ML20151V605

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Insp Repts 50-498/88-39 & 50-499/88-39 on 880601-30. Violations Noted.Major Areas Inspected:Nonroutine Event Review,Shutdown from Outside Control Room,Containment Combustible Gas Control Sys & safety-related Components
ML20151V605
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 08/05/1988
From: Bess J, Bundy H, Garrison D, Holler E, Hunnicutt D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20151V485 List:
References
50-498-88-39, 50-499-88-39, NUDOCS 8808220329
Download: ML20151V605 (23)


See also: IR 05000498/1988039

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APPENDIX B

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-498/88-39 Operating License: NPF-76

50-499/88-39 Construction Permit: CPPR-129

Dockets: 50-498 Expiration Date: December 1989

50-499

Licensee: Houston Lighting & Power Company (HL&P)

P.O. Box 1700

Houston, Texas 77001

Facility Name: South Texas Project, Units 1 and 2 (STP)

Inspection At: STP, Matagorda County, Texas

Inspection Conducted: June 1-30, 1988

Inspectors: h.6 h

M E. Bess, ResTdent Inspector, Project Section D

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Dat/e

Division of Reactor Projects

! . ti]/lll/V)(A'b  ?-3-EY

D. L. Garris'6n, Resident Inspector, Project Date

Section D, Division of Reactor Projects

$/W9Y

H. F. Bundy, Reactor 7nspector, Test Programs .Date

Section, Division of Reactor Safety

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D. M. Hunnicutt, Senior Project Engineer, Project

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Ddte/

Section D, Division of Reactor Projects

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Approved: -1' -

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E. J. Foller, Chief, Project Section D, Division D6te'

of Reactor Projects

8808220329 880812

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Inspection Summary

Inspection Conducted June 1-30, 1988 (Report 50-498/88-39)

Areas Inspected: Routine, unannounced inspection included licensee action on

previous inspection findings, shutdown from outside the control room, monthly

maintenance observation, monthly surveillance observation, operational safety

verification, engineered safety feature (ESF) walkdown, and licensee action on

reported events.

Results: Within the areas inspected, three violations were identified. The

first violation involved failure to perform surveillances in accordance with

Technical Specifications (paragraph 4.a). The second violation involved

failure to meet Technical Specification requirements related to the release of

liquid effluents (paragraph 4.b). The third violation involved the plant

changing modes prior to the completion of required surveillances

(paragraph 4.c).

Inspection Conducted June 1-30, 1988 (Report 50-499/88-39)

Areas Ins)ected: Routine, unannounced inspection included nonroutine event

review, slutdown from outsided the control room, containment combustible gas

control system (hydrogen recombiners), reactor pressure boundary piping, and

safety-related components.

Results: Within the areas inspected, no violations or deviations were

identified.

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DETAILS

1. Persons Contacted

HL&P

  • W. P. Evans, Licensing Engineer
  • S. M. Dew, Manager, Operations Support
  • A. R. Mikus, General Supervisor, Construction
  • D. C. King, Construction Manager
  • J. D. Green, Manager, Inspection and Surveillance
  • M. A. McBurnett, Operations Support Licensing Manager
  • S. M. Head, Supervising Licensing Engineer
  • M. R. Wisenburg, Plant Superintendent, Unit 1
  • J. N. Bailey, Manager, Licensing and Engineering, Unit 2
  • J. T. Westermeier, General Manager
  • G. L. Jarvela, HP Division Manager
  • M. Polishak, Project Compliance
  • M. Herman, Quality Assurance Engineer

Volt

  • J. Guthrie, Startup Engineer

Ebasco,

  • H. A. Garcia, Senior Resident Engineer

In' addition to the above, the NRC inspectors also held discussions with

various licensee, architect engineer (AE), constructor and other

contractor personnel during this inspection.

  • Denotes those individuals attending the exit interview conducted on .

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July 6, 1988.

2. Plant Status

South Texas Project (STP), Unit 1, went critical at 6:55 a.m. (CDT) on

June 18, 1988, following an outage which began on May 25, 1968, because of

the loss of No.11 steam generator feed pump (SGFP). The No. 11 SGFP

received extensive damage during the initiation of a Loss of Offsite

Power (LOOP) test. An investigation into the cause of the.SGFP. turbine

failure concluded that the apparent root causes were: less than adequate

design to protect the SGFP, less than adequate des.'gn of the high pressure

'stop valve which lead to valve binding and inadequate isolation of steam

admission to the turbine. The modifications listed below are being

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implemented by the licensee:

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Modifications to the high pressure stop valves and actuation linkage

to ensure closure

Addition of electrical overspeed trip function set at 105 percent of

maximum rated turbine speed

Addition of vital power to the Electro-Hydraulic Control System

On June 23, 1988, a shutdown from outside control room test was performed

satisfactorily. The plant was shut down and maintained in a hot standby

condition (Mode 3) for 45 minutes from the auxiliary shutdown panel (ASP).

This was the last major test to be performed at the 30 percent reactor

power plateau. During this brief shutdown, the licensee performed a

hardness test on 23 flanges located throughout the component cooiing water

system (CCW) inside containment. The purpose of the test was to comply

with NRC Bulletin 88-05 dated hay 6, 1988. This bulletin identifies a

potential safety concern with nonconforming materials su

Supplies, Inc. (PSI) and West Jersey Manufacturing (WJM)pplied

. The test by Piping

(hardness) results on the 23 flanges indicated that 22 passed the test and

one proved to be harder than the other flanges tested. Test data is still

being evaluated. On June 27, 1988, at 6:43 a.m. (CDT) Unit i reached

48 percent reactor power.

STP, Unit 2, is 96 percent complete and preoperational testing is in

progress. Hot functional testing is scheduled to begin in mid-July.

3. Licensee Action on Previous Inspection Findings (92701 and 92702)

a. (Closed) Violation (498/8808-01): Emergency Preparedness

Procedure Changes - The licensee had not submitted changes made to.

its emergency preparedness procedures since Unit I was licensed

(Operating License NPF-71 later reissued as NPF-76) on August 21,

1987.

