IR 05000322/1981012
| ML20010C544 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 08/04/1981 |
| From: | Higgins J, Kister H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20010C542 | List: |
| References | |
| 50-322-81-12, NUDOCS 8108200177 | |
| Download: ML20010C544 (10) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I
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Report No. 50-322/81-12_
Docket No. - 50-322 Category-B License No. CPPR-95 Priority
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Licensee:
Long Island Lighting Company 175-East Old Country Road
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Hicksville, New York 11801
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Facility Name:
Shoreham Nuclear Power Station, Unit 1 Inspection at:
Shoreham, New York Inspection conducted: July 1 - 31, 1981 Inspectors:
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J.[C.H ns, Senior Resident Inspector date signed
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date signed da e igned
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i Approved by:
H'. B. Kis'teh-Ghief, Reactor Projects Section 1C
[datesi'gned
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Projects Branch #1, DRPI
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Inspection Summary:
Inspections on: July 1 - 31,1981 (Inspection Report No. 50-322/81-12)
Areas Inspected: Routine onsite regular and backshift inspections by the resident inspector (115 inspection hours) of work activities, preoperational testing, and plant staff activities including:
tours of-the facility, test witnessing; comparison of as built plant to FSAR description; review of the CO2 fire protection system and core
- spray system; review of test procedures and preoperational program practices; review of Quality Assurance Program; and, followup on previous inspection findings.
Results : No violations were identified, hoho Region.I torm ic-
't (Rev. April 77)
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DETAILS 1.
Persons Contacted T. Gerecke, Quality Assurance Manager (L)
J. Kelly,- Field QA Manager (L)
W. Klein, Lead Startup Engineer (L)
W. Matejek, Lead Advisory Engineer (L)
B. McCaffrey, Manager, Project Engineering (L)
M. Milligan, Project Engineer (L)
A. Muller, Acting 00A Engineer (L)
J. Riley, Lead Startup Engineer (GE)
J. Rivello, Plant Manager (L)
W. Steiger, Chief Operating Engineer (L)
D. Terry, Assistant Startup Manager (L)
E. Youngling,StartupManager(L)
GE - General Electric L
- Long Island Lighting Company S&W - Stone and Webster The inspector also held discussions with other licensee and contractor personnel during the course of the inspection including management, clerical, maintenance, operations, engineering, testing, quality ass.1rance and construction personnel.
2.
Previous Inspection Item Update (closed) Unresolved Item (32Eff0-14-01): ALARA considerations for manual feedwater line isolation valves: The inspector questioned whether the ALARA concept had been considered when making these valves (1821*HV-055A and B)
manually operated.
The licensee perfomed a review of the design of the valves and documented this in a memo from I. Haas to M. Milligan dated
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7/14/81. The licensee concluded that from both safety and ALARA standpoints the valve design is acceptable.
This item is closed.
(closed) Unresolved Item (322/80-14-12): HPCI pump labels:
In the licensee's component control system, the HPCI pumps (both main and booster) are given a single identifying number,1E41*P-016. The embossed component control identification tag was changed to read HPCI Pump, Main and Booster and was mounted on the common baseplate. Additionally, the licensee made engraved name tags for each pump separately and attached these to the individual pumps.
This item is closed.
(closed) Unresolved Item (322/81-04-08):
Drawing Control: The inspector reviewed Startup Instruction No. 2, which provides the details of how documents are to be used and controlled for electr;:al checkouts. This instruction appears to provide adequate controls for these activities. Additionally, the licensee marked all vendor attached wiring drawings inside of the motor control center cubicles as uncontrolled drawings for information only.
The inspector also reviewed the implementation of Startup Instruction No. 2, as discussed in a following paragraph. This item is closed.
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Plant Tour a.
Discussion The inspector conducted periodic tours of accessible areas in the plant during normal and backshift hours.
During these tours, the following
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specific. items were evaluated:
-- Hot Work: Adequacy of fire prevention / protection ceasures used.
-- Fire Equipment: Operability and evidence of periodic inspection of fire suppression eqeipment.
-- Housekeeping: Minimal accumulations of debris and maintenance of required cleanness levels of systems under or following testing.
