ML20210A275

Insp Repts 50-338/86-28 & 50-339/86-28 on 861117-870111. Violation Noted:Failure to Document Rb-88 Contamination & Inadequate Procedure Resulting in Failure of Charging Pump

ML20210A275
Person / Time
Site:	North Anna
Issue date:	01/29/1987
From:	Caldwell J, Cantrell F, King L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20210A156	List: ML20210A151 ML20210A184 ML20210A275
References
TASK-1.D.2, TASK-TM 50-338-86-28, 50-339-86-28, NUDOCS 8702060446
Download: ML20210A275 (14)

See also: IR 05000338/1986028

Text

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pa utg UNITED STATES

, 'o NUCLEAR REGULATORY COMMISSION

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REGION 11

101 MARIETTA STREET, N.W.

• '- 't ATLANTA, GECelGI A 30323

\...../

Report Nos.: 50-338/86-28 and 50-339/86-28

Licensee: Virginia Electric & Power Company

Richmond, VA 23261

Docket Nos.: 50-338 and 50-339

Facility Name: North Anna 1 and 2

Inspection Conducted: November 18 - January 11, 1987

Inspectors: '/ ( //l(L_. [2h / O

J . L .~ ll Date Signed

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aldwe &, Senior

King, Resident Inspector.

ne Resident Inspector drelan

Date Signed

-Approved by:

F. Cantrell, Sectiropfehief

M /

oate signed

idO

, Division of Reactor Projects

SUMMARY

Scope: This routine inspection by-the resident inspectors involved the following

areas: plant status, unresolved items, licensee event report (LER) followup,

review of IE Information Notices, monthly . maintenance observation, monthly

surveillance observation, ESF walkdown, operational safety verif scation, cold

weather preparations, design changes and modifications, TMI action item, and

administrative problems associated with procedures.

Results: Three violations were identified - (1) failure to take prompt correc-

tive action - see paragraph 6; (2) failure to document Rubidium 88 contamination

- see paragraph 10; and (3) inadequate prncedure resulting in the failure of a

charging pump - see paragraph 7.

6702060446 870129 -

PDR ADOCK 05000338 I

O PDR

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REPORT DETAILS

1. Licensee Employees Contacted

• E. W. Harrell, Station Manager

• R. C, Driscoll, Quality Control (QC) Manager

G. E. Kane, Assistant Station Manager

• E. R. Smith,' Assistant Station Manager

• R. O. Enfinger, Superintendent, Operations

• M. R. Kansler, Superintendent, Maintenance

A. H. Stafford, Superintendent, Health Physics

• J. A. Stall, Superintendent, Technical Services

J. L. Downs, Superintendent, Administrative Services

J. R. Hayes, Operations Coordinator

D. A. Heacock, Engineering Supervisor

D. E. Thomas, Mechanical Maintenance Supervisor

G. D. Gordon, Electrical Supervisor

R. A. Bergquist, Instrument Supervisor

F. T. Terminella, OA Supervisor

R. S. Thomas, Superintendent Engineering

D. B. Roth, Nuclear Specialist

J. H. Leberstein, Engineer

G. G. Harkness, Licensing Coordinator

• D. E. Hickman, Jr. - Supervisor, Health Physics

• T. G. Chaffee. HPES Coordinator

• J. E. Wroniewice, Supervisor, Site Engineering, EAC

Other licensee employees contacted include technicians, operators,

mechanics, security force members, and office personnel.

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• Attended exit interview

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2. ExitInterview(30703)

The inspection scope and findings were summarized on Jaruary 9, 1987, with

those persons liMicated in paragraph 1 above. The licensee acknowledged the

inspectors findings. The licensee did not identify as proprietary any of the

material provided to or reviewed by the inspectors during this inspection.

(0 pen) Violation 338,339/86-28-01 - Failure to take prompt corrective action

to ensure compliance with 10 CFR 50.49 (para. 6).

(0 pen) Unresolved Item 338,339/86-28-0? - Possibly inadequate surveillance

procedures (para. 8).

(0 pen) Violation 338,339/86-28-03 - Failure to document Rubidium 88

contamination (para. 10).

(0 pen) Unresolved Item 338,339/86-28-04 - Verify that Rubidium 88 did not

exceed MPC limits of 10 CFR 20 (para. 10)

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(0 pen) Inspector Follow-up Item - 338,339/86-28-05 - Perform inspections to

determine source of contaminations (para. 10).

