ML19352A829

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IE Insp Rept 50-293/81-02 on 810105-30.Noncompliance Noted: Partially Used Container of Borax Unsealed & Stored on 91-ft Elevation of Reactor Bldg Under Stairway Near Standby Liquid Control Sys
ML19352A829
Person / Time
Site: Pilgrim
Issue date: 03/24/1981
From: Jerrica Johnson, Keimig R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19352A827 List:
References
50-293-81-02, 50-293-81-2, NUDOCS 8106020190
Download: ML19352A829 (17)


See also: IR 05000293/1981002

Text

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TERA #'s fer 50-293/81-02

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ggg-801229

810107

$

U.S. NUCLEAR REGULATORY COMMISSION

50293-810117

0FFICE OF INSPECTION AND ENFORCEMENT

60293-810118

S0293-810119

Region I

50293-810122

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50293-810128

Report No.

50-293/81-02

Docket No.

50-293

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Category

C

License No. DPR-35

Priority


Licensee:

Boston Edison Company

800 Boylston Street

Boston, Massachuset*s 02199

Facility Name:

pugrim ncinar pnwar varinn

Inspection at: Plymouth, Massachusetts

Inspection conducted:

January b - 30, 1981

Inspectors:

Nbd

,

]. Johnson,SeniorResidentInspector

date signed

date signed

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date signed

Approved by:

E;

  1. "

./24 0

R. Keimirf/ ActingChief,

date signed

/Reactor Projects #.ction No.

1B

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Projects Branch No. 7

Inspection Summary:

Inspection on January 5-30, 1981 (Report No. 50-293/81-02)

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Areas Inspected: Routine unannounced safety inspection of plant operations

including followup on previous inspection findings, an operational safety

verification, followup on events, surveillance activities, licensee status

of TMI T.A.P. Category 'B' items, ATWS procedure review, LER followup, a

review of organization / personnel changes, and a survey of potential leaking

detectors.

The inspection involved 92 hours0.00106 days <br />0.0256 hours <br />1.521164e-4 weeks <br />3.5006e-5 months <br /> by the resident inspector.

Results:

Four items of noncompliance were identified in one area.

(Failure

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to perform required surveillances for ATWS instrumention, paragraph 3.b.(1);

Failuce to implemant station administrative procedures for the control of

Borax, for required log entries and for required valve lineup signature veri-

fication, paragtiph 3.b.(2), Failure to properly review, approve, and

distribute station procedures, paragraph 3.b.(3); and Failure to follow alarm

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response procedure for deenergizing annunciators, paragraph 3.b. (4).

Region I Form 12

U106020(90

(Rev. April 77)

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DETAILS

1.

Persons Contacted

r. Famulari, QC Supervisor

E. Graham, Sr. Plant Engineer

R. Machon, Nuclear Operations Manager - pilgrim Station

C. Mathis, Dep'ity Nuclear Operations Manager

T. McLoughlin, Sr. Compliance Engineer

P. Smith, Chief Technical Engineer

R. Smith, Sr., Chemical Engineer

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R. Trudeau, Chief Radiological Engineer

P.. Williard, I&C Engineer

E. Ziemanski, Managemens Services Group Leader

The inspector also interviewed other members of the health physics, opera-

tions, security, maintenance, and technical staffs.

2.

Followup on previous Inspection Findings

(Closed) Noncompliance (293/80-25-01); The licensee reinstructed the per-

sonnel involved on leaving valves out of position and the purpose of the

shift turnover sheet.

Subsequent tours of the control room by the inspector

to verify valve and switch lineups following completion of surveillance

tests have not identified any similar instances.

This item is closed.

(0 pen) Inspector Follow Item (293/80-21-01); The inspector contacted the

NRC:NRR Licensing Project Manager who indicated that the design review of

the ATWS RPT/ARI modification had been completed.

The licensee has yet to

install a backup power supply (inverter).

The licensee expects necessary

instructions and equipment to be available for implementation in April,

1981 and stated that the completion of this modification will be scheduled

for the next outage of sufficient duration prior to the planned refueling

outage of September, 1981.

This item remains open pending review of the

completed modification.