The root cause of this violation was identified by the licensee as a

failure to be fully aware of NRC reporting requirements on the part

of the Emergency Preparedness Manager, who . failed to properly notify

Operations Support Licensing of new or revised Emergency Plan

Implementing Procedures (EPIPs). The following corrective actions

have been taken by the licensee in response to this' violation:

(1) HL&P has submitted copies of all new and revised.EPIP issued

since issuance of the OL on August 21, 1987, to the NRC.

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(2) The Emergency Preparedness Manager has been specifically

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included in the list of recipients of the Reporting Manual.

(3) Additional instructions have been issued to recipients of the

I Reporting Manual to ensure that responsible licensee groups are

j kept fully aware of reporting requirements.

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(4) Copies of approved EPIPs are distributed to Operations Support

Licensing for submittal to NRC.

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(5) The EPIPs are distributed to Operations Support Licensing as

part of the licensee's controlled document distribution program.

This violation is considered closed,

b. (Closed) Violation (498/8816-01): Failure to Follow Procedures - The

NRC inspectors found five untagged electrical jumpers installed which

required temporary alteration tags for status information.

The NRC inspector determined that the five jumpers identified had

been installed for system testing within a scheduled work shift.

StartupAdministrativeInstruction(SAI)14, Revision 5, dated

October 23, 1987, does not require the tagging and logging of

temporary alterations made by startup engineers during a continuous

scheduled work shift. However, the testing associated with the

jumpers subsequently was rescheduled. The licensee removed three

temporary jumpers, which had been placed in preparation for safety

injection preoperational testing located in Solid State Protection

System (SSPS) Cabinet ZRR002-1. The other two jumpers were located

in the mechanical auxiliary building (MAB) HVAC system (SSPS

Cabinet ZRR004-1) and were tagged and logged in accordance with

SAI 14. Additionally, the licensee held group meetings with

engineers and technicians to reiterate the requirements of SAI 14.

This violation -is considered closed.

c. (Closed)-Violation (498/8801-01): High Head Safety In: ection Pump

Controls System Lineup - The NRC inspector found that licensee

Procedure 1 POP 02-51-0002, "Safety Injection System Normal Lineup,"

Revision 6, dated December 30, 1987, was not adequate to control

alignment of the high head safety injection pumps in hode 4 in that

following the alignment in Fonns,3, 7, and 11 of the procedure would

have made the pumps inoperable.

The NRC inspector found that the licensee had revised Fonns 3, 7,

and 11 in Procedure 1 POP 02-SI-0002 to indicate the proper handswitch

alignments for all six modes. The licensee also revised Station

Procedure OPGP03-ZA-0002, "Plant Procedures," Revision 11,' dated

February 29, 1988, to incorporate requirements for an independent

technical review of new procedures. The licensee revised Station

Procedure IP0P02-RH-0001, "Residual Heat Removal System Operation,"

Revision 8, dated January 22, 1988, and reviewed other system lineup

procedures to assure that approved procedures were consistent with

Technical Specifications (TS) requirements.

-This violation is considered closed.

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d. (Closed) Violation (498/8801-04): Containment Integrity - The

ability to :r.?et the 0.6 La criterion of Appenoix J to 10 CFR Part 50

was not determined prior to entering Mode 4 on October 31 and

November 1,1987, in that a local leak rate test had not been

performed on Containment Isolation Valve (CIV' BIRAMOV0003 after

maintenanct

The NRC inspector determined that the licensee subsequently performed

a local leak rate test (LLRT) on this valve. A review of MWRs, LLRT

data, and an HL&P office memorandum dated February 1,1988, verified

that proper testing has been completed by the licensee to assure

containment integrity. The licensee reported this failure to test

Valve CIV BIRAM0V0003 in LER 88-02, "Failure to Perform LLRT on CIV,"

dated February 4,1988.

This violation is considered closed,

e. (Closed) Violation (498/8801-06): Implementation of Technical

Specification Requirements - The NRC inspector found that the

licensee had failed to provide test procedures, which completely

implemented the final TS. Procedure 1 PSP 10-RC-0001, "Reactor Coolant

System Flow Determination," Revision 0, contained acceptance

criterion calling for a figure in the TS, which had been deleted when

the final TS were issued. Procedure OPSP10-11-0003, "Determination

of Limiting Hot Channel Factors and Axial Offset," Revision 2, dated

February 8,1988, contained an incorrect and nonconservative equation

for adjusting the core racial peaking factor limit for fractional

power levels.

The NRC inspector found that Procedure 1 PEP 04-ZG-0007, "Reactor

Coolant System Flow Measurement At Power," Revision 2, dated

January 21, 1988, was identified by the licensee as the proper

procedure for use in reactor coolant system (RCS) surveillance in

lieu of the previously referenced Procedure 1 PSP 10-RC-0001.

Procedure OPGP03-ZA-0002, Revision 11, dated February 2,1988,

requires an independent technical review of new procedures. The

procedure includes requirements to perform a "walk through" of new

surveillance procedures to confinn that the surveillance procedure

requirements can be accomplished. An attribute check sheet has been

added to confirm TS requirements.

The NRC inspector found that Procedure OPSP10-II-0003, "Determination

of Limiting Hot Channel Factors and Axial Offset," Revision 2, dated

February 8,1988, has been corrected to be consistent with TS. The

licensee completed a review of surveillance procedures to assure that

Mode 1 TS requirements are incorporated.

This violation is considered closed.

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f. (Closed) Violation (498/8801-07): Overdue Station Problem Report

Investigation - Sixty-eight of the 204 Station Problem Reports (SPRs)

were overdue (past 17 days) for completion.

The NRC inspector fnund that Procedure IP-1.45Q, "Station Problem

Reporting," Revision 1, dated February 22, 1988, increased licensee

management's involvement in the SPR process. The Plant Manager

establishes the priority and due date and SPRs are taken directly to

the Shift Supervisor by the originator. The licensee also assigned

additional licensing engineers to coordinate resolution of SPRs. The

backlog of overdue SPRs was resolved.

