IR 05000346/1990013

Insp Rept 50-346/90-13 on 900605-0709.Noncited Violation Noted.Major Areas Inspected:Lers,Plant Operations,Refueling, Radiological Controls,Maint/Surveillance,Emergency Preparedness,Security,Engineering & Technical Support

ML20059A677
Person / Time
Site:	Davis Besse
Issue date:	08/10/1990
From:	Jackiw I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20059A674	List: IR 05000346/1990013 ML20059A672
References
50-346-90-13, NUDOCS 9008230168
Download: ML20059A677 (12)

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U.;S. NUCLEAR REGULATORY COMMISSION REGION ~III

ReportNo.'50-346/90013(DRP) .

Docket No. 50-346- License No..NPF-3 i Licensee: -Toledo Edison Company Edison Plaza, 300 Madison Avenue Toledo, OH 43652 .!

Facility Name: Davis-Besse-1 a

Inspection At:~ Oak Harbor,-O .i Inspection Conducted: June 5 through July 9,1990

i Inspector: P. ' M. Byron  !

D. C. Kosloff R. K. Walton j

Approy?! By: I .' ki ief [4'N or Projects Section 3A Dat '

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Inspection-Summary-Inspection on June 5 through July 9,1990-(Report No '50-346/90013(DRP))

Areas Inspected: A routine safety inspection by resident . inspectors of ~

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j licensee actions on previous inspection findings, licensee event reports,  ;

plant operations, refueling, radiological controls, maintenance / surveillance, I emergency preparedness, security, engineering and technical support, and safety assessment / quality verification was performe Results: An inadverten'; loss of auxiliary steam led to:a manual tripping of the . reactor (Paragraph 4). Licensee personnel caused two other events'to ressurizing the decay heat system occur and during seal inadvertent the injection inspection stoppageperiod; overp(Paragraph 4). These events demonstrated a weakness'in plant operations. These two events are examples of an apparent violation of Technical bpecification requirements to.have written procedures for specific evolutions. These events are similar to those described ,

in Inspection Reports No. 50-346/90012 and No, 50-346/90009, that demonstrated a weakness in task managemen Based on the inspector's observations,.the

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licensee's corrective. actions program has not been effective for these event The NRC is considering this weakness for enforcement action. A non-cited-violation was identified for failing to promptly take corrective action to repair heat tracing'(Paragraph 3). A notable posit <;ve aspect observed this period was plant management's decision to suspend plant heat up, based an increase in plant events related to operations performance. Plant management also initiated an independent review of their operations. Participants in this peer review included various senior managers from Callaway, V. C. Summer and Fermi nuclear power station .

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DETAILS Persons Ccntacted Toledo Edison Company i D. Shelton, Vice President, Nuclear

• J. Moyers, Manager,- Quality Verification

• L. Storz, Plant Manager

• Heffley, Maintenance Manager ,

• R.Brandt, Manager,PlantOperations-(Acting)

M. Bezilla, Superintendent - Operations

• E. Salowitz, Director - Plar.r ir.; and Support

• S. Jain, Director - DB Enginver'ng

• D. Timms, Systems Engineering Manager i

• K. Prasad, Nuclear Engineering Manager (Acting)

• E. Caba, Performance Engineering Manager

• V. Watson, Design Engineering Manager G. Grime, Industrial Security Director l J. Polyak, Radiological Control Manager ,

• R. Coad, General Supervisor Radiological Support

• J. Doiron, Supervisor, ALARA

• J. Lash, Independent Safety Engineering-Manager R. Schrauder, Nuclear Licensing Manager

• G. Honma, Compliance Supervisor

• R. Gaston, Licensing- Technologist USNRC P. Byron, Senior Resident Inspector i

• D. Kosloff, Resident Inspector

• R. Walton, Resident Inspector

• Denotes those personnel attending the July 9,1990, exit meetin . Licensee Action on Previous Inspection Findings (92701)