(0 pen) Deviation (293/80-30-02);

The licensee's January

9, 1981 response

to NRR concerning the status of the TMI Task Action Plan item III.E.4.2.6

stated that procedural controls would be implemented by January 15, 1981 to

meet the previous commitment of limiting containment vent and purge valve

operation to 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per year during reactor operation.

The inspector

reviewed the revised procedure No. 2.2.70 " Primary Containment Atmosphere

System," Revision 15, dated January 15, 1981.

This item remains open

pending a review of the implementation of this procedure change and a

review of the justification for not modifying the two remaining 20 inch

purge inlet valves.

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(0 pen) Deviatio7 (293/80-30-03); Following receipt of the IAL dated

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December _ 28, 1980 (concerning shift staffing and overtime hours) the

Itcensee informed Region I of a disagreement between the current

station policy and the. written understandings-in the IAL. As a result

' of discussions ~ with the inspector, the licensee responded to both

Region I and NRR with a letter dated December 31, 1980 which revised

the licensea's commitments and clarified the original commitments.

The current station policy includes the following:

"The Nuclear Operations Manager or his Deputy's approval must be

obtained in order to exceed the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (in the control room

performing safety related functions) however, under normal circum-

stances,

an operator shall not. exceed 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> performing

safety related control room functions.

Deviation from the above

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restrictions may be authorized by the NOM or higher levels of

management in accordance with published procedures and with

appropriate documentation of the cause."

The inspector reviewed entries made in the W.E. instruction log to all

shifts and a revised station procedure No. 1.1.17 " Control Room

Manning" Revision 9,

which include this criteria.

This item remains open pending review of the licensee's response to

Inspection Report 50-293/80-30.

3.

Operatio.lal Safety Verification

a.

Scope

The . inspector observed control room operations, reviewed selected

logs, ana conducted discussions with control room operators

during the month of January, 1981.

The inspector verified the

operability of selected emergency systems, and verified the

proper return to service of affected components.

Tours of the

security perimeter, reactor building, turbine building, process

building auxiliary bay, control room, and vital switchgear rooms

were conducted.

The inspector's observation included a review of

plant equipment conditions, potential fire hazards, physical

security, housekeeping, and the implementation of radiation

protectirn controls.

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These .eviews and observations were conducte.1 in order to verify

confornance with the Code of Federal Regulatians, the facility

Technica' Specifications, and the licensee's administrative

procedures.

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Findings

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(1) During a tour of the control room on January 7,1981, the

inspector questioned the licensee concerning documentation

for surveillance of the ATWS instrumentation required to be

performed by Technical Specification 4.2.G.

The licensee

determined that the daily instrument checks were not being

performed, immediately verified the operation of these

instruments (reactor vessel level and pressure) and took

action to revise station procedures to include these checks.

The inspector also reviewed documentation provided by the

licensee for the (monthly) functional tests performed on

June 19, 1980, July 25, 1980 and December 31, 1980.

Documen-

tation of (quarterly) trip unit calibrations performed for

the pressure and level instruments on May 11, 1980 and for

the level instruments on July 26, 1980, was also reviewed.

Based on this review, the inspector determined that all the

functional tests and trip unit calibrations required by T.S.

4.2.G had not been performed since equipment installation in

May, 1980. The licensee acknowledged the inspector's statements

and stated thit the appropriate surveillance procedures

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would be revised and that the trip unit calibrations would

be performed prior to the end of January,1981 along with

the monthly functional test.

Prior to the end of this inspection, the inspector verified

that the daily instrument checks were being performed and

that the functional test: and trip unit calibrations had

been performed satisfactorily on January 30, 1981.

The licensee further stated that a detailed review of all

changes required by Amendment No. 42 to the Technical Specifi-

cations would be performed to ensure that there were no

similar instances of required surveillances not being performed.

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Failure to perform the surveillances required by T.S.

4.2.G

is considered an item of noncompliance (293/81-02-01).

(2) During facility tours during the month of January,1981, the

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inspector identified several cases where the requirements of

the licensee's administrative procedures were not being

implemented.

During a tour of the reactor building on January 9,

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1981 the inspector observed a partially used container

of Borax which was unsealed and stored under an open

stairway near the Standby Liquid Control System (SLCS).

