ML20005D732

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Insp Rept 50-458/89-41 on 891101-15.No Violations Noted. Major Areas Inspected:Reactor Recirculation Flow Control Sys Malfunctions of 890117 & 18 & Mgt Actions Re Direction & Oversight of Events
ML20005D732
Person / Time
Site: River Bend 
Issue date: 12/04/1989
From: Gagliardo J, Jaudon J, William Jones
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20005D731 List:
References
50-458-89-41, NUDOCS 8912140371
Download: ML20005D732 (11)


See also: IR 05000458/1989041

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APPENDIX

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U.S. NUCLEAR REGULATORY COMMISSION

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RE,GION IV

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i NRC Inspection Report':" 50-458/89-41-

Operating License:

NPF-47

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Docket: 50-458

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Licensee: GulfStates'UtilitiesCompany--(GSU)

P.O.~ Box 220

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St. Francisv111e,- Louisiana 70775~

(Facility Name: River Bend Station (RBS)

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Inspection 4 At:" RBS. St. Francisville, Louisiana

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. Inspection Conducted: November 1-15, 1989'

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[ Inspectors:

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.E.CGgiardo, Chief,OperationalProgramsSection

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AI. B Jones, Resident Inspector

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11nspection Sumary

$ nspection Conducted November 1-15, 1989 (Report 50-458/89-41)

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Areas-Inspected: .Nonroutine, unannounced inspection of the reactor recirculation

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- flow control system malfunctions of January 17 and 18, 1989, and the management

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actions =related to the direction and oversight of these events...

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8912140371 891204

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ADOCK 05000458

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Results: Within the area inspected, several potential violations were identified

involving failure to control troubleshooting and repair activities adequately.

- failure to perform post-maintenance testing, failure to take appropriate

corrective actions regarding the malfunctions, and failure to review and

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evaluate adeouately the malfunctions (Paragraph 2.).

Collectively, these

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potential violations raise serious concerns regarding'the effectiveness of

management's response to the malfunctioning flow control system, particularly

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since troubleshooting and repair activities resulted in inducing uncontrolled

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reactivity changes that resulted in several power and flow oscillations.

Further, management apparently failed to recognize the significance of the flow

control malfunctions and the resulting uncontrolled reactivity and flow oscilla-

tions. Consequently, corrective actions and actions to prevent recurrence did

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not provide adequate assurance that a similar event would be handled in a more

conservative manner.

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DETAILS

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Persons Contacted

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J. A. Bowlby, Shift Supervisor

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J. Boyle, Shift Supervisor

  • G. A. Bysfield, Supervisor, Control Systems

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J. E Booker, Manager, Oversight

  • J.,W. Cook, Lead Environmental Analyst, Nuclear Licensing

D. Dawson, Reactor Operator

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  • T. C. Crouse, Manager, Ouality Assurance (0A)

J. C. Deddens Senior Vice President, River Bend Nuclear Group

  • S. Finnegan~, Shift Supervisor
  • L. A.' England. Director Nuclear Licensing

A.- 0. Fredieu, Supervisor, Operations

C. A. Fu, Field Engineer, G.

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K. J. Giadrosich, Supervisor, Cuality Engineering

P. D. Graham; Executive Assistant

D. Hicks, Field Engineering, G. E.

R. Jackson, Coordinator, Nuclear License Training

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M. Jones, Training Instructor

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  • D. N. Lorfing, Supervisor, Nuclear Licensing

I. M. Malik Supervisor, Operations OA

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  • W; H. Odell, Manager, Administration
  • T. F. Plunkett, Plant Manager

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  • M. F. Sankovich, Manager, Engineering
  • J. P. Schippert Assistant Plant Manager, Operations and Radwaste
  • R. G. West. Assistant Plant Manager, Technical Services

The inspectors also interviewed additional licensee personnel'during the

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inspection period.

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  • Denotes those persons that attended the exit interview

conducted on November 15, 1989.