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(CLOSED) Open Item (346/88026-05(DRP)): Determine root cause for^ failure #

of the torque switch in the motor operator. (Limitorque) for auxiliary feedwater (AF) valve AF 3869. On August 30, 1988, the roll pin-that secured the actuating lever to the torque switch failed. This was the third torque switch failure for this valve since 1985.- The licensee replaced the valve and motor and sent the valve and Limitorque to the vendor for root cause testing. After review of the test results-, the licensee determined that the cause of the torque switch failure was the-valve disc sticking in the valve seat. .The licensee was unable to determine the cause of the disc sticking in the seat. There was no ,

evidence that this problem is common to other similar valves. The root-cause testing also revealed that under certain conditions it is possible to shear the roll pin by placing the valve in manual operation after closing it electrically. This type of failure has not been observed in '

the plant. The inspector had no further concerns and this item is close .,

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(CLOSED) Unresolved item (3tG/89016-13(DRP)): Review roit tause of the ,

failure of the air pressure regulator for Die air operator for the N Auxiliary Feedwater Pump Turbine (AFPT) steam admission valve (MS 5B89A). ;

On June ~22, 1989, a licensee system engineer found the outlet air pressure gage pegged high on the Masoneflan 11odel 77-4 Air Filter Regulator. Further ,

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investigation by the licensee revealed that the regulator had failed making the No. 1 AFPT inoperable. The inspectors reviewed the licensee's root- '

cause determination and concluded thct the root cause was unawareness of !

the heat sensitivity of the regulator. The inspectors also discussed this ,

failure with licensee personnel, reviewed the design specification and i reviewed the licensee's controlled copy of the' vendor's manual. Nomally >

MS 5889A is closed during operation with steam at about 600 degrees on its upstream side. The specified design temperhure for HE 5889A is ;

650 degr2es F. and the regulator was su) plied with NS 586PA. The decir, ion

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to use the Model 77-4 regulator was wit 11n Masone11an's design $ cop ;

MS 5889A was purchased as a Q component. The regulator, which is bolted to the valve yoke, failed because it was exposed to a temperature greater than 180 degrees F. The licensee had removed insulation from the pipinn ;

associated with MS 5889A during an outage and did not reinstall it until after the plant had operated for about three months. This exposed the ;

regulator to a higher than normal temperature. The higher than normal temperature caused a plastic spring cap inside the regulator to lose ,

strength and break. The personnel who made the decision to defer the f insulation replacement did not realize that the increased temperature :

wnuld degrade the regulator. The room temperature with the insulation '

removed did not exceed the maximum room temperature listed in the USA The decision to defer the insulation replacement appears to have been a 4 reasonatie engineering 3 daement because the regulator did not appear to ,

be sub/ect to heat dcyradatan, the resultant room temperature did not exceed the USAR expectations, the regulator had been supplied with MS 5889A :

by its manufacturer who knew the valve service conditions, and the vendor's '.

manual for the regulator did not identify any heat sensit'vt parts or specify any temperature limit ;

The licensee evaluated this failure for Part 21 reportabi*.ity and concluded that it was not reportable because the licensee had c6 2ed the f:.;iluro by deferring replacement of the piping insulation. This appears to be a :

reasonable conclusion. However, Hasonellan had not' informed the licensee of the temperature limit on the regulator and Masoneilan had no knowledge that the maximum temperature of the regulator would be limited by' piping ;

insulati,n or cooling of the AFPT room. It seems that if a manufacturer supplies a component with limitations and has information that indicates

