IR 05000293/1980004
| ML19305D912 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 02/25/1980 |
| From: | Higgins J, Kehoe D, Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19305D910 | List: |
| References | |
| 50-293-80-04, 50-293-80-4, NUDOCS 8004160153 | |
| Download: ML19305D912 (14) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 50-293/80-04 Docket No. 50-293 DPR-35
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License No.
Priority Category Licensee:
Boston Edison Company 800 Boylston Street Boston, Massachusetts 02199 Facility Name: Pilgrim Nuclear Power Station Inspection at: Plymouth, Massachusetts Inspection conducted: January 28-31, 1980 Inspectors:
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D. Ke' fro'e, Re'ador Inspec of/
date si ned l
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J. Higgins, Resident Inspector, dhte signed Shoreham Nuclear Power Station date signed Approved by:
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T. T' Martial Chief Reaptc' r' Projects date signed Section #3, RO&NS Branch Insoection Summary:
Inspection on January 28-31, 1980 (Report No. 50-293/80-04)
Areas Inspected:
Routine, unannounced inspection by one regional based and one resident inspector of ISI implementation, Snubber Program, The Containment Integrated Leak Rate Test Procedure and Plant Tours.
The inspection involved 64 inspector-hours onsite by two NRC inspectors.
Results: No items of noncompliance were identified.
Region I Form 12 (Rev. April 77)
8004160/93 l
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DETAILS 1.
Persons Contacted R. Atkins, Station Electrical Engineer P. Cafarella, Performance Engineer F. Famulari, Engineer
- R. Machon, Assistant Station Manager
- C. Mathis, Methods Compliance and Training Group Leader
- P. McGuire, Station Manager
- T. McLoughlin, Plant Engineer R. Silva, Station Maintenance Engineer
- C. Vantrease, Chief Technical Engineer S. Wollman, Senior Performance Engineer Other plant employees were also interviewed.
- Denotes those present at the exit interview.
2.
Licensee Action on Previous Inspection Items
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(0 pen) Unresolved Item (293/77-26-04): The test, vent and drain lines between containment isolation valves are still not under administrative controls to ensure that the leakage barriers are in place.
The inspector discussed with the licensee's representatives various methods of meeting the intent of this position.
The licensee's representative stated that the controls would be finalized and in t
place by the end of the current outage.
This item remains open.
3.
Containment Integrated Leak Rate Test. (CILRT) Procedure
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a.
General
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The inspector reviewed the " Primary Containment Integrated l
Leak Rate Test" Procedure, PNPS 8.7.1.4A, Rev. I against the i
requirements of 10 CFR 50, Appendix J and ANSI N45.4 and against the most recent NRC positions concerning leak rate testing. With the exception of the below items the inspector had no further questions at this time.
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b.
Acceptance Criteria
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The procedure currently allows the test to pass using either the mass point or the total time method.
Because of inherent biases in the total time method of data analysis, the inspector informed the licensee's representative that the NRC will evaluate the success of the test using the mass point method.
Additionally, since determination of the leakage rate involves statistical analysis of acquired data, the inspector stated that the NRC's position is that the leak rate must meet the acceptance criteria at the 95% upper confidence level.
In summary:
LMP 0 95% UCL + X < 0.75 Lt, where LMP 0 95% UCL is the mass point leakage at the 95% upper confidence l evel,
Lt is the maximum allowable leakage at the reduced test pressure of 23 psig, and, K is a conservative correction factor including Type C additions for systems in operation
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Type C additions for systems not properly vented
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Corrections for sump, reactor vessel and torus level increases
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Since the procedures acceptance criteria do not correspond to the above, this item is unresolved and is designated iten no. (293/80-04-01 ).
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System Lineups The licensee's test procedure currently closes manual valves to contaimnent pressure transmitters on penetrations 25 and 46 for the CILRT. These valves are normally open and would remain open post-accident, therefore, their closure for the CILRT constitutes an artificial leakage barrier.
This item is considered unresolved pending revision of the procedure to leave the valves open and in conjunction with paragraph 3.b above, is designated item no.
(293/80-04-01).
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d.
