IR 05000315/1982010

IE Insp Repts 50-315/82-10 & 50-316/82-10 on 820314-0430. Noncompliance Noted:Failure to Follow Equipment Control Procedures When Taking Unit 2 E Centrifugal Charging Pump Out of Svc & Failure to Make Prompt Rept

ML20054L559
Person / Time
Site:	Cook
Issue date:	06/08/1982
From:	Dubry N, Hayes D, Swanson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20054L556	List: IR 05000315/1982010 ML20054L555 ML20054L558
References
50-315-82-10, 50-316-82-10, NUDOCS 8207080239
Download: ML20054L559 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

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Report No. 50-31'5/82-10(DPRP); 50-316/82-10(DPRP) .

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Docket No. 50-315; 50-316 License No. DPR-58; DPR,-74,

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i Licensen: 'American Electric Power Service Corporation Indiana and Michigan Electric Company '

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New York, NYr 10004 Facility Name: Donald C. Cook Nuclear Planti Tnits 1 and .2 -

Inapection At: Donald C. Cook Site, Bridgman, MI Inspection Conducted: March 14 through April 30, 1982 d () , e -

Inspectors: s E. _. Swanson

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E. DuBry 6-8'82 '

Approved By: yes, Chie Reactor Projects Section IB

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Inspection Summary

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Inspection on March 14 through April 30, 1982 (Report No. 50-315/82-10(DPRP);

50-316/82-10(DPRP))

Areas Inspected _:_ Routine, onsite regular and backshift inspection conducted

.- by two resident inspector Areas inspected included: Licensee Event Reports,

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j Followup on Previous Inspection Findings, Operational Safety Verification,

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Inspection During Long Term Shutdown, Surveillance Observation, Maintenance

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Observations, Plant Trips, Maintenance Outage, Independent Effort, Unplanned Releases, and Emergency Core Cooling System Blockage. The inspection in-cluded a total of 299 isvestion-hours onsite by two NRC inspectors including 69 inspection-hours o'- v d ring off-shift hour .

Results: Of the te, are s to items of noncompliance or deviations were {

identified in ef + re . ~Four items of noncompliance were identified in two area (Fa,'v e ! .sliow equipment control procedures when taking Unit 2 "E" Centr, fugal LLurging Pump out of service, Paragraph 10; failure

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to make a prompt report and timely notification of an unplanned, uncontrolled gaseous release, Paragraph 10; failure to do a safety review of procedures to locate a flow blockage, Paragraph 11; failure to follow or develop pro-cedures for sampling, preparing and adding boric acid and performing main-tenance on the CVCS-Boron make-up system. Paragraph 11).

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82070B0239 820623 PDR G

ADOCK 05000315 i PDR

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DETAILS t Persons Contacted

• W. Smith, Jr., Plant Manager

• B. Svensson, Assistant Plant Manager

• E. Townley, Assistant Plant Manager

• E. Smarrella, Technical Superintendent

• J. Stietzel, Quality Assurance Supervisor

• K. Baker, Operations Superintendent

• T. Beilman, Sr. Quality Assurance Auditor

• Denotes those present at exit interview The inspectors also contacted a number of licensee and contract employees and informally interviewed operations, technical, and l maintenance personnel during this inspection perio I Licensee Event Report (Closed) LER (50-315/81-056/99T-0): A Technical Specification change request concerning the F q(Z) curve was submitted by the licensee on April 7, 1982 (AEP:NRC:0665). Followup on Previous Inspection Findings (0 pen) Open Item (50-316/82-04-06): Evaluation of events during the Unit 1 plant trip on March 5, 1982. The unit was being returned to operation following a maintenance outage and tripped from a low-low steam generator level. During this event the licensee experienced a turbine runback, steam dump actuation, automatic rod control problems, and pressurizer pressure dropping to 2204 psig which is contrary to Technical Specification 3.2.5 (Licensee Event Report RO 82-015/03L-0).

