ML19332B890
| ML19332B890 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 11/01/1989 |
| From: | Eapen P, Lopez A, James Trapp NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19332B887 | List: |
| References | |
| 50-334-89-20, 50-412-89-19, GL-87-12, GL-88-17, NUDOCS 8911210278 | |
| Download: ML19332B890 (8) | |
See also: IR 05000334/1989020
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U.S',NUCLEARREGULATORYCOMMISSION
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REGION I
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Report Nos. : 50-334/89-20
- 50-412/89-19-
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Docket Nos.
50-334~
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50-412-
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License'Nos? DPR-66
NPF-73-
Licensee:1
Duo'esne-Light Company-
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p.0. Box 4
Shippingport, Pennsylvania 15077
Facility Name: Beaver Valley Power Station, Units 1&2
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LInspection At:- Shippingport Pennsylvania
' Inspection Conducted: . September 25-29, 1989
. Inspectors:
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--J.M.(frapp,Sr.TehetorEngineer,Special
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- Test Programs Section,-EB, DRS
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A.TE. Lopez,.Readto m gineer, Special Test
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Programs Section, EB, DRS
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Approved by: . Dr. P.K..Eapen, Chief,'Special Test
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ProgramsLSection,:EB, DRS
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Inspection Summary:
Routine Unannounced Inspection on September 25-29, 1989
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- (Combined-Inspection Report Nos. 50-334/89-20, and 50-412/89-19)
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Areas Inspected:
Licensee actions in response to the " Expeditious Enhancements"
! described:in Generic Letter No. 88-17, " Loss of Decay Heat Removal," including
. supporting instrumentation, training, procedures and staff awareness as related
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to mid-loop operation.
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Results:: The licensee is-prepared to implement all " Expeditious Enhancements"
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described in Gcmeric Letter No. 88-17, except Unit 1 RCS water level instru-
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. mentation,'if the RCS:is drained to a mid-loop condition.
Procedures for
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installation and calibration of RCS level instrumentation were not in place for
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use during Unit-1 mid-loop operation. This item remains unresolved (Unresolved
item 50-334/89-20-01) pending licensee's establishment of installation and
calibration procedures.
8911210278 891109
ADOCK 05000334
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DETAILS
1.0' Persons Contacted
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1.1 Duquesne Light Company
- T.'. Burns, Operations Training Director
- J. Crockett,. General Manager Corporate Nuclear Services
- R. Hec l:t, Site I&C Director
- J. Keegan, Engineer
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- JW. Lacey, General Manager Nuclear Operations Services
- S..Leung, Engineer II-
- S. Nass,: Supervising Engineer
.F. Shafner, Acting Engineering Supervisor
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- J. Vasselo, Licensing Director
1.2, U.S. Nuclear Regulatory Commission.
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- J. Beall, Sr. Resident Inspector
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- J. Durr, Chief. EB, DRS-
- =P. 'dilson, Resident Inspector
'* Denotes presence at exit meeting held on September 29,1989.
2.0 Review of Licensee Actions in Response to Generic Letter (GL) No. 88-17,
Loss of Decay Heat Removal (TI 2515/101)
' Loss of decay heat removal (DHR) during non power' operation and the consequences
of such a loss have been of increasing concern to the NRC. Many events of loss
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of DHR have. occurred while'the reactor coolant system has been drained down for
mid-loop activities such- as steam generator inspection or repair of reactor
coolant pumps. The possibility exists that two fission product barriers could
be breached while these activities are in progress, since the reactor coolant
system and containment may both be open.
GL- 87-12, " Loss of Residual. Heat Removal (RHR) while the Reactor Coolant System
-(RCS)lisipartially filled" was issued to all licensees of operating PWR's and
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holders of construction permits on July 9,1987.
Responses indicated that the
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licensee did not fully understand the identified problems, and problems
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continued as evidenced by events at Waterford on May 12, 1988 and Sequoyah on
May 23, 1988.
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The seriousness and continuation of this problem has resulted in the issuance of
In addition, the Director of NRR has written to the CEO of each
licensee operating a PWR, in which he states, "We consider this issue to be of
high priority and request that you assure that your organization addresses it
accordingly." He also wrote to each licensed operator at all PWR plants on
" Operator Diligence while in Shutdown Conditions," and enclosed a copy of
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GL88-17_ requested the recipients to respond with two plans of actions:
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A short-term program entitled " Expeditious Actions," and
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A long-term program entitled " Program Enhancements."
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This inspection ~ addressed the short-term licensee actions as outlined under
"Expeditinus Actions," of GL 88-17.