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Station procedure No. 1.4.9, Revision 5, " Storage,

Handling, and Disposal of Sodium Pentaborate," Section

III, states in part that Borax will be stored in the

station warehouse and that the containers shall be kept

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sealed.

This was brought to'the attention of station management

and actions were taken to seal the partially used

container of Borax.

The licensee further stated that

procedure No. 1.4.9 would be revised to allow storage

of partially used containers of Borax and Boric Acid in

the vicinity of the SLCS, and to ensure appropriate

labeling and controls to prevent misuse.

During a tour of the main control room on January 13,

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1981, the inspector noted that a summary of the overall

operation of the plant was not being entered in the

Station Operations Log at the end af each shift as

required by procedure 1.3.7 Revision 17, " Records,"

Section- III.A.l.a.

The inspector informed the acting Chief Operuting

Engineer who immediately issued instructions to all

shifts to ensure that this requirement was implemented.

During a review of documentation associated with a

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liquid radioactive discharge of the 'C' monitor tank on

January 20 - 21, 1981, the inspector noted that although

the valve lineup had been verified prior to the discharge,

the valve lineup check sheet, OPER-28, had not been

signed by the on-duty Watch Engineer as required by

Section VIII.B. of procedure no. 7.9.2, Revision 9,

" Liquid Radioactive Waste Discharge."

The licensee acknowledged the inspector's concerns and

stated that appropriate action would be taken to ensure

that this requirement was fulfilled.

These three examples of failures to implement station procedures

are collectively considered an item of noncompliance (233/81-

02-02).

(3) The inspector reviewed controlled copies of selected station

procedures to ensure that the procedures were reviewed,

approved, and distributed in accordance with the licensee's

administrative controls and regulatory requirements.

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Boston Edison Co. QA Manual Volume II, Operation of

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Nuclear Power Plants, Section 5 (revised August 6,

1979) required that Station quality assurance program

related procedures be submitted to the QA Manager for

review and approval prior to implementation. Station

Procedure No. 1.3.4, Revision 21,-" Procedures," Section

III.D., states that each procedure title page contains

a space for the signature of the QA Manager when applicable.

On January 23, 1981, the inspector identified that the

following station QA Program related procedure revisions

(as listed in Exhibit II-5-6 of the QA Manual) had been

approved and distributed for use at the station without

L?ing approved by the QA Manager.

1.2.1, Revision 9, " Operations Review Committee"

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1.3.4, Revision 21, " Procedures"

1.5.3, Revision 13 " Maintenance Request"

1.3.8, Revision 24, " Document Control"

8.1, Revision 6, " Periodic Surveillance Tests"

1.3.9, Revision 22, " Reports"

1.4.6, Revision 5, " Housekeeping"

The licensee was unable to provide the inspector with

documentation to show that the required revisions and

approval had been performed. The licensee stated that

these procedures would be immediately sent to the QA

Manager for his review and approval, and that an independent

QA audit would be performed to ensure that there were

no additional procedures which did not have the required

review and approval.

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Station Procedure No. 1.3.8, Revision 24, " Document Control,"

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Section III.A, states that controlled copies of selected

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volumes and individual procedures are maintained in accord-

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ance with Attachment 1.3.8 A-1.

Attachment 1.3.8 A-1 refers

to attachment 1.3.8 E-1 for a list of additional

controlled

copies of Volume 2.2, system operation procedures, to be

provided specifically to the Radwaste Control Room operator.

During a tour of the Padwaste Control Room on January 21, 1981,

the inspector identified that the manual of procedures in use

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by the Radwaste Operators contained n':ne (out of eleven)

system operating procedures which had been superceded by later

revisions:

Rev.

Current

Title

In Use

Revision

Procedure

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2.2.33

Makeup-Demineralizer System

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5

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2.2.71

Radwaste Collection Syst2m

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2.2.72

Clean ~Radwaste System

4

6

2.2.83

Reactor Cleanup System

7

9

2.2.85

Fuel Pool Cooling and Filtering

System

7

8

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2.2.97

Condensate Deminera'lizer' System 10

13

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2.9.98

Ultrasonic Resin Cleaner

2

3

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2.2.116

Reactor Water Cleanup Sludge

Processing

1

2

2.2.117

Shipment of Spent Resins from

Spent Resin Storage Tank

1

2

The licensee immediately repla:ed the out of date procedures

with up-to-date copies and stat:d that actions would be taken

to ensure proper distribution in the future.

