ML14181A563

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Insp Rept 50-261/94-15 on 940424-0521.Violations Noted.Major Areas Inspected:Operational Safety Verification,Surveillance & Maint Observation & Followup
ML14181A563
Person / Time
Site: Robinson 
Issue date: 06/15/1994
From: Christensen H, Ogle C, William Orders
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML14181A561 List:
References
50-261-94-15, NUDOCS 9406290032
Download: ML14181A563 (14)


See also: IR 05000261/1994015

Text

64p8 REG&

UNITED STATES

0,

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTA STREET, N.W., SUITE 2900

ATLANTA, GEORGIA 30323-0199

Report No.:

50-261/94-15

Licensee:

Carolina Power and Light Company

P. 0. Box 1551

Raleigh, NC 27602

Docket No.:

50-261

License No.: DPR-23

Facility Name: H. B. Robinson Unit 2

Inspection Conducted: April 24 - May 21, 1994

L e a d I n s p e c t o r :

A S

o

e

n I s e t

D e

W. T. ders, SeniorResident Inspector

Date Si ned

Other Inspector:

C. R.]le, Residen Inspector

D te

igned

Approved by:

'----

"

H. 0. Christensen, Chief

Date Signed

Reactor Projects Section 1A

Division of Reactor Projects

SUMMARY

Scope:

This routine, unannounced inspection was conducted in the areas of operational

safety verification, surveillance observation, maintenance observation, and

followup.

Results:

One violation with three examples was identified dealing with the licensee's

failure to properly establish, implement, and maintain maintenance procedures

as they related to maintenance on: control room pressure differential pressure

instrument DPI-6520, paragraph 3; the B boric acid storage tank temperature

controller and alarm, paragraph 4; and the EDG B lube oil strainer

maintenance, paragraph 4.

A second violation was identified involving an operator erroneously draining

safety injection accumulator A instead of accumulator B, paragraph 3.

9406290032 94061

PDR

ADOCK 05000

1

a

PR-

Notice of Violation

2

A third violation was identified involving control room operators failing to

take prompt corrective actions after being provided with chemistry sample

results which indicated that the boric acid concentration in the A BAST was in

excess of the concentration allowed by Technical Specification 3.2.2.c.,

paragraph 5.

An Unresolved Item was identified involving the operability of the control

room ventilation system, paragraph 6.

REPORT DETAILS

1.

Persons Contacted

  • R. Barnett, Manager, Projects Management

S. Billings, Technical Aide, Regulatory Compliance

  • A. Carley, Manager, Site Communications
  • B. Clark, Manager, Maintenance
  • D. Crook, Senior Specialist, Regulatory Compliance

J. Eaddy, Manager, Environmental and Radiation Support

  • D. Gudger, Specialist Regulatory Affairs
  • S. Farmer, Manager, Engineering Programs, Technical Support

B. Harward, Manager, Engineering Site Support, Nuclear Engineering

Department

  • M. Herrell, Manager, Robinson Training
  • S. Hinnant, Vice President, Robinson Nuclear Project

J. Kozyra, Acting Manager, Licensing/Regulatory Programs

  • R. Krich, Manager, Regulatory Affairs

A. McCauley, Manager, Electrical Systems, Technical Support

  • G. Miller, Manager, Robinson Engineering Support

R. Moore, Acting Operations Manager

M. Pearson, Plant General Manager

M. Scott, Manager, Reactor Systems, Technical Support

L. Woods, Manager, Technical Support

  • Attended exit interview on May 27, 1994.

Other licensee employees contacted included technicians, operators,

engineers, mechanics, security force members, and office personnel.

Acronyms and initialisms used throughout this report are listed in the

last paragraph.

2. Plant Status

The unit began the report period operating at 100 percent power, and

performed at power for the entire report period with no major

operational difficulties. Unit power was restricted to less than full

power on selected days to prevent exceeding an environmental limitation

on circulating water discharge temperature.

