IR 05000413/1990019
| ML20059H019 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 08/30/1990 |
| From: | Hopkins P, William Orders, Shymlock M, John Zeiler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20059H014 | List: |
| References | |
| 50-413-90-19, 50-414-90-19, NUDOCS 9009140180 | |
| Download: ML20059H019 (18) | |
Text
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UNITED STATES
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4 NUCLEAR " EGULATORY COMMISSION jjj!jg-; : g- '! *d REGION il ', E' ~ MARIETT A ST REET, '! W " ' *O=-' E' "( ATLANTA, GEORGI A 30323 ,' I f,' j% y. . . ,[I .
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+ a N . Report Nos.: -
50-413/90-19'and 50-414/90-19; i
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;, . ELicensee::'Duk'e Power Company c,' , E
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P. 0. Box.1007 _;
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Charlotte, NC 28201-1007 ti t 4
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License Nos.': NPF-35 and NPF 52;
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n * Dockst Nos.:' 50-413 and 50-414 ma 4 ( 7 1 Facility Name:; Catawba Nuclear Station Units.1-and 2' ,
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. Inspection Conducted: June 24,i1990 . August 2, 1990
!
Inspector V !W. g 0rders
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I [d6 YO ( , 7/ Date. Signed -'
- " Inspector: "
_
,[ A -[-S d-[O Date Signed
- 7 p Hopkins /'
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,. Inspector; &
'J.eZeiler A
v b3~M Date Signed i L
, .
'W/4db
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' LApproved-by: . ._ 8 @ 70 M. B. Shymlq'cA, Chief
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!4 Date Signed Projects:Section'3A
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mp , ; y^, Division of Reactor Projects ; y
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O' SUMMARY
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- i . Scope:- This routine, resident inspection was conducted in the areas of review of plant operations; refueling activities; surveillance Ce observation; maintenance observa-tion; review of licensee event
** m reports; and followup of previously identified item ,
*
1 , .
, ..L lResults: Three violations were-identified;'one violation involved the failure ?!
t> ? to perform an adequate 50.59 safety evaluation prior to securing the ! if upper containment annulus door in the open position, an act which' ?!M 4 rendered the Annulus Ventilation System inoperable (Paragraph 3.c); i '" one violation involved'a failure to initiate prompt corrective action following the discovery of a valve actuator failures in a Diesel L'f' Generator Starting Air System-(Paragraph 4.c); and, the third violation involved a failure to' follow instrumentation procedures -
'
m during the conduct of a plant modification. (Paragraph 5) i W ,,
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90091401BO 900830 PDR ADOCK 05000413 'B G PNV
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REPORT DETAILS- j u w ;
'
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' ' Persons' Contacted , ;
g' Licensee Employees j B. Caldwell,: Station Services Superintendent I s ;Rh Casler, Operations: Superintendent . j
*
T. Crawford, Integrated Scheduling Superintendent q
" , *J. Forbes, Technical Services Superintendent :; ,
R. Ferguson; Shift Operations Manager <
% <-
R.: Glover,iPerformance Manage ;
^ *T;! Harrall Design Engineering : 1 ... *L. .Hartzell,~ Compliance Manager =i * -
_ R. Jones', Maintenance' Engineering Services Engineer !' i - *V. King, Compliance - F g .
'*J. Knuti, Operations Support Manager " #H J 'F. Mack, Project; Servi.ces Manager . *W."McCollum, Maintenance Superintendent
'
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?i . T.;0 wen, St6 tion Manager- , . g t Other'licenseei employees contacted included technicians, operators, '( ,
' mechanics, security force members, and office' personne ,;
-
_ i NRC' Resident Inspectors j N' *W. Order P .' : Hopkins M . y;;
., *J sZeiler f ' - *- Attended exit interview, y .
' 2; ' P16t Operations Review:(71707' and 71710)- ,;,,. . :The. inspectors reviewed. plant operations throughout-the reporting q.
- ' " period 'to . verify conformance with regulatory . requirements, Technical
;
i ,. . Specifications"(TS), and' administrative control Control ~ Room l
- o
- logs, the Technical Specification-' Action Item Log, and the ' remova l
? 1and restoration 11og were rautinely reviewed. Shift turnovers were H' Y observed to verify that they.were conducted-in~accordance wit s
> . approved procedures., Daily _ ' plant status meetings were routinely e ' attended. -~ .
lW The' inspectors' verified by observation and interviews, that.the I L' measures taken to assure physical protection of the facility met l current requirements. - Areas inspected included the security a organization, the' establishment and maintenance of gates, doors', and isolationtzones in the proper conditions, and that access control and badging were proper and procedures followed.
