the detection of obstructions in the scram outlet flow pat This testing was considered to be inconclusive and the licensee proceeded with CRD friction testin The hydraulic flow testing showed that the scram discharge line was not blocked. This was also substantiated by radiographic examination that indicated the discharge manual isolation valves (V102, V112) were in the open position. The friction test data in the form of continuous insert and withdrawal, notching and collet finger actuations, were norma Problems with the CRD mechanism were not identifie The HCU for rod 32-45 was partially disassembled and visually inspecte The accumulator, scram pilot solenoid valve, check valves and scram valves were inspected, and no abnormalities were found. A sliver of material assumed to be Teflon from the outlet scram valve was found in the scram discharge ball check valve, however, the ball was free to move and the size of the Teflon was not large enough to cause a flow blockag A new solenoid scram pilot valve, stainless steel accumulator, both scram valve diaphragms and seats were replaced as part of the HCU refurbishmen Subsequent scram tests (two low energy, two normal pressure) demonstrated i that the CRD scrammed to its fully inserted positio To ensure opera-bility at reactor operation, this CRD was again scram tested at operating pressure during start-up satisfactoril The licensee's investigation of the failure of MSIV F022B to close focused on the performance of a 1/4 inch, three-way dual solenoid operated valve in the MSIV's control system,. Since the MSIV closed properly in the test mode, it was possible to eliminate other components within the control system. The subject solenoid operated valve was manufactured by the Automatic Switch Company (ASCO) and identified with Catalog No. HT8323A2 The solenoid operated valves associated with F022B and the other three inboard MSIV's were initially removed, disassembled, and visually inspecte I

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Initial visual inspection revealed no abnormalities which could explain the failure of F022B to close. However, closer examination revealed that the elastomer (EPDM) seal, which was forced against the metal seat, extruded into a small diameter vent hole at the center of the metal seat of the solenoid valve. As the elastomer was heated by the energized

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coils, the elastomer material expanded and plugged the hol Friction

[. force between the extruded seal material and the metal wall of the hole was i greater than the force of the return spring. Therefore, the internal components could not shift position and the solenoid valve malfunctione Elastomer degradation was found in all eight MSIV solenoids; the solenoids on all eight MSIV's were replaced. Based on the licensee environmental conditions, the inboard and outboard MSIV solenoids were considered to have a qualified life expectancy of 5.9 and 8.6 years, respectively. The solenoids had been in service approximately four year A separate evaluation by ASCO, recommended that the elastamer seals in these solenoid valves be changed at an interval of no longer than 2.8 years. A detailed evaluation is underway to determine the root cause of the even The scram discharge vo Nme failed to drain following resetting the initial reactor trip, the SDV did not drain because one redundant valve in both the SDV drain (F011) and vent (F010) lines failed to open. These valves are " spring to close" and " air to open". Examination showed that a throttle valve in the air supply to these two valves was closed. The normal position for this valve (a 1/2 inch "T" handle valve) is one-eighth turn ope The licensee stated that they had not been able to determine positively why this valve was closed but believe that someone may have brushed against the handle and closed the valve. The valve handle turned freely and'was not locked / wired in position. This valve is on the valve lineup sheet and was indicated to be properly positioned for startup from the third refueling outage (April 1989). Operators are in this general area once per shift to blow down instrument air line I&C mechanics are in this area periodically for instrument air calibrations but maintenance records do not show any work since May 1989. The licensee has locked / wired the valve open in the proper position, placed a warning label on the valve and decontaminated an access area to reroute traffic around this valv l Additionally, the licensee is conducting a " walk-thru" to determine if I there are other valves with potential problem To resolve an issue at the time of plant licensing, redundant series vent and drain valves with separate air supplies were installed for the scram discharge volume. The licensee has agreed to review previous correspondence on this subject and present their recommendations to the NRC. The reevaluation of the scram discharge volume vent and drain design will be an inspector followup item (89-19-04).