E. J. Ford, NRC Senior Resident also

attended the exit-interview,

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2.

' Reactor Recirculation Flow Control Valve Instability

This inspection was conducted to review a previous operational problem

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with the "B" reactor recirculation flow control valve-(FCV) that occurred

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on January 17-18, 1989. During the Maintenance Team Inspection (NRC

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Inspection Report 50-458/89-04) performed during the period of

September 18 through October 17, 1989, the inspector reviewed Condition

Reports 89-0042-and 89-0043, which documented operational instability of

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the "B" recirculation FCV. The inspector initiated an Unresolved Item

(458/8904-01) as a result of this review. The inspector's followup to

this Unresolved Item is discussed in the following paragraphs,

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-DETAILS-

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Persons Contacted

J. A. Bowlby, Shift Supervisor

J. Boyle, Shift Supervisor

  • G. A.-Bysfield, Superviscr, Control Systems

~J. E. Booker, Manager.. Oversight

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  • J. W. ' Cook, Lead Environmental Analyst, Nuclear Licensing

D. Dawson, Reactor Operator

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  • T. C. Crouse, Manager, Ouality Assurance (OA)

J..C. Deddens Senior Vice President, River Bend Nuclear Group

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  • S. Finnegan, Shift Supervisor
  • L. A. England, Director, Nuclear Licensing

A. O. Fredieu, Supervisor, Operations

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C. A. Fu, Field Engineer, G. E.

K. J..Giadrosich,; Supervisor. Cuality Engineering

P. D.- Graham, Executive Assistant

D. Hicks, Field Engineering, G. E.

R. Jackson, Coordinator, Nuclear License Training

M. Jones. Training Instructor

  • D.'N. Lorfing Supervisor, Nuclear Licensing

1. M. Malik, Supervisor, Operations OA

  • W. H. Odell,' Manager, Administration
  • T. F. Plunkett, Plant Manager
  • M. F Sankovich, Manager, Engineering

, J. P. Schippert Assistant Plant Manager, Operations and Radwaste

'*R.-G. West, Assistant Plant Manager, Technical Services

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The inspectors also interviewed-additional licensee personnel during the

inspection period.

  • Denotes those persons that attended the exit interview

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conducted on November 15, 1989.

E. J. Ford, HRC Senior Resident also

attended the exit interview.

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2.

Reactor Recirculation Flow Control Valve Instability

This inspection was conducted to review a previous operational problem

with the "B" reactor recirculation flow control valve (FCV) that occurred

on January 17-18, 1989. During the Maintenance Team Inspection' (NRC

Inspection Report 50-458/89-04) performed during the period of

September 18 through October 17, 1989, the inspector reviewed Condition

. Reports 89-0042 and 89-0043, which documented operational instability of

the "B" recirculation FCV. The inspector initiated an Unresolved Item

(458/8904-01) as a result of this review. The inspector's followup to

this Unresolved. Item is discussed in the following paragraphs,

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Background-

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On January 16, 1989, the licensee synchronized the main generator

onto the grid following replacement of a failed ground fault relay.-

Reactor power escalation continued through January 17,1989,' to

=approximately 8.4 percent. At 10:18'p.m., the "B" recirculation FCV

hydraulic power unit (HPU) tripped because of excessive servo error.

A control: room log entry made on January 17, 1989, at 10:18 p.m.,

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states that,

"HPU for 'B' flow control. valve tripped due to excessive servo

error. Valve position 76%.

Restored.HPU, zeroed servo error,

reset lockup.

Erratic cycling of servo error was observed with

valve motion attempting.to f ollow signal. HPU again tripped on

servo error (motion inhibit). Valve position 74%."

During the first event, the "B"

reactor recirculation loop flow

increased by approximately 2 million pounds mass per hour (mlbm/hr)

as indicated by the individual Recirculation Loop Flow Chart

Recorder B51-R614.- After restoring the "B" HPU and resetting the

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motion inhibit, the "B" recirculation loop flow decreased' by 1

mlbm/hr.