(0 pen) Inspector Follow-up Item - 338,339/86-28-06 - Determine source of CS

138 which caused a Hi-Hi Air Particle Monitor alarm (para.10).

(0 pen) Unresolved Item 338,339/86-28-07 - Modification of commitments to the

NRC regarding inspector concerns and a violation (para.12).

(0 pen) Inspector Follow-up Item 338,339/86-28-08 - Replacement of air

cylinders associated with the auxiliary feed water system (para. 7).

(0 pen) Violation 339/86-28-09 - Inadequate procedure resulting in the

failure of a charging pump (para. 7).

3. Plant Status

Unit 1

. Unit 1 began the inspection period operating at 100% power. On December 25,

1986, at 7:01 p.m. (EST), the unit was ramped dcwn to 20% power to allow

ultrasonic testing (UT) of the feed and condensate piping. This UT was being

performed as a result of the feed water rupture ~ event at the Surry power

plant. The results of the testing revealed Unit I feed and condensate piping

to be above minimun wall. The unit returned to full power on December 27,

1986 and remained at 100% power through the end of the inspection period.

Unit 2

Unit 2 began the inspection period operating at 100% power. At 2:58 a.m.

(EST) on November 25, 1986, power was reduced to 86% due to a leak in the SB

heat exchanger on Unit 2. At 4:30 a.m., power was further reduced to 822

MWe due to 4B heater high flow. Power was later reduced to 70% to plug

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tubes on the SB heat exchanger. The plant increased power to 100% on

November 25, 1986 and remained there for the rest of the period.

l Both Units

The NRC approved the extension of the operating license for both units to 40

years from the date of the approval of the operating license. This amendment

was approved by the NRC on December 30, 1986. Unit 1 operating license now

i expires April 1, 2018 and Unit 2 operating license expires August 21, 2020.

4. Unresolved Items

An Unresolved Item is a matter about which more information is required to

determine whether it is acceptable or may involve a violation or deviation.

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Three unresolved items were identified during this inspection and are

i discussed in paragraphs 8, 10 and I?.

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5. Licensee Event Report (LER) Follow-Up (90712 & 92700)

The following LERs were reviewed and closed. The inspector verified that

reporting requirements had been met, that causes had been identified, that

corrective actions appeared appropriate, that generic applicability had been

considered, and that the LER forms were complete. Additionally, the

inspectors confirmed that no unreviewed safety questions were involved and

that violations of regulations or Technical Specification (TS) conditions

had been identified.

(Closed) LER 338/85-30: Attempted Introduction of Unauthorized Weapon Into

Protected Area.

(Closed) LER 338/86-17: Emergency Core Cooling Actuation in Mode 5. This

event was the result of operator error and is being evaluated by the Human

Performance Evaluation System. This item is being followed up by IFI

86-20-02.

(Closed) LER 339/86-08: Unit 2 Reactor Trip, April 11, 1986. The trip was

a result of the failure of the permanent magnet generator. Failure of the

main generator excitation system was caused when capillary tubing to a

temperature indicator, on the exciter bearing oil drain line, grounded the

excited generator rotor through an uninsulated support strut.

(Closed) LER 338/86-15: Manual Turbine / Reactor Trip Due to High Turbine /

Generator Vibration. The L.P. turbine rotor blades were damaged and were

replaced during an outage.

(Closed) LER 338/85-18: Reactor Operators License Expires Due to Admini-

strative Error. Annual review of the License Expiration Date Tracking

System was completed 9/2/86.

(Closed) LER 338/85-25: Pressurizer PORV Opens in Mode 5 During RCS Heat

Up. This problem was caused during solid water operations where pressure

control is difficult.

(Closed) LER 339/86-11: Surveillance Requirement for Level Indicators Not

Performed. Personnel responsible have reviewed Administrative Procedures

6.11 and 16.14.

(Closed) LER 338/85-23: Inadvertant ECCS Accumulator Injection During Cold

Shutdown. The procedures have been revised to prevent re-occurrence.

(Closed) 10 CFR 21 Report: Rockwell International informed the licensee of

the potential for an ATC time delay relay on the Hydrogen Recombiner not to

be Environmental Qualified. This Part 21 was dated December 17, 1982.