Leakage Repairs The inspector discussed with the licensee's representatives the provisions of paragraph III.A.1.(a) of Appendix J regarding leakage repairs. The inspector stated that, if during the CILRT potentially excessive leakage paths are identified, then the leak may be isolated and the CILRT restarted provided:
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(1) The leak path is locally testable and is in fact tested both before and after repair; (2)
the pre-repair leakage is added to the CILRT results to obtain as found leakage; and (3)
the post-repair leakage is added to the CILRT results to obtain as left leakage.
The inspector further noted that such repairs must be care-fully controlled during the test to avoid invalidating test results. The licensee's representative acknowledged these comments.
e.
Test Failure Paragraph III.A.6.(b) of Appendix J states that if two con-secutive periodic Type A tests fail to meet the acceptance criteria then an accelerated testing schedule shall be implemented.
The inspector noted that the initial attempt of the 1976 Type A test at Pilgrim failed to meet the acceptance criteria and that the test scheduled for this outage constituted the second consecutive periodic test of Appendix J.
The licensee's representative acknowledged this comment.
4.
Local Leak Rate Testing (LLRT)
a.
Test Witness During the inspection the inspector witnessed the conduct of the Type B LLRT performed on the eight Gibbs Manways for the
The inspector reviewed pertinent procedures and instrument calibration records, observed the installation and operation of test equipment, witnessed the pressurization of the double 0-ring manways and taking of data, and observed radiological measures taken during the testing. With the exception of the below two items the inspector had no further comments.
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b.
Test Equipment The leak rate test equipment measures the air flow to the pressurized volume in order to detennine a leak rate out of that test volume.
An in-line flow transmitter measures the air flow.
The inspector noted that the test device had a single bypass valve around the flow transmitter, which was used during initial pressurization of the test volume.
Any leakage through this valve would bias the test results in a non-conservative direction.
The licensee's representative performed a test of this valve in the inspector's
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presence which showed no detectable leakage and stated that
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provisions would be made to either perform this test daily during use of the test device or to add a second valve and a vent in the bypass line to preclude bypass leakage.
This item is unresolved pending those permanent changes and is designated item no. (293/80-04-02).
c.
Calibrations
The licensee was unable to produce documentation during the
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inspection which would certify the traceability of the orifice
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flow transmitter to the National Bureau of Standards as required by the Pilgrim Quality Assurance Manual, paragraph 2.2.2.10.
This item is unresolved pending review of the appropriate documentation (item no. 293/80-04-3).
5.
I and E Bulletins The inspector reviewed I and E Bulletin 78-09, "BWR Drywell Leakage Paths Associated with Inadequate Drywell Closures", Pilgrim's response to this bulletin dated 8/3/78 and Proc. No. 3.M.4-3, " Removal and Installation of Drywell Head", Rev. 3.
The bulletin recommends torquing of head bolts or head to flange clearance readings to ensure reproducibly tight installations.
Pilgrim's current procedure and bulletin response do not include either of these but rather use an air impact wrench.
The inspector discussed methods of ensuring this method gave reproducibly tight head installations including impact wrench overhaul and torque capability certification prior to us.
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The inspector also noted that some of the items mentioned in the Bulletin response letter were not specifically addressed in the procedure.
For example, Procedure 3.M.4-3 currently does not document an inspection of the flange surface, the gasket grooves or the drywell head nuts and bolts nor does it call for a visual check of gaskets just prior to landing the head.
The licensee's representative stated that the above items would be addressed and included in the procedure, as appropriate, prior to drywell head installation.
This item is unresolved (Item No.
293/80-04-04.).
6.
Inservice Testing of Pumps and Valves a.
Documents Reviewed ASME Boiler and Pressure Vessel Code,Section XI, Subsection
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IWP, " Inservice Testing of Pumps in Nuclear Power Plants" (IWP)
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ASME Boiler and Pressure Vessel Code,Section XI, Subsection IWV, " Inservice Testing of Valves in Nuclear Power Plants" (IWV).
Letters BECo. to NRC dated 4/13/79 and 7/24/79 containing
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Pump and Valve Program Submittals.
Letter NRC to BECo. dated 8/15/79 containing interim
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approval of program and relief as requested.
Memos of BECo. and NRC summarizing meeting on 8/8/79 l
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through 8/10/79 concerning the Pump and Valve Testing i
Program.