-- Equipment Preservation: fiaintenance of spec'al precautionary measures for installed equipments as applicable.
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-- Component Tagging:
Implementation and observance of equipment tagging for safety, equipment protection, and jurisdiction.
The inspector noted some delays in hanging Blue juricdictional tags and discussed this with responsible licensee personnel.
-- Logs: Completeness of logs maintained.
-- Security: Adequate site construction security.
-- Control Rods: Machining of control r i velocity limiters to achieve proper slope in accordance with Gent 21 Electric FDI No. 85/88524.
Observed machining; Quality Control checks, engraving and documen'1 tion.
-- Weld Rod Control: Observations to determine weld rod was being controlled in accordance with site procedures.
With the exception of the below item, no discrepancies were identified, b.
Submerged Electrical Cables North of the Screenwell Building there are three electric manholes / cable tunnels that route safety-related cabling to the Screenwell. During a plant tour the inspector observed about three feet of water in each tunnel.
In the blue division tunnel, the water level was above one tray of cables.
There is no drain or sump pump provided for these tunnels.
The licensee's representative acknowledged the irspector's observations and wrote an Engineering & Design Coordination Report (E&DCR), No. F-35998, requesting an engineering evaluation and resolution for the problem. The item is unresolved and is designated item no. (322/81-12-07).
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Operational Quality Assurance (00A)
a.
Discussion The 00A organization provides the Quality Assurance functions for the prcoperational test program and the permanent plant staff operation.
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The inspector reviewed various aspects of the 0QA program, implementing l
procedures and documentation including:
-- QC surveillance of Repair / Rework and maintenance activities;
-- QC review of System Conditional Release packages from construction to startup;
-- The LILC0 Deficiency Report (LDR) System, including all 1981 LDR's both closed and open, and all remaining open LDR's from previous years;
-- 0QA 1981 audit packages, checklists, audit findings and corrective actions, and all remaining open findings from previous years;
-- All 0QA Corrective Action Requests (CAR's) and responses.
The inspector also observed in progress in the plant QC surveillance of various maintenance and Repair / Rework activities. With the exception of the below items, the inspector identified no discrepancies in the areas reviewed and observed.
b.
findings (1) Corrective Action Requests (CAR's)
QAP-S-16.1, " Station 00A Corrective Action", and each CAR require that the responding person date his response and reply by the specified Required Reply Date. Since February 21, 1978 nineteen CAR's have been issued. Of these nineteen, eleven were not replied to by the required reply date and four were not dated by the person approving the report. The inspector noted that all had been responded to and had been satisfactorily closed ^ut but stated that more attention to prompt response was required.
10 CFR 50, Arpendix B, Criterion XVI requires that significant conditions adu.rse to quality, along wi?S the causes and corrective actions, be reported to appropriate levels of management.
QAI-16.1-01,
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Rev. O, " Station 00A Corrective Action Request Distribution During C&I0 and Preoperational Testing" specifies the management personnel who receive CAR's.
Due to organizatioiial changes, two of the three positions listed no longer exist. Additionally, the inspector noted that the Vice President - Nuclear us nnt included on the list in
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QAI-16.1-01 or QAP-S-16.1.
The above two items dealing (with CAR's are considered unresolved and are designated as item no.
322/81-1?-12).
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-5-(2)' Repair / Rework Request Review
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10 CFR 50, Appendix B, Criterion XVI, " Corrective Action", calls for measures to be established to assure that conditions adverse
.to quality such as deficiencies are promptly identified and corrected.
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QAI-15.1-01, " Station 0QA Deficiency Control during C&IO and Preoperational Testing", Rev. 3 describes one LILCO system used for controlling deficient conditions and requires that anyone
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discovering a defined significant deficiency originate a LILCO-Deficiency Report (LDR). The procedure further states that simple deficiencies may be documented and controlled via the Repair / Rework
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Request. 0AI-10.4-01, Rev.1, " Station OQA Repair / Rework Request
Control Prior to Plant Operation" establishes 00A reviews of the
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Repair / Rework Request:
before implementation, to determine the
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information filled out on the form is correct; and, after implementation, upon satisfactory completion of all work,_ inspections and retesting.
