IR 05000373/1988015

Insp Repts 50-373/88-15 & 50-374/88-14 on 880510-0620.No Violations Noted.Major Areas Inspected:Licensee Actions on Previous Insp Findings,Operational Safety,Surveillance, Security,Esf Sys Walkdowns & Emergency Preparedness

ML20150B461
Person / Time
Site:	LaSalle
Issue date:	07/01/1988
From:	Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20150B446	List: IR 05000373/1988015 ML20150B442
References
50-373-88-15, 50-374-88-14, NUDOCS 8807120036
Download: ML20150B461 (13)

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U. S'. NUCLEAR REGULATORY COMMISSION

REGION III

-Reports No. 50-373/88015(DRP);50-374/88014(DRF)

' Docket Nos.-50-373; 50-374 Licenses No. NPF-11; NPF-18 Licensee: Comonwealth Edison. Company Post Office Box 767 Chicago, IL 60690 Facility Name: LaSalle County Station, Units 1 and 2-Inspection At: LaSalle Site, Marseilles, Illinois Inspection Conducted: May 10 through June 20, 1988 Inspectors: R. Lanksbury R. Kopriva L. Zerr Approved By: M.A. Ring,ChiefW 7[;hT Reactor Projects Section IB Date'

. Inspection' Summary Inspection on May 10 through June 20, 1988 (Repcrts No. 50-373/88015(DRP);

No. 50-374/88014(DRP))

Areas Inspected: Routine, unannounced inspection conducted by resident inspectors of licensee actions on previous inspection findings; operational safety; surveillance; maintenance; training; Licensee Event Reports; outages; security; ESF system walkdowns; emergency preparedness; regional requests; spent fuel pool activities; temporary instructions; confinnatory action letter followup; and onsite followup of events at operating power reactor Results: 3f the fifteen areas inspected, no violations were identifie The li.censee is roughly 87% complete with their second refueling / maintenance outage on Unit 1. All major work activities are being completed. The reactor vessel reassembly is almost complete, drywell cleanup and close out is in progress, and final paper work review is underway. The reactor vessel hydro is complete with satisfactory results. During the inspection period, the licensee held their 1988 General Site Emergency Preparedness drill. The exercise went well. One unresolved item (Paragraph 16) was identified during the inspection period dealing with the licensee's reporting of the Parch 9, 1988, power oscillation event. The transmittal letter of this inspection report contains a request for the licensee's corrective actions to ensure that future communications are prompt, accurate and complet gj71200368807og o ADOCK 05000373

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DETAILS Persons Contacted

• J. Diederich, Manager, LaSalle Station

• W. R. Huntington, Services Superintendent

• J. C. Renwick, Production Superintendent D. S. Berkman, Assistant Superintendent, Work Planning J. V. Schmeltz, Asristant Superintendent, Operations

-*P. F. Manning, Assistant Superintendent, Technical Services

• T. A. Hammerich, Regulatory Assurance Supervisor

• J. Gieseker, Technical Staff Supervisor W. Sheldon, Assistant Superintendent, Maintenance J. H. Atchley, Operating Engineer D. A. Brown, Quality Assurance Supervisor M. G. Santic, Master Instrument Mechanic

• W. Marcis, BWR Engineering

• Denotes personnel attending the exit interview on June 23, 198 Additional licensee technical and administrative personnel were contacted by the inspectors during the course of the inspectio . Licensee Action on Previous Inspection Findings (92701)

(Closed) Open Item (373/85017-02; 374/85017-02): Open item concerning evaluating possible use of a self propelled TV camera and coordinating with contractors to determine the failure mode of the High Pressure Core Spray (HPCS) full flow test line piping. The self propelled camera was never used. The licensee excavated the area, caissoned the hole, and removed an elbow section of HPCS piping. Tne section of pipe was sent off site and analyzed. The remaining pipe was capped and the hole was back fille (Closed) Noncompliance (373/84-23-03b; 374/84-30-04b): On August 25, 1984, Unit i experienced a trip of the IB recirculation pump while operating at 100% power. An instrument mechanic improperly positioned a switch during surveillance procedure LIS-NB-09, High Pressure Recirculation Pump Trip Calibration and Functional Test. The IM did not follow procedure LIS-NB-09. All instrument maintenance personnel were retrained on the specific trip logic circuit and ~the procedure was revised to clarify the placing of the bypass switch to the proper positio (Closed) Noncompliance (373/84-23-03a; 374/84-30-04a): This item pertained to the fact that the RPS Electric Power Monitoring Assembly ,