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that those limitations may be challenged then it has an obligation to bring-the limitation to the attention of its customer. Although this failure may-not be reportable under Part 21, the vendor's manual for the regulator should include the temperature limit for the regulator. The licensee has contacted the vendor regarding this issue. This item is close (CLOSED) Unresolved Item (046/89026-04(DRP)): Recirculation line for No. 2 High Pressure Injection (HPI) Pump plugged with. ice due to failed heat tracing circuits. The licensee's preparations for cold weather operetions include performing appropriate preventive maintenance (PM)

work orders (MWO) on required equipment. If work is required beyond

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the scope of the preventive MWO, a corrective MWO is prepared tc control the follow-up work. The FM on the heat tracing circuits identified follow-up work to repair _the HPI heat tracing circuits. A corrective MWO was prepared, but parts were not availcble. Because the PM was done in the summer,-the corrective MWO was not assigned a high priorit The priority of the MWO was not raised as winter approached because the system engineer for the heat tracing system did not realize the importance of the failed circuits. After this incident, the licensee-prepared a priority list of heat tracing circuits to make it easier for the heat tracing system engir.eer to determine if failed heat tracing circuits require high priority for maintenance. During the exit meeting, the licensee also comitted to issue a cold weather preparation' procedure before next winter. The failure to take prompt corrective action for the failed heat tracing circuits is a violation (346/90013-01(DRP)) of 10 CFR 50, Appendix B, Criterion XVI, " Corrective Action." This licensee-identified violation is not being cited because the criteria specified in Section V.G. of the Enforcement Policy were satisfied.- This item is close No other violations or deviations were identified in this are . LicenseetventReportsfollowup(92700)

Through direct observat<on discussions with licensee personnel, and reviewofrecords,thefollowinglicenseeevent. reports (LERs)were-reviewed to determine that reportability requirements were fulfilled and that immediate corrective actions to prevent recurrence were accomplished in accordance with Technical Specifications (TS). The-LERs listed below are considered closed:

(CLOSED)LER90002: Reactor Trip from 73% Power Due to Spurious.RCP, flonitor Circuit Signal. On January 26, 1990, with three of,four reactor coolant pumps (RCPs) operating, a reactor trip occurred during the stem p(erformance RPS). of a surveillance The trip recovery test by was complicated 4 the reactor

'a letdown protection-sy(MU valve - 28)

that failed to open on demand. In addition, two main steam safety valves

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j (MSSVs) did not fully reseat and RCP 2-2 seal return _ temperature increased i as its letdown flow was reduced. The licensee has determined that high-RCP seal temperatures had no effect on seal performance. The seal l i

cartridges were replaced during the 1990 refueling outage by a previously-approved plant modification. The MSSVs were disassembled, inspected t and setpoint tested during the refueling outage. No discrepancies or '

abnormalities were detected. Systems engineering believes that the MSSV response was normal. The post trip secondary pressure control-

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setpoint was reduced to provide more positive '4SSV rescating. Although the conditions of the surveillance test that caused the reactor trip could not clearly be identified, the licensee plans to install new equipment and modify the procedure to-prevent reoccurrence of this even '

Valve MU 28 failed due to the disc separating from the stem. The cause of failure was thermal binding of the disc to the seat. MU 2B was replaced with a new valve that is less susceptible to thermal bindin :

This LER is close A

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(Closed)LER90010: Inadvertent Safety Features Actuation with Injection of 1,000 Gallons of Borated Water. This event was discussed in Inspection Report No. 50-346/90009. The licensee plans to issue a supplemental report for this event. That report will be reviewed during a future inspectio This LER is close . Plant Operations (71707, 71710, 64100, 93702) Operational Safety Verification Inspections were routinely performed to ensure that the licensee conducts activities at the facility safely and in conformance with regulatory requirements. The inspections focused on the implementation and ovcrall effectiveness of the licensee's control of operating activities, and on the performance of licensed and non-licensed o>erators and shift managers. The inspections included direct onervation of activities, tours of the facility, interviews and discussions with licensee personnel, independent verification of safety system status and limiting conditions of operation (LCO), and reviews of facility procedures, records, and reports. The following items were considered during these inspections:

Adequacy of plant staffing and supervisio *

Control room professionalism, including procedure adherence, operator attentiveness, and response to alarms, evc..ts, and off-normal condition *

Operability of selected safety-related systems, including attendant alarms, instrumentation, and control .

