IR 05000245/1980011

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IE Insp Repts 50-245/80-11 & 50-336/80-09 on 800706-0802. Noncompliance Noted:Failure to Require Restoration of Equipment Following Maint & Failure to Require Radiation Work Permit in Accordance W/Procedures
ML19340E732
Person / Time
Site: Millstone  Dominion icon.png
Issue date: 09/16/1980
From: Keimig R, Shedlosky J, Zimmerman R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19340E726 List:
References
50-245-80-11, 50-336-80-09, 50-336-80-9, NUDOCS 8101150546
Download: ML19340E732 (10)


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O u.s. NuCteAR aEcutAr0av C0xxiss10N 0FFICE OF INSPECTION AND ENFORCEMENT

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50-245/80-11 Report No.

50-336/80-09 50-Z45 Docket No.

50-336 DPR-21 License No. DPR-65 Priority Category C

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Licensee:

Northeast Nuclear Energy Company P.O. Box 270 Hartford, Connecticut 06101 Facility Name:

Millstone Nuclear Power Station, Units 1 & 2 Inspection at:

Waterford, Connecticut 06385 Inspection conducted: July 6 thru August 2, 1980 Inspectors:

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. T. Shedlosky r. Resident Inspector date signed S/

8, 9/9//f0 P. Zinnerman es& dent Inspector

/ date signed date signed Approved by:

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9/N,/#0 K. R. Pidimig, Ch1W, feactor Projects date' signed Section No. 1, RO&NS Branch Inspection Summary:

Inspection on July 6 thru August 2, 1980 (Combined Report Nos. 50-245/80-11 and 50-336/80-09)

Areas Inspected:

Routine, onsite, regular and backshift inspection by two resident inspectors (75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br />, Unit 1; 67 hours7.75463e-4 days <br />0.0186 hours <br />1.107804e-4 weeks <br />2.54935e-5 months <br />, Unit 2). Areas inspected included the control rooms and the accessible portions of the Unit I reactor, turbine, radio-active waste, gas turbine generator, and intake buildings; the Unit 2 enclosure, auxiliary, turbine and intake buildings; and the condensate polishing facility; radiation protection; physical security; fire protection; plant operating records; surveillance testing; calibration; maintenance; core power distribution limits; and reporting to the NRC.

Results: Of the ten areas inspected, no items of noncompliance were found in 8 areas; three apparent items of noncomplic.ce were found in two areas (Infraction - failure to require restoration of equipment following maintenance, paragraph 5.b; Infraction -

failure to require a radiation work permit in accordance with H.P procedu es paragraph 6; Infraction - failure to instruct workers of radioactive mater [als in the work area, paragraph 6).

Region I Form 12 (Rev. April 77)

8101150SN

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DETAILS 1.

Persons Contacted The below listed technical and supervisory level personnel were among those contacted:

J. Bangasser, Station Security Supervisor J. M. Black, Unit 3 Superintendent P. Callaghan, Unit 1 Maintenance Supervisor A. Cheatham, Radiological Services Supervisor J. Crockett, Unit 2 Engineering Supervisor F. Dacimo, Quality Services Supervisor E. C. Farrell, Station Services Superintendent H. Haynes, Unit 2 Instrumentation and Control Supervisor R. J. Herbert, Unit 1 Superintendent J. Kangley, Chemistry Supervisor J. J. Kelley, Unit 2 Superintendent E. J. Mroczka, Station Superintendent V. Dapadopoli, Quality Assurance Supervisor R. Place, Unit 2 Maintenance Supervisor R. Palmieri, Unit 1 Engineerir.g Supervisor W. Romberg, Unit 1 Operations Supervisor S. Scace, Unit 2 Operatiocs Supervisor E. Spruill, Health Physics Supervisor F. Teeple, Unit 1 Instrumentation and Control Supervisor 2.

Status of Previous Inspection Items l

(Closed) Noncompliance (336/79-25-02):

Failure to make an appropriate temporary procedure change. A procedure change to SP 2601D was approved

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by PORC on October 5, 1979. Action to prevent recurrence required Operations Department personnel to document review of a letter dated December 28, 1979, from W. G. Counsil to E. J. Brunner.

(Closed) Unresolved Item (336/79-25-01):

Evaluation by licensee of post-refueling startup test data - Cycle 3.

Test data from the following procedures were reviewed and accepted by PORC on February 1, 1980, subsequent to engineering staff approval.