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f, in addition to the areas discussed above, the areas toured were observed for fire prevention and protec*. ion activities and radiological control practices. The irspectors reviewed Problem Investigation Reports to determine if che licensee was appropriately documenting problems and implementing corrective actions, Unit 1 Sumary Unit 1 started the report period i.i Mode 1, at 100 percent power, and continued Mode 1 operation throughout the perio On July 15, the Unit entered the action requirements of TS 3.0.3 due to the loss of both trains of the Nuclear Strvice Water (RN) System. TS 3. was exited in approximately 30 minutes af ter the restoration of one train of RN. This event is dircussed in detail in Paragraph Unit 2 Refueling Activities (60710) Unit 2 be<an the report period in Mode 6, having begun a refueling outage on June 23. On June 28, an unusual Event was declared when a fire was reported in an air handling unit in the ice condenser. The Fire Brigade responded and discovered that the defroster heater to an air handling unit had shorted. The glowing heater coil, which had remained energized after the short, combined with steam from the interaction af water on the coil had given the appearance of a fir Subsequent examination of the equipment indicated that combustion had not occurred. This event is described in detail in Paragraph By July 1, the core was completely unloaded and "No Mode" operation was entered. The inspectors witnessed defueling activities from the control room, containment, and the fuel building to ensure that radiological controls were observed, adequKe communication at these locations existed in order to properly coordinate activities, that proper plant conditions were maintained as required by TS, and that proper housekeeping and material exclusion controls were met. Core reload was completed on July 26. The inspectors witnessed refueling activities and verified periodically that proper plant conditions were maintained as required to support these activities and that adequate communications existed between the control room and the refueling floor to assure licensee control of all activities. At the end of this report period, the Unit remained in Mode 6 in preparation for reactor vessel head installatio No violations or deviations were identifie . Surveillance Observation (61726) During the inspection period, the inspectors verified plant operations were in compliance with various TS requirements. Typical of these requirements was confirmation of compliance with the
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p V ' applicable TSifor reactor coolant' chemistry, refueling water storage
' . tank, emergency power _ systems, safety injection, emergency "
i ! safeguards _ systems,Econtrol room ventilation,- and direct current-
: electrical power; sources. = The'. inspectors verified'that selected surveillance testing was performed in:accordance with; applicable approved procedures itest instrumentation was calibrated, limitin conditions for- 0)eration were met,' appropriate removal: and ,
restoration of tie affecteCequipment was accomplished, test results tmet acceptance criteria and were reviewed by personnel .other than thelindividualf directing the test, and that any deficiencies " identified' during; the testing were properly reviewed and resolved by ~
.*
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appropriate management personne l- The inspectors witnessed or reviewed selected aspects of the
following surveillances:
'
s 1 PT/1/A/4150/01D NC System Leakage Calculation , f PT/1/A/4200/06A Boron. Injection Valve Lineup Verification PT/1/A/4200/14A Ice Condenser Intermediate Deck Door and Inlet Door Position Monitoring System-Inspection
;PT/1/A/4400/02C Nuclear Service Water Valve. Verification-PT/1/A/4450/10B Unit l' Diesel Generator CO Weekly Test
PT/1/A/4450/16L VQ System Cumulative- Purge Time -
, PT/1/A/4600/01 RCCA Movement Test PT/1/A/4600/02A Mode 1 Periodic Surveillance Items PT/1/A/4700/60 RN to KF Pipe Flush-PT/2/A/4200/01C Containment Isolation Valve Leak Rate Test, , .
Enclosure 13.50 .
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Containment Penetration Valve Injection
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4 PT/2/A/4200/01T' Water System Performance _ Test PT/2/A/4200/02D; Containment-Closure Verification (Part II)' PT/2/A/4200/02E- Containment Closure Verification (Part III)
'PT/2/A/4200/04E Containment' Spray Flow Test PT/2/A/4600/02F M6' Periodic Surveillance. Items c .- Annulus Ventilation Inoperability Event _ Summary On the morning of July 19, 1990, during a routine control room tour, the Resident. Inspector noted while reviewing Unit 1 operator shi ' . turnover documentation, that train A of the annulus ventilation system (VE) was operating with a " compensatory action" in plac J' (The licensee uses the term " compensatory action" to describe < '
situations where manual operation of a system, subsystem, train,
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component, or device may be considered to replace a lost automatic or remote manual start /stop capability). When the inspector questioned an operator about the compensatory action, he was m- informed that the system was being operated with the upper annulus w ? mm , , q"
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(secondary containment) door open to facilitate purging test gas ifrom the VE charcoal- filter. The filter had failed a carbon
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x ~ 3 -adsorber penetration test on-July 17. As.a result of the test', the C' . charcoat had adsorbed a significant amount of R-11, the: test gas, and:the test engineer wastattempting to remove the gas prior-to
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j" , t m retesting the syste ,
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' The inspect'o r was concerned about the operability of the VE system with;the door open, and immediately discussed-the issue'with the
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; Performance group which has responsibility for the test, to
'~3 ' determine if the operability of VE:had been. adequately considered-1 F' prior to implementing the' compensatory action.' The ultimate
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t o conclusion:of the. discussion'was, with the door. open, the' VE system;
,e was incapable of creating a. negative pressure in thel annulus as
_ designed, which meant that:the system was inoperable. Coincident' with the discussion with Performance ^,-the annulus door was secured
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f"s .in preparation for performing the aforementioned re-test. The test
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was successful and the. system was returned to service-later that t morning. The door was open from 10:00 p.m. the previous evening,
until approximately 8:15 a.m. that morning, a-period of 10 hours.- i Sys' tem Description 1
7y , Each containment building at Catawba consists of a primary . Nf< containment and,a concentric reactor' building. The space between ~ f the' two'is' the containment annulus' which has.the design purpose of,a
.. , secondary containment. The function of'the containment annulus is l1
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: tof prevent unfiltered leakage: to the. environment.following a LOC This purpose is to'be' achieved by the' establishment of a negative im ?