3. Operational Safety Verification (71707)

a.

General

r

The inspectors evaluated licensee activities to confirm that the

facility was being operated safely and in conformance with

regulatory requirements. These activities were confirmed by

direct observation, facility tours, interviews and discussions

with licensee personnel and management, verification of safety

system status, and review of facility records.

2

The inspectors reviewed shift logs, Operation's records, data

sheets, instrument traces, and records of equipment malfunctions

to verify equipment operability and compliance with TS.

The

inspectors verified the staff was knowledgeable of plant

conditions, responded properly to alarms, adhered to procedures

and applicable administrative controls, cognizant of in-progress

surveillance and maintenance activities, and aware of inoperable

equipment status through work observations and discussions with

Operations staff members. The inspectors performed channel

verifications and reviewed component status and safety-related

parameters to verify conformance with TS. Shift changes were

routinely observed, verifying that system status continuity was

maintained and that proper control room staffing existed. Access

to the control room was controlled and operations personnel

carried out their assigned duties in an effective manner. Control

room demeanor and communications were appropriate.

Plant tours were conducted to verify equipment operability, assess

the general condition of plant equipment, and to verify that

radiological controls, fire protection controls, physical

protection controls, and equipment tagging procedures were

properly implemented.

b.

Control Room Pressure Indicator In Error

On April 29, 1994, the inspectors observed that control room

pressure, as indicated on differential pressure instrument DPI

6520, was less than atmospheric pressure. Following the

licensee's investigation of this observation, the inspectors were

informed that DPI-6520 was in error and that the control room was

actually at a slightly positive pressure with respect to

atmospheric pressure. The inspectors were also advised that to

correct this instrument error, DPI-6520 was subsequently adjusted

by the system engineer.

The inspectors determined from interviews of personnel involved,

that maintenance was performed on DPI-6520 on April 27, 1994, to

correct a previous indication problem with the instrument. This

maintenance consisted of adjusting the control room manometer

(DPI-6520) to the level position and tightening the mounting

screws. Following this adjustment, no "zeroing" of the instrument

was performed to compensate for the new instrument position. A

review of the WR/JO indicated that this zeroing was not specified.

Furthermore, the planner involved in generating the maintenance

ticket was unaware of the need to zero the instrument following

the leveling. Discussions with the system engineer and a review

of a vendor bulletin on the instrument revealed that a zeroing was

appropriate. The inspectors noted that DPI-6520 is used to verify

that CR ventilation equipment performance complies with TS

requirements. Overall the inspectors concluded that the

maintenance instructions provided on the work request were

inadequate.

3

TS 6.5.1.1, Procedures, Tests, and Experiments, requires in part,

that written procedures be established, implemented, and

maintained, covering the activities recommended in Appendix A of

Regulatory Guide 1.33, Rev. 2, 1978, including procedures control

of measuring and test equipment.

Work Request/Job Order, WR/JO 94-AEBT1 was provided to

troubleshoot and repair the control room differential pressure

instrument DPI-6520. This instrument is used to verify that

control room ventilation equipment performance complies with

Technical Specification requirements.

Contrary to the above, WR/JO 94-AEBT1 was inadequate in that, it

did not provide adequate instructions for ensuring the instrument

was properly initialized following maintenance. As a result, the

instrument was returned to service following maintenance on

April 27, 1994, with an erroneous indication of control room

pressure. This is one of three examples, which in the aggregate,

constitute violation, VIO: 94-15-01, Failure To Properly

Establish, Implement, and Maintain Maintenance Procedures.

c.

Inadvertent Draining Of Safety Injection Accumulator A

On April 30, 1994, while attempting to reduce the water level in

the B SI accumulator, the reactor operator mistakenly opened the

drain valve for the A accumulator. Shortly thereafter, a low

level alarm was received for that accumulator. The level had been

reduced to just below 61 percent before the drain valve was shut

by the operator. Since the A accumulator level was then below the

TS limit of 61.5 percent the licensee entered TS 3.3.1.2.a..