T79-7, Criticality / Low Power Physics Test, May 20, 1979.


T79-10, Power Ascension Test, May 17, 1979.


T79-16, Power Ascension to Stretch Power, June 27, 1979.


(Closed) Unresolved Item (336/79-20-01):

InserviceInspection(ISI)

Acceptance Criteria.

Procedure 21101, ISI Pump and Valve Operability Evaluation, Revision 1, October 12, 1979, has been revised to require corrective action in ccnfonnance with AS!E Boiler and Pressure Vessel Code,Section XI, Subsection IWP 3230(A), when test values fall within the

" Alert Range".

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(Closed) Unresolved Item (336/79-20-03):

ISI pump run time prior to i

recording required data. The pump operational readiness test procedures have been revised to conform to IWP-3500, requiring a run time of at least five minutes under stable conditions prior to measuring and recorJing data.

(Closed) Unresolved Item (336/77-31-09):

Procedures for startup test

program.

Cycle 4 startup procedures will be reviewed prior to implementa-tion following the upcoming summer / fall refueling outage.

(Closed)

Inspector Follow Item (336/79-11-01):

Startup Rate (SUR) trip.

The annunciator module for high SUR trip and the high SUR trip bypass -

relay and associated annunciator were removed on May 14, 1979 under Maintenance Request 2-101-79. Removal of the above annunciators deleted all reference to the previously removed high SUR trip.

(Closed) Unresolved Item (336/78-06-10): Calibration of maintenance test instruments. Procedure ACP-QA-904, Control and Calibration of Measuring and Test Equipment, Revision 6, May 9, 1980, has been revised to incorporate programmatic requirements to be followed by each applicable

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department, including the Maintenance Department. Further, the inspector verified that the program being utilized by the Maintenance Department implements the above procedural requirements.

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(Closed) Unresolved Item (245/78-17-05):

Design drawing revision.

Teledyne Engineering Services Drawing No. A-4498, sheet 2 of 4, has been revised to reflect the as built configuration of LPCI "A" restraint CC-H70. The revised drawing was issued December 3, 1979.

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(Closed) Unresolved Item (245/79-20-05, 336/79-16-04): Unlicensed Operator Training. Procedures associated with unlicensed operator training have been revised, requiring supervisory level signatures for operator certifi-l cation to perform specific tasks.

(Closed) Unresolved Item (245/79-26-01):

Reference - item (336/79-28-01)

closed in Inspection and Enforcement Report No. 80-11.

(Closed) Unresolved Item (245/79-26-02):

Reference - item (336/79-28-02)

closed in Inspection and Enforcement Report No. 80-11.

(Closed) Un asolved Item (245/79-26-03):

Reference-item (336/79-28-03)

closed in Inspection and Enforcement Report No. 80-11.

(Closed) Unresolved Item (245/79-26-04): Reference - item (336/79-28-04)

closed in Inspection and Enforcement Report No. 80-11.

3.

Review of Plant Operation - Plant Inspections (Units 1 and 2)

The inspector reviewed plant operations through direct inspection and observation of Units I and 2 throughout the reporting period. Activities in progress at Unit 1 included routine power operations, and scheduled manual and automatic trips on 7/12 to allow completion of actions required by IE Bulletin 80-17; at Unit 2, activities included routine power operations, recovery following a reactor trip on 7/10 resulting from a

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loss of instrument air to the feedwater regulating system, and recovery following a reactor trip on 7/12, when a momentary interruption of heater drain flow resulted in a low suction pressure trip of both feedwater pumps.

a.

Instrumentation Control room process instruments were observed for correlation between channels and for conformance with Technical Specification requirements.

No unacceptable conditions were identified.

b.

Annunciator Alarms The inspar'sr observed various alarm conditions which had been received and acN.awledged. These conditions were discussed with shift personnel who were knowledgeable of the alarms and actions required.

During plant inspections, the inspector observed the condition of equipment associated with various alarms.

No unacceptable conditions were identified.

c.

Shift Manning The operating shifts were observed to be staffed to meet the operating requirements of Technical Specifications, Section 6, both to the number and type of licenses. Control room and shift manning were observed to be in conformance with Technical Specifications and site administrative procedures.

d.

Radiation Protection Controls Radiation protection control areas were inspected.