Channel Functional Test by the Operational Analysis Department (0.A.D.),

was not adequate in that an electrical divisional crosstie was not recognized in the procedural review chain. This resulted in two subsequent isolations of the reactor building ventilation system. The .

operating procedure has been revised and a description of what actions

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occur when RPS busses are transferred was added to the procedur The event was incorporated into the licensee's training program so that unusual system interactions which occur are more ger:erally known. The inspector finds the licensee's actions adequat (Closed) Open Item (373/84-14-06): LER 373/84-026 documents inoperable electric cable cepetrations. The LER was submitted in a timely fashion and contained the required infonnation and is closed; however, the corrective acthr.s specified in the LER had not been completed. The penetrations h3ve now all been sealed and the penetrations are operabl (Closed) Open Item (373/84-02-05): This item pertained to the fact that the sample line for the stack monitor was not heat traced. The heat tracing of the sample line was completed September 15, 1985, through modification 1-0-84-00 (Closed) Violation (373/85019-03): The licensee failed to prepare and issue a detailed procedure for shutting down one CRD pump and starting the other pump at full reactor power, which possibly could have prevented a reactor scram. A new procedure LOP-RD-03 has been written, approved, and issued to provide detailed instructions on how to shut down one control rod drive pump and start another on (Closea) Violation (373/85017-04): This violation concerned the fact that the procedure for performing the calibration of two level switches on March 31, 1985, was not adhered to. This allowed returning the inoperable System B for ADS to service and exceeded the action statement for Technical Specification 3. All Unit 1 and 2 instrur,.ents with similar potential that were modified by an EQ modification were verified correct in the field. Procedure LIS-NB-104 was revised and the architect engineers project procedures have been revised te strengthen the design control s. The inspector finds the licensee's actir.ns adequat No violations or deviations were identified in this are . Opnational Safety Verification (71707) The inspector observed cot: trol room operations, reviewed applicable logs, and conducted discussions with control rcom operators during the inspection period. The inspector verified the operability of selected emergency systems, revicwed tagout records, and verified proper return to service of affected components. Tours of Unit 1 and 2 reactor buildings and turbine buildings were conducted to l observe plant equipment conditions, including potential fire hazards, fluid leaks, and excessive vibrations, and to verify that l maintenance requests had been initiated for equipment in need of maintenance. The inspector, by observation and direct interview, verified that the physical security plan was being implemented in accordance with the station security plan including the following:

the appropriate number of security personnel were on site; acess control barriers were operational; protected areas were well maintained, and vital area barriers were well maintained. The inspector verified the licensee's radiological protection program was implemented in accordance with the facility policies and programs and in compliance with regulatory requirments.

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. The inspectors performed routine inspections of the control room during off-shift and weekend periods; these included inspections between the hours of 10:00 p.m. and 5:00 a The inspections were conducted to assess overall crew performance and, specifically, control room operator attentiveness during night shifts. The inspectors also reviewed the licensee's administrative controls regarding Conduct of Operations" and interviewed the licensee's secur..y personnel, shift supervisors and operators to determine if shift personnel were notified of the inspectors' arrivals onsite during off-shift The inspectors detennined that both licensed and non-licensed operators were attentive to their duties, and that the inspectors'

arrivals on site were unannounced. The licensee has implemented appropriate administrative controls related to the conduct of operations. These include procedures which specify fitness for duty and operator attentiveness, On June 1, 1988, at approximately 9:14 p.m. CDT, the licensee experienced a loss of 120V AC power to the Unit 1 inboard reactor building isolation dampeners. This caused these dampeners to clos Power was also lost to other areas / components such as the 'A'

control room and auxiliary building return fan and the Unit 1 Standby Gas Treatment flow control dampener. The cause of the power failure was traced to tripping of a breaker at the 136X-1 120V AC distribution panel. 1he breaker tripped wMn a contractor, who was