This violation is considered closed.

g. (Closed) Open Item (498/8801-11): Signoff Requirements for

Surveillance Tests - The NRC inspectors noted several chses where the

Unit Supervisor signed for the Shift Supervisor either to authorize

the start of testing or to signify the Operations Department's review

of the test results. Plant Operations Standing Order PRO-23,

Revision 2, allowed the Unit Supervisor to sign for the Shift

Supervisor for a number of things, but the order did not address

surveillance tests.

The NRC inspector determined that Plant Operations Standing Order,

"PRO-23 Unit 1," Revision 4, dated March 15, 1988, paragraph 4.6

states, "The Unit Supervisor has signature authority for the Shift

Supervisor for surveillance tests. In these instances the Unit

Supervisor shall ensure the Shift Supervisor is kept informed of

ongoing surveillances."

This item is closed,

h. (Closed) Violation (498/8817-01): Failure to Follow Procedures: The

NRC inspector found that the unit supervisor log and the reactor

operator log for the period February 29 through March 3,1988, noted

several entries into LC0 conditions which had been logged into one of

the two logs, but not in both logs.

The NRC inspector found that Procedure OPOP01-ZQ-0030, "Maintenance

of Plant Operations Logbooks," was revised on June 4, 1988, to

eliminate the use of dual logbooks. The Unit Supervisor and Reactor

Operator Logbooks have been combined into the "Control Room Logbook."

The control room logbook is maintained by the Reactor Operator.

This violation is considered is closed.

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4. Onsite Followup of Events (93702)

a. Failure to Meet Surveillance Requirements

On February 11, 1988, the Component Cooling Water (CCW) Train IB

quarterly valve operability test was performed. Review by the test

coordinator and the shift supervisor for valve stroke time limits

showed acceptable results, and the package was fomarded for review.

Procedure OPGP03-ZE-0021, Revision 3. "Inservice Testing Program for

Valves," requires the System Engineer to review the completed

surveillance package and perform a stroke time change evaluation.

The required review and evaluation for this test package was not

performed until mid May by the System Engineer.

On May 18, 1988, the Systems Engineer's stroke time change evaluation

for Valve FV-4548 (the Residual Heat Removal Heat Exchange Outlet

Valve) indicated an increase in stroke time greater than 25 percent

of its previous stroke time. In accordance with OPGP03-ZE-0021,

paragraph 7.3.1, the referenced valve surveillance frequency should

have been increased to monthly. However, because of the lack of

timely review and evaluation of the test package, two required

surveillances were missed. The licenste intends to identify the

causes and corrective activities in LER 88-035. This is an apparent

violation (498/8839-01). -

b. Failure to Comply With Technical Specifications Related to Unmonitored

Release of Radioactive Effluent

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On June 4, 1988, at approximately 6:30 p.m. with the plant in cold

shutdown (Mode 5), approximately 1500 gallons of unanalyzed water was

discharged from Waste Monitor Tank (WMT) 1D to the Main Cooling

Reservoi r. WHTs 10, IE, and 1F were in recirculation prior to the

discharge. The licensee's investigation of the incident, as to

causes and corrective actions, indicates that two independent

surveillance data packages were received by the Radwaste Control Room

Operator to make the release from WMT 1E as required by the

licensee's Liquid Waste Effluent Release procedures. . Liquid Waste.

Effluent Radiation Monitor RT-8038 was not operable at this time. In

accordance with TS 3.3.3.10 effluent releases may continue with

Liquid Waste Effluent Radiation Monitor RT-8038 inoperable provided

at least two independent samples are analyzed in accordance with

TS 4.11.1.1.1 and at least two qualified members of the facility

staff independently verify the release rate calculations and

discharge line valving. At approximately 6:24 p.m., on June 7, 1988,

the MAB Roving Operator opened the manual isolation' valves on the

common discharge line. The Radwaste Control Room Operator (RW0)

mistakenly placed the WMT 10 Pump Discharge Valve handswitch in the

discharge position. The RWO should have placed.WMT 1E Pump Discharge

handswitch in the discharge position. At approximately 6:30 p.m., on

June 7,1988, the RWO placed the discharge header three-way valve

handswitch in the discharge position, which resulted in a discharge

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from WMT 1D. After discovering that the wrong tank was lined up and

discharging, the RWO terminated flow at approximately 6:35 p.m., on

June 7, 1988. A total of approximately 1500 gallons of unanalyzed

water from WMT 1D was discharged to the Main Cooling Reservoir. The

licensee intends to identify the causes and corrective action in

LER 88-036. This is an apparent violation (498/8839-02),

c. Failure to Meet Technical Specifications Surveillance Requirements

On June 13, 1988, at approximately 6:50 a.m., Unit 1 entered Mode 2.

At approximately 11 a.m., on June 13, 1988, the licensee discovered

that the Intermediate Range Nuclear Instruments had not had an Analog

Channel Operational Test performed in the previous 31 days as

required by TS 4.3.1.1. On June 12, 1988, prior to changing from

Mode 3 to Mode 2, the shift supervisor attempted to obtain various

department managers' signatures to verify that a review of their work

activities, including surveillance tests, supported a mode change in

accordance with the Plant Operation procedure. The Maintenance

Manager erroneously informed the shift supervisor that there were no

mode change restraints. After the plant entered Mode 2, the I&C

Divisional Surveillance Coordinator informed the shift supervisor

that the Intermediate Range Nuclear Instrumentation Analog Channel

Operatior:a1 Test had not been performed. On June 13, 1988, at

approximately 10:30 a.m. , the tests were satisfactorily performed.

Since this surveillance test was required prior to entering Mode 2,

the licensee was not in compliance with TS 4.0.4 from 6:55 a.m. on

June 13, 1988, to 10:35 a.m. on June 13, 1988. The licensee intends

to identify the causes and corrective actions in LER 88-038. This is

anapparentviolation(498/8839-03).