This

TS requires that the unit be placed in hot shutdown if an

accumulator is inoperable for greater than four hours. According

to the reactor operator logs, eight minutes later SI accumulator A

was refilled and the LCO was exited. Approximately 45 minutes

later the B SI accumulator was drained in accordance with OP-202,

Safety Injection and Containment Vessel Spray System. In response

to this event, the licensee generated an ACR.

The inspectors reviewed the ACR, reactor operator log entries for

the event, and written statements by key watchstanders involved.

Additionally, the inspectors reviewed the completed Section 6.2 of

OP 202 used to drain the accumulator. Based on this effort, the

inspectors concluded that the incident was the result of a non

cognitive error on the part of the reactor operator. Imbedded in

this error was the failure of the individual involved to properly

implement the licensee's self-checking program. Additionally, the

inspectors noted that though draining an accumulator is a

relatively minor evolution, the reactor operator failed to inform

the senior control operator of his actions. As a result, the

senior control operator was unavailable to independently detect

the error on the part of the reactor operator.

4

Technical Specification 6.5.1.1, Procedures, Tests, and

Experiments requires, in part, that written procedures be

established, implemented, and maintained covering the activities

recommended in Appendix A of Regulatory Guide 1.33, Rev 2., 1978

including draining emergency core cooling system components.

Operating Procedure, OP-202, Safety Injection and Containment

Vessel Spray System, provides instructions for draining Safety

Injection Accumulators.

Contrary to the above, on April 30, 1994, OP-202 was improperly

implemented during efforts to drain Safety Injection Accumulator B

in that, the drain valve for accumulator A was opened. As a

result, safety injection accumulator A was inadvertently drained

below the minimum technical specification level.

This is

identified as a violation, VIO: 93-15-02, Operator Error Results

In Inadvertently Draining Incorrect Safety Injection Accumulator.

4.

Maintenance Observation (62703)

a.

General

The inspectors observed safety-related maintenance activities on

systems and components to ascertain that these activities were

conducted in accordance with TS, approved procedures, and

appropriate industry codes and standards. The inspectors

determined that these activities did not violate LCOs and that

required redundant components were operable. The inspectors

verified that required administrative, material, testing,

radiological, and fire prevention controls were adhered to. In

particular, the inspectors observed/reviewed the following

maintenance activities detailed below:

WR/JO 94-ACYR1

Calibrate BAST A Temperature

Controller and Alarm

WR/JO 94-AGRZ1

Troubleshoot Problem With LI-460

Indicating Out of Tolerance

WR/JO 94-ARWOO8

Perform B Emergency Diesel Generator

Quarterly Inspections

b.

Maintenance On Wrong BAST Controller

On April 12, 1994, the inspectors witnessed licensee efforts to

calibrate the A boric acid storage tank temperature controller and

alarm. When the inspectors arrived to witness this maintenance

evolution, the technician was in the process of removing the

temperature sensing bulb for the B boric acid storage tank. After

reviewing the WR/JO present at the job site, the inspectors

questioned the technician on whether he was removing the correct

sensing bulb. The technician reviewed the tank labeling and

5

acknowledged his error to the inspectors. The bulb was then

reinstalled and the calibration stopped.

TS 6.5.1.1, Procedures, Tests, and Experiments, requires in part,

that written procedures be established, implemented, and

maintained, covering the activities recommended in Appendix A of

Regulatory Guide 1.33, Rev. 2, 1978, including procedures for

control of measuring and test equipment.

Work Request/Job Order, WR/JO 94-ACYR1 was provided to calibrate

the boric acid storage tank A temperature controller and alarm.

Contrary to the above, on April 12, 1994, WR/JO 94-ACYR1 was

implemented incorrectly in that the maintenance technician

assigned to perform the calibration, erroneously commenced work on

the boric acid storage tank B temperature controller and alarm.