Verbal confirmation from Art ltow of Rockwell International on the

licensee's contention that their use of the relay was acceptable because the

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relay was located in a zone in which it would not experience the environment

necessary to cause failure was received in June 1985. Written confirmation

that the licensee did not have to replace the relay was received from

Rockwell International in May 1986.

6. Review of I.E. Information Notices (92701)

The licensee informed the inspector that on December 31, 1986, with both

units at 100% power, the steam driven auxiliary feed pumps for both units

were declared inoperable due to an environmental qualification (EQ) problem.

An engineering evaluation was performed and a justification for continued

operation (JCO) was prepared in accordance with Generic Letter 86-15. Based

on the JC0, the steam driven auxiliary feed pumps were declared operable on

January 2, 1987, within the allowed time stated in Technical Specifications,

and the units continued to operate at 100% power.

The EQ problem concerned the affects of increased temperatures in excess of

450 degrees Fahrenheit in the main steam valve house (MSVH) due to super-

heated steam resulting from a main steam line break (MSLB) accident.

The solenoid operated valves (S0Vs) which supply air to the air operated

steam supply valves for the steam driven auxiliary feed pumps are located in

the MSVH and were only qualified to temperatures of approximately 330

degrees Fahrenheit. The JC0 concluded that these S0Vs would be required to

perform their intended function prior to the MSVH reaching temperatures in

excess of their qualification and subsequent temperature increases would not

cause the S0Vs to fail in a manner resulting in the securing of the

duxiliary feed pumps. Therefore, these S0Vs were declared operable.

The question of the affects of superheated steam on equipment in the MSVH

resulted from a corporate engineering evaluation of Inspection and Enforce-

ment Information Notice (IEIN) 84-90, which was issued in December 1984.

This IEIN informed the licensee of a potential problem in their EQ of

equipment affected by temperatures resulting in a MSLB accident. The IEIN

also stated that Westinghouse informed the licensees of Westinghouse plants

in June,1984, of a possible unreviewed safety question concerning the

l temperature envelope used for EQ of equipment resulting from this new

i evaluation. The licensee's engineering department documented an evaluation

l of this IEIN nearby two years later in October 1986 concluding that some

equipment, mostly instrumentation in the MSVH, was not qualified to

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temperatures resulting from a superheated steam condition accident and

l recommended this equipment be relocated. The SOVs for the auxiliary feed

pumps were listed among this equipment. It was not until December 30, 1986,

that a plant deviation report was written and the plant did not receive the

deviation report from the corporate office until December 31, 1986. Once

the deviation reports were received by the plant staff, the steam driven

auxiliary feed pumps were declared inoperable until an engineering evalua-

tion could be performed and a JC0 written to determine their operability.

The action taken by the plant staff, once receiving the deviation reports,

is in compliance with action recommended by the NRC in Generic Letter 86-15.

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The fact that Westinghouse notified VEPC0 in June 1984 of a possible EQ

problem, and the NRC issued an IEIN 84-90 in December 1984 reiterating the

EQ question but VEPC0 did not perform a proper evaluation until October 1986

and proper action was not taken until December 31, 1986, is an example of

failure to take prompt corrective action. Once the licensee took the

appropriate corrective action and prepared a JC0, it was concluded that the

Technical Specification related equipment was still operable, and the

instrumentation affected would have alternate means of indication if they

failed.

10 CFR 50 Appendix B Section XVI, states: " Measures shall be established to

assure that conditions adverse to quality, such as failures, malfunctions,

deficiencies, deviations, defective material and equipment and nonconform-

ances are promptly identified and corrected. In the case of significant

conditions adverse to quality, the measures shall assure that the cause of

the condition is determined and corrective action taken to preclude

repetition. The identification of the significiant condition

adverse to quality, the cause of the condition, and the corrective action

taken shall be documented and reported to appropriate levels of management."

The failure of the licensee to take prompt corrective action to ensure their

compliance with 10 CFR 50.49 will be identified as a Violation 338,

339/86-28-01 . The licensee should also address what, if any, evaluation

was performed in 1984 and what caused the IEIN to be evalurted in October

1986.

7. Monthly Maintenance (62703)

Station maintenance activities affecting safety related systems and

components were observed / reviewed, to ascertain that the activities were

conducted in accordance with approved procedures, regulatory guides and

. industry codes or standards, and in conformance witn Technical Specifica-

l tions.

