IR 05000344/1987036
| ML20236C299 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 10/07/1987 |
| From: | Mendonca M, Pereira D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20236C286 | List: |
| References | |
| 50-344-87-36, GL-81-21, IEIN-87-008, IEIN-87-8, NUDOCS 8710270089 | |
| Download: ML20236C299 (10) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report No:
50-344/87-36 Docket No.
50-344 License No. NPF-1 Licensee:
Portland General Electric Company 121 S. W.-Salmon Street Portland, Oregon 97204 Facility Name:
Trojan Nuclear Plant Inspection at:
Rainier, Oregon Inspection conducted:
September 21-25, 1987
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Inspector:
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'#/7 /f 7 D. B. Pereira, Reactor Inspector /
Date Signed Approved by:
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"/~7/ P7 M. M. Mendonca, Chief, Date Signed Reactor Project Section 1 Summary:
Inspection During the Period of September 21-25 1987 (Report 5_0-344/87-36)
Areas Inspected:
This routine, unannounced inspection by the Project
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Inspector involved the areas of Temporary Instruction 2515/86(Inspection of Licensee's Actions taken to implement Generic Letter No.81-21, Natural Circulation Cooldown), the Onsite followup of Licensee Event Reports, Followup of Open Items, and backshift coverage of the operations personnel.
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During this inspection, inspection modules 30703, 92701, 25586, and 92700 were used.
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Results: No violations or deviations were identified.
8710270089 871008 PDR ADOCK 05000344 O
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DETAILS 1.
Persons Contacted a.
Licensee Personnel C. A. Olmstead, Plant Manager
- R. P. Schmitt, Manager, Operations and Maintenance S..Nichols, Supervisor, Training J. D. Reid, Manager, Plant Services
- D W. Swan, Manager, Technical Services
- C. Brown, Manager, Quality Assurance Operations
- D. Nordstrom, Engineer, Nuclear Safety and Regulation Department W. L. Kershul, Engineer, Nuclear Safety and Regulation Department
- R. Russell, Supervisor, Operations R. Reinart, Supervisor, Instrument and Control b.
U. S. Nuclear Regulatory Commission G. Suh c.
Oregon Department of Energy H. Moomey, Oregon Resident Inspector
Attended the Exit Meeting on September 25, 1987.
2.
Temporary Instruction 2515/86 Inspection of Licensee's Actions taken to implement Generic Letter No. 81-21 Natural Circulation Cooldown The purpose of this inspection was to verify that the pressurized-water-reactor (PWR) licensees have implemented programs for the control of natural circulation (NC) cooldown in accordance with their commitments to Generic Letter (GL) No. 81-21.
As a matter of background, while St. Lucie Unit I was cooling down under natural circulation conditions on June 11, 1980, flashing of coolant produced a void in the reactor vessel upper head, forcing water into the pressurizer.
The reactor was successfully brought to cold shutdown.
Based on the NRC review of the event, multiplant action (MPA) item B-66 was initiated.
This MPA requires that all PWRs implement procedures and training programs to ensure the capability to deal with such events.
Licensees were required by GL 81-21 to provide an assessment of their j
facility procedures and training program, including:
a.
a demonstration that controlled natural circulation cooldown from operating conditions to cold shutdown conditions, conducted in accordance with plant procedures, should not result in reactor vessel voiding.
b.
verification that supplies of safety grade auxiliary feedwater are sufficient to support plant cooldown methods.
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A' description of plant training programs and the provisions of emergency procedures that deal with prevention or mitigation of reactor vessel voiding.
It should be noted.that at the time GL 81-21 was issued, procedures for NC cooldown with upper head (UH) voids were not generally available.
The NRC staff's technical position on UH voiding has changed accordingly.
Controlled voiding into the reactor vessel UH is now an acceptable strategy provided that it can be done using all safety grade equipment with NRC-approved procedures and licensee operators trained in the use of these procedures.
To meet the above: requirements, the Trojan Nuclear Plant submitted responses _to GL 81-21 in a letter dated November 13, 1981 in which they stated that the occurrence of reactor vessel voiding during a natural circulation cooldown does not present a significant safety hazard, as long as the voided condition is not allowed to persist or increase to a point.where core cooling may be impaired.
However, it did present potential concerns with regard to maintaining a stable plant configuration, and thus Trojan supported the Westinghouse Owners Group's analysis and procedure development efforts related to this issue.