Radiation Work Permits in use were reviewed, and compliance with those documents, as to protective clothing and required monitoring instruments, was inspected. Proper posting of radiation and high radiation areas was reviewed in addition to verifying requirements for wearing of appropriate personal monitoring devices. Two items of noncompliance were identified concerning insufficient radiation protection controls, and are discussed in paragraph 6.

e.

Plant Housekeeping Controls Storage of material and components was observed with respect to prevention of fire and safety hazards.

Plant housekeeping was evaluated with respect to controlling the spread of surface and airborne con-tamination. There were no unacceptable conditions identified.

f.

Fire Protection / Prevention The inspector examined the condition of selected pieces of fire fighting equipment. Combustible materials were being controlled and were not found near vital areas. Selected cable penetrations were examined and fire barriers were found intact.

Cable trays were clear of debris.

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Control of Equipment During plant inspections, selected equipment under safety tag control was examined. Equipment conditions were consistent with infomation in plant control logs, h.

Instrument Channels

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Instrument channel checks recorded on routine logs were reviewed.

An independent comparison was made of selected instruments.

No unacceptable conditions were identified.

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Equipment Lineups The inspector examined the breaker position on switchgear and motor control centers in accessible portions of the plant. Equipment conditions, ine'uding valve lineups, were reviewed for confomance with Technical Specifications and operating requireme.its. One item of noncompliance was identified concerning failure to restore valve position following maintenance and is discussed in paragraph 5.b.,

4.

Review of Plant Operations - Logs and Records - (Units 1 and 2)

During the inspection period, the inspector reviewed operating logs and records covering the inspection time period against Technical Specifications and Administrative Procedure Requirements.

Included in the review were:

Shift Supervisor's Log daily during control room

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surveillance Plant Incident Reports 7/6 through 8/2

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Jumper and Lifted Leads Log all active entries

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Maintenance Requests and Job Orders all active entries

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Construction Work Pemits all active entries

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Safety Tag Log all active entries

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Plant Recorder Traces daily during control room

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j surveillance Plant Process Computer Printed daily during control room

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Output surveillance l

Night Orders

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surveillance l

l The logs and records were reviewed to verify that entries are l

properly made; entries involving abnomal conditions provide

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sufficient detail to communicate equipment status, deficiencies,

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corrective action restoration and testing; records are being l

reviewed by management; operating orders do not conflict with the Technical Specifications; logs and incident reports detail no viola-tions of Technical Specification or reporting requirements; logs and records are maintained in accordance with Technical Specification I

and Administrative Control Procedure requirements.

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5.

Plant Maintenance and Modifications a.

During the inspection period, the inspector frequently observed various maintenance and problem investigation activities. The inspector reviewed these activities to verify compliance with

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regulatory requirements, including those stated in the Technical Specifications; compliance with the administrative and maintenance procedures; compliance with applicable codes and standards; required QA/QC involvement; proper use of safety tags; proper equipment alignment and use of jumpers; personnel qualifications; radiological controls for worker protection; fire protection; retest requirements and ascertain reportability as required by Technical Specifications.

In a similar manner the implementation of design changes and madifications were reviewed.

In addition to those items addressed above, the licensee's safety evaluation was reviewed. Compliance with requirements to update procedures and drawings were verified and post modification acceptance testing was evaluated. The following activities were included during this review:

Unit 2 Decontamination of new fuel, performed in accordance with OP 2210C,

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New Fuel Assembly Shipment, Revision 2, July 17,1980.

Turbine-driven Auxiliary Feedwater Pump overspeed mechanism repair.

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Replacement of HPSI Pump A suction drain valve (Job Order 2-102-80(A)).

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b.

Job Orders (J.0.) 2-102-20 and 2-102-80A were initiated to remove the leaking "A" HPSI pump suction drain van (2-SI-0328) and replace it.

i The pump was isolated on May 21, 1980, prior to the start of work, and

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tags were hung on four valves isolating the pump from service to prevent inadvertent valve manipulation. At the conclusion of the main-tenance, on May 30, 1980, the tags were removed from the valves.

One of the four valves, "A" HPSI pump minimum flow recirculation valve (2-SI-423),was not returned to the normal?y locked open position and was left closed following the tag removal.

Ccnsequently, during inservice inspection testing of the "A" HPSI pump on July 3, 1980, pump damage occurred due to insufficient flow through the pump. The pump was l

believed to be aligned for recirculation back to the Refueling Water Storage Tank.

