ML20050A946
| ML20050A946 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 03/18/1982 |
| From: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20050A944 | List: |
| References | |
| 50-244-82-03, 50-244-82-3, NUDOCS 8204020428 | |
| Download: ML20050A946 (2) | |
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APPENDIX A
.N0TICE OF VIOLATION Rochester Gas and Electric Corporation Docket No. 50-244 Ginna License No. DPR-18 During the inspection conducted on January 1,1982 through February 28,1982, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the following violations were identified.
A.
10 CFR 50.55a(g)(4) requires, in part, that components which are classified as ASME Code Class 1, 2 or 3 meet the requirements set forth in Section XI of the ASME Boiler and Pressure Vessel Code and Addenda.
Ginna Station Quality Assurance Manual, Appendix C, dated February 1, 1981, paragraphs 2.1 through 3.2, state that the Inservice Pump Testing Program was developed in accordance with the requirements of Article IWP of the 1977 Edition of Section XI of the ASME Boiler and Pressure Vessel Code through the Sunner 1978 Addenda, and further, lists the pumps which are tested in accordance with Article IWP of Section XI.
Article IWP-6230 requires that the inservice test program include a reference value, alert limit and required action limit for individual pump bearing temp-eratures.
Contrary to the above, as of January 7,1982, the Inservice Pump Test Program did not include a reference value, alert limit, or required action limit for bearing tempcratures associated with ASME Class 2 or 3 pumps listed in paragraph 3.2 of the Ginna Station Quality Assurance Manual, Appendix C.
This is a Severity Level V Violation (Supplement 1).
B.
10 CFR 50, Appendix B, Criterion XII, states, " Measures shall be established to assure that tools, gages, instruments, and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits."
Periodic Test (PT)- 31, Safeguard Pump Bearing Temperature Check, Revision 3(4),
October 20,1980(May 15,1981), step 4.3, requires that the meter used for bearing temperature measurement be checked for accuracy over the temperature range of in-terest at intervals not to exceed 18 months.
Contrary to the above, the following instances of failure to properly calibrate measuring and test equipment were noted.
e204020420 B20318 gDRADOCK05000
APPENDIX A The pyrometer used on March 2 and 4,1981 to measure the bearing temper-atures associated with the three safety injection pumps was calibrated over the limited temperature range of 75-120F, where the indicated bear-ing temperatures ranged from 55-157F.
Calibration records were not available for the digital thermometer used on January 18, 1982 to measure the outboard bearing temperatures associated with the two containment spray pumps.
This is a Severity Level V Violation (Supplement 1).
C.
10 CFR 50, Appendix B, Criterion XII, states, " Measures shall be established to assure that tools, gages, instruments, and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits."
Ginna Station Quality Assurance Manual,Section XII, Control of Measuring and Test Equipment, Revision 4, June 15,1980, paragraph 3.4, requires that the calibration frequency for measuring and test equipment be adjusted when instrument history in-dicates the need.
Contrary to the above, as of January 18, 1982, the calibration frequency for two neutron survey instruments had not been reduced, although data from the past three annual calibrations indicated the need for substantial adjustments prior to re-turning the meters to service.
This is a Severity Level V Violation (Supplement 1).
Pursuant to the provisions of 10 CFR 2.201, Rochester Gas and Electric Corportation is hereby required to submit to this office within thirty days of the date of this Notice, a written statement or explanation in reply including the corrective steps which have been taken and results achieved; corrective steps which will be taken to avoid further violations; and the date when full compliance will be achieved.
Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation.
Where good cause is shown, consideration will be given to extending your response time.
P MAR 181981 Date
,/,vRichard W. Starostecki, Director, 4
Division of Project and Resident Programs
U.S. NUCLEAR REGULATORY COMMISSION Region I Report No. 50-244/82-03 Docket No. 50-244 C
License No. DPR-18 Priority Category Licensee:
Rochester Gas and Electric Corporation 89 East Avenue Rochester, New York 14649 Facility Name:
R. E. Ginna Nuclear Power Plant Inspection at:
Ontario, New York Inspection conducted: January 1 - February 28, 1982 Inspectors:
kk 3 / ll [8cil.