The procedure, however, does not specify or require that 00A review
l the deficiency documented on Repair / Rework Request to determine if it is signficant or if an LDR should be written.
The inspector noted that 0QA inspectors have in the process of Repair / Rework witnessing generated LDR's, but stated that the measures established did not
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appear to ensure that each Repair / Rework would receive an 0QA review
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to determine-if an LDR should be written. This item is designated as
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inspector follow item no. (322/81-12-13).
5.
Electrical Wiring Checkout i
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The licensee performs electrical wiring checks as part of the Startup Check ~
out and Initial Operation (C&IO) Program. This program is described in the~
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Startup Manual, Startup Instruction No. 2, Rev.1, " Electrical Checkout
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Instructions", and in CG.000.067, Low Voltage Control Circuits. These
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instructions define how wire checks are to be performed and, how documents
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and drawings are to be controlled and marked up to indicate completed
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satisfactory checkout. Field Quality Control Procedure QC-5.2, Rev. C, Change 3 also describes docwent control requirements. Typically a controlled
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drawing is yellow-lined to indicate' wire checks are completed. The inspector observed wire checks in progress on the Reactor Pi 'tection System (C71B) ~
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and noted the applicable procedures and requirements were being followed and
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that the test personnel were qualified to perform their tasks. The inspector
also reviewed wire check documentation-for-systems that have had their C&IO
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l program completed and for which the preoperational tests have begun. A number of discrepancies were identified of the following types:
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-- Drawings were not properly stamped;
-- All of the required blanks were not filled in on the drawing stamps;
-- Wrong revision of drawing used for wire check;
-- When a new revision was issued to a drawing, which had already had
its wire checks completed, the proper evaluation was noi made to
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-- Superseded drawings kept in. controlled file and not stcmped to indicate as such.-
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-6-The licensee's representative acknowledged these comments and stated that they would be addressed. This item is unresolved and is designated item no. (322/81-12-08).
6.
Core Spray System a.
Documents Revitwed Shoreham FSAR Sections 6.2.4.3, 6.3.2.2.3, 7.3,14 and NRC Questions.
Specification SH1-232, Special Check Valves, Rev.1.
Drawing FM-23A-13 and related E&DCR's.
PT.203.001, " Core Spray System".
Core Spray System Description, S.D.203 Startup Instruction No. 5, " Maintaining Cleanliness During Repair / Rework of Flushed Systems".
SP.23.203.01, " Core Spray System", Rev. 2.
SP.24.203.01, " Core Spray Piping Vented, Pump Operability and Flow Rate Test", Rev. O.
SP.24.203.02, " Core Spray Valve Operability Test", Rev. O.
SP.24.203.03, " Core Spray Valve Lineup Verification", Rev. O.
Draft Revision 22 to Shoreham FSAR, Chapter 7.
System Logic drawings, LSK 25.10A through F.
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System Elementary Electrical drawings, 791 E419 TF, sheets 1 - 7.
Draft Technical Specifications, sections 3/4.5.3.1.
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Discussions
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The inspector reviewed the above documentation, toured one train of the as-built system ir. the plant and observed installed components, piping i
arrangement and instrumentation. The inspector also witnessed portions o'. the reinstallation of the internals of the air-operated check valve, which acts as the inside the drywell containment isolation valve,for both loops of Core Spray. The inspector noted precautions taken to main-i tain cleanliness of the already flushed piping in accordance with Startup Instruction No. 5.
Based on the system tour, the inspector compared the
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as-built system and approved test procedures to the licensee commitments
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and regulatory requirements. With the exception of the items discussed
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below, no discrepancies were identified.
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-7-During the review of the permanent plant test and operating procedures, the inspector noted several areas where design changes made during construction had not been incorporated.
Discussions with. licensee personnel indicated that all Station procedures are now in a revision cycle, due to the length of time'since the original approval and the number of system changes effected. The majority of the procedure draft revisions will be done by the architect-engineer and will be completed by the end of the year. A final review of Station procedures by the System Startup Test Engineer is required just prior to system turnover to the plant staff.
c.