0 , pressure between the annulus-and the adjacent areer wi.th the VE u system.: d
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- VE consists of two redundant trains of! fans, filters,! dampers,Jand M
'(M .ductwork. The fans are automatically started'upon receipt of a-Hi.Hi Containment Pressure (SP) signal. 'The' dampers are aligned and
- " controlled so that'the annulus is maintained at a negative pressur , ,
with respect.to surrounding area >
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On the morning of> July 17, 1990, with Catawba Unit.1 operating'in Mode 1, at full power, the licensee attempted to. perform test
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. procedure PT/1/A/4450/01A, Annulus Filter. Train Performance Test, on l " - the A train of VE. The test includes the verification of th j charcoal filter adscrbtion efficiency. The test failed and the A Ai ,
1 train of VE was declared inoperable at 4:00 p.m. that afternoon, ,
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entering the 7' day action statement for single train inoperabilit ? AsLa result of the aforementioned test, the charcoal filter had ) adsorbed a significant quantity of test gas, R-11. The test '
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engineer concluded that the gas needed to be purged lfrom^ the ' . .i charcoal.to. prevent biasing subsequent-re-tests. Resultantly, train
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c A of VE.was kept running-in recirculation overnight on the evening: " v ;of July.17. . On the following day, the train was shut down'to ,
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facilitatefan inspection.to determine the reason for the test
' failure. .A bypass flowpath in the charcoal was found and corrected.- , , ilttwas'also concluded that running VE with the. annulus door open would facilitate a more expeditious purge of the charcoal. As'a -
t result, thelupper annulus door was opened -controlled by the
-> ; compensatory action process described in Catawba Station Directive i , ,,
3.1.14,,0perability Determinatie ,,
; , The overall. purpose of the above directive'is to establish the ; < .
Catawba. policy for. determining operability of a: system, train, 1
' "or component, and' provide a means of documenting operability reviews'. Ir, Section C.2 of Enclosure 2 to the directive,'the-process for evaluating the loss-of an automatic or remote manual " '
start /stop. capability is delineated. The policy states that when- s there .ista' requirement -for automatic or remote manual actuation of- a system,' subsystem,. train component, or-device to fulfill a specific
; safety function,: the item shall be declared inoperable upon the loss : of that aJtomatic or remote manual start /stopfCapability. :lt goes on .to say. however that in some situati7ns, manual operation of the-system,3ubsystem, train. component,-.c device may be considered to replace thel lost automatic or remob manual start /stop capability. - 1 This. process is'what is known as a compensatory action, and is ; .
designed to completely replace the lost functio ' A' proposed compensatory action is supposed- to meet certain specified criteria prior.to. implementation,'which includes:
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- . A procedure or -other written instruction is available to > direct j
'the manual operation, j
- The individual designated to perform the function has bee trained / qualifie l
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-- The post-accident environment in which the desigaated individual must operate is acceptabl l l
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' - The response time assumptions of the E:cident' analysis can be ' , ,
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-- An individual can reasonably perform the task (strength, 5 accessibility) . i
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- The signal or indication which will~ signify the individual to .
., perform the function has been clearly defined, an well as the )
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method through which:it will'(can) be communicated ~during-accident condition < W .