Trojan has issued two procedures concerning natural circulation cooldown with a steam void in the reactor vessel in accordance with GL 81-21 requirements.
Event Specific Emergency Instruction (ES)-0.3, Revision 0, dated October 14, 1985, entitled " Natural Circulation Cooldown with Steam Void in Vessel (with RVLIS)", and ES-0.4, Revision 0, dated October 14, 1985, entitled " Natural Circulation Cooldown with Steam Void in Vessel (without RVLIS)" provide actions to continue plant cooldown and depressurization to cold shutdown, with no accident in progress, under conditions that allow for the potential formation of a void in the upper head region.
These procedures provide guidance and instructions to the operators for the cooldown and depressurization rates to be graphed and ncintained.
The procedures provide a step by step method of decreasing
temperature and pressure within the guidelines of graphs at the back of each procedure to ensure that additional formation of voids in the reactor vessel is minimized or avoided entirely.
The inspector verified that the procedures for reactor vessel upper head bubble prevention or mitigation are in accordance with the response to GL 81-21.
The inspector verified that the licensee's training program of tne two above procedures included both classroom and simulator coverage of a natural cooldown.
The inspector reviewed records of the licensee's training program on the specific ES-0.3 and ES-0.4 procedures and on the simulator training program on natural circulation cooldown with voids in the reactor vessel.
The inspector interviewed operators concerning their familarity with the ES procedures and their expected actions concerning a natural circulation cooldown.
The operators expressed no concern over a natural circulation cooldown since the procedures provide a step by step method of decreasing temperature and pressure within specified guidelines.
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The inspector reviewed the NRC's letter dated August 2, 1983, and the safety evaluation for Trojan regarding GL 81-21, Natural Circulation
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Cooldown.
In the review, NRC concluded that there is' reasonable assurance that steam formation at the upper head of.the. reactor vessel during natural circulation cooldown will not occur.
This conclusion was
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Nuclear Plant, the training program for natural circulation.cooldown and i
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-the existence of sufficient condensate supply consistent with their-recommendations.
In their. analysis, the licensee concluded that the plant 'has sufficient condrnsate grade auxiliary feedwater supplies to remove decay heat and cooldown for 18.'5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> following a reactor trip.
In addition, the safety grade Service Water System can supply autiliary
feedwater.' The source for this. system is the Columbia River or, if-necessary, the Cooling Tower Basin. 'The condensate grade auxiliary feedwater supplies backed-up by the Service Water System provides-l sufficient-feedwater supplies.
Based on this. inspector's review of Trojan'.s ES procedures, the training
. program, and personnel interviews, it is felt that Trojan hts a program
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for the control of natural circulation cooldown;in accordance with.their j
commitments to Generic Letter No. 81-21., Temporary instruction 2515/86 is closed.
3.
Follow-up on Previous Inspection Findings
'a.
Violation Item 87-09-03 (Closed) Routine Scheduling of QC Observation of I&C Work Activities Inspection Report 87-09 identified a violation where QC inspectors were observing Instrumentation and Control (I&C) technical specification surveillance every Tuesday, which were performed under Periodic Instrumentation and Control Tests (PICTs)..Several concerns were identified by the inspector which included that: (a)
the observation of work is routine and might not give a true understanding of the quality of I&C work; (b) the QC inspector could be looking at the same surveillance which could inhibit QC's effectiveness; and, (c) QC might not be allowed access to observe work at other times.
The inspector discussed the above identified concerns with the QC supervisor and the I&C supervisor who both informed this inspector that the QC inspections are now random and not scheduled.
Both supervisors acknowledged that the QC inspector could observe any work that is being performed at any time.
The major reason why work was observed only on Tuesday was based on interdepartmental convenience.
Based on the above licensee's responses, the inspector considers violation 87-09-03 closed.
b.
Followup Item 87-05-01 (Closed) Updating Master Surveillance Schedule NCARP87-025 Licensee found discrepancy Inspection Report 87-05 identified a Nonconforming Activity Report (NCAR)P87-025 which indi:ated that the licensee's mechanism to update the master surveillance schedule to reflect Technical Specification or licensee revisions was not as comprehensive or as clear as should have been.