Procedure No. 8.I.1, Rev. O, " Administration of ISI Pump
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and Valve Testing" Procedure No. 8.I.6, Rev.1, "HPCI System Pump and Valve
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Operability Surveillance".
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Procedure No. 8.I.7, Rev. O, "RBCCW System Pump and Valve
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Operability Surveillance".
Procedure No. 8.I.8, Rev. O, " Core Spray System Pump and
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Valve Operability Surveillance".
Procedure No. 8.I.10, Rev.1, " Salt Service Water System
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Pump and Valve Operability Surveillance".
b.
Scope The inspector verified that all pumps, identified in the licensee's program subnittal to the NRC, were tested by approved procedures.
For randomly selected valves, the inspector also verified that approved procedures were available for testing.
On a sampling basis the inspector reviewed procedures for conformance with the requirements of IWP and IWV of Section XI as modified by the approved program submittals to the NRC.
This review included the administrative control procedures, specific system test procedures, and test results documentation. With the exception of the items noted below the inspector had no further questions at this time.
c.
HPCI Pump Test
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Paragraph IWP-3100 of Subsection IWP requires that the pump test be conducted at a speed adjusted to the reference speed for pumps with variable speed drives.
Procedure 8.I.6 does not specify a reference speed and a review of test results revealed some tests run at 4,000 rpm ano one run at 3,900 rpm.
Paragraph IWP-3100 further specifies that the resistance of the system be varied until either the flow or pump differential. pressure equals the reference value.
Then, the other parameters are measured and compared with test acceptance criteria.
Procedure 8.I.6 specifies that resistance of the system be varied until both flow and differential pressure meet specified values.
This item is unresolved and is designated Item No. (293/80-04-05).
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d.
Core Spray Pump Test Procedure No. 8.I.8 requires throttling flow to 3,600 gpm as the fixed reference value specified in IWP-3100.
A review of completed test records revealed that some were run at 3660 and 3700 gpm.
This tends to invalidate the trend monitoring function of the
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test.
The inspector noted that there appeared to be some confusion among persons running the tests as to the intent of this test l
versus the intent of the Technical Specification required test to
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demonstrate full design flow.
The licensee's representative
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stated that training in this area would be conducted.
This item
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is unresolved pending completion of required training (293/80-04-06).
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e.
Inservice Test Quantities
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The licensee's procedures for pump testing do not currently contain the check of lubricant level or pressure required by
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Table IWP-3100-1 nor do they contain an acceptance criteria for pump inlet pressure as required by Table IWP-3100-2.
This item is unresolved (293/80-04-07).
f.
Salt Service Water System Test Procedure No. 8.I.10 was perfomed on January 3,1980 and reviewed by the Watch Enngineer for Technical Specification acceptability the same day.
The trend review required by Section XI within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> was not performed.
The procedure specifies that Perfomance Engineering will perfom this review but due to an apparent misrouting of the data, it was not completed.
After identification of this item by the inspector, Perfomance Engineering reviewed the data on January 31 and noted that one valve's stroke time exceeded its trend limit, requiring an increase in testing frequency to once per month.
The inspector reviewed a sampling of other test results and noted that all others were reviewed within the required 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />. Additionally, the inspector noted that the plant was shutdown for refueling on January 5,1980 within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> after the test was conducted.
This item is unresolved pending further review of the licensee's program to verify reviews will be conducted as required and is designated as (293/80-04-08).
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1 7.
Surveillance of Pipe Support and Restraint Systems
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a.
References 3.M.4-43A-1, Surveillance Functional Testing of Hydraulic
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Shock Supressors.
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3.M.4-28, Visual Inspection of all Hydraulic Snubbers and l
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Arrestors.
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Test and Inspection Procedure 26.A.1, Visual Examination -
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General.
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Visual Surveillance The inspector reviewed the visual surveillance data sheets for the following pipe supports and restraints.
Hydraulic Snubbers SS 10-30-06
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SS 6-10-03
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SS 6-10-05
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SS 6-10-08
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Mechanical Snubbers
SS 1-10-13
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SS 1-10-23
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5 SS 1-10-33
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SS 1-10-38
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SS 1-10-46
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Restraints H 23-1-105A
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H 23-1-73
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H 23-1-265A
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H B-3
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H D-4
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H 12-1-11
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H 12-1-13
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H 12-1-14
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The inspector reviewed the data for the above pipe supports
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and restraints to verify the following.