The inspector cbservations and findings surrounding this event revealed the following. The power increase was in progress using the load limiter to control turbine loading. The unit had reached 46% reactor power when they experienced a turbine runback of about 30% power (300 MW electrical)

while trying to increase the set point on the load limiter. The steam dumps were activated and the rapid cooldown caused the RCS/ Pressurizer pressure to drop to 2204 psig, and the steam generator to shrink re-sulting in a low steam generator level reactor trip. During the trans-lent, to try to get control of the event, the operators placed the rod control in automatic. This resulted in the rods withdrawing at maximum speed and a sudden power escalation. A review of the nuclear instrument recorder indicated a power spike to 58% before the automatic reactor tri The licensee felt that placing the automatic rod control system in automatic partway through the transient, with feedwater control in manual, may have adversely affected the overall system respons . _ - . _ _ . ._ .. -- _ . - _ _ _ . . . .

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v A review in the area of the automatic rod control system and its

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operation during the transient found that conditions may have existed which might have caused the rods to withdraw in automatic. On March 29, 1982, operations memo 82-37 was issued to the operators specifying the caution tag on the rod control switch and precautions i

to observe that the rods move in the desired direction when placing the switch in automati The inspector also reviewed the results of the licensee's trouble shooting ef forts and found the following. A licensee C & I technician had identified on March 29, 1982, a malfunctioning lead / lag circuit on the T-ave. portion of the automatic rod control system. A previously

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intermittent malfunction resulted in a continuous maximum withdrawal signal to be input to automatic rod control at all times. On April 6, 1982, while doing a followup in this area the inspector discovered ,

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, that the operators and their supervisors were unaware of the T-av I fault in the Rod Control System which would result in a maximum speed

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rod withdrawal anytime the selector switch was placed in automati , This matter was brought to the attention of the operations department management who took immediate action on the issue by retracting li operations memo 82-37, and cautioning operators not to use automatic rod contro ;

During exit interviews the inspector asked for an explanation of the communications breakdown between departments, which resulted in the

] plant operating with less conservatism. The licensee's explanation was [

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that in spite of estab1'shed communication methods the C & I technician

. neglected to pass on his findings of the failed T-ave. component. The  ;

inspector also requested the results of further analysis and review  ;

committed to in the abew9 mentioned LER. The licensee stated he would [

provide these results when the analysis and review was complet I i

(Closed) Unresolved Item (50-315/80-01-03; 50-316/80-01-03): The licensee's position on qualification of personnel to Regulatory Guide 1.58 (9/80) and ANSI N45.2.6-1978 has been reviewed by NRR and found l to be acceptabi r I

With respect to qualification and certification of performance personnel I performing leak testing the licensee has committed to implementing a  :

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training program by June 30, 1982, and has taken further steps to assure

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that all personnel who work on site whether plant employee or contractor j are aware of requirements in this area. The licensee's position that

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formal certification of personnel qualifications were unnecessary was j found acceptable.

i i Other exceptions and discussions concerning Regulatory Guide 1.58 are I contained in the licensee's September 14, 1981 letter (AEP:NRC:0567)

, to NRR. Acceptability of their commitments and exceptions was stated, ,

! by NRR, in a letter dated April 9, 198 !

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(Closed) Unresolved Item (50-315/80-01-04; 50-316/80-01-04): In lieu l of substantial evidence to the contrary, the plant's methodology for l

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conducting quality control activities utilizing first line supervisors, engineering personnel, department supervisors and plant management was found to be acceptabl . Operational Safety Verification-Inspection During Iong Term Shutdown The inspectors observed control room operations, reviewed applicable logs and conducted discussions with control room operators during the period of March 14, 1982 through April 30, 1982. The inspectors veri-fled the operability of selected systems, reviewed tagout records, and verified proper return to service of affected components. The in pectors also reviewed surveillance tests required during the Unit 2 shutdown, verified tagouts and records used during the outage, and checked applicable containment integrity requirements. Tours of the Unit 2 containment, auxiliary building, turbine building, and screen-house accessibic areas were made to assess equipment conditions, plant conditions, and radiological controls and safety. Verification that ,

maintenance requests had been initiated for equipment in need of main- I tenance work was also mad I The inspectors observed plant housekeeping / cleanliness conditions and verified implementation of radiation protection controls. During the inspection period the inspector walked down accessible portions of the Unit 2 Safety Injection accumulator system, the containment spray system, and Unit 1 Charging System to verify operabilit By observa-tion and interviews the inspectors verified that the station security plan had been implemented and observed controls associated with radwaste processing and shippin These reviews and observations were conducted to verify that facility operations and maintenance efforts were in conformance with the require-ments established under Technical Specifications, 10 CFR, and adminis-trative procedure On March 18, 1982, while core boring through the "E" control room wall, water was spilling onto unprotected relays and timers located behind the Component Cooling Water pancis which resulted in a number of annunciator alarms. A similar event was brought to the licensee's attention about six months ago when the licensee war drilling through the control room panels and allowing metal shavings to fall onto unprotected relays and terminal boards. Af ter discussions with li-consee representatives the licensee put out directives of precautions to be taken doing future core boring . Surveillance Observations The inspectors observed Technical Specifications required surveillance testing " Ice Condenser Basket Weighing; **12 TilP 4030 STP.211" Unit 2;