The inspectors reviewed the licensee response to Generic Letter No. 88-17, dated
January 13, 1989 in conjunction.with comments made by the NRR. staff, dated
April 11, 1989, " Response To Generic Letter 88-17 On Loss Of Decay Heat Removal
With Respect To Expeditious Actions." The licensee's response provided a descrip-
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tion.of actions taken to_ address the eight recommended expeditious actions
. identified in the Generic Letter.
The inspectors were advised that the licensee has not entered a mid-loop condition
since the issuance of.GL 88-17 and will not enter a mid-loop condition during-
it's present Unit No.1 Refueling Outage.
2.I' Temperature' Indication
-The inspectors verified that for mid-loop conditions, the licensee has taken
adequate administrative and procedural steps to provide two independent, period-
-ically recorded core exit temperature indicators that are representative of the
core exit. temperature conditions.
The licensee monitors the core exit temperature
using fifty thermocouples for Unit I and fif ty-one for Unit 2.
Procedure 1.6.4,
. initial ~ condition, step 15, for Unit 1 and Procedure 2.6.4, initial condition,
step 14, for Unit 2 respectively, require trending a minimum of two thermocouples
at a:10 minute interval on the trend recorder. OST 1.6.11, step 11, for Unit 1
and OST 2.6.11, step 10, for unit 2 respectively, reouire two core exit thermo-
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couple indications be available prior to entering mid-loop condition.
The core
exit thermocouples are not presently alarmed and indication is not available
when the reactor head is removed from the reactor vessel.
Control room operators
record the core exit thermocouple readings twice per shift on operator log sheets
1.54.3 and 2.54.3 for unit No. I and 2, respectively.
The inspectors found the
temperature indication available for Mid-Loop operation to be consistent with-
the expeditious actions of Generic Letter 88-17.
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2.2 RCS Water Level
Unit'1:-The licensee stated in their response to Generic Letter No. 98-17 that
they had two independent continuous RCS water level indications in the control
room.
However at the time of this inspection, procedures for the in:,ta11ation
ar.d calibration of level instruments were not in place. The licensee stated
that the procedures for installation and calibration of the level instruments
will be established prior to conducting mid-loop operations. This item remains
unresolved pending licensee establishment of the above installation and calibration
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procedures (Unresolved item 50-334/89-20-01).
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Unit 2: The inspectors verified that the licensee has two continuous RCS water
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level indications. They consist of one sight glass (LG-101) and one wide range
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. level transmitter (LT-102) which provides continuous recorded level indication
in the m :rsi ;oom.
The level transmite which provides indication in the control room is checked
by an operator twice a shift and has a range of 0 to 180 inches ( Note: Bottom
of hot leg pipe is zero _ inches and hot leg diameter is 29 inches). The Itcensee
recognizes that the range of this instrument and the use of a common tap for
both level indication instruments is less than ideal. Therefore, the licensee
monitors and logs the site glass. indicated RCS level every 15 minutes during
mid-loop conditions.
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The sight glass is permanently installed and monitored in containment. Operating
Log L5-47, " Operating With The RCS At Reduced Inventory - Operating Mode - 5 & 6,"
step.105++ states, "If level is less than 57", then establish a temporary log
and record local level every 15 minutes.
Immediately report to the control
room if signi.ficant level- changes occur (0.5 to 1 inch)."- (Note: 57 inches is
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28 inches above the top of the hot leg pipe)
Both level indicators share a common penetration which is located at the bottom
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- of a hot leg pipe. As such, these level instruments are.not independent. Also,
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procedures requiring periodic draining or flushing to detect blockage of the
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common penetration, as recommended in the GL, were not available.
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generic letter states that when two independent level indications are not
practical in the short term, a single indication'will be acceptable. Therefore,
the licensee's Unit 2 instrumentation is consistent with the short term actions
of Generic Letter No. 88-17. The licensee has committed in a letter, dated
February 23, 1989, to provide two independent RCS level indications in response
to the actions required under GL 88-17 programmed enhancements.
The inspectors found that Procedure OM 2.10.40 (Unit 2), step 5 allows the RCS
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to drain to a level of 13 inches, which is the RHR pump cavitation limit according
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to Procedure OM 2.10.5, Figure No.10-10, " Hot Leg Water Level-Vs.-RHS Flow
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Rate" curve. The inspectors identified this problem and brought it to the
attention of the licensee. The licensee took action by writing a " Operating
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Manual Deficiency Report" to revise this procedure prior to mid-loop operation.
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2.3 RCS Inventory Addition
The inspectors verified that the licensee has procedures and administrative
controls to provide at least two available or operable means of adding inventory
to the RCS, in addition to pumps that are a part of the normal DHR system. One
Charging /High Head Safety Injection (HHSI) pump and one Low Head Safety Injection
(LHSI)-pump are the two available sources of RCS inventory addition, during the
mid-loop operation.