5. Shutdown from Outside the Control Room - Unit 1 (725838)

The purpose of this inspection was to determine whether the test was

consistent with regulatory requirements, guidance, licensee commitments,

and TS.

The NRC inspector reviewed Procedures IFEP04-ZY-0035, "Shutdown From

Outside The Control Room," and IT0P04-Z0-0001, "Temporary Control Room

Evacuation For Power Ascension Testing." The-review determined that the

procedures contained acceptance criteria requiring that the reactor and

turbine must trip and stable hot standby conditions be established and

maintained by manipulation of controls at the Auxiliary Shutdown

Panel (ASP) for at least 45 minutes, with no intervention required from

the Main Control Room. The procedure also required operating crew to be

positioned to monitor plant parameters in the Main Control Room.

The NRC inspector attended a pretest briefing for all personnel involved

in the testing. The test started on June 23, 1988, at 4:15 p.m. (CDT).

The reactor was tripped using the reactor trip switch gear and the turbine

tripped because of the reactor trip. Control of the plant was transferred

to the ASP from the Main Control Room. The plant was declared stable

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approximately 12 minutes after the reactor tripped. The plant was

maintained in a stable, hot standby condition for 45 minutes from the ASP.

After notifying the control room Shift Supervisor, control of the plant

was returned to the Main Control Room. All switches on the ASP were

restored and independently verified and data was collected in accordance

with procedures. There were some equipment problems encountered during

the initiation and restoration phases of the test. The equipment problems

are listed below:

When control of the Letdown Orifice Isolation Valves was transferred

to the ASP, the 150 gpm orifice isolation valve (A0V-0012) closed.

This caused a loss of letdown flow. The 100 gpm crifice isolation

valve was then opened from the ASP to restore letdown flow. When

control was transferred back to the control room af ter completion of

the test, the 100 gmp orifice isolation valve remained open. The

licensee wrote Maintenance Work Request (MWR) CV-59309 to investigate

and repair the problem.

The. Emergency Response Facilities Data Acquisition and Display System

Computer (ERFDAD) digital point for Turbine Trip did not toggle from

N/ Trip to Trip on the ERFDAD terminal at the ASP. MWR-ENa10738 was

initiated to investigated and correct this problein.

The A, C, and 9 Main Steam Isolation Valves (MSIV) above seat drain

valves could not be opened from the ASP and the Train "C" . valve had

no indication. After the completion of the test and transfer of

control back to the Main Control Room, the valves still could not be

opened. This inability to open the valves did not hinder the ability

of the operators to maintain the plant in a stable, hot standby

condition. Following the competion of the test, the transfer switch '

for the Train "C" valve was manipulated several times, and indication

and control of the valve was restored at the ASP.

Nonconformance Report (NCR)88-011 had previously been written

identifying this problem.

None of the problems encountered affected the test results. The

acceptance criteria for the test were met.

No violations or deviations were identified.

6. Monthly Maintenance Observation - Unit 1 (62703)

The station maintenance activities listed below were observed and

documentation was reviewed to ascertain that the activities were conducted

in accordance with approved procedures.

On June 9, 1988, MWRs FW-59253 and FW-59254 were initiated to perform one

of the six modifications recommended by licensee engineers to prevent

recurrence of damages received by the No.11 Steam Generator Feed

Pump (SGFP)onMay 25, 1988. This modification (Modification

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Package-88098) entailed the addition of a low net positive suction

pressure trip to three SGFPs and the Startup Steam Generator Feed

Pump (S/U SGFP). The NRC inspector observed the operation of the S/U SGFP

following the modifications. A review of Modification Package-88098 by

the NRC inspector concluded that the work was performed in compliance with

established procedures. Instructions provided to maintenance personnel in

the MWRs appeared to be adequate for the circumstances. The S/U SGFP

operability test run was within the acceptance criteria. All systems

functioned satisfactorily.

No violations or deviations were identified.

7. Monthly Surveillance Observation - Unit 1 (61726)

The NRC inspector observed selected portions of the surveillances listed

below to verify that the activities were being performed in accordance

with the TS and surveillance procedures. The applicable procedures were

reviewed for adequacy, test instrumentation was verified to be in

calibration, and test data was reviewed for accuracy and completeness.

Identified deficiencies were properly reviewed and resolved. -

a. Procedure 1 PSP 02-SI-0952, Revision 0, "Accumulator IB Level Group 4

Calibration." The NRC inspector witnessed the data acquisition, and

the verification of accuracies for channel sensor, alarm, associated

signal processing equipment, and remote displays as required by

TS 4.5.1.2.b. The NRC inspector noted that the results were within

the TS limits.

b. Procedure 1 PSP 02-SI-0955, Revision 0, "Accumulator 1C Level Group 4

Calibration." The NRC inspector observed portions of the

verification test which checked the accuracy of Channel L-0955 Hi/Lo

alanns. A review of the completed data package by the NRC inspector

confirmed that the results were within TS limits.

c. Procedure 1 PSP 06-PK-0006, Revision 0, "4.16KV Class 1E Tolerable

Degraded Voltage Coincident With SI and Sustained Degraded-Voltage

Relay Channel Calibration." The NRC inspector observed a portion of

the performance of 1 PSP 06-PK-0006 and verified that the test met the

requirements of TS 3/4.3.2, paragraph 4.3.2.1. The NRC inspector

verified that the data acquired was accurate and complete and that

affected systems were restored to normal. No discrepancies were

identified. ,

d. Procedure 1 PSP 03-CS-0003, Revision 2, "Containment Spray Pump 1C

Inservice Test." The NRC inspector observed the performance of

IPSP03-CS-0003 on Containment Spray Pump 1C and verified that the

pump was operating in compliance with the ASME Boiler and Pressure

Vessel Code,Section XI. Additionally, compliance with TS 4.0.5 and

4.6.2.1.b was verified.

No violations or deviations were identified,

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8. Operational Safety Verification - Unit 1 (71707)

The objectives of this portion of the inspection were to verify that the

facility is being operated safely and in conformance with regulatory

requirements, that management controls are effective, that selected

activities of the licensee's radiological protection programs are

implemented in conformance with plant policies and procedures and in

compliance with regulatory requirements, and to inspect the iicensee

compliance with the approved physical security plan.

