IR 05000277/1989082

Insp Repts 50-277/89-82 & 50-278/89-82 on 891113-17. Unresolved Item Noted Re Plant Operations Review Committee Chairman Completing Plant Managers Approval of Meeting Items.Major Areas Inspected:Readiness for Unit 3 Restart

ML20006F330
Person / Time
Site:	Peach Bottom
Issue date:	02/21/1990
From:	Doerflein L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20006F327	List: IR 05000277/1989082 ML20006F325
References
50-277-89-82, 50-278-89-82, NUDOCS 9002270401
Download: ML20006F330 (24)

Text

h

.

.

U.S. NUCLEAR REGULATORY COMMISSION REGION I INSPECTION REPORT i

Docket / Report No.

50-277/89-82 License No. DPR-44 50-278/89-82 DPR-56

'

Licensee:

Philadelphia Electric Company Correspondence Control Desk l

P.O. Box.7520

Philadelphia, Pennsylvania 19101

~

Facility Name:

Peach Bottom Atomic Power Station Units 2 and 3

'

!

Inspection At:

Delta, Pennsylvania

-

Dates:

November 13 - November 17, 1989

't Inspectors:

L. T. Doerflein, Chief, Reactor Projects Section 2B

P. D. Kaufman, Project Engineer J. H. Williams, Senior Operations Engineer

'

G. Y.

uh, NRR Project Manager

'

Approved By :

Al!90

.

L. T. Deerfle

, Chief Date Reactor Proje s Section 2B

. Summary:

'

t Areas Inspected:

Specia' aestart team inspection of. accessible portions of Unit 2 and 3, operations activities, modifications, maintenance, surveillances andmanagementoversight.

The purpose of the inspection was.to determine the e

-

licensee s readiness to restart Unit 3 following an extended outage.

Results:

- Overall, the team concluded that the plant personnel and equipment were either ready' for restart or the necessary processes, tracking systems, and management

'

oversight were in place to ensure tt.e remaining items were resolved prior to

.

restart,

,

The team noted that management was actively involved and provided adequate oversight on ensuring the facility's readiness for restart (Section 6.1).

'

).

The performance of the Plant Operations Review Committee (PORC) was good; however, an unresolved issue was-identified concerning the PORC chairman

,

completing the Plant Manager's approval of PORC meeting items (Section 6.2).

O g22 k hk)

[

a

,

,

+--..-a-

-

-

,,

N,

,

,';

..

-

I

,

l.icensed operators were professional and demonstrated a good understanding of

plant system status and evolutions (Section 2.2).

i Continued management attention is necessary to reduce the equipment problems in the control room (Section 4.2).

!

!

The corrective actions for removing Equipment Trouble Tags were not adequate-(Section 7.2).

'

.!

,

i

.,

>

i

!

>

r

-

N f

h

.

l s

'

l

,

L-

) ~-

.,'

..,

-

q; e*

!

,

i TABLE _OF CONTENTS

!

_P. ate

>

e-1.0 Introduction.................................................

1.1 Background...............................................

1.2 Inspection Scope.........................................

'

2.0 Operations Activities........................................

2.1 Organization and Staffing................................

2.2 Control Room Professionalism.............................

2.3 Shift Observations.......................................

2.4 ESF Walkdowns/ Safety System Status Verification..........

2. 5 S u mm a ry..................................................

3.0 Modifications................................................

3.1 Management Control and 0versight.........................

3.2 Review of Modification Packages..........................

3.3 Operator Training........................................

3. 4 S u mm a ry..................................................

4.0 Maintenance..................................................

4.1 Outstanding Work Request Rev1ew..........................

4.2 Equipment Performance Review.............................

4.3 Work Observation.........................................

4. 4 S u m m a ry..................................................

5.0 Surve111ance..................................................

5.1 Observation of Surve111ances.............................

5.2 Surveillance Tracking Program............................

5. 3 S u mm a ry..................................................

6.0 Management 0versight.........................................

Ib 6.1 Outage Meetings and Self-Assessment Review...............

6.2 Plant Operations Review Committee Activities.............

6.3 Quality Assurance Activities.............................

6. 4 S u mm a ry..................................................

7.0 Housekeeping....................

..........................

7.1 Facility tours...........................................

7. 2 U n i t 3 D rywe l l T o u r......................................

.

8.0 Allegation Fo11owup..........................................

9.0 Unresolved Item..............................................

10.0 Exit Meeting.................................................

=

p

')

,a.

'

l.

i e

',

4 1.0 INTRODUCTION

[

1.1 ' Background

In March 1987 the NRC issued an Order te the Philadelphia Electric

!

L Company (PECo) suspending operation of Peach Bottom Atomic Power Station (PEAPS) Units 2 and 3.

The Shutdown Order also required

'

'

!

that, before proposing operation of either unit, PECo develop a comprehensive plan to assure the facility would be operated safely

'

and comply with all requirements, i

In October 1988, the NRC accepted PECo's proposed " Plan for Restart

of Peach Bottom Atomic Power Station." Following satisfactory NRC

!

assessmet of PECo's performance and implementation of this plan, the requirements of the Order were modified in April 1989, to permit

'

startup and operation of Unit 2 up to 35% power.

The requirements of the Order were modified again in Jt.ne and July to permit operation of Unit 2 at 70% and full power, respectively, following satisfactory l

PECo and NRC assessments (in accordance with the Restart Power Testing Program) of plant personnel and equipment performance.

In

i October 1989, the NRC determined pEco management continued to be.

L aggressive in problem resolution and was directly involved in assuring i

i nuclear safety. Accordingly,.the NRC terminated the requirements of l

the Order, thus permitting operation of both units at full power.

The purpose of this inspection, conducted November 13-17, 1989, was to determine the readiness of the plant personnel and equipment to suppors the Unit 3 startup from the extended outage. During the inspection, Unit 2 operated at or near full power the entire period and Unit 3 remained in cold shutdown, making preparations for startup.

1.2 Inspection Scope r

The inspection focused on the management oversight of ongoing

-,

l activities and the administrative controls in place to ensure that systems, equipment and personnel were ready for restarting Unit 3 following an extended outage. The inspection examined the areas of

.

'

operations, surveillance testing, maintenance and modifications, and

.

consisted of selective examination of procedures and records,

,

interviews with personnel, and observations by the inspectors.

'

2.0 OPERATIONSACTIVITIES(71707,71710,71715,42700)

'

2.1' Organization and Staffing The inspector reviewed the licensed operator staffing and status of conditional licenses. The licensee has a six shift rotation.