-The initial conditions of Procedures 1.6.4 and 2.6.4 for units No. I and 2
respectively, " Draining The RCS To Reduced Inventory of mid-loop Condition",
require satisfactory completion of Operation Surveillance Test (OST) 1.6.11
(Unit -1), and 2.6.11 (Unit 2). OSTs 1.6.11 (Unit 1), and 2.6.11 (Unit 2),
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Step'3 verifies one Charging /HHSI pump-is operable. OSTs 1.6.11 (Unit 1), and
2.6.11:(Unit 2), Steps 5 thru 7 verifies a flow path.from the-RWST via the
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- charging pump to both the hot and cold legs has' been established. Nuclear Shift
Supervisor OperatOnal- Clearance Tags (NSS OCT).are placed on the required valves
Land charging pump controls to provide administrative control-to assure an
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established flow path remains available.
OSTs 1.6.11 (Unit 1), and 2.6'11 (Unit 2), Step 4 verifies that an LHSI pump is
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available to add ' inventory to the RCS, Methods for controlling flow paths to
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the hot and cold legs are similar to that described above for the Charging /HHSI-
pump.
' Abnormal Operating Procedures (A0P) 1.10.2 (Unit 1, currently in draft form)
and 2.10.2-(Unit 2), " Loss of RHR While At mid-loop Conditions," provides guidance
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on re-establishing DHR following .the loss or cavitation of the RHR pumps while
.at mid-loop conditions. The AOP uses the equipment and flow paths established
in OSTs~1.6.11'(Unit 1),'and 2.6.11 (Unit 2) to-increase RCS inventory.
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The inspectors independently verified the makeup capability of the HHSI and the
LHSI pumps was adequate to re-establish RCS level following the loss of DHR.
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Calculations indicate the boil off rate 20 HRS after Reactor Shutdown is approxi-
mately-130 gal / min. -The-nominal flow rate, of the Charging /HHSI and LHSI pumps
- are 550 GPM and 3000 GPM, respectively.
These flow rates exceed the boil off
rate at mid-loop RCS pressures. Therefore, the licensee has sufficient make-up
capability to increase RCS level during a boil off condition. The Engineering
Analysis and Assurance Group provided technically sound and thorough analysis
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to the Procedures Group on mid-loop operating concerns.
However it appears
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that the-engineers did not conduct follow-up reviews to assure the analysis was
correctly interpreted and incorporated into the mid-loop operating procedures.
24 RCS Perturbations
LThe inspectors verified that the licensee has implemented procedures and
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administrative controls to preclude operations that would lead to perturbations
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in the RCS. - Procedures OM 1.6.4AP (Unit 1), 2.6.4V (Unit 2), " Reduced RCS
Inventory Operation Checklist" establish administrative controls for all personnel
involved in: requesting, implementing, reviewing, working or authorizing activities
that may affect.or perturb the RCS water-level while the RCS is operating at
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reduced inventory /mid-loop condition. These procedures provide a list of boundary
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valves between the RCS,-RHR, and CVCS that, if opened, may cause a perturbation
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.of RCS level. This procedure also provides a list of procedures from various
station groups, whose operation may perturb the RCS level. The Nuclear Control
Operator'and the Senior Reactor Operator are responsible for completing this
procedure prior to entering reduced inventory or mid-loop condition and when
reviewing and preparing Valve / Switching Procedure forms. The procedures and
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administrative controls established were found to be consistent with the
expeditious actions described in Generic Letter No. 88-17.
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2.5 Nozzle Dams
Nozzle Dams are not part of the Beaver _ Valley Unit No.1 or 2 system design.
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Loop Stop Valves
The inspectors verified that the licensee has implemented procedures and
administrative controls that assure all hot legs are not blocked simultaneously
by the'. loop stop. val ws. The licensee reouires in procedure OST 1.6.11, step 9
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-m and n for Unit- 1, and OST 2.6.11, step 9d for Unit 2, to verify that all hot
- leg and cold leg ~,oop stop valves are open.
The cold leg loop stop valves have
an interlock ~ preventing them from opening until the hot leg stop valve in the
loop is open.
The licensee has also tagged all of the loop stop valves with
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Nuclear Shift Supervisor Operational Clearance tags to at,sure that these valves
remain open during mid-loop level conditions.
The inspectors concluded that
the licensee's controls of-the loop stop valves during mid-loop operation are
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consistent with the-expeditious actions guidelines of generic letter 88-17,
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2.7 Containment Closure
The inspectors verified that the licensee has prepared procedures and adminis-
trative controls to assure containment closure prior to core uncovery during a
loss of DHR event.
