IR 05000369/1989014

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Insp Repts 50-369/89-14 & 50-370/89-14 on 890422-0601. Violation Noted.Major Areas Inspected:Operation Safety Verification,Surveillance Testing,Maint activities,10CFR21 Reviews,Followup on Previous Insp Findings & LERs
ML20236E647
Person / Time
Site: McGuire, Mcguire  Duke Energy icon.png
Issue date: 07/13/1989
From: Shymlock M, Vandoorn K
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20236E641 List:
References
50-369-89-14, 50-370-89-14, IEIN-87-024, IEIN-87-24, IEIN-88-051, IEIN-88-073, IEIN-88-51, IEIN-88-73, NUDOCS 8907270264
Download: ML20236E647 (13)


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  • 2* NUCLEAR REGULATORY COMMISSION.-

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o * REGION 11

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-[ 101 MARIETTA ST., % , , , *o ' ATLANTA GEORGIA 30323 Report Nos. 50-369/89-14 and 50-370/89-14 Licensee: Duke Power Company 422 South Church Street Charlotte, NC 28242 +

i Facility Name: McGuire Nuclear Station 1 and 2 Docket Nos.: 50-369 and 50-370 License Nos.: NPF-9 and-NPF-17 (

Inspection Conducted: April 22, 1989 - June 1,-1989

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Inspettor:. 1/// ///r /

K.'YafiDoorn, Seniof Resident Inspector 7/)F f Drte/Sigfied a

Accompanying Inspectors: T. Cooper, Reactor Inspector

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B. Bonser, Project Inspector Approve y: -

7!/J fE M. B. Shymlock, Section Chief Division of Reactor Projects SUMMARY Scope:

This routine unannounced inspection involved the areas of operations safety i verification, surveillance testing, maintenance activities, Part 21' reviews, and follow-up on previous inspection findings and Licensee Event Report Results:

In the areas inspected, one cited violation was identified and' one non-cited violations were identified as follows:

Violation 369,370/89-14-01: Inadequate Surveillance Procedures for MSIV' (paragraph 4.d)

Non-Cited Violation 369/89-14-02: Failure to Meet Design Basis Flow for Chilled Water for Control Room Ventilation due to Inadequate Calibratio (paragraph 6)

It was noted that the licensee is not making consistent progress with correcting control room indication problem '

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1 It was also noted that the licensee has recognized that the persistent problems with failure to follow procedures is a widespread problem. The licensee appears to be making a concerted effort at improving managements role in assuring procedure complianc d

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REPORT DETAILS Persons Contacted Licensee Employees G. Addis, Superintendent of Station Services D. Baxter. Support Operations Manager J. Boyle, Superintendent of Integrated Scheduling D. Bumgardner, Unit 1 Operations Manager J. Foster, Station Health Physicist M. Funderburke, Station Chemist

  • Gilbert, Superintendent of Technical Services C. Hendrix, Maintenance Engineering Services Manager -

T. Nathews, Site Design Engineering Manager

  • T. McConnell, Plant Manager D. Murdock, McGuire Design Engineering Division Manager W. Reeside, Operations Engineer R. Rider, Mechanical Maintenance Engineer
  • M. Sample, Superintendent of Maintenance R. Sharp, Compliance Manager J. Snyder, Performance Engineer J. Silver, Unit 2 Operations Manager
  • A. Sipe, McGuire Safety Review Group Chairman
  • B. Travis, Superintendent of Operations R. White, Instrument and Electrical Engineer Other licensee employees contacted included craftsmen, technicians, operators, mechanics, security force members, and office personne * Attended exit interview Unresolved Items An unresolved item (UNR) is a matter about which more information is required to determine whether it is acceptable or may involve a violation or deviation. There were no unresolved items identified in this repor . Plant Operations (71707, 71710)

The inspection staff reviewed piant operations during the report period to verify conformance with applicable regulatory requirements. Control room logs, shift npervisors' logs, shift turnover records and equipment l removal and restoration records were _ routinely perued. Interviews were conducted with plant operations, maintenance, chemistry, health physics, l and performance personne _ _ _ _ _ - _ _ _ _ _