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i a isdesi gned to assure that an'
' ; Compliance with the above.criter , , unreviewed safety question as defined by-10 CFR 50.59.doestnot exis LIn' this particular case,-and in regard to the' above delineated .~ criteria, the licensee did not' perform'an adequate evaluation-
in that with the annulus door open,_the' response time assumptions o , ,
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the accident analysis could not be met. Further, with respect to a q 50.59 specific ^ considerations, it-appears'that the consequences ofi an: accident previously evaluated _in the FSAR may'have.been-
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increased. For example using original' design parameters,. offsite-
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R dose would have been increased had a~LOCA occurred with the door 4, .' open._ Further, the possibility _for'an accident or malfunction of.a4
' different: type.than previously evaluhted may have been created,'ini that neither secondary containment nor the VE system had been: ' ,< analyzed with the door ope Safety Analysis- # Duke Power Design Engineering performed an operability . , ,b""' evaluation / safety analysis of the VE system as part of the normal-problem investigation (PIR) proces In addressing the past operability of the VE-System, the consequences.of the annulus door being open-were considered with-respect' to both the relevant Technical Specifications and FSAR '
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- - analyses. It.is important to. note that:the evaluation assumes that' :n the annulus door. would have been successfully closed within 2 * minutes of the initiation-of design basis LOCA-had such an accident-
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E j The . ultimate issue with respect to the:effect of the annulus door being open, is the final .effect on post accident dose consequences
*4 'and . compliance with -10 CFR part 100. ' One key assumption that ' '
pervades the entire-dose consequence. analysis is that containment leakage into the annulus _is filtered prior to its release to'.the environment, obviously requiring-the VE' System to be operabl Operability of the VE System is defined in Section 9.4.9.1 of the
> FSAR, by'the following design bases: , .i Produce and maintain a negative pressure of at least 0.25" throughout.the annulus; '
Reduce the concentration of radioactivity in the air within, and discharged from, the annulus through filtration and recirculation of annulus air; and
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, . Provide llong' term fission product removal capability by decay; and filtratio /f 1 The VE . System functions in conjunction with the secondary containment to achieve these design bases. 'A' description of the>
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> - secondary containment is provided in'Section 6.2.3,0f the FSAR. The-4 ~ '
design bases of the; secondary containment,-as stated in Section-
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6.2.3.1'of the FSARf are:
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Je , ' Assure that'an effective barrier exists.for fission products-that may leak from containment; and
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I'nsure~ retention of fission products in the annLius for
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-clean-up by the VE Syste %
The relevance-of the secondary conte.inment to this operability'
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evaluation relates to whether or notithe annulus door being=open
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- prevents the secondary containment from fulfilling its . design bases,
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thus preventing the'VE System from fulfilling its design bases. 1The m . licensee performed an analysis of the performance of the secondary containment and the VE System by-simply. assuming that the-annulu ' door'is, closed two minutes from the onset of a design basis'LOCA and
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/then determined the net-effect in offsite dose which would result ~
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* The results indicate that offsite. dose would have been increased
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- but that the ' dose was still 'less than:10 CFR .100 alimits. With the annulus- door open, the VE system was inoperable, but: assuming the-
+. door could have been closed within two minutes of the onset of:a -
LOCA, offsite dose would not haverbeen drastically increased.- g, , y-
'( Regulatory Requirements ,~ '
The Catawba FSAR, Section 9.4.9 specifies that the design 1 basis.of-4 4 VE is to:; (1) produce and mat tain a negative pressure in the J, annulus'following a LOCA; (2) minimize the release of. radioisotopes following a LOCA; and (3) provide long-term fission product removal
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capability'by decay.and filtratio , 10 CFR.50.59 states in part that a licensee may make changes in the-facility as described in the safety analysis report, and conduct j -tests or experiments not described in the safety analysis report, f without prior Comission approval,"unless the proposed change', test or experiment involves a change in the technical specification
,'_ incorporated in the license or an unreviewed safety questio , ..l ,a
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tee. . .hnical: Specification .(TS).'3.6.'l.8. requires tha't two1 independent- -(
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y' Annulus Ventilation Systems shall be OPERALLE in modes _1, 2,:3. and '
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= 4. ,With one Annulus. Ventilation System' inoperable, the inoperable =.
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system must'be restored to operable status within 7. days er the unit: d L must be placed'in at least hot standby within the next 6'ho "
- With both trains of VE _ inoperable; thel unit:is subject to the ection - ; ' -
requirements of TS 3. * - Conclusion ,
. J 0nluly:18,1990, the_ licensee made a change to the Cataw b th't 1: <
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facility as described:in the safety analysis report in-that then '~y ,
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upper annul's u door, part of the annulus' ventilation boundary and i Lsecondary containment,.was secured in the.open position. This , .d
. facility change did not receive.a 50.59 evaluation to determine the ,
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: axistence of an:unreviewed safety question. ,The:open door renderedL theJVE system' incapable of performing it's> intended safety functio ;
as described lin the FSAR, in that with the change in place, VE was ,
,notlcapable;of producing,and maintaining a negative pressure in'th '
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annulus following'a LOCA nor minimizing the release of radioisotopes' ,
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following a_LOC a
. Resultant 19, the unit operated for approximately- 10 hours 'with both: '
trains:of VE' inoperable, in Violation of Technical Specifications - ' j i ;. 3.6.1.8 and 3.0.3. Further, the facility change increased the ~ - W , consequences of an accident previously evaluated in the safety L
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.' analysis report, introduced a malfunction not previously evaluated, .
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:and1 reduced the. margin of safety defined and assumed in the basis-
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for Technical Specification 3.6.1.8.
b y JThis is. sue appears to be a violation of the requirements of, .
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? Technical Specification 3,6.1'.8, Annulus Ventilation System, and 10 b ;CFR'50.59; Changes, Tests, and Experiments. This is identified as .,
; Violation 413/90-19-01: . Failure to Perform Adequate 10 CFR 50.59 4>; a Review Leading to VE Inoperabilit ;
! .MaintenanceObservations(62703)
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: . Station maintenance activities of. selected systems and components t were observed / reviewed to ascertain that they were conducted in
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.accordance' with applicable requirements. The inspectors verified 4 .