These two examples of failure to properly review, approve, and .

distribute station procedures are considered an item of '

noncompliance (293/81-02-03).

(4) Station Procedure No. 2.3.1, Revision 3,

" General Action (Alcrm

Procedures),"Section III, states that a nuisance or malfunctioning

alarm may be silenced by pulling the alarm card, provided that

a yellow tag is placed on the annunciator window with the follow-

ing information: date, maintenance request number, and Watch

Engineer's name. An entry in the Control Room Log indicating this

action is also required.

Section III further states that an

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erratic alarm because of operation'at the setpoint does not require

a maintenance request number, but is required to be reactivated

when the parameter is no longer on the alarm setpoint.

An entry

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in the Control Room Log Book is required any time these actior.s

take place.

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During a review of control room annunciators on January 14,.1981,

the inspector observed that twenty-two annunciator panel alarms

were silenced by pulling the instrumentation card with no

evidence iof log entries being made

in the Control Room Log Book

and that sixteen of these had no maintenance request numbers. entered

on the yellow tag attached to the alarm window.

The licensee stated that a review of all annunciator. panels

would be performed to identify .the deenergized alarms and

that maintenance requests would be prepared for necessary

repairs by February 15, 1981.

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This failure to properly control and document deenergized

annunciator alarms is considered an item of noncompliance

(293/81-02-04).

(5) The inspector also discussed the status of main control

room annunciators with operators on duty to identify the

cause of the alarm, and with licensee management to review

actions being taken to eliminate unnecessary alarms in order

to provide operators with a " black board" if no problems

exist.

During the month of January, 1981 the licensee had taken

action to corr'ect three annunciators that had been pulled

and to clean ten annunciators that were in the alarm condition.

At the end of this month, however, there were still approxi-

mately twenty-one annunciators that were in the alarm condition

and twenty-one that had been deactivated with the alarm card

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pulled because of erratic (nuisance) conditions or because

the equipm,ent was not in use.

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Although the inspector did not identify any items of non-

compliance with the Technical Specification limiting conditions

for operation for the equipment associated with these annunciators,

concerns were expressea to the licensee's management in the

following areas:

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several annunciators which were in alarm could mask

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other problems associated with common inputs.

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several annunciators were normally in alarm during

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power operation (by design) while no abnormal condition

existed.

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several annunciators had their cards pulled because of

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being close to the setpoint and/or because of inoperability

or unused equipment.

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The licensee stated that it was also their desire to correct

the conditions which caused the annunciators to be in alarm

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or deenergized, and that they had established a program to

1 review each alarm, determine whether maintenance or a plant

-design change was needed, and assign the appropriate priorities

to effect resolution.

The inspector acknowledged the licensee's statement and

stated that progress in this area would continue to be

reviewed during further routine inspections.

4.

Followup on Events Occurring During the Inspection

a.

Main Stack Sample Pump Inoperable on January 7, 1981

The inspector verified that the licensee's reports met the require-

ments of 10 CFR 50.72 and that the response was in accordance

with~ procedural

and Technical Specification requirements.

Supplemental radiation monitor recordings for the affected times

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were reviewed by the inspector.

No abnormalities were noted.

No

items of noncompliance were identf.fied,

b.

Spent Resin Spill on January 17, 1981

Description of Event

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On January 17,1981 at 11:30 a.m. , water and about 20 cubic

feet of spent resin was accidentally' spilled in the Resin

Addition Room while auxiliary operators were transferring

spent resin from the

'B' Condensate Demineralizer to the

Cation Tank for backwashing.

About half of the spent resin

seeped under a door to the outside area immediately adjacent

to the building where it was contained.

An operator standing

outside the building observed the spill and immediately

notified the control room.

The leak was immediately isolated;

the licensee initiated a Radiation Alert, and notified

local, state, and federal agencies.

Station Management responded to the alarm and evaluated / monitored

further actions. At 3:00 p.m., after the s'ent resin had

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been contained, cleanup was in progress anc the licensee

determined that no significant personnel exposures or off-

site releases had occurred, the Radiation Alert was terminated.

The appropriate agencies were notified.