Each shif t has a shif t manager, who holds a senior reactor operator (SRO)

license, and at least two other SR0s and three reactor operators (R0s).

.

[

,

p y

,.

e Two shifts have a fourth SRO and three shifts have a fourth KO.

Only three of the SR0s had conditional licenses and it was expected that the requirements for a " bet" licente would be completed in th.

near futura. Two of these SR0; were the fourth SRO in a shift.

The inspector found the licensee's 1teensed operator staffing exceeded the staffing requirements of the Technical Specifications and had no further questions.

2.2 Control Room Professionalism The inspector. observed operations conducted in the control room during numerous shifts. The control room activities were assessed to ensure that the conduct of duty by licensed operations personnel was professional and consistent with safe plant onerhtion.

Regulatory Guide 1.114 " Guidance on Being an Operator at the Controls of a Nuclear Power Plant," and the Operations Department Manual were used c:, reference standards during the control room observations.

Section 2 of the Operations Manual specifies how the conduct of operations is to be performed at Peach Bottom.

The inspector verified that copies of the manual were available in the control room and that operations personnel were aware of their defined day-to-day duties and responsibilities.

Intery!ews with operators revealed that they were knowledgeable of the requirements described in the Operations Manual.

The unit operators demonstrated an awareness of plant status and equipment out of service, and the ability to use procedures as required. The operators were not overburdened with entraneous activities wnich l

I l

would distract them from licensed duties.

The inspector observed timely operator response to off normi alarms. The operators properly utilized procedures and drawings to diagnose problems.

j The communication and interaction practicos used by the operating staff and other departments were routinely performed effectively.

Several operators displayed a sense of unit owner. hip and comend and control of unit activities.

The unit operators were attentive.

W alert, and responsive throughout their shift assignments, f

Overall, the Peach Bottom operating staff was knowledgeable of i

i their shift duties and professional in the execution of dayete-day

)-

facility operations. The operators routinely monitored control

-

room panels to determine equipment and plant status.

The attitudes

of the operators are appropriately focused on nuclear safety and i

i their morale is good. The inspector concludea that the opersting staff is adequately prepared and ready for Unit 3 startup a.ad dual unit power operations.

t

i 1,

f k.

.

,

L

h 2.3 Shift Observations The scope of this review was to witness and monitor the licensee's implementation of applicable operating and administrative procedures.

Particular emphasis was placed on the licensee's administrative tracking systems for completion and closeout of operational activities to assure Unit 3 readiness for restart.

.

The licensee's restart power ascension testing activities for Unit 3 L

were also reviewed to verify that surveillances which could not be performed without sufficient steam pressure were adequately integrated into the power ascension testing schedule. The inspector determined that the required Technical Specification surveillances requiring steam pressure, such as those for the High Pressure Coolant Injection

,

(HPCI) and Reactor Core Isolation Cooling systems, were appropriately denoted on the power ascension testing greph.

Included on the graph were specific holdpoints for licensee management assessments. The required holdpoints are as follows:

Startup Readiness Review; turbine roll review; 70 percent power operation review; and dual unit full power operation review.

The reference standards utilized during the control room observations and assessment were the Operations Manual; and procedures GP-2,

" Normal Plant Startup;" GP-110, " Reactor Protection System Refuel Mode Operation;" A-42, " Control of Temporary Plant Alterations;" and A-41, " Control of Safety Related Equipment." In addition, applicable

!

Operating, Surveillance, and Alarm procedures were referred to during observation of certain plant activities.

During this inspection Unit 2 operated at full power.

Unit 3 remained in the cold shutdown or refueling condition, preparing to enter the startup condition.

Pre-startup activities were focused on completion and closeout of certain design modifications, drywell closeout, review of plant logs, and review of surveillance tests.

The inspector conducted an evaluation of plant system operability status for the plant conditions to verify conformance with Technical Specifications (TSs).

The control room Operator's Equipment Statut File documents, Blocking Permits, Operating logs,

'

System Valve Chect;off Lists (COLs), an.d Temporary Plant Alterations -

(fPAs) were reviewed to determine system operability. The

,

inspector identified no unsafe conditions and found that the licenste was in compliance with TS requirements for the cold shutdown and refueirng conditions. The following Unit 3 systems

,

were verified to be operable during this inspection:

Secondary Containment

--

,

. _

-Standby tas Treatment System

--

J

!

-

,

I.

c h [a'

.k

!

,;

L

-!

6 i

L

!

!

!

Standby Liquid Control System

--

Control Rod Drive System

--

Emergency Service Water

{

i

--

Residual Heat Removal

'

L

--

High Pressure Service Water

'

--

'

The following operational logs and records were reviewed to assess the impact on Unit 3 startup and to verify that the applicable.

!

administrative procedures, guidelines, and controls are being adequately followed to ensure that system status is properly tracked prior to placing the mode switch to startup:

Temporary Plant Alterations (TPA) Log; Information Tag Log; Blocking Status

?

Computer Printout; System Valve Checkoff Lists (COL); Equipment

'

Trouble Tags (ETTs); Equipment Status Files; Unit 3 Operator Log; Limiting Condition for Operation (LCO) Log; and Annunciator

.

Mode Logs.

The inspector's evaluation of the logs and records indicate that

,

system status car, be accurately deteimined by utilizing all of the above documentation. No inacequacies were identified.

However, while conducting the ESF Walkdown a deficiency was found between a COL and a P&ID print (redlined) in the control room (Section 3.2).

t The inspector found that only one TPA would impact Unit 3 startup.

The TPA is adequately being tracked by the licensee.

The TPA involves defeating the main turbine trips to accommodate testing. The tracking method being und to track this TPA is by a blocking permit #3-87-91, which has beer riaced directly on the reactor mode switch. The permit has to be resolved prior to moving the reactor mode ;, witch to

!

Startup.

In addition, a Special Procedure (SP-623) has been issued-to cover the-TPA. GP-2 procedure requires review of all active

.

Special Procedures prior to startup. Any active blocking permits restricting unit startup are being effectively tracked and identified on a computer list. Of the 68 total active blocking permits approxi-mately 29 need to be closed out prior to Unit 3 Startup.

The inspector observed ongoing surveillances on both units, observea.

shift turnovers, and discussed current operating conditions with the operational staff. The inspector found that the shift turnovers were thorough and conducted in a professional manner.

Procedural t

adherence was evident during surveillance testing. The operators were knowledgeable of plant and equipment operational status.