, . ; licensee conformance to the_ requirements in the following areas of inspection: the' activities were accomplished using approved ,
, m', procedures, and functional testing and/or calibrations were , L* performed prior to returning compon_ents or systems to service; i -quality control records were maintained; activities performed were ? accomplished by qualified personnel; and materials used were 1 properly certified. Work requests were reviewed to determine status of outstanding jobs and-to assure that priority-was assigned to safety-related equipment maintenance which may effect system performance.
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74 , The:inspectorsLwitnessed or reviewed aspects of the following-
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y>, 3 04352L . 10PS Packing Leak Repair of Valve 2NV149 e> 003006-- MES ' Inspection of Electrical: Cabinets 'to Identify 01f 0ptical' Isolators that Need to be. Replaced 001682- MES Five Year Inspection Pf Diesel Generator 2 t 007566- PR Investigation / Repair of vaive.1SM-12 After - M, '
. , Stroke Test Failur s ,w
/ cb Diesel; Generator St'arting Air System: Problem
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' ' ;0nJuly14,! Train 1Aoflthe.RN-Systemwasftakenoutofserviceto'. *
clean.the pump's lubefinjection~line and motor cooler. While that' 1' . train of RN was _out of service, the l'censee discovered that the-P , pressure in'the 1B1 and=182 starting air tanks of the IB Diesel
, ' ' Generator (DG) Engine Starting Air (VG) System had decreased to 210 .c psig, significantly below the normal ~ tank. pressure of 235-250 psi The 1.icensee's Design Engine'ering Department had'p eviously_
! determined that a minimum tank pressure of 235:psig is required to support operability ofla diesel. Accordingly, the licensee determined that:-the IB DG'was inoperable while the starting' air tank pressure was below 235 psig _-The inoperable IB DG caused thei inoperability of Train IB of the RN-System. Since train A-ofDRN was-already out of service, ~ the licensee' entered the action requirement - ' of TS 3.0.3. Nuclear Equipment Operators manually aligned the VG air _ compressors to.pressurizetthe tanks and within 28-minutes frome
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entering TS'3.0.3, air pressure.in the: tanks had.been increased to q above 235 psig.. restoring the operability of the IB DG and Train IB- S - e# .ne:RN' Syste l1 The'VG System is designed to provide fast start-capability _for.the
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DG engineLby.using_ compressed air to rotate the engine'until .
' combustion begins'and it accelerates under its. own power. Each DG 1 i- engine-is provided with'two independent ~VG systems, each consistin ; - of-a compressor and aftercooler, a filter / dryer' unit, starting air ~
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tank, and injection lines and valves. Air from the. diesel room-is: 1 compressed, cooled, filtered, dried. and then stored in the' starting j j < air-tanks. The drying unituis located between the aftercooler and ;j d Y starting air tank and a designed to minimize 1the accumulation of' , j f moisture. The air is first passed through a cyclone-type moisture 1 i separator and is filtered before enteringLone of the two alternating C . (alternating between active.and regenerative cycles) desiccant < drying towers. The inlet -valve to each air dryer is controlled by 1 p air operated actuators which pass air flow through one of the two a j 'e drying towers at 5-minute intervals. The starting air tank storage -1 o capacity for each DG is designed for a minimum of five successful : starts without the use of the air compresso The licensee had ; o r
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previously determined that a starting air tank pressure of greater i L than or equal to 235 psig in both tanks was required in order to assure the five-start capability. This determination was documented *
; in aLTS Interpretation, dated March 22, 199 . , Upon investigation, the licensee discovered that the cause of the ,
decrease _in tank pressure was due to sticking actuators-on the VG , air dryer inlet valves which prevented the valves from operin ' This prevented the re-pressurization of the starting air tuk Without makeup air from the compressors, tank pressure had slowly decreased.due to normal' air consumption by the engine control panel , 1
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( instrumentation. The actuators were later disassc*nbled and 1 guniqy substance was detected which prevented the free movement of the ;
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actuator's piston. There was also evidence of previous moisture in the actuator and the Mcensee conjectured that previous moisture : intrusion problems 1, rom the system's aftercoolers hao caused the i ' i breakdown of the actuator's lubricant and once this mixture dried, . the gummy substance was formed causing the valves to stick. These 'l D actuators were later cleaned and replaced on both VG systems for the ' 1B DG, , Design Engineering performed an operability evaluation to determine 1 the minimum starting air tank capacity required to assure that five ; successful starts could be achieved as required by the.DG's design <l , requirements. It was determined that with a pressure of 210 psig in both starting air tanks, there was sufficient capacity for at least _
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five successful starts on the IB DG. Based on this determinatio :the licensee considered the IB DG to have been operable during the i s period on July 15 when the starting air tank air pressure decreased , to 210 psig. . , The inspectors discovered that the licensee had experienced similar !