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Findings

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The inspector arrived at the site at about 3:00 p.m. to

monitor the:11censee's actions and determined that:

The site of the spill had been roped off and barricaded

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with most of the resin placed in several five cubic

feet containers.

Airborne surveys and radiation surveys in the immediate

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area outside the building indicated no significant off-

site release.

Discussions with HP supervisors indicated no internal

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contamination of the Watch Engineer (W.E.) who isolated

the spill.

Surveys of the W.E. following decontamination

(initially externally contamtnated to about 2000 cpm)

showed background activi.ty.

Discussions with station management at the Technical

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Support Center indicated that the cause of the spill

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was a valve lineup error during the last resin addition,

and that actions to preclude recurrence would be taken.

A review of control room logs and completed Radiation

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Emergency procedure notification forms indicated that

the Radiation Alert was reported as reqdired.

Findings resulting from a subsequent special inspection of

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this event will be addressed in Report No. 293/81-04.

c.

Circulating water Piping Corrosion

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On January 18, 1981, the licensee identified a leaking Circulating

Water System outlet pipe from the main condenser No. 1-2 water

box. Investigation revealed general corrosion of the piping,

possibly due to erosion of the internal rubber line.

Nondestructive

examination of the other three outlet piping sections revealed no

similar corrosion. Temporary repairs were made by welding and

providing external reinforcement.

The inspector spot-checked the licensee's sea water radioactivity

sample results taken in accordance with Temporary Procedure No.

81-04 on January 19, 1981, prior to dis' charging.

All samples

were less than minimum detectable activity.

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The inspector will follow the licensee's plans for permar. ant long

term repairs.

No items of noncompliance were identified.

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d.

'E' Servica Water Pumo(SWP) Discharge Check Valve

The inspector reviewed the licensee's actions in response to

noting chat the 'E' SWP discharge check valve failed to close

fully /ollowing routine system surveillance on January 19, 1981.

The check valve was repaired under Maintenance Request No. 81-29-

1 and returned to service on January 27, 1981.

No items of noncompliance were identified.

e.

Reactor Feed Pump (RFP) Trip on January 22, 1981

The inspector verified that the licensee's actions in response to

the trips of 'A'

and 'C' RFP were in accordance with station

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procedures and Technical Specifications.

The licensee's investiga-

tion revealed conservative suction pressure trip setpoints.

The

licensee recalibrated the suction pressure trips and control room

pressure indication and returned the unit to full power on January

23, 1981.

No items of noncompliance were identified.

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f.

Inadvertent Plant Trip on January 28, 1981

The inspector reviewed the licensee's actions in response to an

inadvertent reactor scram from full power January 21, 1981 to

verify that the reporting requirements of 10 CFR 50.72 were met

and that requirements of station procedures and the Technical

Specifications were met.

The licensee's investigation revealed that an isolated level

instrument (used for turbine trip) was returned to service too

quickly, momentarily affecting the RPS instruments which share

common sensing lines.

The inspector reviewed control room

indication and verified that actual level remained normal during

the transient.

The unit was returned to service on January 29,

1981.

No items of noncompliance were identified.

5.

Surveillance Observations

The inspector reviewed Technical Specification (T.S.) required sur-

veillance testing in order to verify that te' sting was performed in

accordance with approved station procedures and met the T.S. limiting

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conditions for operation.

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Portions of testing on the following systems were reviewed:

'A' Standby Liquid Control System Pump out of service for leaking

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gasket (redundant equipment testing and return to service testing).

'E' Service Water System Pump out of service to repair discharge

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check valve (redundant equipment testing and return to service

. testing).

The inspector also observed that several motor operated valves inside

containment were backseated due to previous indications of packing

leakage. .The inspector questioned the licensee concerning assurance

that these valves would meet the T.S. required closing times from the

backseat position. The licensee stated that a station approved

procedure is used to electrically backseat these valves, that all

surveillance testing for required closing times is done from the

backseat position and results to date have shown acceptable closing

times.

The licensee agreed, however, to revise the maintenance

procedure for electrically backseating motor operated valves to include

a record sheet which would be filled out for each valve and to specify

that a caution tag be placed on the valve's control switch indicating

this condition.

The inspector had no further questions.

No items of noncompliance were identified during this review.

6.