The NRC inspector visited the control room on a daily basis and verified

that control room staffing, operator behavior, shift turnover, adherence

to TS Limiting Condition for Operation (LCOs), and overall control room

decorum were consistent with NRC requirements.

The NRC inspector observed the following annunciators illuminated during

each visit to the control room:

Lampbox-3M03, Window D-4-D.G. - Fuel Oil Storage Tank'11 Level Hi.

Lampbox-2M02, Window C-2 - Containment Elec. Pen. El' 60 Leak Hi.

Lampbox-2M02, Window D-2 - Containment Elec. Pen. El' 35 Leak Hi.

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Lampbox-2M02, Window E-2 - Containment Elec. Pen. El' 10 Leak Hi.

After discussing this concern with licensee management, the NRC inspector

was informed that an annunciator task force had been organized to

investigate all annunciator alarms. Futher discussions with a member of

the annunciator task force indicated that Change Authorization

Request (CAR) 88004 had been initiated to identify and correct problems

associated with Lamobox-3M03. Also, Configuration Control

Package (CCP) 1E-FST-0885 had been issued to identify and correct problems

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associated with Lampbox-2M02-C-2, D-2, and E-2. The NRC inspector will

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monitor licensee actions regarding this concern.

Tours were conducted in various locations of the plant to observe work and

operations in progress. A review of Radiation Work Permit (RWP) 88-1-0651:

was made regarding information required by licensee procedures relating to

the performance of work in a safe manner and under controlled conditions.

The NRC inspector verified that the referenced RWP contained information

which referenced: job description, radiation levels, contamination

levels, respiratory protective equipment, dosimetry, and expiration dates.

The NRC inspector noted that RWPs were prominently posted.

On a sampling basis, the NRC inspector verified that the security force

was functioning in accordance with the approved security plan. During

entrance and exits from the protected area (PA), the NRC inspector

verified that search equipment such as X-ray machines, metal detectors,

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and explosive detectors were operational. The NRC inspector noted during

tours of the vital areas that barriers were well maintained and observed

no weakness or obvious breaches.

No violations or deviations were identified.

9. Engineered Safety Feature (ESF) System Walkdown - Unit 1 (71710)

The NRC inspector walked down accessible portions of the tain feedwater

and main steam systems for Steam Generator 1C to verify system

operability. A review was performed to confirm that the licensee's system

operating procedures matched plant drawings and the as-built

configuration. Equipment condition, valve position, housekeeping,

labeling, and support subsystems essential to actuation of the systems

were noted. The systems were walked down using the drawings and

procedures as follows:

Main /eedwater System for "Steam Generator IC,"

Proce dure 1P0P02-FW-0001, Revision 3, Drawing SS139F00063,

Revision 11A.

Main Steam System "Steam Generator 10," Procedure 1P0P02-MS-0001,

Revision 4, Drawing SS109F0016, Revision 6.

No violations or deviations were identified.

10. Licensee Action on Reported Events - Unit 1 (92700)

The NRC inspector performed onsite followup on the.following licensee

event reports (LERs) to determine whether the licensee had taken

corrective actions as stated in the LERs and whether responses to the

events were adequate and met regulatory requirements, license conditions,

and commitments.

i- a. (0 pen) LER 87-03, "Actuator Motor Shaft-to-Pinion Keys Sheared Due to

Incorrect and Defective Material"

This LER reported failure of the shaft-to-pinion keys in the-

Limitorque SMB-0-25 motor operators for all three Unit 1 essential

cooling water (ECW) pumps discharge valves. The licensee also

reported these failures under 10 CFR 21 and 10 CFR 50.55(e). The

failures apparently resulted from use.of incorrect material for

fabrication of the keys. Licensee corrective-actions included

replacing all keys in SMB-0-25 operators with keys fabricated from

. the specified AISI 1018 material. This replacement was completed

only for operators installed in Unit 1. Also, the licensee inspected

a sample of six Limitorque actuator models having less than

25 foot-pounds starting torque and found no deficiencies. The

results of.this inspection were documented in Revision 6 to

NCR 87-121, which was not included in the closeout package originally

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presented to the NRC inspector. The NRC inspector questioned whether

the licensee personnel who recommended closure of this LER were aware

of the results of the sample inspection.

This LER will remain open pending replacement of the keys in the

Unit 2 SMB-0-25 actuators,

b. (Closed) LER 87-05, "Personnel Error and Incorrect Operator Response

Causes Auto-Actuation to Recirculation Mode for Control Room

Ventilation"

This event resulted from incorrect operator response to an

annunciator actuated when a cleaning person inadvertently tripped a

breaker supplying backup power to an inverter. In the restoration

attempt the inverter was deenergized. This resulted in loss of

control power to the toxic gas monitor, which caused auto actuation

of control room ventilation to the recirculation mode. The

licensee's corrective actions included posting of signs anL

appropriate retraining.

This LER is considered closed.

c. (Closed) LER 87-12, "Safety Injection (SI) Cold leg Injection Valves

Found Closed When Required Open"

This event involved having the SI system inoperable for 51 hours5.902778e-4 days <br />0.0142 hours <br />8.43254e-5 weeks <br />1.94055e-5 months <br /> with

the plant in Mode 4. The NRC inspector reviewed procedure and

turnover log changes, which should be helpful in precluding

occurrence of this event and similar events. Also, appropriate

remedial training was conducted for licensed operators.

This LER is considered closed.

d. (Closed) LER 87-14, "Control Room Ventilation Actuation to

Recirculation Mode Due to a Toxic Gas Monitor Detecting Paint Fumes"

This event resulted from inadequate administrative controls for

preventing toxic gas monitors from being exposed to paint fuices.