The "B" HPU remained shutdown with the "B" FCV in the " lockup"

condition. However, a slow hydraulic fluid leakage past the "B"

FCV

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actuator allowed the FCV to drift in the open direction. This

resulted in~ a slow reactivity addition to the reactor. During the

next 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, the reactor coolant flow through the "B" recirculation

loop , increased from approximately 29 mlbm/hr to 34 mlbm/hr. Because

of the increased feedwater demand resulting from the increased steam

production at the higher reactor thermal power (approximately

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92 percent), the reactor ^ operator at the controls (ATC) was required

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to place the startup feedwater regulating valvetinto service. At the

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time, the third _feedwater regulating valve had been tagged out-of .

service.and'was not available. Later, to maintain total reactor

coolant flow below the 100 percent core. flow limit of'84.5 mlbm/hr,

the ATC operator decreased the "A"

recirculation loop flow. -This

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placed the plant into a 2-hour Technical Specification Limiting

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Condition for Operation (Technical Specification 3.4.1.3) with thea

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recirculation loop flow mismatch greater than 5 percent with total

core flow greater than 70 percent. The* basis for the flow mismatch

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specification is to ensure compliance with the emergency core cooling

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system loss of coolant accident analysis design criteria for two

recirculation loop operation.

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On January 18, 1989, at 12:07 a.m., the licensee began inserting

control rods to reduce the control rod line to less than 80 percent.

This was. performed to ensure that if the recirculation pumps tripped,

the subsequent flow coast down would be below the area on the power-

to-flow map where thermal hydraulic instability had been experienced

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at other boiling water reactors.c (Referencellnformation4 Notice

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88-39: LaSalle Unit 2 loss of Recirculation, Pumps with_Powert

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Oscillation Event). This action was completed within'approximately'

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3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

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- ' At this time, the licensee initiated prompt Maintenance Work

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-Order (MWO) R56226 to troubleshoot the "B" FCV " lockup" and excessive'-

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positive and negative control demands. .The MWO authorized the

performance of. troubleshooting activities under the direction-of th5

system engineer. The system engineer subsequently directed the :

instrument and control (I&C) technicians to lift the'1eads from the

"B": FCV' linear variable differential transducer (LVDT), which provided

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feedback to the'"B" FCY controller on.FCV position.

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At approximately 1:40 a.m. on January 18, 1989, the ATC operator was

able to drive the?"B" FCV in the close direction. This was accomplished

by lifting the: leads from the "B"

FCV LVDT, which provided feedback

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to the "B"_FCV controller on FCV position. A negative servo error

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was then input on the "B" FCV by the ATC -operator. The "B" HPU then

started and the valve motion inhibit reset; When the valve reached-

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the desired position, the ATC operator tripped the HPU to stop the-

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. valve motion. The "B" FCV was again operated in the close direction

at approximately 4:00 a.m. on January 18, 1989, utilizing the method

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described above,

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At 6:00 a.m. on January 18. 1989, the oncoming operations crew

-relieved the operations crew that had originally experienced the

malfunction (RBS operations. crews work 12-hour shifts). -At approximately

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8:20 a.m., the ATC operator. attempted to close the "B" FCV by restarting

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the "B" HPU and resetting the motion inhibit. The operator input a

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. hen"the

small negative servo error as indicated by the controller.

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ATC operator reset the "B" FCV " lockup", the "B" FCV ramped open from

84 to 97 percent. Recirculation "B" loop flow changed between 30.5

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and 35.5 mlbm/hr. The ATC operator stopped the "B" FCV movement

by locking up the FCV. Total core flow increased to-104 percent ~and

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the recirculation loop 5 percent flow mismatch.. limit was exceeded.

Total core; flow remained above 104 percent for approximately 3.5

minutes before the ATC operator was able to close the "B" FCV to

match the "A" recirculation loop flow. Reactor thermal power increased

from approximately 74 to 77 percent as indicated by the average power

range monitor (APRM) strip chart.because of the above event. The

licensee has since postulated that the input servo error may have

actually been slightly positive, which ccused the "B" FCV to ramp

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open.