R. P. ZinneNan, Senior Resident Inspector e signed date signed j
date signed Approved by:
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Oate tigned H. B. Kister, Chief, Projects Section 1C, Division of Project &
Resident Programs Inspectinn Summary:
Inspection on January 1 thru February 28,1982 (Report No. 50-244/82-03)
Areas Inspected: Routine, onsite, regular, backshift and weekend inspection by the resident inspector (306 hours0.00354 days <br />0.085 hours <br />5.059524e-4 weeks <br />1.16433e-4 months <br />). Areas inspected included plant operating records; surveillance testing; maintenance; Licensee Event Reports; periodic and special reports; response to the o
January 25th stean generator tube rupture event; licensee action on previous inspection findings; Inservice Pump Test Program; control of measuring and test equipment; and access-
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,1ble portions of the facility during plant tours.
Results: Of the ten areas inspected, two violations were identified in one area, (F?ilure to properly calibrate measuring and test equipment-Paragraph 8.c; Failure to increase the calibration frequency for equipment whose instrument history indicates the need-Paragraph 5.b) and one violation was identified in one area, (Failure to establish bearing temper-ature reference values and limits for the pumps included in the Inservice Pump Test Program
-Paragraph 8.b).
Region I form 12 (Rev. April 77)
i DETAILS 1.
Persons Contacted The below listed technical and supervisory level personnel were among those contacted:
E. Beatty, Operations Supervisor J. Bodine, QC Engineer L. Boutwell, Maintenance Supervisor C. Edgar, I & C Supervisor D. Filkins, Supervisor Health Physics and Chemistry D. Gent, Results and Test Supervisor G. Larizza, Technical Engineer T. Meyer, Nuclear Engineer R. Morrill, Training Coordinator J. C. Noon, Assistant Plant Superintendent C. Peck, Operations Engineer B. Quinn, Health Physicist B. A. Snow, Plant Superintendent S. Spector, Maintenance Engineer J. Straight, Fire Protection and Safety Coordinator R. Wood, Supervisor of Nuclear Security The inspector also interviewed and talked with other licensee personnel during the course of the inspection.
2.
Licensee Action on Previous Inspection Findings (Closed) Noncompliance (244/81-08-01): Administrative Procedure (A)-52.4, Control of Limiting Conditions for Operating Equipment, has been revised to require plac-ing the containment iodine monitor in service upon loss of the containment gas and particulate monitors.
(Closed) Noncompliance (244/81-13-01):
Routine, daily review of the control room log indicates that a satisfactory record of operational events is being maintained, including the reriloval of equipment from service and the subsequent return to op-erable status.
3.
Review of Plant Operations a.
General The inspector reviewed plant operations through direct inspection throughout the reporting period. Activities in progress included routine full power operation, and entrance into a refueling / maintenance outage following a steam generator tube rupture event on January 25th. (paragraph 7 ).
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b.
Shift Logs and Operating Records Operating logs and records were reviewed against Technical Specification j
and administrative procedure requirements.
Included in the review were:
daily during control room Control Room Log surveillance daily during control room l
Daily Surveillance Log surveillance i
daily during control room Shift Supervisor's Log surveillance daily during control room i
Plant Recorder Traces surveillance daily during control room Plant Process Computer Printout i
surveillance 1/1/82 through 2/28/82 Station Event Reports 1/1/82 through 2/28/82 l
I Maintenance Work Orders and Trouble The logs and records were reviewed to verify that entries were being properly 1
made; entries involving abnonnal conditions provided sufficient detail to communicate equipment status, deficiencies, corrective action restoration and testing; records were baing reviewed by management; operating orders did not conflict with the Technical Specification or reporting requirements; logs and records were maintained in accordance with Technical Specification and administrative procedure requirements.