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The failure to require restoration of equipment following maintenance

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is considered to be an item of noncompliance, at the infraction level, with T.S.6.8.1 and ANSI N18.7-1972, Section 5.3.5.3 (336/80-09-01).

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6.

Radiation Protection Controls (Unit 1)

On July 23, 1980, four contractor employees erected portable staging (HP)

on the second floor of the Unit 1 Reactor Building.

Health Physics instructions, given orally to the workers, had required the staging to.

be installed in sections.

Upon completion of each level, the HP Depart-ment was to be contacted with the intention that appropriate protection measures be instituted prior to entry into the overhead cable tray area.

The workers, who were not wearing protective clothing, completed the first level of staging and contacted the HP technician who evaluated the work site and allowed the individuals to start on the second level of staging without initiating a radiation work permit. The second level of staging, once installed, gave the workers access to the overhead cable trays.

Failure to require a RWP for work perfomed in the Unit 1 Reactor Building overhead is considered an item of noncompliance, at the Infraction level, with Technical Specification 6.8.1 and HP 4912 (245/80-11-01).

No contamination surveys or air samples were taken in the vicinity of the cable trays prior to, or after completion of the first level of staging.

Frisking surveys perfomed by the workers upon exiting the work area, following completion of the second level of staging, indicated partial contamination of each worker.

Contamination surveys performed by the HP Department following the occurrence indicated loose surface contamination levels ranging from 1,000 to 220,000 dpm/100 cm2 beta-gamma.

Failure to instruct tildividuals of radioactive materials or radiation hazards in portions of a restricted area is considered an item of noncompliance, at the Infraction level, with 10 CFR 19.12 (245/80-11-02).

Additional aspects of this incident are still under review.

Decontamination procedures were accomplished on the workers followed by whole body analysis with the licensee's onsite counter.

Results of the anclyses indicated no evidence of internal contamination.

7.

Scheduled Emergency Drill (Units 1 and 2)

An emergency drill was initiated on July 24, 1980, following a simulated small break, loss of coolant accident at Unit 2 while cSerating at full power. The inspectors observed tie drill from the Unit 2 Control Room and the Emergency Operations Center.

Although there was no outside participation in the drill, sopropriate notifications to outside authorities were made.

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l The inspector attended the drill critique held on July 25, 1980. The

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licensee identified areas where corrective action would be taken to improve certain aspects of the drill response. The inspector's comments were adequately addressed by the licensee.

No items of noncompliance were identified.

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8.

Licensee Event Reports ~(LER's)

The inspector reviewed the following LER's to verify that the details of the event were clearly reported, including the accuracy of the description of cause and adequacy of corrective action. The inspector determined whether further information was required, and whether generic implications were involved.

The inspector also verified that the reporting requirements of Technical Specifications and Station Administrative and Operating Procedures had been met, that appropriate corrective action had been taken, that the event was reviewed by the Plant Operations Review Comittee, and that the continued operation of the facility was conducted within the Technical Specification limits.

Unit 1 80-08: Repeated Event; Setpoint drift of two Emergency Core Cooling Systen logic pressure switches. The ability of the system to perfonn its intended function was not impaired.

80-09: Setpoint drift of one of four reactor vessel high pressure switches.

The 7emaining switches were found to be at the proper setpoint and were available to initiate the required action.

80-10:

Structural integrity degraded at Low Pressure Coolant Injection IERT) primary containment penetration X-45. One bolt on the pipe support broke during tension testing performed in accordance with IE Bulletin 79-02.

Several bolts were found to have been installed improperly during original plant construction. At the time of the occurrence, the reactor was in cold shutdown and LPCI was not required to be operable.

Unit 2 80-22: Containment air recirculation (CAR) fans did not shift to slow speed automatically, during system testing. After several tests of the

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IA Safety Injection actuating module, the CAR fans did shift to slow speed.

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An actuation module output relay, =si:scted of sticking, was replaced.

80-23: The core barrel monitor was declared inoperable due to the natural end of life failure of two circuit boards.

9.

Training Staff Qualifications l

By letter dated March 28, 1980, the NRC informed all power reactor l

licensees that training ce' %r and facility instructors who teach systems,

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integrated responses, tra

.ent and simulator courses shall demonstrate their competence to the N.C by successful completion of an SR0 examination or apply for an SR0 license examination by August 1,1980.

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l The licensee's training program does not require that all instructors have received an SR0 license.