The inspector concluded that items requiring closeout prior to startup are being adequately tracked and that the operational staff is ready to operate Unit 3 safely and in acccrdance with license requirements.

r

m i

h ;b

'

_.. =

2.4 ESFSystemy_alkdown/SafetySystemStatusVerification The "A" Core Spray Loop was walked down by the inspectors to verify

'

the system was properly aligned and would perform its required safety

.

function.

For the system walkdown the inspectors reviewed the following documents:

1)

Drawing M-362 Core Spray Cooling System 2)

SO 14.1.A-3 Core Spray System for Automatic or Manual Operation 3)

COL 14.1.A-3A Core Spray System Loop "A"

4)

COL 14A.I.A-3 Torus Water Cleanup and Level Control System During the system walkdown, the inspectors noted a discrepancy

'

between the valve check-off lists (VCOL) and the P&ID for the torus flush return isolation valves, HV-3-14A-39025 and HV-3-14A-39037.

The valves were shut as required by the VCOL; however, the drawing

'

indicated they were open.

This discrepancy existed on both Urits 2 and 3.

Based on discussions with the licensee, the inspector noted a formal mechanism does not exist to ensure drawings are updated when VCOLs are revised, which is what apparently happened in this case.

The licensee took action to update (red line) the deficient P& ids and, to prevent recurrence, indicated procedure A-14.3, " Request for

Orawing Changes," would be revised to ensure P& ids are looked at when VCOLs are revised.

The inspector also noted that the stay full system pressure was above that specified for normal system operation (150-175 psig vs

>

50-100 psig respectively). This was due to the core spray stay full flow controller not being set properly. When brought to the licensee's attention, the licensee hung an equipment trouble tag (ETT) on the valve controller and initiated a maintenance work request (MRF) to readjust the pressure setpoint. The inspectors also noted minor packing leaks on two drain valves for which the licensee took action to correct.

,

The inspectors determined that the deficiencies identified during the Core Spray System walkdown were minor in nature and would not affect system performance.

The inspector also determined that the licensee took prompt action to correct these deficiencies. The inspectors had no further questions or concerns regarding the system walkdown.

2.5 Summary i

In the area of control room activities, the licensee demonstrated i

that the programatic administrative controls were generally being i

properly implemented. Through onshift observations and discussions l

.

e w

.

s

-

I

• A '

=

,

with the operational staff, the inspectors concluded that the operators demonstrated a good understanding of plant system status and evolutions. The operators displayed a sense of unit ownership i

and the interaction with other departments was conducted in a professional business-like manner while maintaining good control over

,

plant systems. The licensed operator staffing is adequate for dual unit operation and the operator's morale is good.

The inspector concluded that the plant was being operated in a i

professional, competent, and safe manner, procedural adherence was

!

evident during control room observations.

The licensee's

,

operational staff is ready for Unit 3 startup and dual unit power t

operation.

3.0 MODIFICATIONS (37700, 37828)

,

3.1 Management Control and Oversight

<

The inspectors reviewed a sataple of the design changes and modifi-

'

cations implemented by the licensee during the current Unit 3 outage.

a The inspectors reviewed the adequacy of the following: management control of the modification process through the use of approved

,

procedures, safety analyses prepared by engineering groups and reviewed by the plant safety committee, post modification testing and the review and evaluation of test results prior to the modification i

being declared operable, operator training to include plant changes

'

that resulted from the implementation of the modifications, and

drawing control to reflect as-built plant conditions.

l Management control of the modification process was implemented through the use of administrative procedure A-14 " Plant Modifications,"

Revision 16. During the course of the inspection, Revision 17 was issued.

Procedure A-14 covered modification initiation, design, station review, implementation, testing, turnover to operations, and package closure. The inspectors reviewed three modification work packages and verified on a saniple basis that the steps outlined in A-14 were being followed ar.d tracked by the modification coordination i

group.

In the management oversight process related to the review of

outstanding modifications, the steps in A-14 leading to closure of a modification package were compiled in the form of a punch 11st. The

.

punchlists identified the action item, the responsible individual, his supervisor, and item status information.

These punch 11sts were (-

then reviewed on a line item basis by corporate and station management

,

during Unit 3 outage status meetings. The inspectors attended portions

)-

of the outage status meetings. The meetings were attended by corporate

.

and senior plant management and involved detailed discussions with wide participation by meeting attendees. The inspectors concluded that management control and oversight of the modification process was well implemented. At the time of inspection, 31 modifications scheduled

....

-

-

.

r

.

j..

4=

,

!

t

!

r for completion prior to restart remained to be closed. A review of i

the items left to be completed for these modifications indicated that

in the majority of cases all installation and testing work had been

'

completed and only. documentation updating remained. The inspectors discussed with licensee representatives implementation of the commit-i e

e'

ment tracking system for commitments made to the NRC and other agencies, as well as internal commitments. The inspectors verified on a sampling basis that commitments made to the NRC had been entered

,

into the modification database and were also being tracked.

,

At the scheduled startup of Unit 3, the inspectors noted that approximately 600 station modifications would be outstanding. The

inspectors discussed the process which determined which modifications

,

were required prior to Unit 3 startup, This process involved several

,

reviews of all modifications by station personnel and corporate

!

engineering, in conjunction with information obtained from the commitment tracking system.

The inspectors reviewed the station

,

modification coordination group's tracking of outstanding modifi-cations. This tracking process included a breakdown of the modifi-cations into those required prior to Unit 3 startup, those to be completed during the current Unit 2 operating cycle and prior to

startup from the next refueling outage for Unit 2 and Unit 3, and those designated for possible increased priority, possible cancel-lation or future scheduling, each with assignment to the appropriate work groups.

Also, part of the problem for the large number of i

outstanding modifications was due to a previous process weakness.

As of late 1988, a modification request was no longer considered to be a modification until it had been approved by the Site Modification Management Group.

PECo is currently working to fully implement its

.

Integrated Management Process, which involves a detailed consideration of a modification's expected benefits and risks.

In this vein,

PECo is working to reduce the number of outstanding modifications by reviewing and cancelling older modification requests and sending the rejected modification requests to the modification originator.

3.2 Review of Modification Packages Modification 1316 Modification 1316 provided a safety grade instrument gas system for a portion of the primary containment isolation valves. This removed

'

the need for bottled gas supplies which had previously been used for each of the valves and allows for improved gas supply systen leak rate testing and verification of adecutte system performance. A safety grade instrument gas system header was provided from the vapor space of the Containment Atmospheric Dilution nitrogen tank to a portion of the primary containment isolation valves.