The inspectors observed a seven-day outage of the service water system to

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clean 1-CC-E-1A and 2-CC-E-1B component cooling water heat exchanger. The

! isolation valves to the coolers were replaced. A design change package DCP

l 84-36 was used in conjunction with procedures 1-M0P-49.34 and 1-M0P-49.33 to

l perform the refurbishment and hydrolazing. The outage went extremely well.

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The licensee has become proficient in performing these outages. A reactor

operator was assigned full time to coordinate the outage.

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The operation of pumping sludge out of the low level waste tank to a

l portable filter was observed. This observation included a review of the RWP

(86-1222) associated with this operation.

The inspectors observed the replacement of the charcoal filter 1-GW-FL-1A

l installed in the discharge of the gases vented to the process vent. The

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filter was being replaced due to its dropping below 99.9% efficiency. The

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inspectors reviewed the work request (165692), the radiation work permit

(86-1224), and the associated maintenance procedures for removing and

replacing the filter.

A walkdown of the safeguards building for Unit 1 identified the following

open work requests (WR):

(1) 1 RS-P-2B - W.R. 165078 - annotated " seal trouble" dated 7/18/86

(2) 1-SI-FE-1948 - W.R. 121967 " flange leaks" dated 10/2/86

(3) 1-SI-P-1A - W.R.156728 " leak from jacking bolts penetrating upper

pump casing" dated 5/13/86

(4 2-SI-M0V-28603 - W.R. 239168 "open-closed indicator broken pin" dated

8/18/86

(5) 2-SI-P-1A - W.R. 233514 " relief valve leaks thru" dated 4/30/86

(6) 2-SI-P-1B - W.R. 146958 " seal leaks" (incorrect work request number)

The inspectors will continue to monitor performance of open safety related

work requests in an attempt to detennine the significance of the maintenance

backlog.

During a walkdown of the turbine driven feed pump area for Unit 1, the

inspector noticed that the periodic test was being performed. The mainten-

ance personnel were adjusting tae governor ?t4h the pump running prior to

the operators obtaining the vibcation and temperature data for the periodic

test. The test was being performed as an acceptance test after maintenance

had checked the overspeed trip. The startup of the pump should be tested

after the governor has been finally set. The inspector notified the control

room, and the test was rerun to ensure that the pump would not trip out at

l the present governor setting.

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If the periodic test is used after maintenance, it should give clear

l instructions to the operators that the test needs to be run after the

l governor setting has been reestablished. The alternative would be to record

l the governor setting prior to the overspeed test and after the overspeed

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test to reset the governor and then run the periodic test.

During a review of the operator logs, the inspector discovered the Unit 2

"A" charging pump had to be secured and declared inoperable. Discussion

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with the operators and a review of the licensee's deviation report on the

charging pump failure revealed the following:

On November 26, 1986, maintenance was performed on the 2-CH-P-1A

charging purp. The pump was then restored to service per Maintenance

Operating Procedure (M0P) 2-M0P-8.01 and Operating Procedure 2-0P-8.1.

On November 27, 1986, while taking logs, an operator discovered the

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temperature on the "A" charging pump speed increaser oil cooler to be

approximately 200 degrees Fahrenheit, well in excess of the maximum

temperature. The pump was secured and declared inoperable. The

licensee determined the cause of the overheating of the speed increaser

to be the inadvertent closure of a service water isolation valve to the

speed increaser oil cooler.

The licensee has been unable to determine the cause of the closure of the

service water isolation valve 2-SW-264. This valve was located inside the

isolation boundary established for the maintenance performed on November

26, 1986, and the restoration procedures M0P 2-M0P-8.01 and OP-2-0P-8.1.

Neither procedure repositioned this valve during maintenance or verified the

position of this valve prior to placing the 2-CH-P-1A charging pump back in

service. The operating procedure 2-0P-8.1 did have a step requiring the

operator to verify service water flow through the speed increaser oil cooler

and two other parallel oil coolers, but did not explain how the operator was

to perform this verification. A flow element which indicates service water

flow through all three coolers was available to the operator but with flow

secured to only one of the coolers, the flow observed by the operator

actually increased. Also, temperature elements were available on each of

the coolers, but since the temperature increase due to the service water

isolation was relatively slow, the operator did not notice an abnormal

temperature at the time of pump restoration to service.