Initial Conditions of procedures 1.6.4 and 2.6.4 for unit 1-
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t and 2, respectively, " Reduced Inventory /Mid-loop Operation Checklist," require
.0peration Surveillance' Test (OST) 1.6.11 and 2.6.11 unit I and 2, respectively,
be performed prior to reducing RCS level to the mid-loop conditior
(Unit 1), and 2.6.11 (Unit 2),-Step 1,' require OSTs 1.47.3 (Unit 1) and 2.47.3
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(Unit 2), to be completed. OST 1.47.3 (Unit 1) and 2.47.3 (Unit 2) " Containment
- Integrity Checklist for Refueling - Acceptance Criteria," establishes refueling
integrity prior to reducing RCS inventory.
Refueling integrity requires, in
part, that the equ.ipment door be closed and held in place by a minimum of four
bolts, one airlock door be closed, and each penetration providing direct access
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from containment atmosphere to'the outside atmosphere be. isolated and the
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containment purge valves be capable of isolating. OSTs 1.47.3 (Unit 1) and
-2.47.3 (Unit 2) require a visual inspection be performed to verify that gaps
lbetween the sealing surface of the equipment access hatch do not exist, to assure
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adequate sealing of the equipment hatch. Nuclear Shift Supervisor (NSS) tags
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are used for administrative control to prevent inadvertent opening of penetrations
closed to establish refueling-integrity.
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The licensee stated in their response to the " Expeditious Actions" of generic
letter 88-17, that additional procedure development will be pursued, when
necessary, if_the containment needs to be open while in a reduced inventory
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condition. The inspectors found the licensee's action taken to assure contain-
ment closure during mid-loop operation to be consistent with the expeditious
actions of generic letter 88-17.
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Trainina
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The inspectors verified that training' conducted by the licensee made the station
personnel aware of the risks associated with operation in a reduced inventory /
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.mid-loop condition. The training material and lesson plans reviewed by the
inspectors contained all the material committed to be part of training in the
. licensee response to Generic Letter No. 88-17.
The personnel to be included
'in thet formal training courses are:
Licensed Operators, Non-Licensed personnel,
I&C and Mechar.ical Maintenance personnel, and Chemistry and Radiation Control
personnel,
Outage schedules will include a daily meeting review of the concerns-
of Generic Letter No, 88-17.
For short notice draindowns of the RCS, a self
study gu'ide will be available to all concerned personnel.
The inspectors found
that the personnel, and the non-licensed personnel in particular,. involved in
mid-loop operation were well trained and knowledgeable.
The inspectors concluded
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.that-the. training program and its implementation were consistent with the
expeditious actions of Generic Letter 88-17.
2.9 0A Involvement
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-.The QA organization did not participate in the licensee's actions taken in
response to Generic Letter No. 88-17.
This con be-attributed to the licensee
not having entered a mid-loop level operation since Generic Letter 88-17 was
issued.
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,-3.0= Summa'ry/ Conclusions-
The inspectors found that the licensee has satisfactorily implemented the
. commitments made in it's response to Generic Letter 88-17.
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The . inspectors observed the following strengths as related to the licensee
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response to the expeditious actions for mid-loop operations:
The formal training of non-licensed station personnel on the hazards
associated with mid-loop operation were comprehensive.
The licensee's procedures bhich maintain refueling integrity during
mid-loop conditions are conservative and provide an intact second barrier
during mid-loop operation.
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Procedures and practices to prevent RCS level. perturbations during mid-loop
conditions-were detailed and they provided adequate control to prevent RCS
perturbations.
The inspectors observed the weaknesses in the following areas:
Operating procedures for Unit 2 required maintaining RCS levels during
mid-loop operation which were at the cavitation limit for the RHR pumps,
and did not include margin for level instrumentation inaccuracy. This
issue was corrected by the licensee when identified by the inspectors.
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.The present level instrumentation for unit 2 meets the intent of the
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-Generic Letter for the short term only. An upgrade of the present
equipment is required for accurate control room level indication for
mid-loop RCS' level conditions.
Procedures for installation and-calibration of unit 1 level instrumentation
were not in place. This item remains unresolved pending establishment of
installation and calibration procedures.
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4.0 Exit Meeting
At the conclusion of the site inspection, on September 29, 1989, an exit-
interview was conducted ~with the licensee's senior site representatives (denoted-
in Section 1) to discuss the results and conclusions of this inspection.
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At no time during this inspection was written material provided to the licensee
tar the inspector.- The licensee representatives did not indicate that this
' inspection involved information subject to 10 CFR 2.790 restrictions.
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