At approximately 11:50 a.m. on January 18, 1989, the ATC operator was-

able to operate the "B" FCV in the close direction to match the "A"

recirculation loop flow. This was necessary because of the "B"

FCV

drift that was experienced with the FCV in '? locked up."' In each of

the above cases, total core flow was allowed to drift to approximately

100 percent.

In each case, the licensee was relying on the malfunctioning

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control system to control reactivity and remain within the RBS

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Technical Specification limit for recirculation loop flow. The

"A" and "B" FCV were then operated in the close direction to reduce

total core l flow to approximately 85 percent.

As' a result of the-troubleshooting activities authorized by MWO RS6226..

the licensee concluded that a control card in'the "B" FCV control

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circuit had failed and that a solenoid valve in the "B" HPU was not-

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' operating properly. At approximately 2:30 p.m., the licensee reduced

total-core flow to 61 percent and reactor thermal power to 60 percent.

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This_ action was_taken by the reactor operators to place the "B"

recirculatior loop'into a condition where the "B"

FCV would not

drif t while the "B"' HPU was- out-of-service for the servo valve -

and control card replacement.- Another consideration regarding this

decision was the fact that a 10 percent recirculation loop flowa

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mismatch is, allowed with total core flow below 70' percent. The-

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control card replacement was authorized by MWO R56226 and the solenoid'

valve replacement was authorized by MWO R118514.p

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After completion of the above maintenance activities, at about.

4: 18 p.m., the "B" HPU was started. When the "B" FCV motion inhibit

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was reset, the "B" FCV immediately began following the oscillating

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servo error. .The amplitude of each FCV movement increased with each

cycle until the ATC operator shut down the "B" HPU af ter 5 seconds.

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The emergency response infomation system:(ERIS) data taken indicated'

neutron flux varied between 45 and 8B percent during th_e "B"

FCV

movement. Reactor thermal . power remained relatively steady. The

individual ' recirculation loop flow chart recorder indicated that the

"B" HPU was started and-the motion inhibit reset on at least three

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occasions following the above event. The individual recirculation

loop flow chart recorder indicated that similar "B"

FCV movements

occurred, but ERIS data was not archived fortthe subsequent "B"

FCV

' movements. The-licensee subsequently; determined that the linear

velocity transmitter had failed (as an open circuit) in the drywell,

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and-thus the "B" FCV control' circuity was not receiving a FCV velocity

feedback signal. During this period, the. licensee also determined

that the "B" FCV was moving in excess of the RBS Technical Specifica-

tion limit of 11 percent per second of valve stroke (Technical

-Specification 4.4.1.1.1).

The licensee subsequently declared the "B"

recirculation loop inoperable and entered single loop operation (SLO)

to correct the failed control circuitry.

Prior to the licensee implementing SLO on January 18, 1989, licensee

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engineering personnel discussed with the NRC resident inspector the

planned corrective maintenance actions for the "B" loop recirculation

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FCV. The inspector questioned the potential impact of the proposed

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technical solutions. Various applicable electrical drawings and

schematics were utilized during this process to verify that the

proposed actions would have conservative results.

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The licensee hali determined that a velocity transducer or its signal

wiring was open circuited for the "B" FCV,'thus causing it to be-

inoperable.. The licensee _prepered an unreviewed safety question

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determinationi(USOD) review for the proposed action which involved

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adjustments-to the FCV controller. The adjustments would have the

effect of changing the control of the FCV from a velocity and position

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controller.to a position controller only. Subsequent to these

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discussions,' the inspector discussed, with regional and NRR personnel,-

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the: details of the problems with the "B" FCV, the' licensee's planned

corrective actions, and their intent to go to single loop' operation.