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Activities within the control room were monitored during shifts and at shift changes. Actions and/or activities observed were conducted as prescribed in applicable station administrative di"ectives. The complement of 1 censed personnel on each shift met or exceeded the minimum required by Technical Specification Plant tours taken during the reporting period included, but were not limited to, the turbine buildings, the auxiliary building, Units 1 and 2 electrical equipment rooms, Units 1 and 2 cable spreading rooms, and the station yard zone inside the protected are During the plant tours, ongoing activities, housekeeping, security, equipment status and radiation control practices were observe Unit 1 Operations The unit began the pericd in mid-loop operation due to the steam i

generator tube rupture event described previously. Startup commenced-on May 6,1989 and the unit was placed on-line on May 9,1989. The

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unit remained on-line the rest of the period ending the period at 100% power. Some off-gas problems were experienced in the Auxiliary Building after the Unit 1 startup. The licensee aggressively pursued and corrected the proble Unit 2 Operations The unit generally ran at full power during the entire period with

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some power reductions for fuel conservatio Housekeeping issues described in a previous report (369,370/89-11)

were corrected during this inspection period. During this period the inspector noted an argon gas bottle with no housekeeping tag near the 2B Nuclear Service Water pum The licensee appropriately responded by removing the bottle. The licensee indicated that a more positive control program for both bottles and scaffolding is being develope The inspector also noted many open locks in various locations at Motor Control Centers (MCC's). The licensee indicated that these are locks which are available when needed for various valve lineups, many of which are needed during outages. The licensee's intent is to store most locks in a central location near each MCC. The licensee was asked to review this issu The inspector reviewed the Control Room Ventilation (VC) system capabilities relative to degradation from smok This review was prompted by the fire experienced at the licensee's Oconee Nuclear Station. VC has two 100% capacity filtered trains with smoke detectors. Outside air intake is provided from two well separated locations. The system is capable of pressurizing the control roo Also the system has the capability to purge the ductwork should it become necessary. Air packs are also provided for operators in the ,

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e.- During the Unit 1 outage the licensee discovered minor discrepancies in vendor supplied flow control orificet . and discovered a construction orifice in one train of the Auxiliary Feedwater (CA)

I system. This problem contributed to errors in the flow balance. The l licensee replaced the construction orifice and conducted prototype testing.- A Justification for Continued Operation (JCO) up to 20%

power was documented on May 8, 1989. A rebalance was accomplished at approximately 15% power and a new JC0 issued (see paragraph 4.a).

The licensee inspected Unit 2 for construction orifices and found non The licensee's judgement was that the Unit 2 CA system was operabl Based on testing information from the licensee's Catawba Station relative to Borg-Warner flexible wedge gate valves, the licensee ~was required to evaluate operability of four.CA and four Main Feedwater-(CF) system valves for each unit. The primary purpose of these valves is to close under certain conditions to limit energy input into containment during a faulted steam generator (e.g. feedline -

break) event. It is questionable whether these valves 'could close under maximum postulated differential. pressure. Compensatory actions were provided for the CA Valves ( 1 and 2'CA-38, 50, 54 and 66) on May 16, 1989. The actions involved use of an air-operated valve in the lines or a local manual valv These compensatory actions appeared viable since the. valves are accessible. The analysis for CA assumes no operator action for 15 minutes and appropriate training was provided to operators. The long term fix is under evaluation and will probably include valve replacemen The CF valves, normally shut during operation, were failed shut while further testing and review could be accomplished. A short term or long term fix had not been developed at the end of the inspection period. Although the safe mode is closed, the-licensee would not be able to startup with these valves inoperable. if shutdown occurred since the valves are necessary for startu The inspector noted that the licensee is not making consistent progress in correction of Control Room Indication Problems (CRIPS).

The number of CRIPS has been high for an extended period of time and has been previously noted by the NRC. The number increased during the period from 117 to 13 A dedicated' repair crew and site goals-were previously established, however, it appears this problem ma need more attention if consistent progress is not.more. forthcomin No violations or deviations were identifie . Surveillance Testing (61726)

Selected surveillance ' tests were analyzed and/or witnessed by the inspector to ascertain procedural and performance adequacy and conformance with applicable Technical Specification _ _ _ - _ _

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Selected tests were witnessed or reviewed to ascertain that- current written approved procedures were available and.in use, that test equipment i in use was calibrated, that test prerequisites were met. .that system- !

restoration was completed and test results were. adequat Detailed below are selected tests which were either reviewed or witnessed:

PROCEDURE EQUIPMENT / TEST PT/1/A/4252/15 CA System Flow Leakage Verification PT/1/A/4252/13 Motor Driven CA System Flow Balance PT/1/A/4252/14 Turbine Driven CA System Flow Balance PT/0/A/4600/4 Incore Instrument Detector Calibration IP/0/A/3207/07 Nuclear Instrumentation System Power Range Detector Current Calibration The above Unit 1 Auxiliary Feedwater (CA) leakage test was performed because previous testing had shown lower than expected flows to the steam generators (SG). Leakage was determined to be occurring through the valves which recirculate flow to the Upper Surge Tank from the Motor Driven CA pumps (MDCAP). The original design basis requires pump capacities to be 98% of manufacturers head curv Present performance is 97.5%, 97.8% and 97% for the A MDCAP, B MDCAP and Turbine Driven CA pump respectively. Given the lower than required pump performance and the leakage a special flow balance was i performed to assure optimal flow to each SG. A special analysis was l completed and a Justification for Continued Operation was issued on l May 11, 1989. There are no additional flow margins available in the !

analysis. Therefore, the licensee will attempt to repair the leaking j valves and rebalance the system, A special inspection was performed which served to verify various Technical Specification surveillance were being performed for Diesel Generator Fuel Oil (See paragraph 8.) The licensee identified that leakage surveillance for Containment Purge (VP) valves may be inadequate based on NRC Information Notice I 88-73: Direction-Dependent Leak Characteristics of Containment Purge !

Valves and vendor information. Leakage rate is direction dependent )

for the Fisher Controls Series 9200 butterfly valves and the inside j valves have been tested in a non-conservative direction. While the i surveillance is apparently inadequate, the licensee judged that their valves were operable and documented the decision in an Operability )

Evaluation dated May 26, 1989. Operability was based on several '

facts. The licensee quarterly tests have all resulted in minimal measured leakage. The valves are not opened during operations to assure that the seating characteristics are not disturbe The

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McGuire valves are 24-inches in diameter and the pressure requirement is approximately 15-psig. The valves cited in the Information Notice are 48-inches in diameter with an approximate 50-psig pressure requiremen Satisfactory containment integrated leak rate test results further assure acceptable leak rates for the penetration Further evaluation is in progress relative to a long term fi d. On May 25, 1989 site personnel determined that the Main Steam Isolation Valves (MSIV) for both Units may be inoperable based on NRC Information Notice No.88-51: Failures of Main Steam Isolation Valve The valves are required to close within 5 seconds without air assist per the FSAR, Section 10.3.2 and Technical Specification l (TS) 3.7.1.4. Routine surveillance on the MSIVs has been performed which allows air assistance per surveillance procedures PT/1 and 2/A/4255/03A and 03B, SM Valve Stroke Timing (Shutdown). The licensee provided an operability evaluation that the valves were operable based in part on the following information:

(1) The McGuire MSIVs, under the worst case flow / operating conditions (full pressure, reverse flow) have an operator closing margin of 2264 lb. or 24%,' assuming spring force onl No credit is assumed for air assis (2) Atwood & Morrill (A&M), the manufacturer, has verified actuator margins and stroke time by full flow testing, in both directions at maximum pressure drop in both direction (3) The variables affecting stroke time are packing drag and the l load imposed by the speed control cylinder.

i The values used for packing drag by A&M in the sizing

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cciculations are conservative and according to the licensee, the packing system is original (0P-asbestos, graphite-& zinc).-

The speed control cylinders were rendered inoperative so they_

cannot adversely affect stroke time In addition, the licensee informed the inspector that like valves were tested satisfactorily without air assist at the Catawba Station and these valves had weaker springs and higher packing drag. This operability evaluation was documented on May 26, 198 Corporate personnel documented the concern in Problem Investigation Report (PIR-0-M 89-0122) on May 16, 1989. This PIR was signed out and sent under a cover letter to the site on May 22, 1989. -Site personnel became aware of the letter on May 25, 1989. The letter stated, " Corrective actions need to be taken at MNS since current surveillance testing of the MSIVs does not assure that they will

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close within 5 seconds with spring forces alone. The recommended corrective action is for the MNS MSIVs to be surveillance tested while closing with spring forces alone. The attached PIR was written to initiate corrective actions and should be distributed accordingly."