l Following the turbine trip (fast closure of the stop/ control valves),

both recirculation pumps trippe During a restart of recirculation l

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punip A, the flow control valve (FCV) was opened to 38 percent and the valve tripped on a servo erro In addition, the hydraulic power unit tripped while resetting the A FCV motion inhibit circuit. A similar problem was experienced during startup following the third refueling outage in May 198 I&C cleaned the edge connectors on the control card and the valve positioned properly (same corrective action as used in May 1989 event). The licensee is evaluating to determine if this type problem is generic to other cards or is' isolated to this particular car No violations or deviations were identifie . Maintenance Observation (62703)

During the report period, the inspectors observed portions of the maintenance activities listed below. The observations included a review of the MW0s and other related documents for adequacy; adherence to procedure, proper tagouts, technical specifications, quality controls, and radiological controls; observation of work and/or retesting; and specified retest requirement MWO DESCRIPTION ME5533 Clean PSW side of drywell chiller condenser B001 !

M94631 Clean / replace cooling coil for containment coole Install jacks required for jumpering scram circuitr E95110 Change MSIV solenoid F028A E95109 Change MSIV solenoid F028B E95108 Change MSIV solenoid F028C E95107 Change MSIV solenoid F028D E95017 Change MSIV solenoid F022B E95064 Change MSIV solenoid F022C E9506 Change MSIV solenoid F0220 E95065 Change MSIV solenoid F022A M95012 Inspect condenser expansion joint for leaks (B007B)

M95008 Inspect condenser expansion joint for leaks (B007A)

195011 Replace Bailey positioner

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The inspectors witnessed the work activity (M95012 a'nd M95008) associated with the replacement of the expansion seal for condenser A, B and Inspection of the failed section of the condenser expansion joint indicated that either a manufacturing defect and/or flex and wear at the lower ~ joint clamp location resulted in an opening in the outer protective rubber covering on the water side of the expansion joint. This exposed the reinforcement fabric in the expansion joint to water resulting in the rotting of the fabric. The rotten fabric weakened the expansion joint and resulted in the rupture of the join The replacement of the condenser expansion joints is a short term corrective action. To address the long term corrective actions an investigation has been initiated to obtain industry experience on condenser expansion joint failure, inspection frequency and criteria for replacement frequency, and size (thickness)

utilize Preliminary indication of the investigation suggests that in addition to the visual inspection and durometer reading, a replacement frequency should be added to the condenser expansion joint inspection / replacement criteri No violations or deviations were identifie . Surveillance Observation (61726)

The inspectors observed the performance of portions of the surveillance listed below. The observation included a review of the procedure for technical adequacy, conformance to technical specifications and LCOs; verification of test instrument calibration; observation of all or part !

of the actual surveillance; removal and return to service of the system ;

or component; and review of -the data for acceptability based upon the acceptance criteri IC-1C71-M-2002, Turbine Stop Valve Trip Fluid Low Pressure (RPS/E0C RPT) Channel CH-1D17-W-0017, Gaseous Release Points I-131, 1-133, Tritium, and Particulat <

06-0P-1821-V-0001, MSIV Operability Test, Attachment RE-SC11-V-0402, Control Rod Scram Testing, Rod 32-4 On July 26, 1989, during performance of Chemistry Surveillance Procedure 06-CH-1D17-W-0017, Revision 28, the licensee discovered that the fuel handling area vent particulate and iodine sampler did not have the filter in the cartridge for the period of July 19 through July 26, 198 '

Technical Specification requirement 4.11.2.1.2 and Table 4.11.2.1.2-1 requires a continuous sampling of fuel handling area vent for iodines and particulat Step 5.4.3 of procedure 06-CH-1D17-W-0017, instructs the licensee to remove the filter holder from the quick disconnect and install I

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. s the new filter ' holde Step 5.1.2, for preparation of filter holders, requires the installation of.a clean filte The chemist did not assure that the new filter holder contained the filter and as a result continuous sampling of fuel handling area vert for iodine and particulate was not achieved .over a .seven day period. This is a violation of TS 6.8.1 for failure to follow procedures (89-19-01).