!. pulling cable directly above the panel, accidentally bumped against it. The licensee reset the breaker and returned all systems to normal at 9:50 p.m.. At 10:55 p.m. , the licensee made the required four hour ENS notificatio On June 1, 1988, at approximately 11:38 p.m. CDT, the licensee experienced a loss of their process comnuter. The computer tripped due to overheat.ing which was caused by the loss of the computer room coolers. At 1:40 a.m., the licensee recognized the fact that they could not get the computer back on line within two hours and proceeded to make the one hour ENS notification for loss of emergency assessment capability. The licensee has temporarily fixed the computer room coolers pendir.g receipt of needed parts and was able to restart the process computer at 2:44 a. Subsequently the needed parts arrived and were installed, On June 9, 1988, at approximately 6:14 p.m. CDT with Unit 1 in Mode 5 (refueling) and Unit 2 at approximately 86% power, the control room ventilatien system isolated from outside air sources and went to the recirculation mode through the charcoal filters (odor eaters). This engineered safety feature actuation was caused by a trip signal from the systems aninonia detectors. The licensee determined that the cause of the trip signal was a burned nut optical sensor bulb. The bulb was replaced and the control room ventilation system returned to nor.nal at 5:50 a.m. on June 10, 1988. The licensee made the required four hour Emergency Notification System (ENS) report at 10:01 p.m. on June 9, 198 ._, .

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. On June 17, 1988,-at 6:15 p.m. CDT, the licensee experienced a trip of the Unit 2 LPCS/RCIC room fan. The licensee was able to restart the fan, but at 7:05 p.m. it again tripped. The licensee declared both LPCS and RCIC inoperable'as of 6:15 p.m.. At 9:10 p.m., the licensee made the required four hour Emergency Notification System (ENS) phone call, Investigation by the licensee revealed that a connection on the thermal breaker was loose. The connection us tightened and all other connections were checked for tightness. At 5:00 a.m. on June 18, 1988, LPCS and RCIC were declared operable. At the time of this event, Unit 2 was at approximately 90% power and Unit I was in a refueling outag No violations or deviations were identified in this are . Monthly Surveillance Observation (61726)

The inspector observed Technical Specification required surveillance testing and verified for actual activities observed that testing was performed in accordance with adequate procedures, that test instrumenta-tion was calibrated, that Limiting Conditions for Operation were met, that removal and restoration of the affected components were accomplished, that test results confonned with Technical Specification and procedure requirements and were reviewed by personnel other than the individual directing the test, and that any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personne The inspector witnessed portions of the following test activities:

LOS-HP-M1 High Pressure Core Spray System Operability Test LOS-HP-Q1 High Pressure. Core Spray System Inservice Test When CY Lines Are Isolated LIP-GM-940 Routine Change of Control Room HVAC Ammonia Detector Cassettes LOS-0G-M2 1A Diesel Generator Operability Test LIS-NR-101 Unit 1 Source Range Monitor Rod Block Calibration LIS-LC-406 Unit 2 Main Steam Isolation Valve Leakage Control Outboard Reactor Vessel Pressure Functional Test LFS-100-1 Refuel Platform Main Hoist Interlocks Check for Core Altarations LIS-MS-304 Unit 1 Main Steam Tunnel High Temperature Main Steam Isolation Valve Isolation Fenetional Test LIS-NR-S02 Unit 1 Intertnediate Range Manitor Rod Block and Reactor Scram Functional Test LTS-1100-4 Scram Insertion Times LLP-88-011 Unit 2 MSIV Scram, ISI and ASCO Solenoid Functional Test LIS-NB-108 IWt 1 Reactor Vessel Low Low Water Level High Pressure Core

.o -ay (HPCS) Initiation Calibration: On May 29, 1988, at eyroximately 4:00 p.m. CDT, the licensee was performing

'.5-NB-108, "Unit 1 Reactor Vessel Low Low Water Levei High Pressure Core Spray (HPCS) Initiation Calibration."