These components included nine (per unit) purge and vent valves used in the Containment Atmosphere Control System, six valves in the Containment Atraospheric

. s, s

-,

,.-

,i.

?

!

!

}

!

Dilution System, and the inflatable seals between the disc and seat f

of several purge and vent butterfly valves.

The gas system header

!

also serviced two (per unit) Containment Atmospheric Dilution System

'

vent line control valves.

The modification also involved the addition of header pressure instrumentation to comply with Regulatory Guide 1.97, Revision 3, requirements.

I The inspector reviewed the associated safety evaluation and verified that nodification acceptance criteria were specified in related engineering documents.

During the time of inspection, the 11cersee

,

had attempted several modification acceptance tests and various changes to the modification, including the addition of a vent path for the pressure control valves and the replacement of the pressure l

control valves with another make and model.

The safety evaluation was revised to reflect the various changes.

A correction was identi-

'

fied and made by corporate engineering to the safety evaluation to account for a postulated failure of a pressure control valve in the open position.

The inspector noted the safety evaluation was also ccrrected at Revision 6 to discuss the related Technical Specifications

change as discussed in a November 6, 1985 letter to J. Stolz, NRC, l

from S. Daltroff, PECo.

The NRC will conduct a further review of the safety analyses for the safety grade instrument gas system as part of

its review of the related proposed Technical Specifications change.

At the end of the inspection, the licensee was continuing with

.

hardware changes for Modification 1316.

.

Modification 2106 Modification 2106 involved the replacement of portions of the Emergency Service Water (ESW) system piping for Unit 3 incitMing the ESW torus room ring header and branch piping to various core standby cooling

!

system room coolers and related system changes. This modification addressed flow balancing, through-wall pitting corrosion, and thin

-

walled piping problems experienced in the ESW system.

The inspector reviewed Revision 1 of the associated safety evaluation and verified that the Plant Operations Review Committee (PORC) had approved the evaluation. A modification team, consisting of representatives from various groups, including corporate engineering, operations, health

>

physics, modification construction, and the architect engineer, were responsible for the implementation of the changes. The associated engineering work letter, dated October 13, 1989, clearly specified the modification testing acceptance criteria. The testing included a hydrostatic test and the successful completion of surveillance test

)

procedure ST 21.5-3A, "ESW Flow Test Through ECCS Room Coolers, RHR Seal Coolers, and Core Spray Motor Oil Coolers - Unit 3."

Turnover to operations occurred on October 14, 1989, and the modification training letter was distributed to operations support and subsequently incorporated in reading package RE 89-14B.

The modification training letter described the modification and its effect on operations. The P

l

-[a-

?

'

!

t'

modification acceptance test was completed on August 24, 1989, which resulted in low flow rates to the core spray pump motor oil coolers.

The as-measured flow rates were evaluated per an engineering work request, and the evaluation was reviewed by the Plant Operations

'

Review Committee. The inspectors verified that the surveillance

'

procedure, ST 21.5-3A, was revised to document the revised acceptance criterie. for the core spray pump motor oil coolers. The inspectors

verified that control room drawing M-315 affected by the pipe replace-

!

'

ments and associated system changes reflected the completion of

)

Modification 2106.

,

Modification 5187 Modification 5187 added fuses to the Automatic.Depressurization System (ADS) bellows leakage detection circuitry to provide electrical isolation between the non qualified pressure switches and the safety

,

grade power supply.

This isolation provided protection against

.

potential loss of supply voltage to the associated main steam relief valves. The safety evaluation, dated October 24, 1989, addressed the fact that the fuses would be dedicated for a Class IE mild environment

,

and noted the review of various Updated Final Safety Analysis Report

,

sections.

The safety evaluation was approved by the PORC on October

'

26, 1989.

The modification testing acceptance criteria were specified in the associated engineering work letter. The inspector verified

that the modification acceptance test checked for continuity of the circuitry and for operation of the ADS bellows pressure switch alarm in accordance with the engineering work letter.

The inspector noted that drawing M-1-S-52, which was affected by this modification, was not updated in the control room and was at the.. time of the inspection in the as-built drawing process. Per licensee

,

procedures, this drawing was required to be updated W hin 60 days of receipt of documentation that the modification was ;mplete or within 15 days after plant restart. Neither of these due (fates had lapsed at the time of inspection.

In discussions with 11:ensee represen-tatives, the inspector understood that a Performance Improvement Program recommendation to shorten the as-built drawing process has been made.

In the interim, PEco has in place controls specified in administrative procedure A-6, " Drawing Control," Revisicn 16, which required the use of controlled drawings updated ner tho Drawing Change Document Tracking System which include those facility changes documented in drawing change documents not reflected in the as-built drawings.

.

-

3.3 Operator Training The inspectors reviewed the operator training provided for the three modifications discussed above, as well as for several other modifi-cations. As required by A-14, a modification training letter was

I.

l

.

b

^ ^ ^

.

-

.

p ix

.,

d-w

.

.,

,

.

prepared for Modificatfans 2106 and 5187 and transmitted to the

'

Operations Support group, The inspector noted that status reports for Modification 1316, which was undergoing hardware changes at the time of the inspection, were provided to shift personnel. The inspector verified that these modification training letters were incorporated into required reading packages for the licensed operators, as appropriate. Operations Support determined that the modification training letter for Modification 5187 did not need to be. included in a reading package.

This was based on the determination that the changes to the pressure switch circuitry were reflected in the operator's aid affixed to the circuit panel door, and on the minimal impact the modification had on operations.

In discussions with operations support personnel, the inspector understood that approp-

,

'

riate portions of the training letter were provided to non-licensed operators.

The modification training letters were checked by operations by review of the modification package to verify that appropriate information regarding the modification was included. The inspector verified on a sampling basis that the required reading packages were being signed by on-shift personnel to document their review.. In addition to the distribution and tracking of the required reading packages, operation support personnel issued overdue required reading assignment memos to shift management based on its review of each shift's signoff sheet completion status.

3.4 Summary The inspectors reviewed Modification 2106 on ESW piping replacement, 1316 on a safety grade gas supply system,,and 5187 on the ADS bellow pressure switch fuses, as well as managemert control and oversight of

.the modification process. The inspection team concluded that adminis-

'

trative control of the process per A-14 was being satisfactorily implemented, operator training was being well controlled, and that

'

the associated safety evaluations and modification acceptance testing were adequate.