4 The rapidly occurring events associated with the January 25th steam generator tube rupture precluded control room operators frem maintaining substantive logs and records.
In addition to the data provided by the process computer and trend recorders, the inspector stated that during an event where sufficient manpower is believed to be available onsite, additional consideration should be i
giveninthefuturetomaintainingasdetailedalogaspracticable. The li-1 1
censee acknowledged the inspector s coment.
c.
Plant Tour l
1.
During the course of the inspection, tours of the following areas were conducted:
Control Room Auxiliary Building 1
Intermediate Building (including control point) i I
l Containment Service Building l
Turbine Building 1
Diesel Generator Rooms
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4 Battery Rooms
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l Screenhouse j
l Yard Area and Perimeter
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2.
The following observations resulted from the tours:
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a.
Monitoring instrumentation. Process instruments were observed for l
l correlation between channels and for conformance with Technical j
Specification requirements.
J b.
Annunciator Alarms. Various alarm conditions which had been re-i ceived and acknowledged were observed. These were discussed with
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shift personnel to verify that the reasons for the alarms were i
understood and corrective action, if required, was being taken.
I c.
Shift manning. Control room and shift manning were ot, served for l
l conformance with 10 CFR 50.54 (K) Technical Specifications, and
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administrative procedures.
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d.
Radiation protection controls. Areas observed included control point operation, posting of radiation and high radiation areas, compliance with Radiacion Work Permits and Special Work Permits, personnel monitor-ing devices being properly worn, and personnel frisking practices.
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e.
Equipment lineups. Valve and electrical breakers were nrified to be in r
i the position or condition required by Technical Specifications and plant J
J lineup procedures for the applicable plant mode. This verification in-cluded control board indications daily and a partial valve lineup of the fire protection system on January 5th.
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Equipment tagcing. Selected equipment, for which tagging requests had
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been initiatec, was observed to verify that tags were in place and the equipment in the condition specified.
g.
Fire protection.
Fire detection and fire fighting equipment and controls l
1 were observed for conformance with Technical Specifications and adminis-J trative procedures.
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Security. Areas observed for conformance with regulatory requirements.
l the site security plan and administrative procedures, included vehicle j
and personnel access, protected and vital area integrity, escort and i
badging.
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5 1.
Plant housekeeping controls. Plant conditions were observed for con-formance with administrative procedures. Storage of material and components was observed with respect to prevention of fire and safety hazards. Housekeeping was evaluated with respect to controlling the j
spread of surface and airborne contamination.
No violations were identified.
4.
Inspector Witnessing of Plant Maintenance and Modifications During the inspection period, the inspector observed various maintenance a.
and problem investigation activities to verify compliance with regulatory t
requirements, including those stated in the Technical Specifications; com-pliance with administrative and raintenance procedures; compliance with applicable codes and standards; required QA/QC involvement; proper use of safety tags; propet equipment alignment and use of jumpers; personnel quali-l fications; radiological controls for worker protection; retest requirements; and ascertain reportability as required by Technical Specifications.
In a similiar manner the implementation of design changes and modifications were reviewed.
Compliance with requirements to update procedures and drawings were verified and post modification acceptance testing was evaluated.
b.
The inspector witnessed the following maintenance activities:
video scans of portions of 'A & B' Steam Generator secondary sides, performed February 10 through 16, 1982.
bench testing of a pilot-operated, three way solenoid valve similiar to the one associated with the relief valve (PCV 430) which stuck open on the pressurizer.
No violations were identified.
5.
Cal.bration and Control of Survey Equipment - Health Physics a.
The inspector reviewed the calibration and controls associated with radiation survey instruments.
Included in the review was verification of proper storage and labeling of survey instruments, adherence to calibration schedules, tag-ging controls for instruments out of service for maintenance / calibration, and establishment of adequate individual history files.
b.
The following items were identified as a result of the above review.
The procedures for calibration of alpha and neutron survey instruments did not contain acceptance criteria.