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One of the five Millstone Nuclear Station Training Department instructors.has never successfully completed an SR0 examination on Unit I or II. That individual holds an R0 license on Unit I.

The licensee's present position is not.to apply for an upgraded license for that instructor. The licensee has informed the Millstone Site Resident Inspector that their position on training staff qualifications will be addressed in a response to the referenced letter.

An additional finding of the Resident Inspector is that portions of the licensed operator training program make use of non-licensed corporate and site engineering personnel and consultants as instructors.

Due to the subject material covered by these individuals, this action may also be in nonconfonnance with Enclosure I, paragraph A.2.d of the referenced letter.

This area will be reviewed during future inspections following the acceptance of the licensee's training program by the Operator Licensing Branch, Office of Nuclear Reactor Regulation.

10.Bulletin 80-17, Failure of Control Rods to Insert During a Scram at a BWR Testing required by this Bulletin was completed on 7/12. This testing was witnessed by the resident inspectors. Actuation times of key parameters of Reactor Protective System (RPS) and the Scram Discharge Volume Sub-system were recorded to an accuracy of within several milli-seconds using a plant sequence of events recorder.

Following both RPS actuations, normal rod insertion occurred. The values of monitored parameters followed the expected results with the following exceptions:

a.

During testing, the licensee monitored the actuation times of the two time delay relays which prevent reset of the RPS. Those relays actuated 17 seconds after the RPS trip.

However, on 7/16 the reset sub-system of the RPS was wire checked because of a controversy within the operations staff as to the existence of that feature.

It was discovered that the RPS reset time delay relays were not wired into the reset circuit properly.

Although time delay relays were installed, their contacts which interrupt the reset logic were being bypassed by permanent plant wiring. The design change implementing the addition of a time delay was installed in August,1970, prior to fuel loading. The time delay logic scheme appears on plant control schematic drawings.

However, the plant wiring was found in conformance with wiring termination drawings. That wiring caused the time delay relay contacts to be bypassed.

At 1610 hours0.0186 days <br />0.447 hours <br />0.00266 weeks <br />6.12605e-4 months <br />, 7/16, the licensee had processed a design change and tested the proper operation of the 17 second time delay.

b.

The licensee attempted to measure the drain time of the scram discharge volume and the instrument volume by measuring the time from RPS reset to the time that the lowest level switch (3 gallon) of the instrument volume cleared.

It was concluded that clearing of the instrument volume level switches was an erroneous indication of successfully draining the

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scram discharge volume. Trapped air in the top of the instrument volume blew down the instrument volume level in 22 seconds.

Following that, the instrument volume drained faster than the scram discharge

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i volume could fill the instrument volume.

Following the second RPS actuation, the low point of the south scram discharge volume drained after 11 minutes, 8 seconds. This was measured by ultrasonic testing.

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c.

The vent from the north scram discharge volume was a closed piping run back to the drain line from the instrument volume. The licensee re-directed the vent to an open drain on 7/22. The south scram discharge volume was found to drain to an open drain.

d.

The licensee was unable to electronically time the maximum rod insertion time. Following the first RPS actuation, three rods stopped at position 02, and following the second actuation, two rods stopped at position 02 and one indicated beyond position 00.

In both cases, these final rod positions prevented picking up the Reactor Manual Control System All Rods In Relay.

The resident inspector conducted a walk-down of the SDV to determine that the drain slope was correct over the entire piping run, no loop seals were present, potential problems caused by system connections were not evident and drawings accurately reflected system features.

As noted in item c, above, the vent from the north scram discharge volume had been a closed pipe. This has been changed.

There were no unacceptable conditions identified.

11.

Review of Periodic and Special Reports Upon receipt, periodic and special reports submitted by the licensee pursuant to Technical Specification 6.9.1 and 6.9.2 and Environmental Technical Specification 5.6.1 were reviewed by the inspector. This review included the following considerations:

the report includes the information required to be reported by NRC requirements; test results and/or supporting information are consistent with design predictions and performance specifications; planned corrective action is adequate for resolution of identified problems; determination whether any information in the report should be classified as an abnormal occur-rence; and the validity of reported information. Within the scope of the above, the following periodic reports were reviewed by the inspector:

Monthly Operatiny Reports Unit 1 and 2, June,1980.

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12.

Exit Interview At periodic intervals during the course of the inspection, meetings were held with senior facility management to discuss the inspection scope and findings.

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