While the operability evaluation is appropriate, the inspector is concerned that an inadequate surveillance was allowed to exist from early August 1988 when the Information Notice was received until late May 1989. The inspector is further concerned with the process of notification of the site by corporate personnel of a possibly significant operability issu In that it took nine days to identify an operability concern to site personnel and to initiate corrective action The licensee intends to perform the adequate surveillance during the next available outage since the surveillance is not possible at powe It is noted that Unit I has had two extended outages since the fall of 1988 which afforded the. opportunity to test the MSIVs had the problem been addressed earlier.

l Because the NRC wants to encourage and support licensee initiative for self-identification and correction of problems, the NRC will not i

generally issue a Notice of Violation for a violatior that meets specific criteri However, a violation for inadequate surveillance procedures to test the MSIVs is being cited because corrective actions were not accomplished in a reasonable time period. This is i Violation 369,370/89-14-01: Inadequate Surveillance Procedures for 1 MSIV l One violation was identified as described abov l S. Maintenance Observations (62703)

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Routine maintenance activities were reviewed and/or witnessed by the '

resident inspection staff to ascertain procedural and performance adequacy and conformance with applicable Technical Specification !

l The selected activities witnessed were examined to ascertain that, where j applicable, current written approved procedures were available and in use, j that prerequisites were met, that equipment restoration was completed and ,

maintenance results were adequat ;

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i ACTIVITY WORK REQUEST / PROCEDURE l Valve Operator Testing of 2CF126 96698 NSM

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l Trouble Shoot Spurious OP Delta T WR 138606 OPS Runback / Rod Stop Alert Alarm Replace Control Room Switch for WR 88828 MNT IND4B ,

1A NI Pump Couplino Alignment WR 097076PM/MP/0/A/7150/44 The inspector noted during observation of the activities listed above that procedures were being referenced and followed. The Safety- l Injection (NI) pump alignment procedure was a broad procedure written I for complete teardown. Specific sections to be used were reference '

on the work request and were being followed. It was noted that the mechanic had to push in on the turning bar to obtain consistent )

readings on the coupling face. Also the motor side flange was wired )

back to keep from interfering with the dial indicator mounting. The I mechanics attempted to use a specially made NI Pump socket for the motor bolts which would no longer work because heavier washers were apparently being used since the socket was manufactured. Also this special tool was not referenced in the procedure. These observations were passed on to the licensee for consideration of improvements in l tooling and procedure guidance. During the NI pump inspection a mechanic indicated the Quality Assurance (QA) inspectors sometimes require bolt torque to be verified by simply checking torque and l other times by requiring bolts to be untorqued and retorqued while l

being observed. The inspector inquired of QA Supervision why the j inspections varie The inspector was informed that -the general inspection procedure only requires verification of minimum torque, however, some inspectors choose to occasionally verify that bolts ar not being overtorqued and require the loosening and retorqueing to be accomplished. This is an acceptable practice to QA management.

i The inspector also discussed maintenance goals with the Maintenance j Superintenden While a nuniber of goals are being met, those 4 involving outstanding work requests and control room indicators are j l

l not being met. The licensee indicated that management attention is j being placed on these issues and improvement is expecte !

l The licensee appears to have recognized that the general problem of j procedural compliance is a cultural one and appears to be making a i concerted effort at improving managements role in assuring procedural ^

complianc This comment is based on discussions with licensee 4 management and a review of information presented by the licensee'in recent line staff meeting No violations or deviations were identifie "

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i Licensee Event Report (LER) and Part 21 Followup (90712,92700) The below listed Licensee Event' Reports (LER) were reviewed to i determine if the information provided met NRC requirements. The determination included: adequacy of description, verification of compliance with Technical Specifications and regulatory requirements, I corrective action taken, existence of potential generic problems, i reportieg requirements satisfied, and the relative safety significance of each even Additional inplant reviews and discussion with plant personnel, as appropriate, were conducted for ]'

those reports indicated by an (*). The following LERs are closed:

369/87-22, Rev. 1: Fire Barrier Blanket Breached Without-Compensatory Action. Since this event occurred additional problems have occurred. However, the licensee has taken generic corrective actions and problems in this area have diminished (see NRC Report 369,370/89-01).