The safety analysis for Modification 1316 will be further reviewed as part of the NRC's review of the related Technical Specification change.

The inspectors found the modification accep-tance testing to be adequate for the modifications reviewed.

The team

'

found that management oversight of the outstanding modifications for restart of Unit 3 appeared to be thorough and comprehensive through the use of detailed punchlists, tracking of commitments, and station p

management meetings.

4.0 MAINTENANCE (62700,62704,62705)

The team reviewed this area to determine if components, systems, and structures were being maintained in a condition to support Unit 3 startup and continued power operation. The effectiveness of the existing main-tenance program was determined by looking at performance in the following areas: management involvement, maintenance back log and significance, l

I

{

l i

I

'

,

s[ *

,

!.

,

f

L,.

trends, on going work, work to be done before startup, and whether

'

components were being maintained at a level of reliability commensurate i:

with their importance to safety.

Plant walkdowns were conducted to observe overall plant and equipment material condition and on going maintenance activities. The condition of valves, pumps, motors, piping,

< ~

batteries, electrical equipment, tegged equipment, labeling and annun-ciators was examined.

l 4.1 Outstanding Work Request Review The team reviewed four special computer generated reports prepared by the licensee which broke down maintenance work into the following categories:

o.

Report #1 --

Maintenance Outage Work:

a listing of 40 jobs to be completed before startup.

Report #2 --

I&C Outage Work:

a listing of 109 jobs to be completed by I&C before startup.

Report #3 --

Non Outage Corrective Maintenance (CM) Backlog Report:

a listing of 761 jobs that do not require an outage and are not considered necessary to complete before startup.

Report #4 --

Outage CM Tasks not in this outage:

a listing of 179 jobs that require an outage but will not be done before startup.

Each job was~ represented by a Maintenance Request Form (MRF) which has seven sections representing various stages of job completion.

The MRFs listed in these reports could be at any one of the first six stages of completion.

During this review, the inspectors focused on identifying maintenance work that the team believed should be completed before startup and was not categorized as such by PECo.

Factors considered in making this determination included Technical Specification requirements, personnel safety and hazards, ALARA and environmental conditions to which the equipment is exposed.

Followup was required on about 60 items that appeared to need more attention than was given by the licensee.

In most cases it was found that the licensee had given y

these jobs the necessary priority. A number of the deficiencies

/

identified on the MRFs included conditions related to moisture it: trusion and other undesirable environmental impacts. These were adequately considered by the licensee.

The four items described below required a more complete examination to conclude that no

'

significant problem existed, a

K~

~

,

'

a

'

.

[. go -

-

.

p I4

.c l

!

f During a Regulatory Guide 1.97 walkdown, the licensee identified jumper wires on Panel 3AC065 which were not the specified environmen-tally qualified wires. MRFs (8909043, 8909044) were initiated on

June 26, 1989, to replace the jumpers; however, the work was not done i

.and on November 10, 1989 the licensee prepared an analyses to justify use of the existing wires until the next refueling outage rather than j

1mpact startup activities. Based on material identification,

{

'

similarity to tested wires and existing qualification reports, the

,

licensee concluded the existing jumpers were qualified as-is and n.ay j

<

'

be used until restart from the next refueling outage. After review

-

of the licensee's justification, the inspector had no further questions.

]

The team noted several MRFs dealing with valves not meeting their I

individual valve leakage rates and questioned the basis for not repairing these valves before startup. The valves in question were:

"

Valve Leakage Leakage Criteria SV-3671G 125 cc/ min 100 cc/ min SV-5948B 925 cc/ min 500 cc/ min

'

A0-9098B 2.5 ml/ min 2 ml/ min The team found that PORC had approved the delay of work on November

2, 1989 at Meeting 89-252. The delay is until the next refuel outage and was ascribed to replacement parts not being available.

The inspector noted that the current 10 CFR 50 Appendix J Local Leak Rate

Test (LLRT) running total was less than required value of 0.6 La and had no further questions at this time.

MRFs 8909448 and 8909482 deal with secondary containment isolation

valves which do not meet their leakage acceptance criteria as i

stated in ST30.202, LLRT, "LLRT Refuel Floor Isolation Valves -

i Supply Valves A0-30452 and A0-30453, Exhaust Valves A0-30461 and A0-30462." The acceptance criteria was 9000 cc/ min and the leakage was stated to be about 10 cfm (283,200 cc/ min).

ST30.202 is a new test procedure (revised from a Routine Test which had no leakage acceptance criteria) and there was uncertainty about the approp-

'

riateness of the acceptance criteria.

However, the Unit 2 isolation valves met the 9000 cc/ min leakage criteria. The inspectors noted the valves will shut on an isolation signal and that the licensee has successfully tested secondary containment integrity as required by Technical Specifications.

Discussions were held with the license over the need for the test, the acceptance criteria and the need to

'

maintain safety technical equipment in satisfactory condition. The licensee acknowledged the team's comments and is pursuing resolution of these issues.

Since the licensee has successfully tested the secondary containment in accordance with the Technical Specifications, the inspectors had further questions on this issue prior to startup.

m

l}

F L

I

.

>

,

L j

On August 19, 1989 ST21.5-3A, "ESW Flow Test Through ECCS Room Coolers, RHR Seal Coolers, and Core Spray Motor 011 Coolers - U/3,"

'

Revision 1, was conducted as part of the MAT for MOD 2106. The test indicated that flow through all 4 of the Core Spray Pump Motor 011 i

Coolers was inadequate. The minimum flow rate specified by the vendor is 4 gpm and the measured flow rates were as low as 2.5 gpm.

j Pressure drop through the heat exchangers was measured as 15-20 psid which is much larger than the 5 psid expected at 4-6 gpm. An Engineering Work Request (EWR) was written on August 24, 1989,

)

describing the flow problem and MRFs 89066698-701 were written the i

next day. On August 28, 1989 full flow performance data was taken for core spray pump "B" to allow calculations of bearing oil tem-j perature.

Engineering responded to the EWR on August 30, 1989

indicating Bechtel had concluded that bearing oil temperature would a

not exceed 125 degrees Fahrenheit (F) at 2 gpm. This is less than j

the 150 degrees F raximum specified by the vendor. The licensee

!

contacted the vendor, who acknowledged that flow less than 4 gpm may

'

be acceptable but could not quantify the flows without further o' '

calculation.