Maintenance of quality records and report The inspectors observed that control room shift supetvisors, shift managers, and operators were attentive to plant conditions, performed frequent panel walk-downs and were responsive to off-normal alarms and condition On June 11, 1990, with the plant shut down, an equi > ment operator tripped the auxiliary boiler when he inadvertently control switch. The loss of auxiliary boiler steam lit the boiler requir'd operators to break condenser vacuum. Although all control rods were already 1

' fully inserted, the reactor was manually tripped to open the reactor l trip breakers, which had been shut for testing. This was done to prevent these breakers from being tripped automatically by the t Anticipatory Reactor Trip System which would have caused an

unnecessary challenge to the reactor protection circuitr On June 16, 1990, during completion of Attachment 16 to DB-0P-06900,

" plant Heatup," in conjunction with the performance of DB-SP-03179,

" Core Flood Tank (CFT) Isolation Yalves 9efueling Interval Operability Test," valve CF IB was cycled prior to closing decay heat (DH) valve DH IB. Check valve DH 77 did not seat and backflow through DH 77

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allowed apsroximately 760 gallons of reactor coolant to pass from '

CFT 1 to t1e DH system before CF IB was' shut. Reactor coolant, at- ,

about 600 psig, entered the lower pressure rated DH piping causing relief valves to lift sending water into the Reactor Coolant Drain ;

Tank. The licensee concluded that the DH system integrity was not i challenged by this event. Of the two procedures used, only DB-0P-06900 -

requir % DH 18 be closed prior to cycling CF 18. The root cause :

of ti s eve: was personnel error. A pre-job briefing was not held r with nrsm ,1 involved even though the operations su)erintendent had l empha. 1 that one be done. Disciplinary action is aeing evaluated by the ,nt manager. The licensee has made changes to both .

l procedures to prevent recurrence of this event. The inspectors have :

This is an example of a violation ;

reviewed the p(rocedural (346/90013-02a changes.Specification 6.8.1 which requires-DRP)) of Technical  :

that written procedures be implemented for activities listed in Regulatory Guide 1.33, Appendix A, paragraph 3.c. related to j shutdown cooling syste .

On June during the restoration phase of DD-PF-10094, ;

21,1990,feedandBleedTest" Makeup. Pump (MVP)-No.1,

"flakeup Enhanced whichwasprovidingnormalmakeupandreactorcoolantpump(RCP) .

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seal injection, was inadvertently stopped by an. operator. After the ,

5 minutes data run was complete, the operator attempted to throttle ;

the HUP No. 2 discharge valve. The valve was not a throttle valve- ;

and went closed. While the operator was trying to reopen the valve, the shift supervisor, realizing that there was no minimum flow l through HUP No. 2, connanded tie operator to stop the pump. The ;

operator, without looking, stopped MVP No. 1 instead of HUP No. The operator realized his error and insnediately restarted HUP N ;

1. However, DB-0P-02512, Loss of RCS liakeup, Rev. 1, dated April 6, i 1990, step 4.1.9 requires that flow be increased gradually to ,

minimize thermal transients to the RCP seals. The licensee believes #

that no damage occurred to the RCP seals. An analysis of o)erator actions during performance of the procedure revealed that t1e operators prepared a handwritten procedure whichctotally resequenced restoration steps 6.4.21 through 6.4.29 of DB-PF-10094, " flake-up Enhanced Feed and Bleed Test," Rev. 1, dated liay 18, 1990. The root ;

cause of this event was personnel error. This is an apparent violation (346/90013-02b(DRP) of Technical Specification 6.8.1 which l required that written procedures be implemented for activities listed in Regulatory Guide 1.33, Appendix A, paragraph 3.a. related to 'the reactor coolant syste The licensee had several events as the plant w6s being prepared for i restart which were either caused by or not mitigated by the operator !

On June 21, 1990, the plant manager decided to cool down the plant to-

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flode 5 to perform repairs and tr utilize experienced independent; outside reviewers to provide conmu on the recent events and to observe the operations department. Additional operator training was also provided. The licensee discussed its actions with NRR and ~ !