This NCAR, dated February 13, 1987,
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reported that license changes were not adequately controlled to j
ensure that the changes were incorporated into the Plant Operating i
Manual.
The licensee's Nuclear Division Procedure (NDP) No. 700-2 l
provides guidance on distribution and implementation of license j
changes.
Quality Assurance staff discussions with Operations, and
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Plant Engineering personnel indicated'that this guidance was inaoequate.
The inspector's review of the licensee's corrective actions to revise.NDP-700-2 determined the following:
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Any license change requests will be required to identify any-known documents which will need to be updated when the change is approved by the NRC.
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Require plant supervisor identification and revision of procedures whicn need to be changed as a result of a technical specification change, c.
Require that license change requests include a time allowed for implementation'after NRC approval (typically one month).
j The above corrective actions were incorporated into NDP-700-2 via revision 8 issued August 7, 1987.
Based upon the licensee's I
corrective actions, the inspector considers followup item 87-05-01
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closed.
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Violation Item 87-09-02 (0 pen) Failure to comply with Trending Procedural Requirements Inspection Report-87-09 identified a Notice of Violatt n in which the licensee did not note trending information after e ch audit or surveillance.
Nuclear Quality Assurance Procedure (Ni P) No. 114 required trending information obtained from Nuclear Qt'Lity Assurance Department (NQAD) audits to be entered onto. Trend Analysis Data Form (TADF) on a ongoing basis.
When the inspector asked to review the data forms, the inspector was informed that the TADFs were not being completed as required.
Four audits and one surveillance were completed since implementation of NQAP No. 114.
The inspector was informed by the licensee that NQAP No. 114 was deleted in its entirety and will be replaced by the Performace Monitoring / Event Analysis (PM/EA) Department Procedure (PMEAP) 101 Rev. O, entitled "PM/EA Department Procedure Trend Reporting".
This procedure when issued will establish the methods for reporting l
trends in root cause data accumulated through analysis of Nonconformance Reports, Nonconforming Activity Reports, and Event
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PMEAP No. 101 has NCAR and ER Trending Input Forms.
This procedure when issued will provide the details for the schedule for reports, collection of data, analysis of data, and reporting of trend data. Item 87-09-02 will remain open until PMEAP 101 is issued j
and trending of audits and surveillance is recognized as a fact.
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Followup Item 87-19-01 (0 pen) Maintenance Program Licensee Identified Deficiencies.NCAR's P87-041.and P87-037-
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'1 Inspection Report 87-19 identified two. Nonconforming Activity l
Reports (NCARs) P87-041, and P87-037. 'NCAR P87-041 discovered that-the current maintenance program lacked procedural requirements for updating and revising, in that it'did'not define the interfaces with equipment lists, DCPs, and the Q-list.
In addition, there was also r
no objective evidence that the Trojan' Scheduling System Users Manual; referenced in MP-3-8 had been reviewed and approved or was being j
controlled.
NCAR P87-037 discovered that the current preventive maintenance program did not specify requirements for the control of.
f computerized records.
The inspector?s review of the licensee's corrective actions
indicated that NCAR P87-037 was closed.
Maintenance Procedure
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MP-3-8, " Trojan Preventive Maintenance Scheduling System" was-l revised to define the preventive maintenance record retention requirements, and identify the methods of retention. 'NCAR P87-041 is still open, however, the Trojan Scheduling System Users Manua1 has been upgraded and was controlled with the Maintenance Supervisor's review and approval.
A Trojan Preventive Maintenance Program Manual was being developed (scheduled for issue mid-October)
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which would provide the aGainistr stion of the Trojan Preventive j
Maintenance Program.
This manual would provide the objectives, scope, requirements, approvals, documentation, and other facets of
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the Trojan program.
This followup item will remain open until the Maintenance Program Manual is issued and fully functional.
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IE Ir. formation Notice No. 87-08 (Closed) Degraded Motor Leads in i
Limitorque DC Motor Operators Information Notice No. 87-08 was provided to alert licensees of J
potentially defective dc motors installed in-Limitorque motor operators.
The motors in question were manufactured by H.K. Porter (now Peerless-Winsmith) between December 1984 and December 1985. The motors are fitted with Nomex-Kapton insulated leads that are susceptible to insulation degradation and subsequent short circuit failure.
The Nomex-Kapton leads are different than the leads which
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were tested and reported in Limitorque Qualification Report B-0009,
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dated April 30, 1976.