This is one of three examples which in the aggregate constitutes a

violation, VIO: 94-15-01, Failure To Properly Establish,

Implement, And Maintain A Maintenance Procedure.

The inspectors also noted that within a minute of the inspector

questioning the appropriateness of the maintenance technician's

activities, an auxiliary operator entered the work area with

similar questions. Subsequent discussions with control room

personnel revealed that the auxiliary operator was dispatched

based on the reactor operator's concerns with an unexpected alarm

on the boric acid storage tank B. The inspectors concluded that

this represented a positive example of a questioning attitude on

the part of the reactor operator and on-shift personnel.

c.

EDG B Lube Oil Strainer Maintenance

On April 25, 1994, the inspectors observed portions of EDG B

quarterly maintenance activities. During the reassembly of the

lube oil strainer, the inspectors observed that the pressure plate

washer was not installed during the reassembly as required by Step

7.3.10 of CM-507, Emergency Diesel Generator Lube Oil Strainers.

When the inspectors questioned the maintenance technicians on this

apparent discrepancy, the strainer reassembly was halted and

efforts were made to locate the washer. The inspectors were

subsequently advised by the manager of mechanical maintenance that

the washer was not present when the strainer was disassembled.

Despite specific references to the washer in three separate,

completed steps of the procedure (disassembly, inspection, and

reassembly steps) the technicians involved failed to detect the

missing washer. Following the installation of a replacement

washer, the unit was assembled and the EDG returned to service

that evening.

TS 6.5.1.1, Procedures, Tests, and Experiments, requires in part,

that written procedures be established, implemented, and

maintained, covering the activities recommended in Appendix A of

Regulatory Guide 1.33, Rev. 2, 1978, including procedures for the

maintenance of safety related equipment. Corrective maintenance

procedure, CM-507, Emergency Diesel Generator Lube Oil Strainers,

provides instructions for the disassembly, inspection, and

reassembly of the emergency diesel generator lube oil strainers.

Contrary to the above, on April 25, 1994, CM-507 was not properly

implemented in that the lube oil strainer was improperly re

assembled. This occurred when the maintenance technicians failed

to install a pressure plate washer as required by step 7.3.10 of

the procedure.

This is one of three examples which in the aggregate constitute

violation, VIO: 94-15-01, Failure To Properly Establish,

Implement, And Maintain Maintenance Procedures.

On April 26, 1994, the inspectors questioned maintenance

department management on whether the technician had documented the

material condition of the non-existent washer on the maintenance

data sheet in the procedure. The inspectors were advised that

this had occurred, but that after the washer was identified as

missing by the NRC inspectors, the maintenance data sheet was

revised to correct the error. The inspectors' subsequent review

of this data sheet revealed that the check mark in the

satisfactory column denoting the satisfactory inspection of the

washer had been crossed out and initialled. (The subsequent

unsatisfactory entry was also crossed out to reflect the

acceptable material condition of the replacement washer.)

The

inspectors were subsequently advised by the maintenance manager

that recording the material condition of the non-existent washer

was the result of a process error on the part of the technician.

The technician had grouped all the strainer internals in one

location during disassembly. The parts were then inspected in

mass without individually referencing them on the procedure

inspection checklist. Following this group inspection, the

checklist was annotated to reflect all parts as satisfactory.

d.

Pressurizer Level Indicator Restoration Following Maintenance

On May 6, 1994, the inspectors observed licensee troubleshooting

of pressurizer level indicator, LI-460 in accordance with WR/JO

94-AGRZ1 and LP-017, Pressurizer Level Protection and Control

Channel 460. This maintenance was conducted to remedy a reported

out of tolerance condition of the instrument.