Calibration data did indicate, however, that if adjustment was necessary, in all cases the survey in-struments were returned to an accuracy within several percent of full scale prior to being returned to service. The licensee representative stated that an acceptance criteria would be added to each procedure prior to the next calibration of the equipment.
The inspector will review the procedural revisions (82-03-01).
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t During the review of calibration data associated with two Eberline j
neutron survey monitors, the inspector noted that over the cast three l
years the instruments required significant adjustment to obtain the t
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desired reading stated in the procedure.
i Model PNR - 4, SN 1169 actual as found as found as found mr/hr(range)
August,1979 June, 1980 July,1981 I
4 (0-50 4
15 5
i 40 (0-50 35 32 25 i
40 0-5K 280 450 150 2000g((0-5K 4200 500 500
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t Model PNR - 4, SN 3323 actual as found as found as found 1
mr/hr(range)
August, 1979 June, 1980 July,1981 l
i 4 0-50 5
2.5 5
l 40 0-50 50 N/A2 50 400 0-5K 430 250 400 i
- i 20001 0-5K 4500 2500 3000 1
1.
In 1979,the actual source reading was 2300 mr/hr.
2.
Discussions with plant personnel indicate theas foundareading should
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have been recorded as 40 mr/hr and the " meter after adjustment" col-i umn as N/A.
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The inspector stated that based on the above data, the calibration fre-quency for the above instruments should have been reduced from the current i
annual frequency.
Failure to adjust the calibration frequency when in-strument history indicates the need, is a violation of 10 CFR 50, Appendix B, Criterion XII and the Ginna Station Quality Assurance Manual,Section XII (82-03-02).
In several instances, the inspector and licensee representative found it difficult to trace an instrument's history to detennine dates when the meter was taken out of service for maintenance / calibration, and subsequent-l ly available for use. Further, information on the nature of the problem and maintenance performed was sometimes vague. The licensee representative stated the method of uiaintaining instrument history files would be review-ed and revised by June 1, 1982. The inspector will follow the licensee's actions regarding instrument history recordkeeping (82-03-03).
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7 6.
Inspector Witnessing of Surveillance Tests a.
The inspector witnessed the performance of surveillance testing of selected components to verify that the surveillance test procedure was properly ap-proved and in use; test instrumentation required by the procedure was cali-brated and in use; Technical Specifications were satisfied prior to removal of the system from service; test was perfomed by qualified personnel; the procedure was adequately detailed to assure performance of a satisfactory surveillance; and test results satisfied the procedural acceptance criteria, or were properly dispostioned.
b.
The inspector witnessed the performance of:
Periodic Test (PT)-2.1, Safety Injection System Pumps, Revision 31, November 4, 1981.
No violations were identified.
7.
Licensee Event Reports (LER's)
The inspector reviewed the following LER's to verify that the details of the event were clearly reported, and to verify the accuracy of the description of cause and adequacy of corrective action. The inspector determined whether further informa-tion was required, and whether generic implications were involved. The inspector also verified that the reporting requirements of Technical Specifications and station administrative and operating procedures had been met; that appropriate corrective action had been taken; that the event was reviewed by the Plant Op-
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erations Review Comittee; and that the continued operation of the facility was conducted within the Technical Specification limit.
81 -21 : Containment Isolation Valve Leakage - December 17, 1981.
During perfomance of routine check valve exercising the containrrent gas radiation monitor return line check valve (1599) failed to completely seat. The line was isolated for repair ren-dering the containment gas radiation monitors temporarily inoperable.
Emergency Main-tenance procedure (EM)-298 was followed to blow instrument air through the valve to remove any foreign matter. Subsequent surveillance testing found the valve acceptable and the system was returned to service.
The inspector noted that the LER describing the event was dated January 21,1982, a period in excess of thirty days. The event date was incorrectly reported by the li-censee as December 22, 1981, and was considered by the inspector to have been an isolated administrative error.