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there was no visible deterioration or corrosion i
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there was no physical damage or deformation which could
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render the pipe support or restraint inoperable
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the pipe supports or restraints were not in a " frozen" or l
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" locked up" position
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bleed holes are open and free if applicable
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the individuals performing the inspection met the minimum
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qualifications as specified in the procedure No items of noncompliance were identified however, two unresolved
items are discussed below, i
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(1) The inspector noted that those pipe supports and restraints other than safety related snubbers were being inspected in cunjunction with the ASME XI Inservice Inspection Program. The licensee was using a contractor and a contractor procedure to perform these inspections.
During the review of the procedure being used, the data sheets and discussions with the personnal involved the inspector detennined that spring hanger setpoints were not being checked.
The licensee acknowledged the above and stated that the procedure being used to implement
this inspection would be revised to include checking hangers for their cold setpoints.
Further, all those
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hangers done to date would be re-checked for the above item. This item is unresolved pending review of the above actions by NRC:RI (293/80-04-09).
(2)
The inspector noted that the licensee had not yet completed his review of the accessible snubbers and determined a
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schedule for the next inspection.
During the inspection of accessible snubbers the RHR snubber in the Torus room was found to be inoperable, in addition, a HPCI snubber had been found to be inoperable during the time frame since the last inspection.
Based upon the inspectors interpretation of snubber inspection schedules and previous guidance received from NRR, the inspector determined that the next interval should be six months for accessible snubbers. This item remains unresolved pending the licensee's determination of an inspection interval and review by NRC:i.I.
(293/80-04-10)
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Functional Testing The inspector reviewed the functional testing data sheets for the following snubbers.
SS 10-30-06
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SS 2-20-25
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SS 6-10-08
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SS 23-10-01
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SS 6-10-10
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SS 6-10-03
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SS 6-10-05
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SS 10-10-46
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SS 23-03-31
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No items of noncompliance were identified.
d.
Observations The inspector examined fixed pipe supports, component support structures and selected snubbers on the following systems.
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Recirculation Main Feed
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Snubbers inspected were checked for the following conditions:
leaks, excessive loads, accumulator level, cold piston setting, cleanliness, loose fittings, proper attachment, clean reservoir vent and general defonnation. The inspector had no questions in this area.
8.
Control Rod Drive Replacement During the course of the inspection a contractor employee expressed concerns over the conduct of operations relative to control rod drive replacements.
The contractor enployee stated that the replacement operation was not being perfonned in accordance with the procedure, that equipment had been damaged and their tools had been tampered with.
The inspector determined by way of interviews with the contractor, his supervisors, other contractor employees and plant personnel, that the tools had been tampered with but the other concerns could not be substantiated.
Further, the plant manager was actively investigating the tampering of the tools.
The inspector had no further questions.
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9.
Plant Tours The inspectors conducted tours of the accessible plant areas listed below, at various times to observe the status of plant systems and to observe activities in progress.
The plant areas inspected include the Control Room, Reactor Building, Pump House, Turbine l
Building, Truck Lock, Security Building and the Drywell.
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following were among the items observed.
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Radiation controls properly established;
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Housekeeping, including attention to the elimination of fire
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hazards; No fluid leaks of significance;
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Pipe vibration, including the condition of hangers and seismic
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restraints; Status of pre-selected jumpers;
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Equipment tagging for compliance with administrative requirements;
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Control Room manning in accordance with Technical Specification
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requirements;
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Reasons for lighted Annunciators in the control room; Inspection tags on fire extinguishers, no obstruction of fire
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hoses, etc; No items of noncompliance were observed.
10.
Unresolved Items Unresolved items are findings about which more infomation is l
required in order to ascertain whether they are acceptable items, items of noncompliance or deviations. Unresolved items are contained in paragraphs 3.b, 3.c, 4.b, 4.c, 5, 6.c, 6.d, 6.e, J.f, 7.b(1) and 7.b(2).
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11.
Exit Interview The inspectors met with licensee representatives (denoted in paragraph f
1) at the conclusion of the inspection on January 31,1980.
The inspector sumarized the purpose, scope and findings of the inspection.
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