Contributing factors were two open pipe penetrations between

Room 501B and the air inlet chase for the control room. The licensee

posted warning signs concerning use of solvents and paints on the air

intake room doors. Procedure OPGP03-ZF-0007, Revision 2,

incorporates requirements which should prevent inadvertent

auto-actuation of control room ventilation to the recirculation mode ,

because of painting. Also, installation of air tight seals in

Room 501B was accomplished per Contractor Work Request 2348.

This LER is considered closed.

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e. (Closed) LER 88-17, "Pressurizer Low Pressure Safety Injection

Setpoint Too Low Due to Procedural Error"

This event involved incorrect and nonconservative translation of a TS

setpoint required for Safety Injection (SI) to surveillance

procedures, which resulted in operation with a setpoint in violation

of TS. In following up on this error, the licensee discovered the TS

setpoint for power range flux high positive rate was not covered by

surveillance procedures. The NRC inspector reviewed procedure

changes, which corrected both these errors, and audit reports stating

that no further TS translations errors exist. The licensee changed

its program, subsequent to this event, to require verification of

implementation of TS changes by the Nuclear Assurance Department.

This LER is considered closed,

f. (Closed) LER 87-19, "Slave Relay Surveillance Deficiency Due to

Personnel Error"

,

This event occurred as a r1 sult of incorrectly deleting a

surveillance procedure fie d change, which would have tested a slave

relay contact necessary for containment spray actuation. The

licensee's corrective actions included counselling instrumentation

and control group technical supervisors regarding the necessity of

independent review of field changes to surveillance procedures prior

to performing the affected procedures. Also, similar procedures were

reviewed to ensure that identical errors nad not been made.

This LER is considered closed.

g. (Closed) LER 87-21, "Inadvertent Actuation of Engineered Safety

Features (ESF) Load Sequencer and Standby Diesel Generator"

This event involved ESF Train "B" standby diesel start and load

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shedding when the load sequencer was partially deenergized for

troubleshooting. Load sequencing then began when the load sequencer

was reenergized a few minutes later. The licensee determined that

the load shedding and sequencing would.not have occurred if the load

sequencer had been deenergized by opening the main circuit breaker.

The licensee's corrective actions included the following:

  • Revision of the vendor manual to clarify the proper method for

deenergizing the ESF sequencer.

  • Conducting training for instrumentation and control technicians

on the proper method of deenergizing the ESF sequencer

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Placing caution signs on the ESF sequencer to warn technicians

and operators to use the main circuit breaker for deenergizing

the sequencer

This LER is considered closed.

h. LER 87-24, "Control Room Ventilation Actuation to Recirculation Mode

Due to Inadvertent Operction of Pushbutton By Technician"

This event occurred during performance of a modification to disable

the pushbutton which was inadvertently pushed to cause actuation of

the control room ventilation system to the recirculation mode. The

technician had just disabled a similar pushbutton for the fuel

handling building radiation monitoring system (RMS) and intended to

push that pushbutton. The involved pushbutton subsequer,tly was

disabled as planned. Also, a meeting was held for RMS technicians to

reinforce the need for attention to detail in performance of work.

This LER is considered closed.

i. (Closed) LER 88-04, "Loose or Corroded Toxic Gas Monitor Computer

Board Electrical Connection Results in ESF Actuation"

A failed computer chip in the toxic gas monitor caused an ESF

actuation of control room ventilation to the recirculation mode. The

licensee inspected and cleaned the monitor card cages and boards and

adjusted the card frame assembly covers. No apparent reascn for the

failure was discovered; however, the licensee believes the most

probable cause was a loose connection on an integrated circuit board.

Licensee engineering determined that vibration of the circuit board

frame should not have contributed to the loosening of connections.

The licensee doec not expect further similar failures. - A' licensee

task force is studying a design modification to reduce the number of

unnecessary ESF actuations and challenges to the system resulting

from toxic gas monitoring malfunctions.

This LER is considered closed.

_j. (Closed) LER 88-09, "Unanticipated Safety Injection Signal From'SSPS

Resulting From Procedural Deficiency"

An unanticipated ESF Train "A" SI actuation occurred during a

surveillance test of Master Relay K-736R. This was being performed

in accordance with a field _ changed procedure, which failed to require

placing the Paster Relay Selector-S switch to off prior to placing

the Mode Selector to operate. This event was similar to LER 87-019

discussed above and, therefore, indicated 'a need for more rigorous

reviews of procedure field. changes.' A similar procedure had

previously been completed successfully.for Train "B" because the

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technician performed the step without pointing out the procedure

deficiency. The licensee's corrective actions included:

Training to emphasize the importance of procedure reviews,

procedure compliance, initial performance of revised procedures,

and reporting of procedure deficiencies

Requiring a second, independent technical review of procedure

revisions and new procedures

This LER is considered closed,

k. (Closed) LER 88-11, "Non Performance of a Scheduled Test for

Essential Chilled Water Pump as a Result of a Lost Test Package"

This event occurred as a result of apparent loss of a surveillance

test package during routing between the surveillance program

scheduler and the main control room. A contributor to the event was

the failure of the missed surveillance to be properly flagged by the

overdue report feature of the program. Also, a mode change report

had the wrcng due date for tne surveillance. The frequency of this

test had recently been shortened because of previous test results in

the alert range. The licensee's corrective actions included:

  • Verifying that tests were not missed in other instances when the

test frequency had been changed

Adding a requirement in Procedure OPG03-ZE-0004 for divisional

surveillance coordinators to periodically review upcoming tests

to ensure the.t test packages are received by the start date

  • Documenting the method of changing the test frequency based on

previous test results in Procedure OPGP03-ZA-0055

This LER is considered closed.

1. (Clesed) LER 88-19, "Prematurely Terminating a TS Limiting Conditicn

for Operation (LCO) Requirement Cult,_o_ Personnei Error"

This event resulted from the failure:of shift operators to properly

log the inoperability of SI and containment spray when Train "A"

essential c. hiller became inoperable. This error ultimately resulted

in improperly exiting an LC0 with both Train "A" and "C" low head SI

inoperable. Licensee corrective action included:

  • Revision of Procedure OPOP01-ZQ-0030 to provide a more

structured review for impact of inoperable equipnent on other

systems, including independent evaluations

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Training for operations personnel on determining impact

inoperable components may have on other systems

This LER is considered closed.