PORC revised the acceptance criteria on August 31, 1989 at Meeting.89-189. A new ST21.5-3A was issued on September 13, 1989,

~,

however the quarterly test, ST21.5-3 had not yet been revised.

The inspector noted the licensee has ordered new heat exchangers which have a 10 month lead time.

Based on the full flow performance data

'

test and PORC review, the team concluded this issue was adequate for startup.

!

Subsequent to this inspection, the team obtained a copy of the

!

Bechtel calculation used as the basis for the change in flow acceptance

'

criteria for review.

It was dated October 2, 1989.

The inspector

'

expressed concern with the apparent non-conservative assumption of i

constant heat transfer with reduced flow when the flow reduction is -

due to clogging of the tubes. Also, it was not evident that the

,

worst case was considered in the calculation, i.e. heat loads in the coolant and room.

In addition, it does not appear that the long term

'

operability of the motor oil coolers was considered.

For example the crud material could work in a manner that further restricts flow or tubes could leak due to wall thinning. The adequacy of the calcu-

'

lations for the revised flow acceptance criteria will be reviewed in

!

more detail in Inspection Report No. 50-277/89-26; 50-278/89-26.

4.2 Equipment Performance Review The inspectors looked at equipment problems as identified by Equipment f

Trouble Tags (ETTs) in the Control Room for both units.

Equipment problems were reviewed for the impact on system operability, plant operation, the total number of problems and trends in the number of eql.ipment problems.

Discussions were held with licensee management on these issues.

During a control room inspection, the inspectors noted 77 identified problems on Unit 2 and Common and 31 identified problems l'or Unit 3.

Trends in equipment problems were examined from data in TitIPOD and as reported by the facility using INPO criteria.

>

,$

>

+

Z D

.

~

!

i

,

Differences in criteria for counting equipment problems causes discrepancies in the number of deficiencies counted.

From historical data Unit 2 (and Common) appears to have about 80 equipment problems

and Unit 3 has about 50. These numbers do not appear to t'e decreasing

'

in time.

The team expressed concern that the number of equip:nent l

problems for Unit 3 would probably increase during startup in the

same manner as occurred on Unit 2.

The licensee's stated goal is to reduce the number of out of service control room instruments to nine before startup of Unit 3.

The present count is.about 25 (INPO

criteria). With this number (9) and the regulatory requirements for i

startup, there should be no impact on safety system operability.

However, the number of equipment problems will still be large and many of them require sn extended outage to repair which means the deficiency will rema c for some time. The operators will be deprived of equipment and information used to operate the plant, and this is not desirable.

Licensee management is aware, appears concerned about the problem, and has programs to reduce the amount of tne out-of-service equipment.

-

Management attention and oversight is evident from TRIPOD reports

and Station Review Meetings.

Equipment required for startup is given

'

priority attention.

However, the total number of ETTs in the control room does not appear to be decreasing. The team could not conclude that a specific safety concern existed, however, it was concluded that a significant reduction in the number of equipment problems would

,

enhance operations and safety.

4.3 Work Observation During the time the team was on site, very little maintenance activity was on going in the plant.

The team observed HCU decontamination and painting of equipment. Both activities appeared to have adequate planning.

Plant equipment was observed to be maintained in a clean

condition.

'

4.4 Summary Maintenance of equipment is adequate for startup, however a few cases were noted where safety related equipment was not being maintained to the design specifications. While management appears to be concerned over 'the ETTs in the control' room, the historical

data indicates the number is not decreasing.

5.0 SURVEILLANCE (61726, 42700)

5.1 Observation of Surve111ances

The inspector reviewed the surveillance testing program administrative controls and observed performance of surveillances to verify proper program implementation.

.

,

_

pFJ

>

t Tho surveillance testing program is controlled end implemented through

[

administrative procedures A-43, " Surveillance Testing System;" A-47,

" Surveillance Test Procedures;" and guideline AG-49, " Surveillance Guideline." The inspector utilized these documents and ANSI N18.7-1972, " Administrative Controls for Nuclear Power Plants," as

,-"

reference standards during his review.

The Surveillance Test Coordinator (STC) is responsible for scheduling and tracking all surveillance tests.

The STC utilizes a computerized r

system called Surveillance Test and Records System (STARS) to accom-L plish this task. The inspector witnessed portions of surveillance testing activities being performed on both Unit 2 and Unit 3.

Most of the surveillances being conducted oa Unit 3 were Instrument and Control (I&C) surveillances. Portions of the following I&C surveil-lances were observed: ST6.8-3, "Feedwater Calibration;" SI3f t-1-5271-ADCM, " Calibration Check of Turbine Stop Valve Position Switches; "

and SI 3N-60A-APRM, "APRM Calibration / Functional." The inspector also observed Unit 2 Core Spray surveillance test ST 6.7.1, " Daily Core Spray 'B' System & Cooler Operability." The Core Spray test was being performed because the "A" Core Spray pump was inoperable due to a problem with a cell switch in a breaker. The inspector verified.

that the appropriate LCO was entered into the unit's LCO Log book.

During the testing, the inspector observed good communications and interaction between the unit operators, auxiliary operators and I&C technicians. The operators maintained complete control over activities being conducted on their respective units. While conducting the Core Spray surveillance the operator followed the procedure step by step.

The. test was satisfactorily performed.

Prior to the I&C technicians conducting their surveillances they would thoroughly brief the unit operator with an overview of the scope of testing, what equipment response would be, which alarms to expect, and what verifications were required.

No unacceptable conditions were identified.

The inspector concluded that surveillance activities were performed in accordance with procedural requirements.

5.2 Surveillance Tracking Program The inspector reviewed the licensee's surveillance tracking process to ensure the required Technical Specification (TS) surveillance tests were complete or properly tracked and controlled prior to placing the reactor mode switch to startup.

Licensee Procedure A-43, " Surveillance Testing System," and the Technical Specifications were used as reference standards during the inspectio g

,

E i

j

,{

d

'

\\

-l

,

The master surveillance test schedule is compiled from the computerized t

,

STARS program.

The STARS program is also utilized to produce special

!

surveillance tracking reports. A special report, which denotes exactly the remaining surveillance tests require completion prior to L

placino the reactor mode switch to startup, is presently issued to all responsible supervisors of the various organizational groups on

)

t.

daily basis.

j Daily planning meetings provide the control of scheduled operational activities and are utilized to coordinate support from the various s.

station groups.