Region III management on June 21 199 The independent reviewers i presented their observations to the licensee and the licensee has discussed the reviewers' findings with the inspector ,

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'. O_ff-shif t Inspection of Control Rooms The inspectors performed routine inspections of the riv.rol room during off-shift and weekend periods; these included .nspections between the hours of 10:00 p.m. and 5:00;a.m. The inspections were conducted to assess overall crew performance and,-specifically, _

control. room operator attentiveness during night shift The inspectors determined that both licensed and non-licensed operators were alert and attentive to their duties, and that th administrative controls relating to the conduct'of operation _were being adhered t ESF System Walk-down The operability of-selected engineered safety. features was confirmed by the inspectors during walk-downs'of the accessible portions of several systems. The following iteras were included: verification-that procedures match the plant drawings, that-equipment, instrumentation, valve and electrical breaker line-up status is in-agreement with procedure checklists, and verification that locks,'

tags, jumpers, etc., are properly attached and identifiable. The following systems were walked doen during this inspection 4 Hod:

480 Volt AC Electrical Distribution System

Component Cooling Water System

Emergency Diesel Generator System

DC Electric Distribution System ,

Service Water System _ Plant Material Conditions / Housekeeping The inspectors performed routin: plant tours'to assess material conditions within the plant, ongoing quality activities and-plant-wide housekeeping. Housekeeping was adequat Plant deficiencies were appropriately tagged for deficiency. correctio l No other violations or deviations were identifie .J RestartEffort(62703.71707,72700.92701) I The inspectors provided augmented shift coverage prior to the licensee's i entrance into Mode 2 (Hot Startup). At the end of the inspection period, the licensee was close to reactor criticalit 'l

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. . RadiologicalControls(71707,92720,8475l1 The licensee's radiological controls and practices were routinely ubserved by the-inspectors during plant tours and varing the inspection of selected work activities. The inspection included direct observations of health physics (HP) activities relating to radiological surveys and monitoring, maintenance of radiological control signs and barriers, contamination, and radioactive waste controls. The inspection also included a routine review of the licensee's radiological and water chemistry control records and report The inspectors noted that there were several instances where yellow material, used to prevent the spread of radioactive contamination, was in contact with hot equipment. The inspectors were concerned with potentia thermal degredation of the radiological containers and informed radiological controls. The licensee has adequately addressed the inspectors' concern Health physics controls and practices were satisfactory. Knowledge and training of personnel were satisfactory, ho violations or deviations were identifie . Maintenance / Surveillance (37828, 61726, 62703, 37828, 60710, 73756, Y2701,93702)

Selected portions of plant surveillance, test and maintenance activities on systems and components important to safety were observed or reviewed to ascertain that the activities were performed in accordance with ap procedures, regulatory guides, industry codes and standards, and the proved Technical Specifications. The following items were considered during-these inspections: limiting conditions for operation were met while components or systems were removed from service ap)rovals were obtained prior to initiating work; activities were accomp;lis1ed using approved procedures and were inspected as applicable; functional testing or calibration was performed prior to returning the components or systems to service; parts and materials used were properly certified; and appropriate fire prevention, radiological, and housekeeping conditions were maintaine Maintenance '

The reviewed maintenance activities included:

Trouble shooting SW 1424 actuator

Cycle Test of valve RC 2

Troubleshooting RC 11 failure

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Installation and operation of the Integrated Control System (ICS) Data Aquisistion and Analysis System (DAAS). On June 19.-

1990, at 0:55 a.m., the licensee was installing a computerized monitoring system known as the DAAS when leads were improperly installed in the ICS cabinet, causing a feedwater transien . ,

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Steam generator water levels were be hg controlled in automatic by the ICS at a programmed level vi 40 inches. Steam generator water levels increased about 7 inches before the technician,

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sensing an error, removed the. leads. The'ICS returned steam generator water levels to ncrmal.- The work order required that-a pre-job brief be performed end that control room personnel be informed of the DAAS insta11atan. This was not done. .The root cause of'this event was personnel error. While the-ICS is a non-safety-related system, thipis an example of the licensee not performing a pre-job briefing. The resident staff will monitor the licensee's corrective actions, b. Surveillance The reviewed surveillances included:

Procedure N Activity ST-5030.09 RPS Response Time Test DB-SP-03164 AFW Train 2 Flow Verification Test DB-SS-03091 Motor Driven Feed Pump 0"arterly Test DB-SS-03092 Motor Driven Feed Pump 18 Month Test DD-MI-03353 Channel 3 ARTS Functional Test 0B-50-03272 Control Rod Exercising Test DB-ME-03041 SFAS Sequencer D1 Bus Undervoltage Relay Functional Test On June 9, 1990, coincident with maintenance personnel removing test leads from the D1 bus undervoltage (UV) reldy, a fuse to the UV sensing device blew. The device, sensing'an apparent UV condition, caused the D1 bus to shed its electrical loads, started the emergency diesel generator and deenergized the Auxiliary Boiler. fuel oil. pum The loss of steam necessitated the intentional-breaking of condenser vacuum. Coincident with this event a test of the Steam and Feedwater Line Rupture Control System (SFRCS),was being performed. This test required the Main Feed Pum) (MFP)'controllerbe' reset. Although the MFP was not operating at tie time, it received a low condenser vacuum trip signal. The Anticipatory Reactor Trip System (ARTS) received a MFP trip signal and opened the reactor trip breakers. 'All control rods-were already fully inserted prior to the trip. An investigation of this event revealed that the cause of the fuses blowing may not'have been due to maintenance in the cabinet. Similar trips of the'C and ;

D 4160 volt electrical busses have occurred before.- Corrective actions' '

to these events were in place when this event occurred.' The cause of this event is still being investigated by the license <

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The licensee discovered that plugs were installed in the air actuator manual vent lines to the Atmospheric Vent Valves (AVV). These plugs inhibit manual operation of the AVVs. In the licensees Compliance '

Assessment Report with Appendix R of 10 CFR 50 (Nuclear Power Plant Fire Protection), an AVV is required to be operated manually to provide secondary system pressure control during a severe control. room fir Licensee procedures do not reference removal of these plugs and if the procedures were performed as written, the AVVs would not operate and could possibly be permanently damaged. The licensee has since removed the plugs and threaded piping from the vent lines. It is unknown when and for how long the plugs were installed. The licensee has thoroughly reviewed this event and concluded that plugs are not installed in any other system Personnel performing maintenance or surveillances used correct procedures and proper work control documents. Work authorization had been obtained for the jobs performed. Prerequisites for performing the job, such as worker protection and tagging had been performed. Surveillance continues to be an area where only an occasional minor problem arises.-

No violations or deviat.ons were identifie . Emergency Preparedness (71707. 82701)

An inspection of emergency preparedness activities was performed to assess the licensee's implementation of the emergency plan and implementing procedure The inspection included monthly observation of eme,gency facilities and equipment, interviews with licensee staff, and a review of selected emergency implementing procedures, i i

No violations or deviations were identifie . Security (71707. 81070. 81052)

I The licensee's security activities were observed by the 1.nspectors during routirie 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 thoroughnes j Security personnel were observed to be alert at-their posts. Appropriate compensatory measures were established in a timely manne Vehicles-entering the protected area were thoroughly searche No violations or deviatior.s were identifie . Engineering and Technical Support (37828. 62763. 71707. 92701. 92720)

An inspection of engineering and technical support activities was-performed to assess the adequacy of support functions associated with operations, maintenance / modifications, surveillance and testing activitie !