" Containment Spray Nozzle Air Flow Test, **12 THP 4030 STP.216, Unit 2; and " Containment Spray System Operability Test, 2-OllP 4030 STP.007, and verified testing was performed in accordance with adequate procedures, that limiting conditions for operations were met, that removal and

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restoration of the affected components were accomplished, that test results conformed with Technical Specifications and procedure require-ments. The results were reviewed by personnel other than the individual directing the test. The inspectors also noted that any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personne The inspector also witnessed / reviewed portions of the following test activities:

Unit 1 12 THP 6010 RAD 592 " Process Monitor Detector Calibration" (R-28)

12 THP 4030 STP.362 "Incore/Excore Detector Calibration" Unit 2 12 THP 6030 IMP.069 "APDMS" 2 THP 4030 STP.113 " Pressurizer Pressure Protection Set III" 12 THP 4030 STP.207 " Ice Condenser Lower Inlet Door Surveillance" 12 THP 6030 IMP.087 " Pressure Indicator Calibration" 2 OHP 4030 STP.015 " Full Length Control Rod Operability Test" While observing the " Containment Spray Nozzle Air Flow Test" surveillance the inspector noted that four stringers in the lower containment failed to have any flow and that a number of the nozzles on the lower contain-ment annulus ring had been taped over. Concerning the latter, the inspector noted that the personnel performing the surveillance cleared the obstructions as they were found. The former problem was found to be water draining into the low portions of the system and forming loop water seals in the stringers. The licensee was able to vacuum the water out of these area It was analyzed as water from the RWST based on boron concentrations and activity levels. The nozzles were again tested and found to be satisfactory. This water seal would have been forced out of the line if containment spray mere initiate . Maintenance Observations Station maintenance activities of safety related systems and components l listed below were observed / reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides, and industry codes or standards, and in conformance with Technical Specification The following items were considered during this review: the limiting conditions for operation were met while the components or systems were removed from service; approvals were obtained before initiating the work; activities were accomplished using approved procedures and were

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inspected as applicable; functional testing and/or calibrations were performed before returning components or systems to service; quality control records were maintained; activities were accomplished by quali-fied personnel; parts and materials used were certified; and radiological controls were implemente .

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The following maintenance activities were observed / reviewed:

Unit 2

• • 12 MHP 5021.001.019 Maintenance Procedure for Inspection and Repair of Velan Valve (2-ICM-111, RHR loop 2 & 3 cooldown supply).

MHP 5021.001.024 Maintenance Procedure for Inspection and Repair of Copes-Vulcan Valves. (2-NRV-164, Pressurizer Spray Valve) and (2-NRV-163, Pressurizer Spray Valve).

12 MHP 5050 SP.005 Hydro of RCS following Repairs to 2-RC-108-L MHP 5021.001.007 Maintenance Repair Procedure for Conal Clamp-Scal Valves (SI-125, BIT bypass valve).

Both Units MHP 5021.003.001 Maintenance Repair Procedure for Centrifugal Charging Pumps (Pumps 1 E&W; and 2 E5W).

During tours the inspector also observed work in progress on CS 381, Reactor Coolant Filter Drain Valve; Unit 2 Containment Sump; 2 S1-170-L3; Cold Leg RCS/SI injection flow check valve; and No. 22 Steam Generator Manway decontamination and repai Following completion of maintenance on RC-108-L4 and the high pressure charging system, the inspector verified that these systems had been returned to service properl . Plant Trips Following the Unit i reactor trip / turbine trip on loss of vacuum from 100% power on April 27, 1982, the inspector ascertained the status of the reactor and safety systems by observation of the control room indicators and discussions with licensee personnel concerning plant parameters, emergency system status, and reactor coolant chemistr The inspector verified the establishment of proper communications and reviewed corrective act.ons and sta up preparatory actions taken by the licensee. All systems responded as expected, and the plant was returned to operation on April 28, 198 . Maintenance Outage On March 11, 1982, Unit 2 was removed from service and conducted a normal shutdown from 75% power because of increasing No. 23 Reactor Coolant Pump (RCP) motor temperatures and evidence of primary system leakage from the No. 23 RCP seals. This resulted in a 20 day main-tenance outage while repairs were made. During this time the licensee also conducted ice condenser surveillance and maintenance, and contain-ment spray system surveillanc :