In conjunction with entry into SLO, the inspector reviewed the-implemen-

tation of Procedure G0P-0004, " Single Loop Operation" and observed

Surveillance Test Procedure STP-050-3001, " Power Distribution- Limits

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Verification."

b.

Assessment'of the Malfunctioning Flow Control Valve System

This section of the report assesses the licensee's actions that

resulted in, or followed the events described in Section 2.a. above.-

It also identifies the potential violations that were identified by

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the inspectors.

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The licensee had experienced periodic problems with the recircu -

lation FCVs drifting during the 2 years prior to these events.

Corrective actions to stop the valves from drifting while

" locked up" were not effective until the FCV actuators were

rebuilt during the last refueling outage. Based on this past

experience, when the "B" HPU tripped to the maintenance mode on

January 17, 1989, because.of excessive FCV' servo error, the ATC

operator made several attempts to restart the "B" HPU. These

attempts resulted in the FCV moving with the oscillating servo

error, and ATC. operator intervention was required to " lockup"

the "B" FCV and terminate the "B" FCV movements.

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The MWO that authorized the-troubleshooting activities to be

perfomed at the. direction of the system: engineer did not provide

positive procedural controls. The engineer subsequently

directed the I&C technicians to lift the control leads from the

"B" LVDT. This resulted in the control system for the "B"

FCV

sensing the valve to.be at 50 percent open. With the leads

lifted, the ATC operator was able to establish a negative servo

error and drive the FCV in the close direction. The valve was

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then stopped by the ATC operator shutting down the HPU when the

valve reached the desired position. The licensee's failure to

provide positive procedural controls for the troubleshooting of

the flow control system (which involved lifting leads from the

control circuits) is a potential violation of Technical Specification 6.8.1.

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On January 18,'1989,'at approximately 8:20 a.m., the ATC operator.'

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apparently had not establish'a sufficient _ negative servo error

prior to restarting the "B"

HPU. When the FCV motion inhibit

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<was reset.ithe~"B" FCV ramped opened from 851t0 97 percent and

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~ he HPU shutdown. This caused the total-recirculation core flow)

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to exceed 10.4- percent for greater than '3 minutes until the "B"

FCV could be' driven,in the closed direction as described above.

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The licensee documented the above event in Condition

. Report 89-0042. This' is another example of insufficient proce-

dural guidelines / directions, which is'al potential violation

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o.f Technical' Specification 6.8.1 thatfled to an operational

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event.

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Replacement of the "B" FCV control circuit " Modicon" card and

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"B" HPU servo valve were authorized by MW0s R56226 and R118514 .

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respectively. Neither maintenance activity-had a specified

functional / operability test performed prior to placing the compo-

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nent back.in' service. -Gain ~ adjustments to both the position and

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velocity controllers appeared to have been made~on January 18,

1989, in accordance with field engineers direction, but the

unreviewed safety question determination was not performed 'ntil

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' January 21s 1989, when the nuclear steam supply systam vendor

recommended specific gain adjustments to make the controller

operate in the' proportional mode only( This is another example of

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activities, which were performed without specifically approved

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procedural. guidance / directions and constitutes a potential

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violation of Technical Specification 6.8.1.

The fact-that-th_e

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gain adjustment were made without a safety evaluation is also a

potential violation of the requirement of 10 CFR 50.59.

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Following replacement of the control card and solenoid valve,

the operator started the "B" HPU. When the FCV motion inhibit

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was reset, the FCV began tracking .the oscillating servo error

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signal. The FCV position modulated between 25 and 38 percent

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open. .The neutron flux subsequently varied between 45 and

88' percent as indicated on the APRMs. ~The neutron flux oscilla-

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tions were a direct result of the FCV movements. The. amplitude

of the valve swings, while tracking the servo error, increased-

with each cycle. The FCV cycled with a frequency of less than is

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Hz and the event was terminated by the ATC operator.after

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approximately 5 seconds. The "B" FCV was subsequently operated

an additional three times for troubleshooting activities as part

of MWO R56226.