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The inspection fccused on routine engineering involvement in plant operations and response to plant problems. The inspection included direct observation of engineering support activities and discussions ,

with engineering, operations, and maintenance personnel.- ,

On June 6,1990 at 4:10 a.m., the inspectors reviewed the licensees'

log for performance of DB-PF-10103, " Reactor Coolant System Hydrostatic Pressure Test." The inspectors noted two log entries made for the times of 4:15 a.m. and 5:00 a.m. The inspectors determined that the entries '

were anticipatory and were used to inform his relief of his planned location. The performance engineer responsible for the entry revised the log after being contacted by the inspectors as to the validity of '

making a future log entry. The inspectors met with licensee management to discuss the importance of maintaining accurate logs. The licensee t counseled this individual involve ,

On June 16, 1990, at 3:01 a.m. during performance of DD-SP-03363, <

" Pressurizer Power Operated Relief Valve (PORV) Cycle Test," the motor i o)erated PORV block valve, RC 11, failed to open from its shut positio T1e plant was cooled down to Mode 5 and the failed valve was replaced.'

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The licensee believes that the valve failed due to thermal binding. A~ .

valve of similar design, HU 28, failed after a plant trip on January 26, !

1990. The licensee's investigation _into the failure of MU 28 revealed *

that several valves in the plant have a potential problem with thermal .

binding, including RC 11. Previously, RC 11 had been replaced with a !

valve having a flexible wedge design making it less susceptible ta thermal binding. The licensee is continuing its investigation of tnis '

valve failur >

System engineering and design engineering continue to provide adrquate coverage and respons .

No violationr. or deviations were identifie . Safety Assessment / Quality Verification (35502, 92701, 92720, 30703, 15707, 92720, 35701, 92700, 90712)

An inspection of the licensee's quality programs was performed to' assess I the implementation and effectiveness of programs associated with management control, verification, and oversight activities. The inspectors considered ,

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areas indicative of overall management involvement in quality matters, ,

self-improvement programs, response to regulatory and industry initiatives, i the frequency of management phrt tour: and control room observations, and management personnel's participation in technical and planning meeting '

The inspectors reviewed Potential Condition Adverse to Quality Reports (PCAQR), Station Review Board (SRB) and Company Nuclear Review Board meeting minutes, event critiques, and related documents; focusing on the licensee's root cause determinations and-corrective actions. The inspection also included a review of quality records and selected quality assurance audit and surveillance activities, b

The licensee discovered on June 9,1990, that a 4 inch service water (SW)

line supplying cooling water to an-Emergency Core Cooling System (ECCS)

Room 2 cooler had developed a small leak. On June 11, 1990, the licensee

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decided to use the system with a temporary non-code repair until it could be permanently repaired. NRC Generic Letter (GL) 90-05 was issued on June 15, 1990, to provide guidance for performing temporary non-code repair of pising. On June 26, 1990, the inspectors reviewed GL 90-05 and recognized t1at the licensee could not o>erate the plant with the temporary repair without specific NRC approval. T1e inspectors brought this to the attention of the licensee. A telephone conversation between the licensee and NRC concerning the use of the system and the requirements of GL 90-05 was held on June 26, 1990. The licensee 31ans to submit _L relief request to allow continued plant operation with t1e existing conditio No violations or deviations were identifie . Violations for Which a " Notice of Violation" Will Not Be Issued'

The NRC uses the Notice of Violation (NOV) as a standard method for -

formalizing the existence of a violation-of a legally binding requirement;=

However, because the NRC wants to encourage and support licensees'

initiatives for self-identification and correction of problems, the NRC will not generally issue a NOV for a-violation that meets the tests'of 10 CFR 2, Appendix C, Section V.G.I. These tests are: (1).theviolation was identified by the licensee; (2) the violation would be categorized as Severity Level IV or V; (3) the violation was reported to the NRC, if required; (4) the violation will be corrected, ine'luding measures to prevent recurrence, within a reasonable time peviod;-and (5) it was not'

a violation that could reasonably be expected to have been prevented by the licensee's corrective action for a previous violation._ A. violation of regulatory requirements identified during the inspection for which a NOV will not be issued is discussed in Paragraph 3.:

13. _ Exit Interview (30703)

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

throughout the inspection period and at the conclusion of the. inspection and summarized the scope and findings of the inspection activities. The licensee acknowledged the findings After discussions with the. licensee, theinspectorshavedeterminedther.e is no proprietary data contained in this inspection repor