6.- Instrument Air System Walkdown The inspectors conducted a walkdown on selected portions of the instrument air system. The walkdown consisted of the following: confirming that the system lineup procedure matches the plant drawing and the as-built configuration; identifying equipment condition and items that might-degrade plant performance; verifying that valves in the flow path are in correct positions as required by procedure and that local and remote position indications are functional; verifying the proper breaker position at local electrical boards and indications on control boards; and verifying that instrument calibration dates are curren The inspectors walked down the system using system operating instruction 04-1-01-P53-1, Instrument Air System, and piping and instrument diagram (P&ID)' M-1067A through Additionally, the inspectors reviewed the response to Generic Letter 88-14; Instrument Air Supply System Problems

'Affecting Safety-Related Equipment; the system technical manuals; the preventative maintenance program; and the instrument air sampling progra The' system walkdown identified the following deficiencies:

- S0I 04-1-01-P53, Attachment V, page 2, Valve FZ745 is incorrect, the valve'is labeled FZ743 and P&ID M-1067G indicates FZ743 for the Dew point analyzer isolation valv Dew point monitor 2P53MIR040 was in alarm and had a deficiency tag dated May 4, 1989. Monitor IP53MIR040 had an MWO issued, but its deficiency tag was missin '

- 22 valves on Unit I and 2 instrument air drier system had their packing glands or valve stems painte Unit 2 instrument air compressor had several oil leak Electrical breaker 52-154123, Instrument air supply to ADS receivers,

+ was labeled incorrectly.

l_ The correction of the above items will be inspection followup item (89-19-02).

The instrument air systems electrical lineup, and annunciators were in accordance with the system operating instruction. The review of the

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maintenance planning and scheduling system for instrument air. identified the following deficiencies: l E - Non-maintenance work centers (operations and chemistry) failed 'to update the planning and scheduling system for completed maintenance task CH1202 and OP1098.

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- Dew point monitors, IP53-MI-R040 Ed 2P53-MI-R040, were not included into the PMS progra General maintenance instruction, 07-5-14-26, 011 Change for the o Centac Centrifugal Compressors, has steps that require the installa-tion of an oil drain line and isolation valv The step was a one E time requirement and should have been delete The correction of the abcVe items will be additional examples of inspector followup item 89-19-0 Chemistry procedure, 08-S-03-10, Chemistry Sampling Program, requires an instrument air sample semi-annually for condensible hydrocarbon, dew point and particle siz The requirements are condensible hydrocarbon less than 1 ppm; dew point -40*F; and particle size less than 1 micro Procedure 08-S-04-24, Determination of Condensible Hydrocarbons, and Procedure 08-S-03-21, Sampling Instrument Air Supply to ADS, are used to meet this requirement. Procedure 08-S-03-21 acceptance criterion for particle size is one particle 50 microns or large This differs from the sampling program procedure requirement Additionally, Procedure 08-S-03-10 requires that nuclear plant engineering be notified of the sample results and that an engineering evaluation be performed within seven days if the results did not meet design specifications. Procedure 08-S-03-21, Step 6.7, requires, that if the results are above specifications listed, initiate a MNCR with a 7 day revie During the period October 1986 to October 1988, seven instrument air samples were taken, all seven samples failed the acceptance criteri Only three MNCRs were generated to address the sample results and the evaluations did not meet the 7 day evaluation period. Failure to perform the required engineering evaluations and within the reouired time period on the instrument air samples is an example of violation of T.S. 6. (89-19-01). A review of sample data sheets indicated that the sample results were not transferred to plant files as required by Procedure 01-S-05-1, Nuclear Records Procedur Procedure 01-S-05-1 requires plant records be delivered to the records management no later than 80 days. The 1988 records were not delivered to the record management. This is another example of violation 89-19-01. The semi-annual sample for instrument air for 1989 had not been taken as of August 4,1989. Discussion with the chemistry department indicated that the task card had not been issue Failure to perform the required semi-annual instrument air sample per Procedure 08-S-03-10 is another example of violation 89-19-01.