Review of the outstanding surveillance tests (STs) and routine tests (RTs) required to be completed before placing the mode switch into L

startup revealed that 40 STs/RTs remain outstanding as of November 15,

,

1980 The STARS tracking program is sufficient to ensure the ST/RT program is carried out effectively.

'

The inspector reviewed several completed STs to verify that STs wer9 processed and tracked in accordance with procedural requirements.

No

!

inadequacies were noted.

The inspector concluded that the surveillance testing tracking method was acceptable to support the Unit 3 startup.

,

5.3 Summary l

Overall, for the area of control over Technical Specification surveillance testing activities, the licensee demonstrated that the programmatic controls were being implemented properly.

The personnel performing the surveillance testing were following the

. procedures, All surveillance tests required to be completed prior t

to Unit 3 startup were being adequately tracked, 6.0 MANAGEMENT OVERSIGHT (40500, 35502)

6.1 Outage Meetings and Self-Assessment Review The inspector attended several of the daily outage planning meetings to assess the licensee's process for determining the facility's readiness for restart. At the meetings, the inspector noted the licensee had developed detailed printouts to track the status of items to be completed prior to restart including maintenance work requests (MRFs), surveillance tests, nonconformance reports (NCRs),

licensee event reports, valve checkoff lists, and modifications.

For

,

each modification, the licensee had punchlists to pinpoint exactly

'

what was lef t to complete including redline drawings, disposition NCR, turnover to operations, perform modification acceptance tests (MAT), obtain PORC review of the MAT results, complete operational

,

verification forms (OVFs), revise procedures, and complete the

,.

.

[

l (Y.

/

,

i L

modification package. These various printouts were discussed at the

,

meetings to identify potential problems or delays, request assistance from nther departments, coordinate activities, and estimate completion times. The inspector found that the printouts and meeting discussions

provided licensee management with excellent system / equipment status.

The inspector acted senior plant management, including the site vice

,

president, attended the outage meetings. Management was actively involved through qurestions and direction. The inspector found the l

focus was always on safety not schedule.

The inspector found the

outage meetings to be valuable in providing coordination and communication between departments and ensured effective management oversight of restart activities / preparations.

In addition to the schedule / status type outage meetings, the inspector also attended the station self-assessment review on November 9, 1989.

The meeting was attended by senior plant and corporate management.

During this meeting, each organization presented a self-assessment of

,

its personnel and hardware readiness for restart.

Each presentation

was usually follwed by quessions from the other managers on part'icular

,

issues.

In general, the inspector found the self-assessments to be critical and an indication of the licensee's positive attitude in ensuring Unit 3's readiness for restart.

6.2 Plant Operations Review Committee Activities The inspectors attended portions of Plant Operations Review Committee (PORC) meetings to assess its effectiveness.

,.

The inspectors noted PORC met daily to review activities in support

'

,

of Unit 3 restart.

Items reviewed during the observed meetings included various procedure changes, changes to modification acceptance

!

tests (MATS), and approval of MAT results.

In general, the inspectors i

observed an active participation and a critical, questioning attitude l

by PORC members in their review of meeting items.

The inspecturs

'

l noted PORC rejected procedure changes for lack of information or if the pre-PORC review and approval process was not followed. Also, the I

inspectors noted PORC would summon an individual with a particular expertise to clarify issues when necessary. Overall, the inspectors found the performance of PORC to be good. The inspectors also verified the Technical Specification requirements related to PORC

'

were met.

The inspectors also reviewed completed PORC meeting minutes.

The

- '

. inspectors noted that meeting minutes at Peach Bottom were prepared by the person presenting the review item and submitted to the PORC secretary upon completion of the presentation.

These minutes were reviewed by the PORC chairman and PORC secretary prior to publication L

of the meeting minutes. They were not reviewed prior to publication I

m

..

.

.

.

-..

-

,4--

,

,

bm

_ht

_

)

_,

@,.

-

,

ma

b[

,

-

by the other PORC members who attended the meeting. A review of a sampling of meeting minutes for the past year revealed brief written

discussions with little or no indication of comments or questions

.

raised in the PORC meeting. The. inspectors noted that tne lhiclear

'

Review Board, as part of its_ independent review of plant activities, has the responsibility for reviewing PORC meeting minutes, _as required by Technical Specification 6.5.2.7.

More detailed PORC meeting.

minutes would enhance this review. In addition, it was noted that the i

meetir.g minutes-included boiler plate language on page 2 which stated

.,

-

that the procedures reviewed by the PORC did not involve unreviewed safety questions. Th_is statement appeared to apply to all procedures and items discussed on subsequent pages of the meeting minutes. -These

.

observations _were discussed with licensee representatives, who stated i:

that-they would consider improvements as appropriate.

"

.The inspectors also noted thit on Exhibit AG-12-4, "PORC Review /

Approval Form," to Administrative Guideline AG-12, "PORC Administration,"

Revision _2, the PORC chairman in many cases also signed the Plant.

t Manager approval line.

The inspector discussed this with a PORC chairman and-noted this signature was apparently used for Plant Manager approval of those PORC reviewed items required by Technical Specification 6.5.1.7.

The inspector was also informed the Plant'

,

Manager had delegated this responsibility to alternates, normally the same individuals who serve as PORC chairmen, for the more routine

_.

' items. Given the advisory function of the PORC to the Plant Manager Ll on safety related matters per Technical Specification 6.5.1.1, the inspector ' questioned the appropriateness of the PORC chairman's

'

ccmpletion of'the Plant Manager's approval line._ This matter is

,,

L unresolved-pending further NRC review for acceptability (VW 9.77/

I 89-82-01). The inspector did note that.the Plant Manager was on

y distribution for all PORC meeting minutes.

L 6.3 _ Quality Assurance Activities

,

i The inspector reviewed Nuclear Quality Assurance (NQA) group activities to determine NQA involvement with restart preparations i

and the adequacy of the corrective action tracking process.

.

The inspector noted NQA had performed two surveillances related to restart, one on modifications and one on outage restoration.

The

. ;

latter. involved system walkdowns.looking for damaged components, missing supports, terminations not made, etc. The inspector also

\\

found the Technical Monitoring Section had an approved monthly

)

schedule of activities / areas to be monitored, many of which were related to restart preparations. These areas / activities included control room performance, control board walkdown, valve and switch lineups, _ locked valves, and temporary circuit alterations. The inspector noted each activity to be monitored had a_ guideline /

,

reference which provided specific guidance to the observer on l

!

attributes to look /cr. The inspector found the types of activities

'

F looked at to be gooo and concluded this level of NQA involvement -in restart preparations to be adequate.