81 -22: Error Discovered in Accident Analysis - December 21, 1981. The licensee dis-covered that the containment fan cooler heat removal rate used in the Loss of Coolant Accident Analysis performed by Exxon Nuclear Company (ENC) in December 1977 (Report XN-NF-77-58)wasnonconservative. The capacity of a single fan was used in the analysis rather than the combined capacity of all four fans. The additional contain-ment cooling will reduce containment pressure and calculated reflooding rates with a resultant increase in the calculated Peak Cladding Temperature (PCT). The results of the 1977 analysis indicated conformance to 10 CFR 50.46 with an allowed linear
8 heat generator rate corresponding to 2.32 and a PCT of 1922F.
ENC informed the licensee that the effect on PCT with the increased fan cooler capacity will be small as it is only one of several significant containment energy removal systems.
Further, sub'tantial PCT margin exists to the 2200F limit with the actual linear heat generator rate below 1.74.
Calculations will be performed prior to start-up of cycle XII to include the revised fan cooler capacity. This item will be reviewed by the inspector prior to cycle XII and is considered unreso M d (82-03-04).
82-01: Violation of Containment Integrity - January 7, 1982. During nonnal op-eration, a leak was identified from the 3/8" pressurizer sample line containment isolation valve (966B). The valve was isolated and repaired. The system was re-turned to service without performing the necessary leak test. The test procedure, PT-23, which required that the plant be at cold shutdown to perform the leak test, was changed to allow performance at power.
82-02: Reactor Coolant Drain Tank Pump Line Leak - January 13, 1982. An operator on routine tour noticed two pinhole leaks from a weld on a common suction to the
'A' Reactor Coolant Drain Tank Pump and the recirculation phase of emeraency core cooling. The pinhole leaks, in a 3" long cold lap in the initial weld, were ground out and repaired.
82-03:
'B' Steam Generator Tube Rupture - January 25, 1982. A tube rupture in the U team Generator resulted in significant primary system depressurization, actu-ation of the emergency core cooling systems and minor release of radioactive mater-ials.
Investigation after achieving cold shutdown revealed that the tube at row 42, column 55 h&d an approximately 5" axial split (fishmouth) running from 3" to 8" above the tube sheet.
Details associated with the event will be documented in NUREG 0909.
82-04: Removal of Fire Watches from Inoperable Fire Zones - January 25, 1982. As a result of the steam generator tube rupture event discussed in LER 82-03 a site evacuation was conducted.
Fire watch personnel were evacuated in accordance with plant procedure SC-1.5.
Fire watches were removed from eight inoperable fire zones at 10:44 A. M. and returned to their posts at 4:00 P. M..
Fire suppression system activation was not necessary during the tube rupture event.
Five of the eight inoperable zones were taken out of service due to welding /gringing activities within the areas. The inspector stated that procedural consideration should be given to returning those zones taken out of service for welding / grinding activities to an operable status following a site evacuation. The licensee acknow-ledged the inspector's coninent, and stated that a procedure change would be made.
82-05: Pressurizer PORY Inoperable - January 25, 1982.
In an effort to reduce pri-mary system pressure during the January 25th tube rupture event, a pressurizer PORY (PCV 430) was cycled.
The PORV stuck open during the fourth manual actuation. The l
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9 primary system depressurization was stopned by closing the associated block valve. Cause of the failure is believed to have been due, in part, to a crimp in the vent of the actuating three-way solenoid valve. The restriction in the vent was made to increase the number of available cycles for the nitrogen low pressure protection system which is an additional function the PORV serves. The restricted vent has been removed and an orificed check valve installed between the PORV and the solenoid valve. The licensee is continuing to evaluate the fail-I ure mode with the manufacturer. This item is unresclved, pending completion of the review of the failure mechanism (82-03-05).
82-06:
Inadvertent Reactor Coolant System Dilution - February 3,1982.