Following the

alignment of the instrument, the inspector noted that the

technicians were about to perform the instrument restoration out

of the sequence specified by LP-017. Specifically, the

technicians were proceeding to return toggle switch, CT-460, to

its normal position prior to removing the test equipment. This is.

reverse of the order specified in the procedure. The inspectors

questioned the technicians on their intended sequence. Following

this questioning, the technicians removed the test equipment and

7

returned the toggle switch to the correct position in the proper

sequence. Based on their subsequent review of the instrument

drawing, the inspectors concluded that the potential safety

significance of this near-deviation from the procedure was

minimal.

5.

Surveillance Observation (61726)

The inspectors observed certain safety-related surveillance activities

on systems and components to ascertain that these activities were

conducted in accordance with license requirements. For the surveillance

test procedures listed below, the inspectors determined that precautions

and LC~s were adhered to, the required administrative approvals and

tagouts were obtained prior to test initiation, testing was accomplished

by qualified personnel in accordance with an approved test procedure,

and test instrumentation was properly calibrated. Upon test completion,

the inspectors verified the recorded test data was complete and

accurate. Test discrepancies were properly documented and rectified,

and that the systems were properly returned to service. Specifically,

the inspectors witnessed/reviewed portions of the following test

activities:

OST-401

Emergency Diesels (Slow Speed Start)

(EDG B Only)

SP-1307

Emergency Diesel Generator Test

a.

BAST A Boric Acid Concentration Exceeds TS Limits

At approximately 6:30 p.m. on May 4, 1994, the shift supervisor

recognized that BAST A exceeded the TS limit for boric acid

concentration. This discovery occurred during his review of the

daily chemistry sheet when he noted that the 22,681 ppm boric acid

concentration recorded for the tank exceeded the 22,500 ppm limit

in TS 3.2.2.c. Following this discovery, BAST B was placed in

service and backup samples of tank A were ordered. These

additional samples confirmed that the boric acid concentration in

the tank exceeded the TS limit. Following an addition of water,

the boric acid concentration in the tank was confirmed below the

TS limit at 5.35 a.m. on May 5, 1994.

In response to this event, the inspector interviewed key control

room watchstanders and chemistry personnel involved in the initial

out of specification reading. The inspectors reviewed log entries

for the event, chemistry surveillance results sheets, and

historical graphics of BAST boric acid concentrations. During the

course of this review, the inspectors were advised that the out of

specification chemistry results were provided verbally to the

control room almost seven hours prior to the shift supervisor's

recognition of the problem. In fact, the out of specification

results were recorded in the reactor operator's log at 11:46 a.m.

that day.

8

From interviews, the inspectors noted that the reactor operator,

chemistry technician, and chemistry supervisor all recognized the

boric acid results as in excess of the administrative limit but

failed to recognize exceeding the T.S. limit. This failure

delayed action to correct the out of tolerance condition for

almost seven hours. The inspectors also noted that several other

factors contributed to the untimely resolution of this issue.

These included: a communications failure between the reactor

operator and the senior control operator which resulted in the

senior control operator not being aware of the sample results in a

timely fashion; the lack of acceptance criteria on the chemistry

technical specification surveillance sheet; and a dulled sense of

concern on the part of plant personnel for elevated BAST boric

acid levels as a result of recent excursions above the

administrative limit.

While the TS limit for BAST A boric acid concentration was

exceeded, the inspectors concluded that sufficient boric acid was

available in the other tank to satisfy TS requirements.

The

licensee is investigating the reason why the boric acid

concentration in the A BAST increased to above the TS limit. The

inspectors will monitor this effort.

Appendix B, Criterion XVI requires that measures be established so

that conditions adverse to quality, such as failures,

malfunctions, deficiencies, deviations, defective material and

non-conformance are promptly identified and corrected.

Contrary to the above on May 4, 1994, an out of specification

boric acid concentration for BAST A was not promptly identified

following sampling. As a result a boric acid concentration in

excess of Technical Specification 3.2.2.c. went unrecognized for

almost seven hours. This is identified as a violation, VIO 94-15

03: Failure To Take Adequate Corrective Action To An Out Of Spec

BAST Boron Concentration.