IE Bulletin Followup

The inspector reviewed the licensee's actions in response to the IE

Bulletins listed below to verify that the actions and responses adequately

addressed the concerns of the Bulletin.

IEB 80-21; " Valve Yokes Supplied by Malcolm Foundry Co. Inc."

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Following a request by the inspector the licensee committed to

provide a supplemental response which would address all valve

parts and not just yokes as specified in the Bulletin.

IEB 79-27; " Loss of Non-Class-1-E Instrumentation and Control

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Power System Bus During Operation." The licensee committed to

provide a supplemental response by mid-February, 1981 which would

include a schedule for completion of procedure revisions and/or

design changes.

IEB 80-24; " Prevention of Damaga Due to Water Leakage Inside

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Containment." The inspector reviewed the licensee's internal

memorandum summarizing a review of records from 1973 to the

present for any evidence of leaks inside containment and held

discussions with the staff engineer who performed the review.

One minor leak from a fan cooler in 1973 was identified.

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The inspector also reviewed system drawings to verify that the

Reactor Building Closed Cooling Water System is a closed

system and that the Service Water and Circulating Water Systems

do not penetrate primary. containment as open systems.

No

further information is required and this bulletin is

considered closed.

IEB 80-17; " Failure of Control Rods to Insert During a Scram

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at a,BWR" Supplement 3, Item No. 2 - The licensee modified

computer inputs and revised station procedures to implement

the acceptance criteria for scram discharge instrument volume

limit switch operability as described in the December 5, 1980

letter to Region I.

The inspector verified implementation of

the procedure changes by observations of a reactor scram on

January 28, 1981.

Supplement 4 - The licensee performed single rod scram tests

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on January 4,1981 in accordance with Temporary Procedure No.

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TP 80-87,'as required by item No. 2 of the Supplement.

Positive

indication of level from all 4 transducers was monitored on a

CRT scope and videotaped.

The test results were discussed in

a telephone conversation between the licensee, IE Region I, and

HQ personnel on January 5,1980, and it was concluded that the

CMS was considered operable.

The ir.spector also observed

the alarm indication in the control room from each of the four

transducers following a scram on January 28, 1981.

This bulletin remains open pending review of additional actions

required by the licensee including a full test of the CMS, and

implementation of periodic surveillance procedures.

No items of noncompliance were identified during the review

of these bulletins.

7.

Status of TMI Action Plan Category 'B'

Items

The inspector reviewed the current status of the licensee's implementa-

tion of selected Category 'B' TMI T.A.P. items. This information was

provided from a review of the licensee's December 15, 1980 response,

a draft version of the licensee's January 1,1981 response, and

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discussions with the licensee's station management.

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The status of each item as provided to the inspector on January 12, 1981

is described below.

' Item

Remarks

I.A.l.l(STA)

Training program has been implemented and degreed

(or equivalent) engineers are on shift.

I.A.1.3

The licensee has noc committed to all the NRC

(Shift Manning)

criteria.

Partial commitments (as specified in

separate correspondence to NRR and IE) will be

implemented via station procedures by January 16, 1981.

I.A.2.1 (4)

The training program has been implemented

(R0/SR0 Training

Program)

I.C.5 (Feedback

The licensee has implemented procedures.

of Operating

Experience)

I.C.6 (Veri fy

The licensee has not yet committed to this item.

Performance of

The licensee plans to review station policy and

Operating

determine by Juae, 1981 to what extent the NRC

Activities)

criteria will be implemented.

II.E.4.2.(Sa)

The licensee considers that the current setpoint

(Containment

meets the criteria.

Pressure Setpoint)

II.E.4.2.(6)

The licensee had not implemented the " Interim

(Containment

Criteria for Containment Vent and Purge Valve Opera-

Purge Valves)

tion; and committed to have procedures in place by

January 15, 1981 to limit operation to 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br />

per year.

II.K.3.22a

Procedures to implement this item wou',d be

(RCIC Suction)

prepared by January 15, 1981

III.D.3.3

Upgrading of Iodine monitoring had been implemented.

.

(Inplant Rad.

Monitors)

The inspector had no further questions concerning the status request

and forwarded the information to NRC:IE HQ for review.

4

9

4

15

.

8.