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The reactor was started up on March 30, 1982, and returned to the grid on March 31, 198 . Independent Inspection Effort Instrument Room Purge On December 7, 1981, in the text of a letter (AEP:NRC:0642) to Harold R. Denton, Director, Office of Nuclear Reactor Regulation, United States Nuclear Regulatory Commission, from R.S. Hunter, Vice President, Indiana and Michigan Electric Company, a commitment was made to keep the Containment Instrument Room purge isolation valves 1-VCR-101, 1-VCR-102, 1-VCR-201, and 1-VCR-202 closed in operating modes 1, 2, 3, and 4. All circumstance concerning the commitment and reasons for its origin were reported via LER 50-315/81-059/03L-0 and 50-316/81-072/03L-0 dated January 6, 1982. Design change RFC 12-2578 has reportedly been initiated to have R-2 initiate containment ventilation isolation in applic-able modes to correct the need for this commitmen The licensee's letter of February 11, 1982 to the Region III Administrator reported a deviation from the above stated commit-ment and that procedure would be revised to prevent reoccurrenc The inspector verified that actions to modify operating procedure OHP 4021.028.010 were completed on March 2, 1982 for Unit 1 and March 9, 1982 for Unit Primary Coolant System - Pressure Isolation Valve Testing The April 20, 1981 order for modification of Unit 1 and 2 licenses revised Technical Specification 3.4.6.2 and specified leak testing of certain check valves. IE Report 50-315/81-13(DPRP); 50-316/

81-16(DPRP) Paragraph 3 discussed the use of leakage correction criteria used in the testing procedure **12 THP 4030 STP.226 as being improperly applied. After the licensee's investigation of the criteria with further ASME guidance the licensee developed the following equation to be used in procedure **12 THP 4030 STP.226: '

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g =n (APp )(p )~

T (APT )(PF)

Where:

hp = Corrected leak rate at functional differential pressure, L = measured leak rate at test differential pressure, T

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AP =

p functional differential pressure across the valve AP = test differential pressure across the valve, T

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= upstream density at functional pressure and temperature, and, p

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= upstream density at test pressure and temperatur The inspector had no further concern . Unplanned Releases-Auxiliary Building / Containment Evacuations During this inspection period the licensee experienced one unplanned release of one week in duration; two evacuations of Unit 2 containment and two partial evacuations of the auxiliary building due to high airborne activity; and one evacuation of the auxiliary building due to hydrazine gas releas On April 2, 1982, at 0723 EST there was an evacuation of the auxiliary building due to high airborne activity resulting when leakage into the clean and dirty sump tanks caused overflow and offgassing. The release was 0.2% of the integrated technical specification limits. This was an unplanned, accidental, uncontrolled release. Official notification of the NRC operations center was not made until approximately 1040 on April 2, 1982. This is a violation of 10 CFR 50.72. (50-315/82-10-01; 50-316/82-10-01)

One suspected source of leakage contributing to the release was the Unit 2 East Centrifugal Charging Pump seal. During the period from about 1900 hours0.022 days <br />0.528 hours <br />0.00314 weeks <br />7.2295e-4 months <br /> on April 2, 1982 through 0117 hours0.00135 days <br />0.0325 hours <br />1.934524e-4 weeks <br />4.45185e-5 months <br /> on April 5, 1982 the pump was taken out of service by valving out and opening breaker Although tagged out prior to and af ter this period, there were apparently no administrative controls untilized during the subject period to verify that the pump was properly removed from service and returned to servic This constitutes a violation of technical specification procedural re-quirements for equipment control as set forth in the Appendix (50-316/

82-10-02).