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At 5:30 p.m. during the calibration of Static-0-Ring (S0R)

differential pressure switch 1821-N031B, the switch was found incapable of being calibrated. The switch appeared to have a blown diaphragm. HPCS has been inoperable due to other work on the system during the current Unit i refueling outag The licensee notified the senior resident inspector at 5:30_p.m. and made the required ENS notification at 6:35 (the licensee is required to report all SOR switch failures due to previous problems and history of SOR switches at LaSalle). The licensee removed the defective SOR switch and replaced it with a new SOR switc No violations or deviations were identified in this are . Monthly Maintenance Observation (62703)

During the inspection period, the inspector observed portions of the following maintenance activities:

L74526 Control Rod. Drive Overhant and Replacement L80281 Reactor P2 circulation Pung Discharge Valve Work (IB33-F067A)

L79272 Reactor Recirculation Motor and Pump Work L72043 '1A' Turbine Driven Reactor Feed Pump Overhaul On May 17, 1988, at approximately 10:50 a.m. CDT, the licensee received a Primary Containment Isolation System actuation and a half scram signal on Unit 1 due to the deenergization of the 1B Reactor Protection System (RPS) bus. This occurred when a jumper being installed on the Unit 1 Group I isolation logic became grounded causing the IB RPS Motor Generator (MG) set output breaker and Power Monitoring Assemblies (PMA) to open. De-energizing 1B RPS bus also caused the Unit 2 reactor building ventilation to isolate and both trains of Standby Gas Treatment (SBGT) to automatically star The licensee wasControl Electro-Hydraulic preparing (EHC) oil.to Thisstart would flushing requirethe main turbine cycling of the main turbine stop valves. The jumper being installed was to defeat the Group I isolation associated with an open main turbine stop valve with no condenser vacuum. At 10:55, the Unit 1 SBGT train was shut down and jumpers were installed to defeat the Unit 2 main steam tunnel high temperature and differential temperature Group I isolation in the anticipation of restarting the Unit 2 reactor building ventilatio At 10:58, the licensee reset the isolation signals, secured the Unit 2 SBGT tre m and restarted the Unit 2 reactor building ventilation syste No violations or deviations were identified in this are ~ , Training (41400)

The inspector, through discussions with personnel and a review of training records, evaluated the licensee's training program for operations and maintenance personnel to determine whether the general knowledge of the individuals was sufficient for their assigned task , ..

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In the areas examined by the inspector, no items of concern were identifie No violations or deviations were identified in this are . j_icenseeEventReports(92700)

Through direct observations, discussions with licensee personnel, and review of records, the following Licensee Event Reports (LERs) were reviewed to detennine that reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had been accomplished in accoraance with Technical Specifications, The following reports of noncoutine events were reviewed by the inspectors. . Based on this review it was determined that the events were of minor safety significance, did not represent program deficiencies, were properly reported, and were properly compensated for. These reports are closed:

374/88005-00 - High Pressure Core Spray Pump Minimum Flow Bypass Differential Pressure Switch Found Below Reject Limit 373/88005-00 - Inability of the 1A Diesel Generator to Meet Load Acceptance Criteria During Surveillance Testing 373/88006-00 - Continuous Conductivity Indication Inoperable Due to Vessel Draindown for Chemical Decontamination 373/88004-00 - Trip of ' A' Reactor Protection System Due to Improper Installation of ' A' Average Power Range Monitor Relay The following reports of nonroutine events involved violations of regulatory requirements. These reports are considered close Event closure is being tracked by the associated violatio Appropriate cross references are provide /88003-00 - Two Inoperable Intermediate Range Monitors During Refuel Due to Personnel Error o No violations or deviations were identified in this are . Outages (71707 - 61715)

The inspectors observed or reviewed the licensee and contractor activities associated with plant outages. The inspection focused on

, outage management program implementation, including planning, scheduling and oversight activities. The inspection included attendance at the planning and scheduling meetings, direct observation of selected modifications, repair or testing of safety systems or components, and the review of quality record , .. -