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In response to Generic Letter 88-14, the licensee has taken several i stens to improve instrument air qualit The plant has installed a l'

3 micron filter in the ADS filter bypass line, and installed dew point monitors on the outlets of the instrument air dryers. Additionally, a DCP (87/0047) is being developed to install the 3 micron filters and filtered bypass lines at corrosion resistant branch lines for safety related component The licensee will also develop an instrument air quality standard, an air quality test program and implement an inspection and maintenance program for component filters and regulator These programs are scheduled to be completed by the end of Decenter 198 A review of the February 1,1989, samples for the Division I diesel generator Division starting air indicated poor quality for hydrocarbons, 2.4 ppm and particles,1142 particles greater than 50 microns. The Air System Design Review dated February 14, 1989, states that Circle Seal Controls solenoid valves require filtration of all particles 10 microns or larger. The diesel air supply does not meet this requirement. Additionally, the design review recommoded the implementation of procedures for sampling the air quality of the starting air systems for the diesels and establish acceptance criteri The establishment of the above program will be an inspector followup item (89-19-03).

The deficiencies noted in the instrument air system do not cause an operability concern at this time; however, they do demonstrate the lack of attention placed on a system important to safet . Reportable Occurrences (90712 & 92700)

The event reports listed below were reviewed to determine if the informa-tion provided net the NRC reporting requirement The determination included adequacy of event description and corrective action taken or planned, existence of potential generic problems and the relative safety significance of each event.- Additional, inplant reviews and discussions with plant personnel as appropriate were conducted for the reports indicated by an asteris The event reports were reviewed using the guidance of the general policy and procedure for NRC enforcement actions, regarding licensee identified violation (Closed) LER 88-12, Reactor Scrm Induced by Lightning Strikes Affecting Neutron Monitoring Syste On July 22, 1989, the unit scrammed due to a lightning strik The will be administratively closed and the corrective actions will be tracked under LER 89-1 (Closed) LER 88-13, Reactor Scram Due to Tag-Out Error. The event was discussed in NRC inspection report 88-19. The LER will be administratively closed and the corrective actions will be tracked under violation 88-19-01.

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(Closed) LER 88-14, Reactor Water Cleanup I;,olation on High Delta Flo The event was discussed in NRC inspection report 88-19, paragraph 7. A RWCU isolation occurred on May 8,1989 and is documented in LER 89-0 LER 88-14 will be administratively closed and the corrective actions tracked under LER 89-0 (Closed) LER 88-16, Unanalyzed Conditions May Exist During Load Movements Over Irradiated Fuel. The licensee determined that there existed situations during cold shutdown and refueling where certain loads normally handled nyer irradiated fuel were not bounded by events analyzed and not restricted by administrative control The licensee has implemented administrative controls to cover the unanalyzed conditions and have submitted a technical specification amendment to enforce the administrative controls. This item is close (Closed) LER 89-06, Reactor Scram on Low Water Leve The event was discussed in NRC inspection report 89-14, paragraph 3. The system operating instruction for the feedwater system was revised, system design changes are being evaluated and the operators were trained on the operatic.i of throttleable valves and the RFPT reset logic. This item is close (Closed) LER 89-09, RWCU/RCIC I 21ations and Delinquent LCO Action Due to Personnel Errer. The event was discussed in NRC inspection report 89-17, paragraph 3. This LER will be administrative 1y closed and the corrective actions will be tracked under violation 89-17-0 No violations cr deviations were identifie . Action on Previous Inspection Findings (92701,92702)

(Closed) Inspector Followup Item 87-19-01, Illegible Figures in Instructions. The licensee's plant licensing group conducted a review of all . maintenance procedures / instructions to determine the magnitude of the issue and concluded that illegible figures were common, especially in I&C instructions. However, after meeting with !&C and Maintenance Engineering supervision to determine the impact of this issue on the craft personnel actudly performing the work, it was determined that this issue had no detrimental effect on the craft's ability to complete its work. The figures are used basically for general information. If accurate detailed information is required, it is listed in the reference section of the procedure / instruction. Furthermore, if questions remain,