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L actuetor sticking problems. In December, 1989,.one actuator was .
-found to be sticking, but the impact of one sticking actuator was not enou,h to decrease the starting air tank below 235 psig. The '
actuator was manually cycled, freeing the actuator and it appeared " to operate properly. A work request was written, but it was designated as low priority, consequently, no work was performed on the actuator. Most recently, on July 10, a similar event as that on
: July 15 occurred in which an operator discovered that pressures in the same starting air taaks had decreased to 230 psig and both VG compressors were running and relieving through their discharge :
relief valves. Again, the actuators were manually cycled, which appeared to free the sticking pistons in the actuators, and pressure in the starting air tanks was restored. However, the licensee , a failed to write a work request to initiate investigation as to the t root cause of the problem, nor was additional surveillanc implemented to ensure that the actuator problem did not recur and cause the reduction in starting air tank capacit ;
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10 CFR 50, Appendix B, Criterion XVI requires in- part that measures ! be established to ensure conditions adverse to quality such as i
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failures and malfunctions are promptly identified and corrected to preclude repetition. In this case, measures were inadequate to prevent the repetition of a problem effecting the operability of the DGs as detailed above. .This is identified as Violation
'413/90-19-02: Failure to Take Prompt Corrective Action to Preclude Repetition of Condition Adverse to Qualit j
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. d. -During a review of PIR 0-C90-150, the inspectors noted that licensee contractor personnel had performed a maintenance procedure without '
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obtaining the Shift Supervisor's approval as' require " On May 1.L1990, with both Units in Mode 1 operation, contract ,
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ventilation personnel obtained a charcoal filter sample from train B l- of the Control Room Area Ventilation (VC) System. _ The sample was '
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taken between 8:15 a.m. and 8:25 a.m., using mai,itenance orocedure l MP/0/A/7450/31, Obtaining MSA Charcoal Filter Test Sample. Train A - of the VC System was in operation when the sample was_take l Personnel performing the procedure contacted the Control Room SR0, ~) but failed to notify the Shift Supervisor before the sample was t taken. -The Shift Supervisor's approval was required b ! prerequisites in the procedure. The Shift Supervisor learned that ; , the. sample had been taken when the contractor personnel returned to I the control room at 9:30 a.m. to obtain his sign-off for the > ' ' prerequisite, , The licensee's review of opposite train work performed during this L time, discovered that between 8:23 a.m and 8:32 a.m., the 1A DG had : l been rendered inoperable when placed in " maintenance mode" to l L perform an air roll of.the DG per PT/1/A/4350/02A, DG 1A Operability l Test. The 1A DG was removed from " maintenance mode" at 8:32 a.m., I following a successful air roll. Therefore, for approximately three
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minutes one train of VC was inoperable while-the other train had its-emergency power supply remove The licensee determined that no Technical Specifications were ' violated as result of this incident, although they had unknowingly entered Action Requirement c of TS 3.8.1.1 in that, the 1A DG was , technically inoperable while in " maintenance mode" and the opposite i train of the VC System was inoperable during the time the charcoal , sample was obtained. The Action Requirement essentially required L that train B of the VC System be restored to operable status within 2 hours or within 6-hoers the unit would had to have been placed in l at least HOT STANDBY. The Action Requirement was met when train B L ' of the VC System was returned to service at 8:25 a.m., three minutes from entering the Action Requirement.
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I This issue is identified as a violation of the requirements of : m Technical Specification 6.8.1 which requires in part that
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maintenance performed on safety-related equipment be performed i ! , accordance with' written, approved procedures. After review of the ! circumstances relative to this issue, it wts determined that this '
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i event constitutes a licensee identified violation, and as such will- l not be cited in that the criteria specified in Section V.G.1 of.the i t NRC Enforcement Polic This is documented as : L Non-CitedViolation(yweresatisfied.NCV)413/90-19-03: Failure to follow i ' Maintenance Procedure ,
, . Reported Fire in Ice. Condenser Air Handling Unit '
At: 3:43 a.m., on June 28, 1990, with Unit 2 in Mode 6. the control I
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roo.it was informed by personnel performing work in the ice condenser : C that there was a fire in the 2B2 Air Handling Unit (AHU). . * Operations personnel and the fire brigade took immediate action to j extinguish the reported fire. The licensee declared this as an - l; unusual event-at 4:06'a.m. due to a fire in the plant taking longer i
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, than 10 minutes to extinguis >
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o ~ Subsequent to deenergizing the equipment, the Fire Brigade found no
, , evidence of an actual fire. Half of the rear heater element of the ,
AHU defroster was brittle and deteriorated. It was determined that ;
, + the heater wiring had come in contact with one of the heate *
elements. The heat from the element had deteriorated the termination point and the wire from the front heater shorted against f the center of the rear heater element which in essence.placed full ,
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voltage across half the resistance heater. The element became red hot and steam was produced from the melting cf ice covered coils, giving the appearance of smoke. Further, the reflection of the red
' * , -hot coil gave the appearance of flames. It was ultimately determined that no fire actually existe ;
i The inspectors discovered that there had been past cases where AHU - heater wires had burned through or shorted out due to the close proximity of the wiring and elements. The manner in which the i heater wires shorted out in this instance was unusual in that half i of the heater element remained energized and the heater breaker did not tri The licensee examined Wiring in the other Unit 2 AHU's to ensure i that it was not in close proximity with the heater elements. Any AHU's with defective wiring were repaired with high temperature
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wiring. The wire termination ends were also braided with glass tape !