!

l

'

dit.>!'

.

-

-

-

- - -

-

-

,.

,

y t

'

N jp *

p

'

k

,'

2.,

The licensee uses the Quality Assurance Trending and Tracking System

'

(QUATTS) to track corrective action requests -(CARS) and nonconformance -

reports (NCRs).

The system contains all relevant information on a

-;

finding including the description,. the system, who has responsibilty,

,

the. mode affected, the date issued, the response due date, the date

'

~NQA agrees with the. disposition, the date to implement corrective

<

,

action and the date NQA verifies completion of the corrective i

?

a c ti on'.

The_ inspector noted NQA prepares monthly status reports for management'use at the station review meetings detailing _the status,

(i.e. number opened, closed ~or overdue) of CARS and NCRs. Trending-1s also included on the age of overdue findings _.and the age _ of NCRs u

requiring site work. The inspector reviewed one of these reports, as

well as other QUATTs data printouts, and found the data useful and'

>

provided managemcnt with a good status of corrective actions.

The

.

inspector noted the system also tracked audit recommendations and if

,

not acted on or.if NQA does not accept their resolution, these will become re-audit items. The inspector had no.further comments or

_ questions in this area.

,

.

,

6.4 Summary-t Management was actively involved, and>had the necessary tracking

,

systems. in place, to ensure the facility was ready to restart.

Management focus was on safety not schedule..PORC performance was l good. ' Nuclear Quality Assurance involvement 1. restart activities and in corrective action tracking were adequate.

7.0-HOUSEKEEPING.(71707).

.

7,1 Facility Tours

-

The inspectors made numerous tours of access.ible portions of the

,

facility and found housekeeping and equipment material ecndition to

'

_

be-adequate. A few areas, such as the. core spray pump rooms, were-

very:well kept. One area that needed more' attention was the turbine

-

.

building lower level where the team noted a large: number of_55

gallon drums of low level radioactive waste and numerous boxes of

,

_ equipment' and material used during the outage. Apparently, this

'

area:was used as a s+.orage area prior to removing it from the process-buildings. 'The licensee acknowledged the teams comment and indicated there mere plans to move this material. The inspectors did not identify any problems or deficiencies during the tours which would prohibit startup.

'

'7.2 Unit 3 Drywell Tour

.

The inspectors conducted an inspection of the Unit 3 drywell prior to the licensee's final inspection and closecut.

The walkdown was

!

performed to verify the material condition of the drywell, as well as

'

equipment status prior to unit startup. The licensee performed their

,

final > drywell walkdown inspection the following day, November 15, 1989, t

SC lk.

L

'

'

_

l c

y y

3:

>

.

,

j,

,1

<

,

h

'

w The " reference standards used during this walkdown inspection-were

,

. Regulatory Guide 1.39, " Housekeeping Requirements for Water-Cooled

,

r NPPs," licensee procedures A-41, " Control of Safety Related Equipment,"

and A-30, " Plant Housekeeping Controls," and Checkoff Lists (COL)-

-

COL 7.1.A-3, 7.1.B-3, 7 1.C-3.

-i I

In general, the drywell was clean and f ree of material which would impact operation of safety equipment.

Equipment care _was evident in good cleanliness and preservation._ No valve leakage was identified.

-

-3 Environmental qualification connections appeared adequate.

'

The inspectors noted several Equipment Trouble Tags.(ETTs) were still

,

,

.in place. These ETTs were discussed with licensee management to. deter-

,

F mine why work had not been performed on these identified deficiencies prior._to the: licensee preparing for their drywell closeout inspection.

,

Licensee's review and evaluation of these ETT's found_that all required work activities. associated with these ETTs had already been performed and'the ETTs had not been properly removed upon work

<

completion.

Procedure A-26, " Corrective and Preventive Maintenance

Using Champs," requires that ETTs be removed and discarded by the_

'

,

. Lead Work Group after all work has been completed. ;The licensee's failure to remove ETTs after work activity completion was previously y'

identifiedbythelicenseeduringNuclear.QualityAssurance(NQA)

,

surveillance PS89-07.

Corrective Action Request CAR 9-07-01 was issued as a result of this NQA finding.

The CAR was closed based'on corrective actions taken by the maintenance and Instrument & Control departments. The corrective actions consisted of unit walkdowns to resolve any ETT: deficiencies and status all acceptable existing ETTs.

Since the NRC inspectors identified the same deficiency, it appears the. initial corrective action was not effective and the licensee is

'

pursuing additional corrective actions.

The inspectors did not identify any. conditions or problems during the drywell tour which would prevent startup.

-.

(

'

8.0 RI-89-A-0090 ALLEGATION FOLLOWUP (92701)

3.

On July 31, 1989, the NRC received an allegation concerning an individiial who was allowed site access at Peach Bottom Atomic Power Station ;cer allegedly being terminated for wrongful conduct. This J

information was turned over to PECo to evaluate and determine if a problem or weakness existed with the access control program.

In a

,

letter'to the NRC dated October 13, 1989, PEco indicated its investi-gation determined the allegation to be without substance.

<

r The inspector reviewed P.Eco's internal investigation report and noted the individual involved was layed off due to lack of work and not j

wrongful conduct.

He was subsequently reassigned when his services were needed. The licensee determined the alleger's office lock was g

.L '

broken to perform radiation surveys; however, the investigation found h

,

h a

'

k

'

'L

,

QTJ g

'

Npi

"

no evidence to support the alleger's accusation that articles had been stolen from his office. Also,~the inspector-noted the alleger was-terminated for cause.

The. inspector found the licensee's investigation to be thorough and had no further questions regarding this matter.

Based on his review, the. inspector concluded the allegation was unsubstantiated and considers it closed.-

,.

9.0 UNRESOLVED ITEM Unresolved items are matters about which m,

information is required

.

in order to ascertainwhether they are. acceptable, deviations or

]

violations. One unresolved item was identified and is discussed in

!

section 6.2.

10.0 EXIT INTERVIEW (30703)

During the inspection, the inspectors periodically informed _ license l

management of the preliminary inspection findings.. An exit meeting was' held on November 17 1989, with the site Vice President, Mr. D.

,

M. Smith,-and the plant manager, Mr. J. F. Franz, and members of

'their staffs to summarize the 1'spection scope.and findings.

No written-inspection-material was provided to licensee representatives during the inspection.

.i

,

!

q l

a l

I

-!

l

)

l

?

i

,

k it