l 369/87-27: Entered Hot Shutdown Without Containment Spray Heat Exchanger 1B Cooling Water Inlet Valve Being Retested Due To .,

Personnel Error. Appropriate procedure chtnges were made and the ]

retest of the valve was satisfactor In addition, due to a

.l violation which occurred since this event (369,370/88-29-01), the licensee has strengthened the retest progra /87-33: Four Main Steam to Auxiliary Feedwater Valves Were Omitted From The Inservice Valve Testing Program. This problem was identified during an NRC inspection and an Unresolved Item has been established for followup (See UNR 369,370/88-31-18)

369/87-37: Waste Gas Surveillance Sample Was Not Obtat.ed Within Technical Specification Time Limit. Appropriate procedure changes have been made to require verification of sampling requirements by two individuals and no similar events have occurred in recent histor *369/88-17, Rev.1, A Containment Isolation Valve Was Inoperable Due To Defective Procedure. The inspector reviewed the corrective actions taken as a result of this item and found them complete and adequate to address the issu *369/88-27, Rev. 1: Surveillance Requirement Was Not Performed Prior To Entering Mode 4. This event was caused in part by weaknesses in the work request program. The licensee has made appropriate program change *369/88-36: Units 1 and 2 Diesel Generators Were .Potentially-Inoperable Due To A Design Deficiency With Starting Air System.

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Followup inspection of this issue has previously identified a possible violation (see 369,370/89-05-03). Further followup will be accomplished through followup of the violatio _ _ _ _ _ _ _ _ _ _ - _


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369/88-48: Shrinkage of Boraflex Neutron Absorbing Material Could  !

Cause A Resultant Increase In Reactivity Not Previously Considered (Voluntary Report). l 369/88-49: Residual Heat Removal Pump 18 Manually Stopped Due To Air i Binding Causing A Loss of RHR (See Violation 369,370/89-11-01).  !

  • 369/89-02: Design Basis Nuclear Service Water Flow To The Control Area Chilled Water System Cannot Be Justified Between December 8, 1987 And February 24, 1989 As Required By Technical Spec. Licensee Performance personnel' identified this proble Control Room 4'

Ventilation remained operable during the time period. This violation is not being cited bei.ause the criteria specified in Section V.G. of

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I the Enforcement Policy were satisfied for Sever"y Level .IV or V violations identified by the license The lic.asee has performed adequate retesting using properly calibrated equipment. Also, the licensee reviewed this event with appropriate personnel. Corrective  ;

actions are considered complet This is Non-Cited Violation j 369/89-14-02: Failure to Meet Design Basis Flow for Chilled Water l for Control Room Ventilation due to Inadequate Calibratio l

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  • 369/89-05, Charging Pump Recirc Valves for Unit 1 And Unit 2 Were Not Being Tested As Specified By Inservice Test Requirements. Corrective actions were reviewed and were determined to be adequate to resolve the issu *370/87-09, Rev. 1: Reactor Trip Breaker Failure Due To Mechanical Failure. A detailed NRC Augmented Inspection Team previously )

j reviewed this issue (see Report 369,370/87-22). In addition an NRC Bulletin 88-01 was issued. The licensee changed the Reactor Trip i procedure to require a local verification of the breaker trip and i

added appropriate inspections to the maintenance procedure which the )

l inspector verifie Additional inspections will be performed l l

relative to the Bulleti l

  • 370/88-02, Rev. 1: Both Trains Of Annulus Ventilation System Were Made Inoperable Due To Deficient Communication And Planning /Schedu-ling Deficiencie Analysis showed that the systen would have  ;

functioned to prevent significant radiation releases. The plant was

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in Mode 3 and shutting down at the time of the event. Licensee Operations personnel discovered and reported the event. The licensee has revised standing work requests to provide adequate control of '

controlled access door (CAD) readers and reviewed this event with appropriate personnel. Corrective action is considered complet *370/89-01: Unit 2 Reactor Trip Because Of An Unknown Caus The reactor tripped on High Negative Neutron Flux Rate during a routine rod movement test. While the root cause was not determined the licensee have done all that could be reasonably expected to find the cause and provided appropriate management review prior to start up.