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During this inspection report period, Unit 1 continues its refueling /

maintenance outag The licensee has completed roughly 87% of the maintenance activities in preparation for a planned July 3, 1988 start up of the uni Some of the major activities that took place during the outage are as follows: Refueling of the reactor Control rod drive overhaul and replacement Work on the 1A Reactor Recirculation Pump Work on the 1A Reactor Recirculation Pump 67A Discharge Valve Chemical decontamination of-the reactor recirculation piping Overhaul of the main turbine No violations or deviations were identified in this are . Security (71881)

i The licensee's security activities were observed by the inspectors during routine facility tours and during the inspectors' site arrivals and departures. Observations included the security personnel's performance associated with access control, security checks, and surveillance activities, and focused on the adequacy of security staffing, the security response (compensatory measures), and the security staff's attentiveness and the qughness. The security forces' performance in these areas appeared ;tisfactor No violations or dev1ations were identified in this are . ESF System Walkdown (71710)

The operability of selected engineered safety features was confimed by the inspectors during walkdowns of the accessible portions of several systems. The following items were inc5ded: verification that procedures match the plant drawings, equipment conditions, housekeeping

, instrumentation, valve and electrical breaker lineup status (per procedure checklist), and verification that locks, tags, jumpers, et are properly attached and identifiable. The following systems were walked down during this inspection period:

Unit 2 Standby Gas Treatment Unit 2 Reactor Core Isolation Cooling Unit 2 Low Pressure Core Spray Unit 1 High Pressure Core Spray Unit 1 Low 9ressure Core Spray

'1A' Emergency Diesel Generator

'O' Emergency Diesel Generator Unit 1 125V DC Power Source Unit 2 Standby Liquid Control No violations or deviations were identified in this area.

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1 Emergency Preparedness (82301)

An inspection of emergency preparedness activities was performed to assess the licensee's implementation of the emergency plan and implementing procedures. The inspection included monthly observation of emergency facilities and equipment, interviews with licensee staff, and a review of selected emergency implementing procedure On June 15, 1988, the licensee held their 1988 Generating Station Emergency Plan (GSEP) exercise. The exercise was a daytime event to test the integrated capability and a major portion of the basic elements existing within the licensee's emergency preparedness plan. The exercise included mobilization of the licensee's resources adequately enough to verify their capability to respond to an emergenc .The resident inspectors attended meetings on June 14, 1988, on site and at the Emergency Offsite Facility in preparation for the exercis The exert:ise comenced at 8:00 a.m. on June 15, 1988, and was terminated at approximately 2:30 p.m. The exercise went well and the licensee's response to the scenario in the exercise was well execute On June 16, 1988, at 1:00 p.m., the NRC held their exit on the drill in the Emergency Operations Facility. The results of the exercise are reported in Inspection Reports No. 373/88017 and No. 374/8801 No violations or deviations were identified in this are . Regional Request (92701)

During the current inspection period, the inspectors received a memorandum from the Region III office pertaining to "Containment Isolation Valve Operability." A licensee at a plant in Region 11 maintains a written Technical Specification (TS) position statement which says, concerning the isolation valves covered by TS 3.6.4, "If the valve is closed, then the valve is operable." The Office of Nuclear Reactor Regulations (NRR) was asked for an interpretation on the meaning of OPERABILITY as applied to containment isolation valves. NRR's conclusion of the aforementioned statement is that the licensee's position is incorrect because it is contrary to the definition of OPERABILITY in plant TS and because it is contrary to the Action Statement in TS 3.6.4. Also, it has safety significance because it can lead to unsafe conditions. As an example, if an inoperable isolation valve is inadvertently opened, it may not close when automatic isolation is needed. As another example, an inoperable isolation valve may be a

"dual function valve" which must be able to open to allow operation of another system such as an emergency core cooling system. The NRC position is that an inoperable valve should be declared inoperable and licensees should comply with applicable action statement The inspector reviewed this memorandum with the LaSalle Station operators, operations department and the training department to ascertain LaSa11e's interpretation of valve operability. The licensee's response to the question of valve operability concurred with NRR's positio __

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No violations or deviations were identified in this are . Spent Fuel Pool. Activities (86700)