After meeting with plant management on April 8, 1982 the licensee took actions to strengthen their administrative controls concerning clearance permit Operators had apparently not understood that equipment controls were required for Technical Specification equipment when intentionally secured to prevent cocratio An April 5, 1982, while performing surveillance on the"E" centrifugal charging pump (2 OHP 4030 STP.005) portions of the auxiliary building experienced high radioactive airborne levels resulting in a partial evacuation of th auxiliary buildin On two occasions during this inspection period the containment access was limited due to elevated radioactive airborne (chiefly Iodine) as a result of maintenance and cleanup efforts. Adequate radiological pre-cautions were taken and access was re-establishe .

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On March 31, 1982, portions of the auxiliary building were evacuated when concentrations of hydrazine in excess of 2 ppm were experience The gas came from leaking storage tanks. The rooms effected were purged with fresh air and access restored. There were no injurie Hydrazine is used as a corrosive inhibitor in the non-nuclear system during normal operations; and as an oxygen scavenger in the nuclear systems during maintenance activitie . Emergency Core Cooling System Blockage While performing maintenance of the Bu or. Injection System, recircula-tion of the Baron Injection Tank (BIT) was secure (Flow through this path assures that the BIT contains at least 900 gallons of borated water within a specified concentration and uniform temperatures to pre-vent crystallization of the solution (Technical Specification 3.5.4.1.)

The volume and concentration must be verified every 7 days and the water temperature must be verified every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.) Maintenance was performed between April 6 and April 14, 1982, on several flanges and valves to repair leaks, heat trace circuits were repaired and sample lines were unplugged. The last recirculated BIT sample was taken on April 6,1982, assuma:.g it was not drawn between 1226 and 1444 when the system was isolated. On April 13, 1982, other maintenance pre-vented normal recirculation so the operators opened a downstream valve with the Boric Acid transfer pump running to verify the BIT was ful On April 15, 1982, the grace period for verifying the BIT concentration expired and a sample was taken by flushing several gallons from the BIT

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and then sampling. This action had the potential to reduce the BIT volume below that required by Technical Specifications and there were no administrative controls in place to prevent this situatio The licensee could not provide any documentation indicating exactly when the recirculation flow blockage was discovered. Clearances to repair two valves on April 13, 1982 were released on April 14 and no other work was apparently done i the system until efforts to unblock the flowpath commenced on ti.e 19th of April. An entry in the Nonconforming Equipment Log on April 16th indicates that a flow-path blockage existed. Also, the system retest for the flowmeter gasket replacement was for some unexplained reason, delayed until April 18 when recirculation flow still could not be used to verify the tank full. Circumstantial evidence leads to the conclusion that apparently the system became blocked between April 7 and April 14, 1982, and efforts to unblock it did not commence until the 19t Again, on the 18th as on the 13th the BIT was " verified full" by opening a downstream valve and running a Boric Acid transfer pum This method of verifying the volume of the BIT was not approved as a temporary change and constitutes a violation of the Technical Specification administrative controls for Surveillance Procedure Operations Surveillance procedure 2-OHP4030.STP.030 requires the verification of BIT recirculation flow to satisfy Technical Speci-fication 4.5.4.l Starting on April 19, 1982, the licensee made

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preparations to find the blockage in the recirculation line-up by doing flow verifications on portions of the system. This was accomplished by attaching a hydrostatic pump, with a 10 gallon per minute capacity, and charging demineralized water into sample or test connections upstream and venting the system downstream. These charging evolutions into portions of the Emergency Core Cooling boron injection flowpaths were started at approximately noon on April 20, 1982. On April 21, 1982, the question was raised by the Resident NRC Inspector whether the BIT was full and within the boron concentration specification limits. Later, at 2340 on April 21, 1982, a general consensus of opinion by licensed senior reactor operators on shift and the maintenance foreman was that the BIT might be partially drained and the Boron concentration would be found low out of the specification limits when sampled (if and when recirculation flow was established). <

1he Shif t Supervisor subsequently telephoned the Operations Superin-tendent at his home and conveyed his intentions to shut the Unit 2 reactor down by the end of the shif t if attempts to establish recir-culation flow and sample the BIT were unsuccessfu (Technical Specification 3.5.4.1 requires the tank to be restored to operable within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or the reactor be shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.)