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to minimize the impact of the heater elements coming in direct contact with the wiring. All wiring was physically moved as far
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away from the heater elements as possible, r
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The licensee's design engineering department, in consultation with i the vendor are investigating the possibility of usin; a different ! type of heater element which would have the. separation of heater l element and wiring inherent in its design. This item will followed= ! upunderInspectorFollowupItem(IFI) 413,414/90-19-04: -' l Investigation of Heater Element Problem in the Ice Condenser' Air Handling Uni L 5. Review of Licensee Event Reports (92700) :, Ouring a review of LER 414/90-05,-the inspectors noted that licensee . instrumentationandelectrical(IAE)personnelhadperformedmaintenance on the Unit 2 VE System without documenting certain aspects of the work as prescribed by the applicable procedure On March 8, 1990, with Unit 2 in Mode 1. Train A VE System heaters did , not energize during the performance of PT/2/A/4450/03A, Annulus J J Ventilation System Train 2A Operability Test. Train A of the VE System was declared' inoperable and~ the licensee initiated a work request to determine why the heaters did not energize. It was found that wires were disconnected from tenninals 9 and 30 in the VE Heater Control Panel. The i wires were terminated, PT/2/A/4450/03A was successfully performed, and ! Train 2A of the VE System was restored to operability on March 1 j Through subsequent efforts to determine how these wires became ! disconnected, the licensee noted that on March 2, pursuant to Nuclear i Station Modification (NSM) Work Requests 3567 and 3568, temperature (
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setpoints were adjusted on the heater controllers for both trains of the VE Syste To make these setpoint adjustments, the wires had to be disconnected from terminals 9 and 10 in the electrical cabinet of the ; heater control panel. Following the adjustments IAE personnel verified - that the heaters deenergized at the new setpoints by installing a test instrument at terminals 9 and 10 and applying a signal which simulated i the setpoint. The wires were then retenninated. However, during these activities, neither the lifting nor the retermination.of these leads were documented, as required by the procedures controlling these activitie , In as much as the licensee is absolutely certain that the leads in question had been reterminated during the setpoint adjustment work, the i specific activity responsible for disconnecting the wires could not be identified. It is known that it occurred sometime between March 2 and March It is likely that the wires were disconnected during the setpoint adjustments on March 2, since 18 temperature controller setpoints were adjusted which invo?ved the lifting of similar leads in heater electrical cabinets of the VC, Auxiliary Ventilation (VA), Control Room Ventilation (VC), and Fuel Pool Ventilation (VF) Systems. The - licensee inspected the other ventilation electrical cabinets opened during the March 2 setpoint adjustments and no other disconnected wires , were identifie '
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=i l . ' Each of two VE filter trains uses heaters to limit.the relative humidity j of the air entering the carbon filters, ensuring filter efficiency. Each !
of the heaters is controlled by two temperature controllers: a primary 1 controller, with a setpoint of 185'F (at which the heater will trip), and ' a backup controller, with a heater trip setpoint of 250'F. The purpose i of the NSM performed on March 2 was to increase these-temperature i setpoints to 500'F to ensure that the heaters would remain energized j
whenever the VE System was operatin '. ' Technical Specification 3.6.1.8 reciuires both trains of VE to be operabl l
'" - in Modes 1 through 4. The Technical Specification Action Statement I requires that with one train of VE inoperable, the' inoperable- train must ;
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be restored within seven days, or the Unit must-be.in at least Mode 2 within the next 6 hours, and:in Mode 5 within the following 30 hour ! Due to the likelihood of the wires being disconnected on March 2, the licensee determined that Train'2A of the VE System was inoperable from ..i March 2 until the train was declared operable on March 10. The seven day
. Action Requirement expired on March 0 therefore, the licensee was in 3 ,
violation of the Action Reaciremen J During the period which Train 2A of VE was assumed to be' inoperable, 1
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Train 2B was operable, with the exception of March 5, between 1:00 and 6:00 a.m., when Diesel Generator 2B was inoperable. The licensee 1 maintains, however, that the VE System was capable of performing it ) design function on March 5, based on a past Design Engineering evaluation . and the implementation of a compensatory action on February 28, 199 ! Earlier _in the year Design Engineering had performed an evaluation which addressed the consequences of a failure of a heater in one of the VE e
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filter trains ~following a LOCA. It was found that insuring a filter ] train with a failed heater operates no more than eight hours minimizes ; the impact of a heater failure on dose consequences. Therefore, on . February 28, a compensatory action was implemented which required that ; within eight hours after a safety-injection, operability of the heaters i would be' verified. If a VE heater was found inoperable, that train of VE .