FSAR Description The inspector noted a number of areas where the installed system did not agree with FSAR descriptions. Discussions with licensee personnel and a review of Draft Revision 22 to the FSAR clarified some of these discrepancies. About ten items of the following types remained:
valve descriptions, control arrangements, pump flow rates, relief valve discharges, vent and drain line caps and indication of protective actions.
The licensee's representative acknowledged each of the discrepancies identified. This item is unresolved pending action to make the FSAR and installed systems agree and is designated item no. (322/81-12-04).
d.
Preoperational Test _
Section 8 of the Startup Manual states that the Preoperational Tests verify the system design bases and the full operating range of the system.
Chapter 14 of the FSAR gives additional specifics to be included in the Core Spray Preoperational Test such as; valve sensor and logic tests, valve interlocks and pump flow tests. The inspector noted that the test procedure did not include the following:
- Verification that air-operated check valves (*A0V-081A & B) cycle normally, have correct position indication, close on reverse flow even though the test switches are positioned for open, and will open when pump pressure exceeds reactor pressure even if the test switch is positioned for close:
- Verification that the test bypass valves. (*M0V-035A & B) cannot be opened with an ECCS initiation signal present; injection valves (*M0V-033A &'B)
- Checkout of manual operation of the loop (closure permitted and with an ECCS initiation signal preser.t
reopening permitted only if differential pressure requirement met);
- An establishment of system conditions to be used for permanent plant surveillance testing per Technical Specification 4.5.3.1. c, which requires a flow of 4725 gallons per minute at a reactor vessel pressure of at least 113 psig; and
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- A consistent value for required pump minimum flow.
This item is unresolved and is designated r' item no. (322/81-12-05).
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Co_ntrol Room Panel The inspector observed the Core Spray panel in the main control room and noted some discrepancies: the lights for *M0V-081 are labeled as *A0V-081;
- M0V-081 is not mimicked; the *A0V-081 disc position tag is still present even though valve disc position has been eliminated; and, the A-loop switch for the testable check valve has five positions while the B-loop switch has only four positions. These items a re unresolved and are designated item no. (322/81-12-05).
f.
Loop Injection Valves Each of the two Core Spray loops contains a pump and independent piping and valving to direct water to the reactor vessel.
Each pump starts on an Emergency Core Cooling System (ECCS) initiation signal, but no water is injected into the reactor vessel until reactor pressure has decreased so that a loop injection valve (*M0V-033) and a check valve can open. The inspector noted that the opening logic for the loop injection valves did not agree with that described in the FSAR.
The FSAR states that four reactor pressure sensors are arranged in a one out of two taken switch logic to open each loop injection valve, when reactor pressure has dropped to 500 psig. The installed design opens the loop injection valves based on a differential pressure detector signal (*PDS-033) across the valve itself. This signal opens the valves at 450 psid and is arranged in a simple one out of one logic.
The draft Revision 22 to the FSAR did describe the new logic. The inspector questioned the reduction of redundancy incor-porated into the new design, which would allow failure of a single detectnr to prevent injection of one of the two redundant core spray loops.
Additionally, the inspector noted that Core Spray Pump discharge pressure was 290 psig. Together with the 450 psid setting of *PDS-033, this implies that reactor pressure would be about 740 psig when the loop injection valve opens. The piping upstream of the loop injection valve is designed for 500 psig and has a relief valve which is set at 500 psig and which discharges to the radic&ctive waste (rad waste) system outside of the reactor building.
If the loop injection check valve were to stick open or leak, then the core spray piping would, post-accident, be exposed to excessive pressures and a flow path would be established from the reactor vessel through the relief valve to the rad waste building. The inspector therefore questioned the setpoint of the differential pressure switch. The above two items are un-resolved and are designeted item no. (322/81-12-11).
7.
Carbon Dioxide (C0 ) Fire Protection
a.
Documents Reviewed Shoreham FSAR Chapter 9.5.1 and 14 Specification SHI-238, ' installation of Low Pressure Carbon Dioxide Fire Protection System", with Addenda 1 and 2.
Pertinent system piping and instrumentation drawings (P&ID's) and related E&DCR's.
System Description S.D.501 " Carbon Dioxide", Rev.1.
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NFPA Standard No.12, C0 Extinguishing Systems.