Emergency Procedures for Coping with Anticipated Transients Without

Scram (ATWS) Events

a.

Scope and Acceptance Criteria

The inspector reviewea 'he licensee's Emergency Procedures describing

actions required during ATWS events and other transients resulting

i.1 the inability to shutdown with control rods.

This review was

performed to determine whether the licensee's procedures contained

the following items:

Actions specified in IE Eulletin 80-17, Paragraph 4

-

-

Operator authority, responsibility, and criteria for initiation

of the-Standby Liquid Control System (SLCS), and

The requirement for the SLCS key to be readily available.

-

The following procedures were reviewed:

2.1.6 ' Reactor Scram," Revision 12

-

2.1.5 " Controlled Shutdown from Power," Revision 19

-

5.3.15 " Reactor Isolation Without Scram or Loss of Offsite Power

-

(ATWS)," Revision 4

5.3.2 " Inability to Shutdown with Control Rods," Revision 7

-

2.4.1 " Stuck or Inoperable Control Rod Drives," Revision 3

-

2.4.3 " Rod Drift," Revision 6

-

2.4.4 " Loss of Control

Rod Drive Pumps," Revision 3

-

1.1.1 " Station Organization Responsibilities," Revision 7, and

-

-

2.2.24 " Standby Liquid Control

System," Revision 7.

b.

Findings

The inspector determined that the licensee's procedures contained

the requirements and criteria specified in paragraph a.,

above,

.

"

for coping with ATWS related events.

l

The inspector also discussed these procedures with the Senior

Nuclear Training Specialist who stated that criteria for use of

the SLCS was included as a routine and continuing part of the

licensee's training program.

_

_

-

.

-

s

e

16

The inspector has observed the SLCS initiation key readily available

on the main control panel (as required by station procedures)

during daily tours of the controi room.

No unacceptable items were identified during this review.

9.

Licensee' Event Report Followup

The LER listed below was reviewed to determine the sa'fety significance

and whether the reporting requirements of the Technical Specifications

were complied with.

LER 80-94/04T; Anomalous Measurement of Iodine-131 in milk from

-

Plymouth Plantation

The inspector questioned the licensee concerning an apparent error in

the event date and' justification for the conclusion that the measured

concentration was " unquestionably the result of a recent Chinese

weapons test." The inspector also stated that the report was about

four days late.

The licensee acknowledged the. inspector's comments, stated that the

~ event had inadvertently been considered in the category of a 14 day

vice 10 day report and that a revised LER would be issued correcting

the event date and providing further details justifying the conclu-

sions concerning the cause of the increased iodine concentration.

The inspector reviewed the past seven anomalous measurement reports

which had been issued within the required time frame and considered

this an isolated case.

The inspector also reviewed the revised

report LER 80-94/04T-1 and had no further questions.

10.

Personnel and Organization Changes

The inspector reviewed the qualifications of personnel recently assigned

to both on-site and off-site management positions.

This review was

performed to determine whether the education, training, and

experience described in resumes provided to the inspector by the

licensee met the requirements of ANSI N18.1-1971 " Selection and

Training of Nuclear Pover Plant Personnel."

Positions reviewed included the following;

. ._ .

. . - .

. - -

.

1

,

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17

.

.

On-Site

Deputy Nuclear Operations Managers (2)

Staff Assistant - Nuclear Safety

Off-Site

Quality Assurance Manager

,

Nuclear Engineering Department Manager

Nuclear Operations Support Manager

The inspector determined that the qualifications of the personnel

assigned met the requirements of. ANSI N18.1-1971 and had no further

questions.

11.

Survey of Possible Leaking Detector Sources

Because of concerns at another power plant, the inspector was

requested to inform the licensee of the possibility of removable

contamination on certain detectors manufactured by Ion Track

t

Instruments, Inc.

,

On January 22, 1981, the licensee performed a leak test of the sub-

ject . instruments (four of model No. 75, ar.d one model No.c70) with

all Ni-63 source smears indicating less-than minimum detectable

activity (less than 10 pico curies beta / gamma).

The inspector had no further questions and provided this informa-

tion to NRC Region I personnel.

12.

Exit Interview

At periodic intervals during the course of the inspection, meetings

were held with senior facility management to discuss the inspection

.

scope and findings.

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.

4

l