The licensee has performed corrective maintenance and returned the 2-CH-P-la

charging pump to operability. At the time of the event, the other two

charging pumps "B" and "C" were operable and TS require only two operable

charging pumps for the mode of operation the plant was in (Mode 1 approxi-

mately 100% power) at the time of the event. The licensee has locked valve

2-SW-264 in the open position and is continuing an evaluation into addi-

tional corrective action as well as performing a human factors evaluation of

the event.

Technical Specification 6.8.1.a. requires written procedures to be

established, implemented and maintained covering the startup operation and

shutdown of the chemical and volume control system. The failure of 2-0P-8.1

to provide adequate instructions to ensure that 2-CH-P-1A was properly

placed in service resulting in the inoperability of tne charging pump will

be identified as a violation 339/86-28-09.

In October 1985 the resident inspector requested the licensee to evaluate

the use of the air cylinders supplying backup air to the steam supply valves

for the steam driven auxiliary feed pumps. The licensee performed this

evaluation in engineering work request (EWR)85-704. This EWR concluded that

these air cylinders were not designed for this use and corrosion products

could collect in these cylinders with the potenial for blocking the air

lines. The EWR requested the present air cylinders be replaced with properly

designed air cylinders. EWR 85-704 was evaluated in January 1986 but the air

cylinders still have not been replaced. The inspector determined that a

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quarterly surveillance test was being performed operating the steam supply

valves via the air cylinders. This surveillance demonstrates that the air

lines are not blocked approximately every three months. The replacement of

these air cylinders with properly designed air cylinders will be identified

as Inspector Follow-up Item 338,339/86-28-08.

8. Monthly Surveillance (61726)

The inspectors observed / reviewed Technical Specification required testing

and verified that testing was performed in accordance with adequate

procedures, that test instrumentation was calibrated, that limiting

conditions for operation (LC0) were met and that any deficiencies identified

were properly reviewed and resolved.

The inspectors reviewed 2-PT-231A " Quadrant Power Tilt Ratio". This is

required to be performed every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> due to (N 43) Power Range Channel 3

being inoperable. The procedure is performed by the reactor engineer during

the day and by the shift test advisor during the, evening.

During the week of December 1-5, 1986, a team of NRC inspectors and

contractors visited the North Anna site to inspect the control room

habitability system. The results of the inspection revealed several

potential problems. The first- problem involved flow measurements of the

control room emergency ventilation system that were taken by the team.

These measurements indicated that emergency ventilation was not in

compliance with Technical Specifications (TS). The following week, the

licensee entered the TS action statement for an inoperable control room

emergency ventilation system, backdated to December 5,1986. The licensee

proceeded to take their own flow measurements and confirmed that they were

l not in compliance with TS. The inspector was informed by the licensee that

l flow dampers have been adjusted to bring the ventilation flow rates into

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compliance with TS within the time limits specified by TS.

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The following week, a potential problem with the control bottled air system

was discussed during telephone conversations between the licensee and the

NRC. The team determined based on observations that the bottled air system

may not meet TS requirements. The bottled air system is required to

pressurize the control room envelope to 0.05 inches water gage above the

! outside atmosphere. It appears that the lower emergency switch gear

l ventilation rooms will be at a lower pressure than the adjacent chiller

l room. - The chiller rooms communicate directly with the turbine building.

l With the ventilation room at a lower pressure than the chiller room, a

l potential path exists for flow from the turbine building into the control

room envelope. Discussions with the licensee revealed the 18 month

surveillance test on the bottled air system to ensure compliance with TS

does not measure the differential pressure between the ventilation rooms and

the chiller rooms. The inspector was informed this measurement was not

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taken because differential pressure instrumentation was not installed in

l these compartments. The licensee has determined that the low pressure in

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the lower ventilation room is a result of too small an opening from the

emergency switchgear room to the ventilation room. This opening will not

pass sufficient air flow into the ventilation room when the ventilation fan

is operated. The licensee has taken temporary corrective action blocking

off possible flow paths between the chiller room and the ventilation room.

The long term corrective action will be to increase the size of the opening

between the switchgear room and the ventilation room.

The inspector is concerned that the surveillance procedures performed by the

licensee to ensure that they are in compliance with TS surveillance

requirements have been inadequate. These surveillance procedures should

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have already identified the problems that were identified by the team of NRC

inspectors and contractors. The possibility for these surveillance

procedures to be inadequate resulting in the licensee being in noncompliance

with TS will be identified as an Unresolved Item 338,339/86-28-02, pending

further investigation by the resident inspectors.