6.

Engineering

a.

Control Room Ventilation Operability Evaluation

During a Region II specialist inspection which ended on May 6,

1994, the results of which are documented in Inspection Report

94-14, a Region II inspector questioned the licensee's testing

methodology associated with confirming the ability of the control

room ventilation system to maintain the control room at a positive

pressure with respect to all

adjacent areas during an accident.

The inspector noted that previous testing assessed the system's

ability to maintain a positive pressure relative to the outside

atmosphere, but did not verify the system's ability to maintain a

positive pressure in the control room envelope with respect to

adjoining plant spaces, which is a design basis function. This

apparent deviation from the test methodology as described in the

9

UFSAR, was identified to the licensee as an apparent Deviation.

The resident inspectors questioned the system's operability, given

the apparent inadequate scope of system testing. The Plant

Manager directed his staff to ascertain, and perform the testing

necessary to determine operability.

On the afternoon of May 6, 1994, the control room ventilation

system was tested in the emergency pressurization mode to

determine if the system could produce and maintain a positive

pressure relative to adjacent areas. The testing revealed that

the control room could only be pressurized to a pressure

approximately equal to an adjacent electrical equipment room. By

modifying the system's air flow balance, the licensee was

successful in creating a positive pressure between the control

room and the electrical equipment room, as well as all other

adjacent areas.

On the following day, an auxiliary building exhaust fan was turned

off to support ongoing auxiliary building ventilation flow balance

efforts. This resulted in another electrical equipment room

adjacent to the control room, the EI/E2 room, going to a pressure

of 0.2 inches of water higher than the control room. This

pressure was greater than the maximum pressure differential

attainable by the control room ventilation system when in the

emergency pressurization mode, based on the previous days testing.

This in turn indicated that in that configuration, the E1/E2 room

would have been at a positive pressure with respect to the control

room during certain accident scenarios. The licensee restarted

the auxiliary building exhaust fan, and declared the control room

ventilation system inoperable until the issue could be resolved.

Ultimately, the licensee de-energized the auxiliary building

supply fan which created a large negative pressure in the

auxiliary building which resolved the immediate concern relative

to the E1/E2 room and the control room. Subsequently, the

licensee restarted the auxiliary building supply fan after

applicable procedures were modified to de-energize the supply fan

in certain accident scenarios.

At the end of the report period, the control room ventilation

system had been balanced to maintain the control room at a

positive pressure with respect to adjacent areas during accident

scenarios. The licensee is evaluating the event to determine long

term corrective actions, the past operability of the system, and

the safety significance of having had a potentially inoperable

system. Pending the completion of that evaluation, this issue

will be maintained as Unresolved Item: URI 94-15-04, Control Room

Ventilation System Operability.

7.

Review of LERs (30703)

The below listed LERs were reviewed to determine if the information

provided met NRC requirements. The determination included: adequacy of

description, verification of compliance with Technical Specifications

and regulatory requirements, corrective action taken, existence of

potential generic problems, reporting requirements satisfied, and the

relative safety significance of each event.

LER 92-012: Reactor Trip At Shutdown During Surveillance Testing.

LER 92-019: TS Violation Due To Mode Change With WCCU-1A

Inoperable

LER 92-020: Alert Declaration Due To Unplanned Release Of Toxic

Gas

LER 92-021: Failure To Enter TS Action Statement For Inoperable CV

Isolation

LER 89-011: Auxiliary Feedwater Flowrate Could Exceed Limit

LER 90-001: Loss Of All Control Rod Indication

LER 90-006: Breech Of Containment Integrity

LER 91-003: Containment Vessel Fire During Refueling

LER 91-004: Rod Control System Urgent Failure

LER 91-008: TS 3.0 Implementation

The corrective actions for the above LERs have been completed. These

items are closed.