On June 1,1988, refueling of the Unit i reactor commenced. Seven hundred and sixty four (764) bundles 'were reloaded into the reactor with only minor delays in refueling due to water clarity and/or mechanical problems. Refueling was completed on June 7,198 '

During the refueling / maintenance outage, the inspector, through direct observation, witnessed the spent fuel handling operations. During the

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. observation, the-inspector verified that the correct revisions of applicable procedures were in use, he qm stioned the operators to determine if they had satisfactory knowledge regarding normal refueling activities and operator actions for abnormal indications possibly I encountered during fuel handlin Other items observed while reviewing the refueling operations were proper spent fuel pool water level, spent fuel pool ventilation system maintaining the reactor building at the specified negative pressure, and that the spent fuel pool cooling and cleanup system was mainthining pool temperature within the designed Technical Specification limit The inspector also observed fuel movements from the control room. Repeat backs between the refueling personnel and the control room nuclear shift

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operator for each fuel move were good and consistent. Also in attendance was the nuclear engineer overseeing and verifying the fuel move No violations or deviations were identified in this are . Temporary Instructions (25593)

TI 2515/93 "Inspection For Verification of Quality Assurance Request Regarding Diesel Generator Fuel Oil Multi-Plant Action Item A-15" ,

During the inspection period, an inspection was performed to verify that the licensee had complied with a January 1980 Office of Nuclear Reactor Regulation (NRR) letter to all licensees that required the licensee to check their Quality Assurance (QA) program with respect to Diesel Generator (DG) fuel oil, and to include DG fuel oil in their QA programs, if not already included, or provide justification for not doing s The inspector verified that the' licensees QA manual, Quality Procedure Q.P. No. 4-51, "Procurement Document Control For Operations Processing Purchase Documents", Attachment A, "Instruction For Specifying Quality Assurance Documentation", Paragraph 3.10 "Diesel Fuel", addresses the area of concern. The inspector also verified that the licensee has in place procedures for receipt inspection (LOP-D0-01, "Receiving Diesel Oil"), and sampling and analysis (LCP-110-62, "Sampling and Analysis of Diesel Generator Fuel Oil"), of DG fuel oi ;

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No violations or deviations were identified in this are . IE Bulletin, Confirmatory Action Letter, and Generic Letter Followup (92703)

On May 19, 1988, an Augmented Inspection Team (AIT) was formed to review the failure of all eight Dresden Unit 2 Main Steam Isolation Valves (MSIVs) to close during a special test. The test, which was conducted on May 16 and 17, 1988, was perfonned as part of an investigation by the licensee of a December 1987 incident in which an air line became disconnected on one MSIV, and the MSIV did not fully close on spring pressure alone as per design. The MSIVs are kept open against the force of the springs by air pressure and, therefore, with the loss of air pressure, the valves are expected to close as a fail safe mechanis On May 18, 1988, a Confirmatory Action Letter (CAL) (CAL-RIII-88-12) was issued to the licensee to confirm their agreement to investigate the MSIV problem. One of the actions included in the CAL was a requirement to perform an evaluation of other Commonwealth nuclear plants to determine if similar problems' exis In response to this request, LaSalle perfomed an onsite review of the ability of their MSIVs to close upon a loss of air. This review is documented in LaSalle Onsite Review (LOSR) Report 88-32 dated May 20, 1988. The inspector reviewed this document and determined that the review that was performed only pertained to Unit 2 - Unit I was at the time of the review, and still is, in a refueling outag In addition, the inspector noted that the review did not address the root cause of the failure of the Dresden MSIVs to fully close under spring pressure alon That root cause was detemined to be binding of the valve stem due to over tightening of the stem packing. The LaSalle Updated Final Safety Analysis Report (UFSAR), Paragraph 5.4.5.1, "Safety Design Bases", (Mair Steamline Isolation System), states in part, "The main steamline isolation valves, individually or collectivel . . e. use local stored energy (compressed air and/or springs)y:to close at least one isolation valve . . . .' UFSAR Paragraph S.4.5.2, "Description", states in part, "Helical springs around the spring guide shafts close the valve if air pressure is not available."