The safety evaluation for special test 2-ST-51 "Tavg Reduction at Core

Uprated Power" was reviewed by the inspector. The inspector discussed this

evaluation with the regional and headquarters staff on November 18, 1986 and

a determination was made that the performance of 2-ST-51 was acceptable for

Unit 2 and the similar test 1-ST-70 was acceptable for Unit 1.

No violations or deviations were identified.

9. ESF System Walkdown (71710)

The following selected ESF systems were verified operable by performing a

walkdown of the accessible and essential portions of the systems on

January 8, 1987.

The inspectors walked down the control room bottled air pressurization

system for Unit 1. Valve Checkoff 1-0P-21.9A was used. The following

comments were noted:

The normal position for 1-CA-6, #1 header outlet isolation valve is open,

but it was found closed. The normal position for 1-CA-11, #2 header outlet

isolation valve is closed, but it was found open. The valve checkoff should

indicate that either position is acceptable as long as at least one valve is

open.

The valve lineup for 1-CA-19, TV-HV-1306B inlet isolation valve indicates

that it should be open, but the actual position was locked open. If the

valve is required or desired to be locked open, then the valve lineup

procedure should reflect that position.

The individual compressed air bottle isolation valves are missing valve

tags.

The above items were brought to the attention of the licensee and no

violations or deviations were identified.

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10. Operational Safety Verification (71707)

By observations during the inspection period, the inspectors verified that

the control room manning requirements were being met. In addition, the

inspectors observed shift turnover to verify that continuity of system

status was maintained. The inspectors periodically questioned shift

personnel relative to their awareness of plant conditions.

Through log review and plant tours, the inspectors verified compliance with

selected Technical Specification and Limiting Conditions for Operations.

In the course of the monthly activities, the resident inspectors included a

review of the licensee's physical security program. The performance of

various shifts of the security force was observed in the conduct of daily

activities to include: protected and vital areas access controls, searching

of personnel, packages and vehicles, badge issuance and retrieval, escorting

of visitors, patrols and compensatory posts. In addition, the resident

inspectors observed protected area lighting, protected and vital areas

barrier integrity and verified an interface between the security organiza-

tion and operations or maintenance.

On a regular basis, radiation work permits (RWP) were reviewed and the

specific work activity was monitored to assure the activities were being

conducted per the RWPs. Selected radiation protection instruments were

periodically checked and equioment operability and calibration frequency was

verified.

On December 12,1986, at 3:00 p.m., the inspector exited the auxiliary

building and alarmed the portal monitor. Several other personnel were

identified as contaminated at this time. The inspector inquired from the

health physics technician as to the source of the contamination. He was

told it was probably the result of the chemists taking a primary sample.

Clothing was analyzed, and it was determined that the source of contamina-

tion was Rubidium 88 and some Cesium.

On December 13, 1986, the inspector requested the health physics office

provide him a list of the contamination reports of the previous day.

Followup by the inspector identified that a contamination report had not

been filled out for a technician who was contaminated. Health Physics

Procedure 3.1.7 requires a contamination report form be filled out for

Rubidium 88 personnel contaminations. The failure of the licensee to

document the Rubidium 88 contamination will be identified as Violation

338,339/86-28-03.

The inspector questioned several plant personnel and determined that

contamination due to Rubidium 88 was not unusual when a primary sample was

being taken.

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On the morning of December 23, the inspector and the health physics

supervisor both alarmed the monitor on exiting the auxiliary building. This

was again determined to be Rubidium 88. Followup indicated that no chemistry

sample had been taken for several hours.

No air samples were taken during either of these incidents. The licensee

should provide data on the contamination occuring on December 12 that the

Rubidium 88 contamination did not exceed the MPC limits of 10 CFR 20. This

will be identified as unresolved item 338,339/86-28-04.

The inspector requests the licensee to: (1) examine the flow across the

primary hood; (2) investigate the technique for taking primary samples;

(3) check for leaks on the discharge side of the air handling system. This

will be identified as inspector follow-up item 338,339/86-28-05.

On December 24,1986, at 1:30 a.m., there was a Hi-Hi alarm on RM-VG-105 Air

Particle Monitor. The inspector investigated and found that air samples had

been taken which indicated CS 138, but that the cause of the alarm had not

been found. This will be identified as inspector follow-up item 338,

339/86-28-06.