11. Nonroutine Event Review - Unit 2 (90711)

The NRC inspector reviewed Interdepartmental Procedure IP-1.45Q,

Revision 1, dated February 22, 1988, "Station Problem Reporting," and

completed discussions with licensee personnel to ascertain whether the

licensee had assigned responsibilities for the review of off-normal

operating events on planned and unplanned maintenance activities. The

inspection verified the following:

"

The licensee had assigned responsibilities for a timely review and

evaluation of off-nonnal operating events to assure identification of

safety-related events. The iaquirements for the plant manager,

Station Problem Report (SPR) coordinator, nuclear assurance, Nuclear

Safety Review Board (NSRB), Plant Operating Review Comittee (PORC),

classification and control officer, security force supervisor, and

administrative controls are addressed in Procedure IP-1.45Q.

The licensee had delegated the responsibilities for the timei/ eview '

of planned and unplanned maintenance and testing activities to assure

identification of violations or potential violations or problem areas

for proposed TS Limiting Conditions for Operations (LCOs). (NOTE:

all requirements shall be fully applicable when the station TS are

issued in conjunction with the Operating License.)

Procedure IP-1.45Q addressed these delegations of responsibilities.

The licensee had delegated responsibilities for assuring completion

of corrective actions relating to safety-related events. The

delegation of responsibilities addressed in Procedure IP-1.450

included the originator, first-line supervision, management, SPR

coordinator, and other appropriate personnel.

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The licensee had delegated responsibilities for assuring completion

of corrective actions relatir.g to safety-related operating events.

Procedure IP-1.45Q discussed the responsibilities for corrective

actions in detail, provided guidelines for imediate investigations,

and discussed types of data which should be included in establishing

the root causes, generic implications, and the corrective actions.

12. Shutdown From Outside The Control Room - Unit 2 (70352)

The NRC inspector reviewed Procedure 1 TOP 04-Z0-0001, "Temporary Control

Room Evacauation For Power Ascension Testing," Revision 0, and

Procedure 1 PEP 04-ZY-0035, "Shutdown From Outside The Control Room,"

Revision 2.

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These procedures describe the methods to shutdown the reactor, maintain

the reactor subcritical, maintain reactor coolant inventory, and achieve

and maintain the reactor in hot standby (Mode 3) from cutside the main

control room using the minimum number of shif t operating personnel. These

procedures meet the NRC requirements, and licensee conmitments stated in

the TS (proposed); FSAR Chapter 14.2.12.3, Test Description 25,

Amendment 53; and Regulatory Guide 1.68, "Initial Test Programs for

Water-Cooled Nuclear Power Plants," Revision 2, paragraph 5, "Power

Ascension Tests," Test d.d (page 1.68-18).

13. Containment Combustible Gas Control System (Hydrogen Recombiners) -

Unit 2 (70342)

a. Description

The Electric Hydrogen Recombiners (EHR) are natural convection,

flameless, thermal reactor-type hydrogen / oxygen recombiners. The EHR

consist of two independent recombination units. Each unit contains

electric heater banks, a power supply panel, and a power control

panel. The EHRS are permanently installed inside the Reactor

ContainmentBuilding(RCB). The power supplies and control panels

are located outside the RCB.

b. Documentation and Procedure Review

The NRC inspector reviewed the following documentation and procedures

related to operation and testing of the EHR:

  • 0917-00001-BWN, Revision B, "Electric Hydrogen Recombiner,"

Model B, FCR BN-00256 DE-1802, Technical Manual, South Texas

Nuclear Generatirl Station, Units 1 and 2

NSD-TO-E-74-20, "Hydrogen Recombiner Temperature Instrumentation

Checkout, Calibration & Test Procedure," Revision 1, dated

December 4, 1974

NSD ELEC-2, "Storage of Electrical Instrumentation and Control

Equipment,' Revision 2, dated August 1973

  • 2-CG-P-01, "Electric Recombiner," Revision 0, dated

September 15, 1987

Regulatory Guide 1.68, "Initial Test Programs for Water-Cooled

Nuclear Power Plants, Revision 2, dated August 1978 and

Appendix A. "Initial Test Program," paragraph 1.h.(4)

  • FSAR, Amendment 61, Section 6.2.5, "Combustible Gas Control in

Containment" and Section 14.2.12.2 (103), "Combustible Gas

Control System Preoperational Test Summary"

Applicable Drawings are listed below:

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Vendoe Dwg. No. Sht/Rev Controlled Drawing No.

9553 0 97/1/5 N159 X 3153 - WN

9553 0 97/2/3 N159 X 3154 - WN

9553 D 97/3/1 N159 X 3155 - WN

9553 D 97/4/3 N159 X 3156 - WN

9553 0 97/5/2 N159 X 3157 - WN

c. Review of Preoperation Test Procedure

The NRC inspector reviewed Preoperational Test Procedure 2-CG-P-01,

"Electric Recombiner," Revision 0, dated September 15, 1987. This

procedure requires testing that will demonstrate the minimum air flow

(EHR design minimum air flow capacity is 10C scfm) through each EHR

1s adequate, and each EHR will have sufficient electrical power (EHR

electrical requirements are: 4-wire, 3-phase, 60 Hz. 480 VAC, 75 KW

maximum power output) to achieve recombination tempet.+.ure (1225 + or

- 10*F).

The preoperational test acceptance criteria and requirements and the

EHR design characteristics are addressed for normal operating

conc'itions and postulated LOCA operating conditions. The test

procedure adequately addressed NRC requirements and licensee

commitments related to testing and verification of operating

requirements for the two EHRs. Preoperational testing of the two

EHRs are scheduled for Novernber 1988. The NRC inspector wiM observe

the preoperational testing of the EHRs at Unit 2.

No violations or deviations were identified.