The inspector discussed the above issues with the licensee. The licensee noted that their review was performed prior to the root cause determina-tion at the Dresden station and, therefore, they had only used the infonnation available at the time of their onsite review. The inspector noted, however, that upon determination of the root cause of the failure at Dresden that they had not then supplemented the onsite review to address that failure mechanism. The licensee has agreed to supplement the original LOSR to address MSIV stem binding due to over tightening of sten packing and to include Unit 1 in the LOSR.

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16. Onsite Followup of Events at Operating Power Reactors (93702)

I On March 9,1988, LaSalle Unit 2 experienced a dual reactor recirculation

. pump trip from approximately 84% power. The plant's response to this event resulted in core performance anomalies consisting of neutron flux oscillations, as seen on the Average Power Range Monitors (APRM's), of between 25% and 50% power every two to three seconds. In responte to this event, on_ March 16, 1988, NRC formed an Augmented Inspection Team

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(AIT) to investigate the circumstances surrounding the event and to s follow the licensee's investigation and corrective actions. The results of this inspectlon are contained in Inspection Reports No. 373/88008(DRP)

and No. 374/88008(DRP). One of the areas of concern to the AIT involved the licensee's reporting of the event in accordance with the requirements of 10 CFR 50.7 The inspector followed up on this issue and reviewed the response of the licensee, as documented in the AIT's report, reviewed the requirements of 10 CFR 50.72, and interviewed members of the licensee's staff. The inspector determined that the licensee correctly classified the notification as a four hour reportable event due to the actuation of an Engineered Safety Feature (ESF) and that the required Emergency Notification System (ENS) phone call was made well within the allotted four hours (the phone call was made 53 minutes'after the reactor scram).

However, the ENS notification only communicated information 'on the dual reactor recirculation pump loss dce to a personnel error, the loss of feedwater heating and the reactor scram on high APRM flux. No mention was made of the neutron flux oscillations. The licensee did state,

"We are still investigating hil our alunn typers and everything else."

No further ENS phone calls were made by the licensee, however, further communications were established at various times, subsequent to the event, between the licensee and various members of the NRC. During these ensuing phone calls, which started as soon as one hour and 21 minutes after the reactor scram, the licensee did make mention of the neutron flux oscillations, as seen by the operators on the APRM's, of between 25% and 50% powe One question that arises from thi is whether or not a formal ENS followup phone call in accordcoce with 10 CFR 50.72(c)(2) should have been made by the licensee. 10 CFR 50.72(c) states in part, "With respect to the telephone notification made under Paragraphs (a) and (b)

of this section, in addition to making the required initial notifica-

tiens, each licensee, shall during the course of the event: ...

(2) Immediately report (i) the results of ensuin assessments of plant conditions, , . . and (iii)g evaluations infonnation or '

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to plant behavior that is not understood." The crux of the questii is what constitutes when the event, as used in 10 CIR 50.72, is ovt if the event is over when the reactor is in a stable, safe condition, such as after the reactor scram for this particular event, then there is no requirement for a followup phone call under the provisions of 10 CFR 50.72(c). If, however, the event is not over until the analysis of the circumstances surrounding the event are complete and the event is fully understood, then the licensee did not comply with the provisions of 10 CFR 50.72(c).

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c This question is-being discussed with the Office of Nuclear Reactor Regulation (NRR) to get an interpretation of the intent of the ,

requirement for followup notifications. Pending receipt of this interpretation and final resolution, the issue of the licensee's compliance-with the notification requirements of 10 CFR 50.72, as well as any other issues regarding the reporting of this event, will be treated as an unresolved item (50-374/88015-01).

Within this' area no violations or deviations were identified, however, one unresolved item was identifie . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, open items, deviations, or violations. An unresolved item disclosed during the inspection is discussed in Paragraph 1 . Exit Interview (30703)

The inspectors met with licensee representatives (denoted in Paragraph 1)

throughout the month and at the conclusion of the inspection period and summarized the scope and findings of the inspection activities. The licensee acknowledged these findings. The inspectors also discussed the likely informational contents of the inspection report with regard to documents or processes reviewed by the inspector during the inspectio The licensee did not identify any such documents or processe, as proprietar _ __ ._