8.

Licensee Action on Previous Findings (92701, 90702)

a.

(Open) URI 94-12-02, Basis For Closed Systems Outside Containment

IR 94-12 documents an URI related to credit taken in a licensee

containment isolation valve study for closed systems outside

containment which are normally vented to the RWST. In an attempt

to understand the licensee's basis for this "closed" system

classification, the inspectors reviewed testing associated with

several systems which are normally vented to the RWST.

Specifically, the inspectors reviewed the following Operations

Surveillance Test: OST-155, Safety Injection System Integrity

Test; OST-254, Residual Heat Removal System and RHR Loop Sampling

System Leak Test; and OST-355, Containment Spray System Integrity

Test. OST-254 is used to demonstrate compliance with RHR system

leakage testing requirements specified in TS 4.4.3. All three OST

procedures (and others) are used to verify compliance with

Operating License requirement 3.G.2 to conduct integrated leak

tests of systems outside containment that would or could contain

highly radioactive fluids during an accident.

Following this

review, the inspectors were concerned that potential

inconsistencies and apparent shortcomings existed in the OSTs.

These concerns could be categorized into two broad areas:

the

adequacy of OST methodology and the apparent failure to conduct an

"integrated" leak test. The latter concern dealt primarily with

the failure of the licensee to conduct a check for seat leakage

past the SI-864 A/B RWST Discharge an SI-856 A/B High Head SI Test

Lined to RWST, valves. Seat leakage past these valves during the

recirculation phase could result in unmonitored release through

the RWST vent.

These concerns were identified to cognizant licensee personnel

during the week of May 9, 1994.

In response, the inspectors were

advised near the end of the inspection period that a licensee

review of these concerns would be conducted. Additionally,

immediately after the report period, the licensee advised the

inspectors that no seat leakage testing had been conducted on the

SI-864 A/B valves. Hence, no firm data existed to quantify the

magnitude of this potential unmonitored release path.

However,

the licensee indicated their intention to develop a plan to

resolve this potential shortcoming as well as review the adequacy

of their existing leakage tests. The inspectors were presented an

unverified calculation on May 27, 1994, that demonstrated that

with seat leakage at the initial procurement limit for the SI-864

A/B valves, no appreciable increase in off-site doses would occur.

Pending further review by the inspectors of the apparent test

inconsistencies and a review of the potential unmonitored release

path by NRR, this item remains open.

9.

Exit Interview (71701)

The inspection scope and findings were summarized on May 27, 1994, with

those persons indicated in paragraph 1. The inspectors described the

areas inspected and discussed in detail the inspection findings listed

below and in the summary. Dissenting comments were not received from

the licensee. The licensee did not identify as proprietary any of the

materials provided to or reviewed by the inspectors during this

inspection.

Item Number

Description/Reference Paragraph

VIO: 94-15-01

Failure To Properly Establish, Implement, and

Maintain Maintenance Procedures. (paragraphs 3

and 4)

VIO: 93-15-02

Operator Error Results In Inadvertently Draining

Incorrect Safety Injection Accumulator.

(paragraph 3)

12

VIO: 94-15-03

Failure To Take Adequate Corrective Action To An

Out Of Specification BAST Boron Concentration.

(paragraph 5)

URI: 94-15-04

Control Room Ventilation System Operability.

(paragraph 6)

10.

List of Acronyms and Initialisms

ACR

Adverse Condition Report

BAST

Boric Acid Storage Tank

CM

Corrective Maintenance

CV

Containment Vessel

DPI

Differential Pressure Indicator

EDG

Emergency Diesel Generator

LI

Level Indicator

OP

Operating Procedure

OST

Operators Surveillance Test

RWST

Refueling Water Storage Tank

TS

Technical Specification

UFSAR

Updated Final Safety Analysis Report

URI

Unresolved Item

VIO

Violation

WO/JO

Work Order/Job Order