Draft Shoreham Technical Specifications, sections 3/4.7.7.3.
PT.501.001, "M43 Carbon Dioxide Fire Protection System Preoperation Test Procedure" dated 5/21/80.
Vendo" documentation and manuals.
10 CFR 50, Appendix R and Shoreham review against Appendix R (letter SNRC-572).
b.
_D_i_scussion The inspector toured the plant in company with the construction engineers and observed the installation and arrangement of the CO2 system piping, valving, components, wiring and instrumentation. Based on the document review and the system tour the inspector compared the as-built plant and approved test procedures to licensee commitments and regulatory requirements.
With the exception of the below items the inspector identified no discrepancies.
c.
Rollup Doors
The Shoreham FSAR, section 9.5.1, and the Shoreham evaluation against 10 CFR 50, Appendix R (letter SNRC-572) state that the plant fire protection systems conform to the National Fire Protection Association (NFPA) Standards. Further page 9.5-20 of the FSAR and article 2221 of
- NFPA Standard No.12 call for automatic closure of doors in areas protected by CO. The two large rollup doors in the Recirculation Pump Motor-Generator
Room and the Normal Switchgear Room have no automatic closure feature.
This item is unresolved and is designated item no. (322/81-12-01).
d.
Cable Tunnel Below the Normal Switchgear Room is a cable tunnel containing wiring and cabling from two safety-related divisions enroute from the emergency switchgear room to the reactor building. The tunnel is designated as Electrical Manhole No. 1.
Both the Normal Switchgear Room and this cable tunnel are provided with CO2 total flooding fire protection. The inspector noted the following with respect to this tunnel.
- The current draft of the Technical Specifications, section 3.7.7.3, lists the CO2 subsystems or areas that must be operable, but does not include this cable tunnel;
- The local temperature switches for initiating C02 flooding to _this area, shown on FSAR Fugure 9.5.1-3 and Drawing FB-44A-6, were not shown on electrical drawings and were not installed;
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- Table A of FSAR Figure 9.5.1-3 and Drawing FB-44A-6, which lists all sehty related temperature switches, does not include temperature switches for this cable tunnel.
This item is unresolved and is designated item no. (322/81-12-02).
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Preoperational Test Based on a review of PT.501.001 the inspector had the following two comments.
Article 2523 of NFPA Standard No.12 requires that, for total flooding C02 systems to areas with deep-seated fires, the CO2 concentration in the area must reach 30% in two minutes. The test procedure verifies the final required CO2 concentrations (which is greater than 30%), but for the deep-seated fire areas it does not verify that 30% concentration is reached in two minutes.
The inspector stated that other NRC licensed facilities have experienced C02 inleakage into the main control room when C07 was released into adjacent areas. This could create a hazard in the controT room,possibly requiring evacuation. The test procedure currently does not measure CO2 or oxygen concentrations in the control room when CO2 is released to adjacent areas.
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above two items are unresolved and are desigr.ated as item no. (322/81-12-03).
f.
Warning Horns FSAR Figure 9.5.L 3 and Drawing FB-44A-6 show local CO discharge alarms
or warning horns for Battery Rooms, A, B and C.
These horns are not shown on electrical installation drawings and are not installed. This item is unresolved and is designated as item no. (322/81-12-09).
g.
Valve and Pipe Arrangement The Piping and Instrumentation Drawing (P&ID) for the C02 fire protection
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system, FB-44A-6, does not show all of the supply piping and valving V the C02 storage tank and some of the valvi-no shown is incorrect. Additionally there does not appear to be another controlled drawing which shows the correct valve and pipe arrangement. This item is unresolved and is designated as item no. (322/81-12-10).
3.
Unresolved Items Areas for which more information is required to determine acceptability are considered unresolved.
Unresolved items are contained in Paragraphs 3, 4, 5, 6 and 7 of this report.
9.
Management Meetings At periodic intervals during the course of this inspection, meetings were held with plant management to discuss the scope and findings of this inspection.
The resident inspector and a rcgion-based inspector also attended a meeting between the licensee and the Office of Nuclear Reactor Regulation on July 1 to discuss Fire Protection and Cable Separation.