Valves with these Nomex-Kapton leads have recently failed to actuate on demand at two nuclear plant sites.
Trojan Nuclear Plant issued a'10 CFR 21 Defect Report:on May 6, 1986
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which identified a defect from an apparent deviation in the quality of the motor lead insulation in replacement motor actuators installed at Trojan during the 1985 refueling outage.
This 10 CFR i
21 Report indicated that the' motor lead insulation exhibited a brittle nature, and that movement of the leads during maintenance could cause cracks in the brittle insulation The weakened insulation would then be subject to failure under the normal vibration and operating environment of the motor actuator,
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In Licensee' Event Report (LER) 86-01,' Trojan reported'the corrective action of repairing the cracked insulation on the auxiliary.
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feedwater valve motor operator using Ray Chem insulation. The valve j
was declared operable prior to entry into Operation Mode 2.
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Maintenance Request 86-0717 performed the installation of the Ray Chem insulation and retesting of the auxiliary feedwater valve motor operator.
Based on the licensee's corrective actions and. response of issuing a.
10 CFR 21 Report, the inspector considers Information Notice 87-08 closed, f.
Part 21 86-14-P1 (Closed) Automatic Sprinkler Corporation Mercury Check Device Leakage and Update on Model C Vy ves l
This Part 21 Report details the " Automatic" Sprinkler Corporation of America (ASC0A) potential problems of 6" Model C valves that failed to trip properly even after being serviced within the last six to twelve months.
The valves stuck inside where the latch touches the valve clapper, thus preventing the flow of water.
The reason for the clapper latch assembly sticking to the clapper is related to a metallurgical phenomenon known as cold welding.
Similiar metals, pressed together under high pressures for long periods of time, have have a tendency to partially fuse together.
The mercury check device is a component of most Rate-of-Rise Sprinkler Systems.
The mercury check device is made up of two molded plastic parts which are bonded together.
A number of these mercury check devices have developed a leak in the bond area.
This could allow air to escape from the device.
This condition may take years to develop, if at all.
To be safe, all existing plastic mercury check devices should be repaired.
The licensee performed an Operational Assessment Review (OAR)
numbered 86-20 in February,1986 in which they performed maintenance in accordance with the ASC0A letter of 12/12/85.
The maintenance consisted of valve disassembly, valve clapper being
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removed, the latching mechanism being inspected and refinished with
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220 grit sandpaper followed by crocus cloth to obtain smooth mating surfaces, cleaning with lacquer thinner, then coating with a thin I
coat of molybdenum disulfide lubricant, 813MS, and being l
reassembled.
This maintenance was performed via Maintenance Request (MR)-86-1426.
In March 24, 1986, during maintenance per the above MR a 2&l/2" deluge valve to deluge system No.1 identified that the clapper to the latch fit was found to be corroded to the point where approximately 400 ft-lbs were needed to open the clapper.
Normally these parts are designed to slip easily apart.
The licensee disassembled the deluge valve, and the internal parts were grit blasted and coated with a corrosion inhibitor paint.
Parts were coated with a fluorocarbon gel.
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An ASC0A letter of Novembe 5,1986 provided two solutions that would alleviate the condition.
The first is the application of the
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molybdenum disulfide lubricant, 813S, as stated in their December l
12, 1985 notification letter, which the licensee has performed.
The l-second solution is to retrofit the valves with a new clapper latch dssembly and latch arm.
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The ASC0A letter cf November 5, 1986 required that all plastic j
mercury check devices manufactured after January 1, 1967 must be replaced.
They also recommended replacement of older plastic mercury check dedces because they may ultimately deteriorate with age.
The replaceme't device was easily identified because it is mechanically sealed with bolts and a red gasket, between the top and the body.
The licensee has ordered 16 replacement mercury check devices per
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maintenance service request (MSR)-87-060 and has plans to replace the mercury check devices upon receiot.
Based on the above licensee's corrective actions, the inspector considers Part 21 Report 86-14-P1 to be closed.
g.
Licensee Event Reports (LER) 86-10-LO&L1 (Closed) Deficiencies Identified in the Analysis of High Energy Line Breaks (HELB)
in the Turbine Building LERs 86-10-L0&L1 described the result of a study of main steam line breaks outside of Containment by the Westinghouse Owners Group, which in turn made the licensee review the analyses for such events
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previously performed for the Trojan plant.