In each case, the "B"

FCV attempted to respond

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to the oscillating servo error, and the flow charts indicated

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that flow oscillations similar to those in the initial event (at

8:20 a.m.) were experienced. The initial event was documented

by the licensee on Condition Report 89-0043. The licensee's

failure to have detailed post-maintenance test procedures-to

test the flow control system following the repairs and the fact

that the testing was performed on an operating loop led to

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the subsequent' power and flow oscillations ~ The licensee's

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Administrative Procedure - ADM-0028, " Maintenance Work Order,"

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Revision-10, paragraph 5.12.26 states, " Ensure post-maintenance

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- testing is performed and the required documentation-is-attached

to the MWO.

Appropriate post-maintenance testing shall be

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specified for all components that have been reworked, repaired,_

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Text / Operability Area of the MWO." "The licensee's failure to

replaced..or modified. . Record test results'in the Functional

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have documented post-maintenance testing of the required' flow-

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. control system with adjusted gain: controls, is a: potential

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violation of this procedure and Technical ^ Specification 6.8.1.

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On January 18. 1989, the licensee determined that the "B"

FCV:

movements documented in Condition Reports.89-0042 and 89-00431

exceeded the 11 percent per second Technical. Specification

limit for the. valve's movement in both open and close. directions.

- The licensee subsequently declared the "B" recirculation loop

inoperable and entered into single loop operation.- This-

determination was made after completion of the "B" FCV' trouble-

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shooting that led to the power and flow oscillation event described

in Condition Report 89-0043.

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Condition Report 89-0042 addresses the RBS Technical Specifica-

tion' requirement that the FCVs " lockup": on a loss of HPU pressure.

The operators' had observed a 13 percent per hour of full stroke

drift of the "B" FCV at the higher total core flow rates.- The

licensee cited the October 9, 1981, loss of coolant accident

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(LOCA) that analysis with recirculation FCV closure (LRG-II) in

determining'the FCV drift, with the valve " locked up," was

within the Technical Specification requirement. The LRG-II

analysis references the emergency core cooling system (ECCS)

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analysis presented in chapter 6.3 of the USAR which assumes the

FCVs undergo a " lockup" in their present position on high

drywell pressure following a LOCA. The analysis also assumes

' that one FCV fails to " lockup" and closes at'a rate of,11 percent

per second. The FCV closure results in an increased peak fuel

cladding temperature (PCT) of 450F. The increased PCT was

determined to remain within the limits of 10 CFR 50.46. Because

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the FCV drift problem had been in the conservate direction

(open) and the drif t rate magnitude was small, the licensee

concluded the "B" FCV was within the RBS Technical Specification

requirement for FCV " lockup". The inspectors did not concur

with this conclusion. The FCV had an uncontrolled drift of only

13 percent per hour, but this drift was observed in the " lockup"

mode when no valve movement was expected. The flow control

system was malfunctioning and the licensee did not take a

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conservative approach in their analysis.

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The licensee subsequently concluded that the 1,inear' velocity

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transducer had failed with an open circuit in the drywell. _ This

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resulted in the complete loss of the velocity feedback. signal to

the contro_1 system. During the second refueling outage, the

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licensee identified that fluid from the FCV actuator had leaked

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onto the linear.variab1e transducer (LVT) and caused the open

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circuit. A modification was made to'both FCVs to direct any

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' hydraulic fluid leaks away from1the:LVTs and the LYDTs.

The NRC staff is concerned;that in addition to the potential

violations,-the licensee's plant and engineering staff relied on

the malfunctioning "B" flow control system to maintain recircu-

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lation loop flows within the RBS Technical Specification mismatch

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limits. The' action resulted in uncontrolled reactivity' changes,

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c.

Management lnvolvement

Operations: management' up to the level of assiistant plant manager for.

operations;was aware of the flow control. problem at the time.of the

' event. ; Although the licensee did insert control rods and reduce the

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control rod line to less than 80 percent early in the sequence of-

events, it does not appear that stringent precautions or guidance was

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given to the. operators other than a' tacit approval to continue their

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troubleshooting activities.