.would be secured and operation of the other train would be initiate . i LTherefore, if a LOCA had occurred on March 5. Train 2A of the VE System ;
would have started as required. Within 8 hours it would have been found that the heater in that train was not operating, and the opposite train of VE (28) would have been placed in operatio ;
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The inspectors reviewed instrumentation procedures IP/2/A/3160/01, j
. Annulus Ventilation System, and IP/0/A/3890/02, Controlling Procedure for Changes on Systems and Components, which together were used to adjust and ;
- , check the. temperature controller setpoints. The inspectors noted that IP/2/A/3160/01 did not provide guidance regarding the specific leads
which were required-to be lifted, nor did it include specific signoffs ! for the individual steps necessary for accomplishing these activitie .
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Three general signoffs were provided, one each for the completion of the
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adjustment, for the removal of the test equipment, and a double signoff ! o for the equipment returned to service. Since the event, the licensee has enhanced the procedure to include specific instructions and signoffs for r the controller leads required to be lifted during the conduct of the .' L procedur ! ' Another area of concern discussed with the licensee was the apparent lack l
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L of. post-modification testing, normally required following modifications
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to safety-related components or systems. After the temperature . j
'l controller setpoints were adjusted, the licensee verified the setpoints i
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< :were correct, as discussed above, however, a VE operability test was not conducted, nor were the heaters verified to be operable by actually energizingthem. The licensee contends that the instrumentation
; procedure s~ independent verification that the equipment was returned to service was sufficient to prove operability of the VE System. However, i
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the licensee has since revised IP/2/A/3160/01 to include energizing the heaters to verify their. operation after temperature controller setpoint testin .This incident is attributed to the IAE personnel failing to follow l procedures -since the lifting and retermination of the wires during the temperature'setpoint adjustments were not documented as required by >I IP/0/A/3890/02. This is identified as Violation 414/90-19-05: Failure : to Follow Instrumentation Procedure ; Followup on Previous Inspection Findings (92701 and 92702) f (Closed) Violation 413,414/88-34-01: Failure to Follow Procedures or Inadecuate Procedures. The licensee revised appropriate operational
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procecures, provided training for operators on the changes, and placed j . the requirements in requalification guidelines and insured that incoming l crews;were adequately briefed before assuming operational duties. A > complete review of Action Level 3 Shutdown Criteria took place along with i procedures review that resulted in changes and for upgrade of the-procedures. Based upon the licensee's actions and review by the j
.l inspectors, this item is close '
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i (Closed) Violation 414/89-34-01: Inadequate Equipment Tagouts Causing a Waste Gas Release and Turbine Runback. This event was the result of ' personnel error in that waste gas valve IWG182 was not identified as part of the isolation required for the caintenance work being performed. The l result was that a portion of the system having maintenance performed on . E it was not completely isolated, leading to an inadvertent radioactive gas ; releas ;
The licensee revised OP/01B/6500/26, Radwaste Chemistry Operating ; Procedures, for preparing and isolating the various compenents of the i j gaseous waste systems for maintenance, were revised to insure that valve ' stem leakoff headers are isolated when work is being performed on the
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applicable equipment along with other changes to pertinent operational l procedures requiring tagouts. Based upon corrective action by the licensee, this item is close ,
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i (Closed) Deviation 413/89-16-03: Shutoff Head Testing of Fire Pump l The licensee issued the acceptance criteria data sheets through Design !
' ! Engineering and these were made a part of PT/0/A/4400/01A, Exterior Fire L Protection Functional Capability Test. This.new acceptance criteria data i
- 1 sheet insures the verification of satisfactory performance of the set ,
point of the discharge relief valve in lieu of testing the shutoff head ',
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condition. Based on these actions taken by the licensee, this item i' ,
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close : No violations or deviations were identifie ; Exit Interview , f The inspection scope and findings were summarized on August 2, 1990, with those persons indicated in paragraph 1. The inspector described the
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m areas inspected and discussed in detail the inspection findings listed below. No dissenting. comments were received from the license The 'f licensee did not identify'as proprietary any of the materials provided to , or reviewed by the inspectors during this inspectio .
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Item Number Description and Reference ,
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VIO 413/90-19-01 Failure to Perform Adequate 10 CFR 50.59 Review Leading to VE Inoperability. (Paragraph 3.c) , VIO 413/90-19-02 Failure to Take Prompt Corrective Action : Following the Discovery of a Valve Actuator ; FailuresintheVGSystem.(Paragraph 4.c) j NCV 413/90-19-03 Failure to Follow Maintenance Procedure l'
(Paragraph 4.d)
-IFI 413, 414/90-19-04 Investigation of Heater Element Problem in the
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IceCondenserAirHandlingUnit.(Paragraph 4.e) VIO 414/90-19-05 Failure to Follow Instrumentation Procedure '
(Paragraph 5)
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