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The inspectors kept informed, on a daily basis, of overall status of both

units and of any significant safety matter related to plant operations.

Discussions were held with plant management and various members of the

operations staff on a regular basis. Selected portions of operating logs and

data sheets were reviewed daily.

The inspectors conducted various plant tours and made frequent visits to the

Control Room. Observations included: witnessing work activities in progress;

verifying the status of operating and standby safety systems and equipment;

confirming valve positions, instrument and recorder readings, annuciator

alarms, and housekeeping.

l On December 31, 1986, at 5:55 a.m., the inspector observed a simulated fire

j drill in the administration building cafeteria area. All brigade members

responded and were dressed out in a timely fashion. The inspector attended

the critique that followed the drill.

11. ColdWeatherPreparations(71714)

The inspectors reviewed 1-MISC-18 " Cold Weather Operations". This is a

general procedure that expresses concern about freezing weather on plant

operations. It lists several cautions and items that have frozen in the

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past. It is required that the shift supervisor review the contents of this

procedure with all shift personnel in the form of a safety meeting presenta-

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tion during the last week in September of each year.

The inspector reviewed the records of ten preventative maintenance proce-

dures that are required to be done for cold weather. All procedures were

confirmed as completed.

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No violations or deviations were identified

12. Design Changes and Modifications (37700)

Design Change Procedure 85-33 " Gas Stripper Knockout Drum" was reviewed.

(See inspection report 338,339/86-13 for details on problems associated with

the design change procedure on station batteries)

In Inspection Report 338,339/86-25 the inspector reviewed Administrative

Procedure (AP) 3.1 and closed out violation 338,339/86-13-02 based on the

changes made to AP 3.1. The inspector obtained the latest revision

of AP 3.1 and noted that a step had been added on page 9 which stated that

"There may be situations where the formal use of this procedure is not

required". The step was not clear. See the inspection reports

referenced in paragraph 14 of this report concerning legibility of changes

to procedures. The inspectors are concerned that a step has been added

which negates changes made to the procedure to resolve a violation and

inspector concerns documented in Inspection Report 338,339/86-13. They are

also concerned the problem identified in Inspection Report 338,339/86-13 may

still exist. A further concern is that SNSOC approved this step considering

the response to Inspection Report 338,339/86-13. This will be listed as an

unresolved item 338,339/86-28-07, pending further discussion with the

licensee.

No violations or deviations were identified.

13. TMI Action Items (71707)

Item I.D.2

Licensee letter 86-053 dated March 7, 1986, requested a scheduled extension

until October 1,1986, for completion of outstanding items on the SPDS. A

December 15, 1986, letter 86-053A, again requested an extension until May 1,

1987, for completion of the SPDS. The licensee had several telephone

conversations with the NRC about missing their commitment of October 1,

1986. However the written request for relief was not made until December 15,

1986, after the commitment had already been missed. The licensee was

reminded that if a commitment is going to be missed, written NRC approval

l must be received prior to the connitment date. This will ensure that

l enforcement action will not be taken.

Item I.C.I.2.B & I.C.I.3.B

The licensee is presently using revision "0" c' the Emergency Operating

Procedures (E0Ps). By letter dated May 30, 1986 the licensee has stated

that they intend to implement the improved E0Ps by April 30, 1987. These

improved E0Ps will have corrected the deficiencies and weaknesses identified

during the NRC audit performed the week of May 5, 1986.

No violations or deviations were identified,

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14. Administrative Problems Associated with Procedures

In attempting to identify the problem with gaseous activity in the auxiliary

building, the inspector reviewed 1-0P-12.0 " Sampling System" procedure and

2-PT-53.1 " Reactor Coolant System Chemistry and Gross Activity" procedure.

Procedure 2-PT-53.1 was marked up to the extent that it makes the procedure

difficult to follow. This problem was identified in Inspection Reports

338,339/85-31, 85-22, 85-18 and 84-37. Inspection Report 338,339/85-31

identified the fact that hand written procedures have led to past technical

problems. Procedures that have been changed to this extent should be

rewritten instead of marked up. Procedure 1-0P-12.0 should be consistent

with 2-PT-53.1. This concern was brought to licensee management

attention.

No violations or deviations were identified.