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  • 370/89-03: Reactor ' Trip Occurred Due To Failure' 0f Positioner.For:

Cteam Generator 2C Main Feedwater Regulating Valv *370/89-02: Reactor Trip on B S/G Lo-Lo Level Following Loss of 2B CFPT Because of Equipment Failure (Suction Pressure Switches). The:

inspector verified completion of work requests -associated with _ this-even The inspector verified that_ the licensee- had received and evaluated'

10 CFR.21 reports applicable. to the plant and had .taken corrective t actions as necessary. .The following Part 21 items are closed:

P2188-03 (Both Units): ' Gamma-Metrics Cable _ Assemblies Installed As'

Part Of The Neutron Monitoring System May Possibly Lea P2188-06 (Unit 1 Only): Inconel 600 Steam ' Generator Tube Plugs Susceptible To Stress Corrosion Cracking Supplied By B and P2189-01 - (Both Units): Brown Boveri K-Line - Circuit L Breakers l Delivered Prior To-1974 Need Rebound Spring Added To Slow Close Pi '1 No other violations or deviations were identifie . Follow-up on Previous Inspection Findings (92702)

The.following previously identified items were reviewed to ascertain that-the licensee's responses, where applicable, and licensee actions were in compliance with regulatory requirements and corrective actions have been completed. Selective verification. included record review, observations, and discussions with licensee personne i l (Closed) Violation 370/87-35-01: Failure To Establish Or Implement !

An Adequate Procedure To Control The Installation Of CRDM Shield 1 Block The licensee committed to do a generic review of civil-i i structures in containment and to assure these structures were-being l l maintained. The inspector verified that this review was ~ accomplished ;

and appropriate inspections had been implemented., ' (Closed) Violation 369,370/88-33-01: Failure To Follow Proceour l For Diesel Generator Testing. . The response to this item was submitted on March 16, 1989. The inspector verified implementation-of corrective actions which included _ appropriate procedure _ changes:

and training, (Closed) Violation 369/88-33-08: Failure -To Follow TS For.-

Containment Integrity. The response to this item _ was submitted on March 16, 1989. The inspector verified implementation of corrective actions which included appropriate procedure changes and program enhancement i No violations or deviations were identifie l I

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1 Special Inspection Diesel Generator Of Oil Fuel Prop (er Receipt, Storage,' And Handling Of Emergency TI 2515/100).

The inspector performed a special inspection.to assure that the license was properly receiving, storing and handling emergency Diesel Generator '

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(DG) fuel oil; that Technical- Specification surveillance were' being -

performed and covered by appropriate procedures; and.that the licensee had'

appropriately addressed NRC Information' Notice No. 87-04: Diese Generator Fails Test Because Of Degraded Fue The licensee did evaluate the Notice and verify appropriate design' and controls were in place to assure quality fuel'and an ope _r able flow pat A storage tank recirculation system with filters is regularly utilized (monthly). Water accumulation is checked and removed from a low point off the storage tanks and day tanks once per month.and in from the day-tank whenever the DG is run for greater than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Storage tanks'.are cleaned and inspected at 10 year interval Fuel oil is sampled and analyzed prior to. addition to.the storage tanks-and the storage tanks are sampled for particulate - monthl Fuel-additives are used to prevent oxidation and bacterial growth.-

The fuel oil system utilizes transfer filters and. duplex fuel? oil filters on each engin Differential pressure is monitored on the fuel oil filters whenever the DG is run and filters are in the preventive maintenance progra Storage Tank and Day Tank levels are alarmed in the DG rooms with a DG trouble alarm in the control room. Level-instrument' -1 tubing is seismically qualified, however, instruments.are not since.their primary purpose is to assure enough fuel prior to an event. A tygon tube or a dipstick could be utilized if necessar No violations or deviations were icentifie . ExitInterview(30703)

The inspection scope and findings identified below' were summarized 'on

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June 1,1989, with those persons indicated in paragraph 1 above. The following items were discussed in detail:

Violation 369,370/89-14-01:

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Inadequate Surveillance Procedures For:MSIV's !

(paragraph 4.d.)  !

Non-Cited Violation 369/89-14-02: Failure To Meet Design Basis Flow For .

Chilled Water For Control Room Ventilation Due To Inadequate Calibration:

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j The licensee representatives present offered no' dissenting comments, nor-did they identify as proprietary any of the information reviewed by the'- 1 inspectors during the course of their inspectio l l

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