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the craft has been instructed to contact engineering before continuing wor Also, the Plant . Administrative Procedure 01-S-02-3, Author's Guide," has been modified to add a new entry to the checklist which specifically addresses the legibility question of figures and charts appearing in the new procedure / instruction. Finally, the quality programs group has reviewed the procedures / instructions for illegible i

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figures, trying to improve their quality by redrawing them or by making clearer reproductions. However, this cannot be done for all figures due to their complexities and large number of man-hours needed for redrawin The licensee has taken positive steps to address the concerns raised by this item. Therefore, this item is close (Closed) 87-21-01, Unresolved Item. Adequacy of Maintenance Documentatio The eight items identified in this unresolved item were individually addressed in a memo from the Operations Department to the file, dated May 10, 1989. The explanations presented were satisfactory. However, one error was noted. Item No. 5 refers to MWO 54601. After checking with the maintenance staff, it was determined that there was a typographical error and that the correct number should be 54610. This item is close (Closed) 89-14-01, Violation. Removal of Contaminated Area Boundary without Proper Authorizatio The licensee initiated Radiological Deficiency Report No. 89-04-017 to document the incident, including corrective action taken and recommended. Also, the General Manager issued a memo to all plant personnel emphasizing the importance of observing and complying with all radiological posting and barriers throughout the plant. Finally, to impress upon the subcontractor whose workers were at fault that this issue is viewed seriously by management, the maximum penalty, pursuant to contractual provisions, was deducted from their outage schedule bonu Taken together, these actions demonstrate the licensee's strong commitment to employee protection against radiological hazards. Therefore, this item is close . Exit Interview (30703)

The inspection scope and findings were summarized on August 25, 1989, with those persons indicated in paragraph 1 above. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspecters during this inspection. The General Manager couraitted to developing a diesel generator air sampling program and stated that design changes are being considered for the diesel air start syste Item Number Description and Reference 89-19-01 Violation Failure to fellow procedure, four examples, iodine activity filter not installed, engineering evaluations not performed, semi-annual air sample not performed, and chemistry records not delivered to records managemen IFI Instrument air walkdown item {

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89-19-03 IFI Diesel- generator air sample progra IFI Reevaluate the scram discharge volume vent and'

drain desig . Acronyms and Initialisms ADHRS- Alternate Decay Heat Removal System ADS -- Automatic Depressurization System APRM - Average Power Range Monitor ASCO - Automatic Switch Company CRD - Control Rod Drive DCP -

Design Change Package DG -~ Diescl Generator ECCS - Emere ncy Core Cooling System EPDM - EthySene Propylene Diene Monomer

~ESF - Engiptering Safety Feature FCV - -Flow Control Valve HCU - Hydraulic Control Unit HPCS - High. Pressure Core Spray HPU - Hydraulic Power Unit I&C -

Instrumentation and Control IFI - Inspector Followup Item IST -

Inservice Test LC0 - Limiting Condition for Operation LER .

Licensee Event Report LPCI - Low Pressure Core Injection LPCS - Low Pressure Core Spray MNCR - Material Nonconformance Report MWO' - Maintenance Work Order NPE - Nuclear Plant Engineering NRC - Nuclear Regulatory Commission PDS -

Pressure Differential Switch P&ID - Piping and Instrument Diagram PSW -

Plant Service Water QDR - .

Quality Deficiency Report RCIC - Reactor Core Isolation Cooling RHR -

. Residual Heat Removal RPS - Reactor Protection System RWCU - Reactor Water Cleanup RWP - Radiation Work Permit i SBLC - Standby Liquid Control SDV - Scram Discharge Volume SERI - System Energy Resource, In S0I - System Operating Instruction SSW - Standby Service Water TCN - Temporary Change Notice TS - Technical Specification l

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