Apparently, based on the opinion of the reactor operators and main-tenance foreman that the BIT concentration might be low, the Shift Supervisor requested at 0115 on April 22, 1982, that a highly con-centrated boric acid batch be made in preparation for addition to the system. The high concentration was requested to compensate for suspected dilution of the BIT and "S" BAST (south boric acid storage tank) during the maintenance effor The inspector determined that there were no formal procedures being used to conduct or control the maintenance efforts to locate and clear the flow blockage nor were appropriate records maintaine This appears to be contrary to the administrative controls required by Technical Specification 6.8.1. The inspector reviewed the Emergency Job Order issued to control the work and found the following description of the completed work:

" Considerable flushing, hydro cleaning, dismantling of valves and flow meters was done in order to purge the line of pluggage".

It was also noted that the Job Order mechanism for controlling Technical Specification limiting work was not properly completed to reflect that personnel involved with the work recognized the safety related aspects of the work they were doing. Further, no safety evaluation or review was conducted although management was fully aware of the scope of activities being conducted. This is contrary to Technical Specifi-cation 6.5.1.b and 10 CFR 50.5 _ - - .. _

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Between April 20th through April 22, 1982, there was no documentation  !

of the amount of demineralized water being added nor the amount of -

borated water being drained from the system. The licensee was able to '

I clear the recirculation flowpath at 0509 on April 22, 1982, and at 0511 i l the previously prepared batch of boric acid was added to the CVCS Boron  !

!. makeup system aligned to the "S" boric acid storage tank (BAST). At  !

i this time the licensee experienced approximately a 150 gallon loss of [

1evel in the "S" BAST which appeared to indicate that the BIT was )

I 3 partially drained and therefore not within the defined Technical Specification level limits 3.5.4.1.a.

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Subsequent results obtained at 0625 on April 22, 1982, showed the BIT  !

concentration to be out of the specified range (20,000 - 22,500) at ,

l 24,100 ppm. ESC notification of this high concentration was made at l 0723. After farther recirculation, a sample taken at 0717 resulted i

in a concentration of 22,318 ppm. This result was known to the  ;

j operators one minute af ter plant shutdown had been initiated according ,

j to the Technical Specification Action Statement. Lack of sufficiert  :

recirculation tima was suspected by the licensee to have been the cause of the high sample value.

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! A rudimentary mass / concentration balance done by the inspector indi-

} cated the BIT boron concentration may have been as low as 16,700 ppm.

! On May 3, 1982, the inspector requested that the licensee conduct calculations which would support their conclusion that the BIT was operable throughout the period of testing. Subsequent discussions i resulted in the understanding that the sampling and volumetric in- l accuracies involved in a mass balance calculation render the results  ;

inconclusive. To affirm position that they were not' exceeding the I Limiting Condition for Operation, the licensee reconstructed the

, event utilizing pump and tank capacities, and personnel recollection ,

, of the testing performed, flowpaths used, and the time durations of

! additions and draining during the testing,

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i l Review of this event also disclosed that procedure 12 OHP4021.007.001, '

l " Boric Acid Solution Preparation and Transfer" had not been followed j

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when preparing and making the batch tank addition. The licensee sub-  ;

j sequently revised this procedure to allow such action in the future, i l The revised procedure was reviewed by the plant nuclear safety review  !

committee (PNSRC) on May 6, 1982.

! f I In summary, there appears to be two items of noncompliance resulting j i from this even First, contrary to Technical Specification 6.5. ;

j and 10 CFR 50.59, no safety evaluation of the testing and/or experi- l mentation was done to consider its impact on systems and equipment e

, important to nuclear safety. Second, contrary to Technical Specifi- l

cation 6.8.1.a

Surveillance required by T. S. 4.5.4.la was not i accomplished according to 2-OHP4030.STP030; the BIT boron sample was [

l drawn on April 15, 1982, was not done according to normal sampling i practices (no recirculation flow) and this had the potential of i degrading the operability of the BIT; a chemical addition was made '

on April 22, 1982, without knowing the actual concentration of the

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BIT utilizing a higher concentration than specified in the procedure (12-OHP4021.007.001); and no procedure was utilized to control the maintenance testing and experimentation conducted on the BIT recir-culation system while the Unit 2 reactor was operated at 100!. powe Exit Interview The inspectors met with licensee representatives (Paragraph 1) throughout the inspection period, and on May 3, 5, 7 and 13, 1982, summarized the scope and findings of the inspection activities. The licensee acknowledged receipt of the items of noncompliance (Paragraphs 10 and 11) and recon-firmed the commitments found in paragraph