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The inspectors interviewed the shift supervisors and other members of

the operating crews 'that were on shift during the course of these

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events. The operating log for the evening of January 17.--1989,

indicates that the operations supervisor was notified of the -problem

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at about 10:30 P.M., which was s_hortly after the problem wi_th the FCV

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was'first observed. According to the shift supervisor that was on

watch at the time of the initial problem on January- 17, 1989, he was

notified by the operations supervisor to " restart the plant" Land

reset the " motion inhibit".for the FCV. The shift supervisor said

that every time they tried to reset the " motion inhibit" and tried to

close the' valve, it would begin to.open instead.

He said that the

engineer, who had been called in to troubleshoot the problem lifted

a lead in the circuit to restrict the motion of the-valve in the open

direction. An MWO (R56226)'had been issued to troubleshoot the flow

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control-circuit, but the inspectors found no definitive procedural

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controls cther than Procedure GMP-0042 (which is the procedure for

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controlling lifted leads) to cover these troubleshooting activities.

The inspectors asked the. operators if they were concerned about

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Two of the operators (one was a

shift supervisor)g with the plant.

what was happenin

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said that they were concerned about the uncontrolled

reactivity additions and had expressed their concerns to their management.

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The managers said that their' management was not happy with the

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situation, but they were satisfied with what was being done to

correct the problem.

None of those interviewed said that they had

recommended to their management that the plant be shutdown or that

the plant be placed into single loop operation until the problem was

resolved.

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After the problem had been. initially identified as being caused by a

defective: solenoid'and a defective control card, tie- solenoid and the

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control card were replaced. The licensee reduced tower and recircula-

tion flow to less than 60 percent;to make the repairs. Upon completing.

the repairs, the licensee perfonned what was termtd as' troubleshooting

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activities on the system. They did not term these activities as'

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post-maintenance testing, and no specific post-traintenance testing

was performed following the replacement of the card and solenoid.

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The " troubleshooting" activities that were performed following the

maintenance resulted in the; flow and power oscillations, which

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occurred on four separate occasions.

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d.

' Lessons Learned:and Corrective Actions

The inspection findings indicated that the licensee did not understand

the significance of the events of January 17 and 18, 1989. As a result,

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their corrective actions were not appropriate to the significance of

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-the events.

The. inspectors asked the individuals' interviewed to discuss the;

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lessons they learned from the events of January 17 and 18, 1989.

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Most of the individuals interviewed said that they could not think o.f

any lesson learned-from the events. A;few of the operators did note

that as a result of the events, they' had come to know. more'about <the

recirculation flow control system. Only one'of the individuals

interviewed expressed concern with what had happened;

He said that

he had mentioned' this concern to a manager. . His concern involved the-

fact' that specific procedural controls and technical" specifications

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are, prescribed for. reactivity additions because of control' rod

dri f ts. He said that the changes in recirculation flow,also induced

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reactivity changes -but.there werelno prescribed actions to be taken

forithis mode of reactivity addition. He said that he could not

understand why the recirculation flow changes were not covered by

similar Technical' Specification and procedural requirements;

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Several of the operators interviewed said that they had experienced

drifting with the FCV prior to the events of January '17 and 18,1989.

Apparently the. licensee's failure to recognize the significance of-

the earlier problem contributed to their failure to give more serious

attention to the events of January 1989.

The Independent Safety Engineering Group (ISEG) was tasked to analyze

the performance of the plant following the initial conduct of SLO.

Following the events of January 17-18, 1989, the plant entered into

SLO for the first time.