14. Reactor Pressure Boundary Piping - Unit 2 (49053and49055)

The NRC inspector performed an inspection of selected systems in the

reactor pressure boundary piping, and the related records to determine

wi ether licensee activitie: associated with the fabrication of the reactor

pressure boundary piping system and docunentation of these activities had

been completed in accordance with the specifications, drawings, and

procedures. The NRC inspector selected the High Head Safety Injection

Sy stem (HHSI), Low Head Safety Injection System (LHSI), and the

Containment Spray System (CS) in the Train "B" for this inspection. These

three :ystems are located between columns 28 and 30 and on both sides of

the pump centerline from elevations -29 feet to -10 feet in the fuel

handling building,,

a. Work Observation

The NRC inspector verifiea that +.h3 as-built piping systems were

constructed in accordance with the drawings. The welding,

nondestructiveexaminations(NDE),andinstallationofpipinghangers

were not included in the inspection. This inspection verification

started at the suction header at column line 28 and proceeded through

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the bay and back through the discharge and selected auxiliary lines

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to the column 28 line, lhe piping was inspected for dimensional

conformance to the piping isometric drawings. The systems were also

inspected for nonconforming conditions, including visible or surface

damage, proper pipe sizes, fabrication errors, and related

construction and installation items. The following isometric

drawings were referenced and used for comparison during the

inspection activities:

5F-369P-SI-572, Sheet 1, Revision 7, LHSI Discharge

2F-362P-SI-572, Sheet 5, Revision 0, HHSI Discharge

2F-369P-SI-572, Sheet 4, Revision 9, LHSI & HHSI Suction

5F-069P-SI-572, Sheet A01, Revision 10, Auxiliary Systems

2F-369P-SI-572, Sheet A09, Revision 9, Auxiliary Systems

5F 369P-SI-572, Sheet A02, Revision 7, Auxiliary Systems

5F-369P-SI-572, Sheet A04, Revision 5, Auxiliary Systems

SN-129 F05014, No. 2, Revision 9, Safety Injection and Piping

Diagram

2F-369P-SI-572, Sheet 01, Revision 7. CS Suction. Discharge, and

Auxiliary Systems

5F-369P-CS-515, Sheet 04, Revision 2, Auxiliary Systems

  • SN-109F 05037, No. 2, Rsfision 9, CS Piping Diagrom

The NRC inspector noted that the licensee had identified a problem

area in flange connections. A licensee procedure, "Site Specific

Procedure - 10" (SSP-10), required bolt tightening as "snug." The

NRC inspector determined that this requirement does not h?se a

functional meaning. The licensee is revising the applicable

procedures to include torque values and/or definitions to the

assembly process. The NRC inspector will reinspect the flange

connections subsequent to completion of the licensee's rework.

b. Records

The NRC inspector reviewed records packages for selected portions of

the systems inspected to assess conformance and verify that:

The records were properly identified and retrievable within a

reasonable time.

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The records confirmed that the components were installed and

inspected as required.

The records reflected that the materials installed were the

materials specified.  ;

The records were complete and provided a traceable path for the

construction process. The following records were reviewed:

- High head and low head safety injection suction line flange

bolt-up, including Flanges S-1 and N-1.

- High head and-low head safety injection pumps to flange

conections. These components are detailed on Piping

Is. +ric Drawing F-369P-SI-572, Sheet 4, Revision 9, and

the ri es were designated as M21-MBFC-SI-2201-01, -02, -03,

and 4. The NRC inspector reviewed the piping fabrication

ch w ists, bills of material, bolted connections,

inspection reports, and the mechanical equipment / mechanical

supports checklist.

- Spool piece data packages for HHSI, the 6-inch discharge

line, SI-2206-DB2, which included Spool Pieces SI-2206-A,

-B, and C are shown on Drawing 2F362P-SI-572, Sheet 5,

Revision 0. The records are filed in a file designated as

505-SI-2206-A, -B, and -AB.

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The contents of the ASME Code data packages were reviewed for

the required drawings, Matarial Test Reports (MTRs), and NDE

reports.

The NRC inspector deterniined that the records were adequate and contained

the required information to complete the package and document the related

activities.

No violations or deviations were identified.

15. Safety-Related Components - Unit 2 (50073 and 50075)

The NRC inspector performed an inspection of safety-related components to

evaluate the fabrication and installation process and to determine whether

the installation was in accordance with the applicable drawings,

a. Spray Additive Tank

1. Work

The Train "B" spray additive tank as shown on

Drawing SN-129P-05014, Sheet 2, Revision 9; em' Wettinghouse

Drawing 1212E61, Revision 2, was inspected in letail by the NP.C

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inspector. The inspection included weld quality, detail of

parts, fabrication, damage, and dimensions. The manhole covers

were inspected for cladding, bolting, and functional ability.

2. Itecords

The vendor data package was easily retrieved from the records

vault by licensee personnel. The NRC inspector reviewed the

records for required ASME Code required forms, materials test

reports for the shell, welding consumables (electrodes), bill of '

materials, drawings, and NDE records. The records were reviewed

for correctness, completeness, legibility, and identification.

No descrepancies were identified,

b. Components

The NRC inspector also inspected tha following components during the

inspection of the spray additive tank. These items were inspected

for attributes that could be identified by visual inspection.

'

Equipment / Components Inspected for:

Area radiation monitors Damage, cables, installation and

status

Emergency lighting Test function and loss of power

Valve remote control These units were being cleaned by

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disassembled reach rod licensee personnel at the time the

assemblies inspection was being performed

! HHSI, LHSI, and CS pump motors Grounding, instrumentation, oil, .

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level, damage, bolting, and

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general appearance

No violations or deviations were identified during the inspection.

16. Exit Interview

The NRC inspectors met with licensee representatives (denoted in

paragraph 1) on July 6,1988, and sumarized the scope and findings _of the

inspection. Other meetings between NRC inspectors and lice- ae management ,

were held periodically during the inspection to diMuss identified

cor; ' erns . The licensee did not identify as proprietary any of the

information provided to or reviewed by the inspectors during this

inspection.

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