Procedure T-7F Filling and Purge of 'B' Steam Generator, was used to place the faulted steam generator in a wet lay-up conditior. The procedure required, as an initial condi-tion, that a cam lock plug be placed in the failed tube, but did not specify both ends. Due to the procedural inadequacy only the hot leg side of the ruptured tube was plugged. During the filling operation, the control room operator noted an in-crease in primary system level and stopped the operation. A transfer of approx-imately 2300 gallons of demineralized water occurred, resulting in an RCS dilution of 1900 ppm to 1684 ppm. Shutdown margin was maintained above 10%.
8.
Inservice Pump Test Program - Bearing Temperature a.
The inspector reviewed the Inservice Pump Test Program, as it applies to pump bearing temperatures to ensure surveillance tests were performed with proper-ly approved procedures, measuring and test equipment used were p hperly con-trolled and calibrated; test results satisfied the acceptance criteria or were properly dispositioned; and data received adequate supervisory review.
b.
The inspector noted that reference temperature values, alert limits and required action limits had not been extablished for the pumps included in the Program and listed in the Ginna Station Quality Assurance Manual, Appen-dix C.
Failure to develop reference values and limits for individual pump bearings is contrary to 10 CFR 50.55a(g)(4), the 1977 Edition of Section XI of the ASME Boiler and Pressure Vessel Code through the 1978 Addenda, and the Ginna Station Quality Assurance Manual, Appendix C.
This is considered a violation (82-03-06).
The inspector stated that although Periodic Test (PT)-31, Safeguard Pump Bearing Temperature Check, sets an administrative limit of 160F for stopping the surveillance test, no mechanism, such as an alert limit, exists to require increasing the frequency for performing the test from annually following higher-than-normal temperature measurement. As an example, the inspector discussed a March, 1981 surveillance test in which the 'C' Safety Injection Pump was stopped due to the outboard bearing temperature approaching 160F. The cool-ing water lines were flushed of sediment and the test rerun satisfactorily.
The test frequency; however, was left unchanged.
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c.
The bearing temperatures associated with the three safety injection pumps l
were measured on March 2 and 4, 1981.
The West instruments pyrometer (serial number 7704B178) used in the test was calibrated over the limited range of 75-120F, where the indicated bearing temperatures ranged from 55-157F.
i The bearing temperatures associated with the two containment spray pumps were measured on January 18,1982. Calibration records were not available for the Cole-Parmer digital thermometer (serial Number 01908020) used to measure the outboard bearing temperatures.
Both of the above tests were performed using Periodic Test Procedure (PT)-31, Safeguard Pump Bearing Temperature Check, Revision 3(4), October 20, 1980 (May 15,1981), which requires that the meter used for bearing temperature measurement be checked for accuracy over the temperature range of interest at intervals not to exceed 18 months. Failure to follow procedures and properly calibrate and control the temperature measuring and equipment is contrary to 10 CFR 50, Appendix B, Criterion XII, and is considered a violation (82-03-07).
Discussions with cognizant plant personnel indicated assurance that the digital thermometer used on January 18, 1982 had been properly calibrated in accord-ance with the manufacturer's one point calibration prior to the containment spray pump surveillance test. However, as of February 28, 1982, the thermom-eter of interest could not be located in order to verify that the instrument was within acceptable tolerances.
9.
NRC Witnessing of Radiation Emergency Exercises A radiation emergency exercise was conducted on January 21, 1982 from about 5:00 A. M. to 6:00 P. M..
Details associated with the exercise are documented in NRC Region I Inspection Report 82-01.
- 10. Review of Periodic and Special Reports Upon receipt, periodic and special reports submitted by the licensee pursuant to Technical Specification 6.9.1 and 6.9.3 were reviewed by the inspector. This re-i view included the following considerations: the report included the infomation required to be reported by NRC requirements; test results and/or supporting in-formation were consistent with design predictions and performance specifications; planned corrective action was adequate for resolution of identified problems; determination whether any information in the report required classification as an abnormal occurrence; and the validity of the reported information. Within the scope of the above, the following periodic reports were reviewed by the inspector.
Monthly Operating Reports for November and December,1981.
No violations were identified.
- 11. 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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