ISEG evaluated the SLO oprations and the

events leading to SLO. This evaluation was documented in Operating

Experience Report (0ER)89-004 that was issued on July 21, 1989. The

inspectors asked the individuals interviewed regarding their awareness

of the report, which analyzed-the events that led to the SLO and the

success of the SLO. Most of the individuals interviewed were unaware

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of the ISEG report, but said that'it may have been placed on their'

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required reading list and they.just did not_ recall it. The ISEG

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report addressed the flow oscillation problems and had a number of

good conclusions and recommendations that should have been the subject

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of critical evaluation by the plant staff. At the exit interview,

the inspectors were provided with a copy of the staff's response to

some of the~ recommendations of the report. The response, which was

dated November 7, 1989'(nearly four months after the report was

issued), did not address all of the report issues. The recommendations

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that were addressed (four of the six) were only marginally acceptable.

Recommendation 89-004-04, which urged the use of $1.0 to troubleshoot

flow control problems.and prevent the oscillations of January 1989 -

were not effectively addressed in the response. This does not reflect

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a strong safety concern on the part of plant management for a problem

s'that has such an effect on plant power levels.

The inspectors also asked the individuals interviewed to describe any

training-that-they had received-concerning the events of January

1989. The inspectors found that no training had been provided to the

operating crews regarding these events. The assistant plant manager

said that he believed:that the two condition reports, which described

the ev'ents, had been placed on the required reading lists for the

operators. The operators did not recall reading the condition

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reports, and the inspectors were not successful in locating a' copy of

the-required reading list that contained the subject condition-

reports. The training supervisor interviewed said that a training

subject, such as the condition reports, would normally not be placed

into the operator training schedule unless it was recommended by the

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operations staff. The licensee should consider the need for the

training staff to take a more pro-active approach to determining

lessons learned issues that need to be included in the training

programs for all plant disciplines.

The inspectors found that CA had performed a surveillance regarding

single loop operations, but they had not recognized the significance

of the events of January 1989 even though they had received the ISEG

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report and the two condition reports that addressed these events.

Cuality assurance:also needs to be more sensitive to these types of

events and take a pro-active approach to alerting management regarding

potential problems that have safety significance.

The inspectors found that the facility review committee (FRC) had

reviewed Condition Report 89-0042 for resolution of the FCV system

failures. However, the inspectors noted that the FRC did not consider

the fact that the operations staff was relying on the malfunctioning

FCV system to remain within the RBS Technical Specifications. This

condition was apparent in both Condition Reports 89-0042 and 89-0043.

The FRC, however, had not reviewed Condition Report 89-43, which

documented the flow and power oscillations. According to a licensee

representative they had not reviewed Condition Report 89-43 because the

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event reported in it did not involve a Technical' Specification limit

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being exceeded. The FRC's review responsibilities in Technical

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Specification 6.5.3 require that they review issues that present a

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potential hazard to nuclear safety. 'The events of. January 1989

certainly approach a reasonable threshold-for issues.that- should be

included in this' category.. This is a potential violation.of the ,

requirements of. Technical Specification 6.5.3.

The licensee needs to'

reevaluate the screening process employed to assure that this committee

is receiving the material (i.e. significant conditions reports)-

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necessary to carry out its intended mission.

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Conclusions

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The weaknesses identified in these sections indicate a number of

potential violations, wtiich individually may not constitute a signifi-

cant safety concern, but collectively raise serious questions regarding

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.the safety consciousness of the operations and engineering staffs and

'their managment. Further, the weaknesses. identified above regarding

the subsequent review and evaluation of this event raise concerns

about the effectiveness of management controls and oversight over the

RBS corrective action program. The apparent lack of responsiveness

of the operations staff to the ISEG report conclusions and.recommenda-

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tions'is of particular concern in this regard.

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3.

Exi t~- Interview

An exit' interview was conducted with licensee representatives! identified

in paragraph 1.on November 15, 1989. During this interview, the inspectors

reviewed.the scope and findings of the report. Other meetings between the

inspectors and licensee management were held periodically during the

inspection period to discuss identified concerns. The licensee-did not-

identify as proprietary any information;provided to, or reviewed by, the

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inspectors.

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