This review revealed several assumptions made with respect to the Turbine Building in previous analyses were incorrect and two doors protecting safety-related equipment would not withstand the peak differential pressure expected.
Additionally, safety-related equipment
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previously determined to be safe due to compartmentalization, was jeoparized due to ingress of the harsh environment through ventilation systems.
Temporary modifications were made to protect the safety-related equipment in the interim until further analyses were performed.
A portion of the Turbine Building siding was removed to reduce the peak pressure and temperature in the event of a high energy line break and modifications were made to safety-related compartments to minimize the ingress of the steam environments.
Subsequent analysis indicated the auxiliary fcedwater system could have been subjected to an environment for which it was not qualified.
Permanent corrective actions are being implemented which include modification of steam vent paths and replacement of selected equipment.
The licensee's permanent corrective actions included the following:
1)
Modification of portions of the Turbine Building metal siding to permit venting and, hence, HELB energy release to the e
outside atmosphere.
At some siding span locations, existing
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fasteners have been replaced with pressure release fasteners which would release at reasonably low HELB overpressure but will resist wind suction pressures.
Atfother span locations, fastener capacities are increased to preclude the siding.from becoming a secondary missile concern should venting occur.
2)
Modification of heating, ventilating, and air conditioning-
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.(HVAC) paths for the remote shutdown panel room, auxiliary feedwater pump room (A and B trains), and engineered safety features switchgear room to effectively-isolate safety-related equipment from potential Turbine Building HELB environments.
3)
Modification of roll-up doors and structural elements of other barriers as required to. withstand potential HELB overpressure such as to maintain acceptable environments-for the emergency diesel generator (A and B trains) main air intake, diesel auxiliary feedwater pump room (B train), and engineered safety features switchgear room (A train).
4)
Replacement of the main steam line and turbine first stage pressure transmitters.
5)
Replacement of the main feedwater control and bypass control valves' solenoid valves, the main feedwater pumps' trip solenoid valves, and a portion of cabling for the
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Cooling Water (CCW) makeup pump.
All licensee corrective actions, except for 5) have been completed during the 1987 refueling outage.
Components-in 5) above are scheduled to be replaced in the 1988 refueling outage.
As previously stated, an environmental qualification review was performed and justification for continued operation written for this equipment.
The Topical Reports PGE-1004 and PGE-1025, as well as the Updated Final Safety Analysis Report, will be revised to reflect the analytical results and corrective actiores.
Based on the above licensee's corrective actions and future action, the inspector considers LERs 86-10-LO&L1 closed.
h.
Licensee Event Report 87-07-LO&L1 (Closed) Pressurizer Safety Valves Lifted Out-of-Tolerance During Surveillance Testing LERs 87-07-LO&L1 described that during the performance of pressurizer safety valve (PSV) testing on April 1, 1987, PSV-80100 lifted at 2596 psig.
On August 22, 1987, PSV-8010A lifted at 2658 psig and PSV-8010B lifted at 2598 psig.
These exceeded the Technical Specification allowed tolerance of 2485 psig +/-1% (ie, 2460 to 2510 psig).
The valves lift setpoints were adjusted and the valves retested satisfactorily.
The cause of the event is a j
deficiency in the bench test procedure for the PSVs in that the lift
settings established in bench testing do not correlate to the j
in place testing lift settings.
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The licensee's' corrective action has been to perform in place
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testing'of,PSVs for. establishing final-lift settings.,.. Eventually 'a ci
. bench-to-in place testing setpoint: correlation will be developed for each of the PSVs if bench testing is used.in the. future.
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Based on the above licensee's, corrective actions, the inspectorz
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considers LERs'87-07-LO&L1' closed.
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Deep Backshift' Coverage Inspection During this inspection, the inspector ' observed the control roo;n operators
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during the period of time between 2200.and 2400 hours0.0278 days <br />0.667 hours <br />0.00397 weeks <br />9.132e-4 months <br /> on~ Thursday night,
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September ~24, 1987.
The inspector observed that the control. room
' operators wereL attentive and knowledgeable. of. the plant activities.
The
. inspector. observed the swing' shift to graveyard turnover and observed
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that the shift turnovers were orderly and professional.
No horseplay or joking about was' observed.
i Based on the inspector's' observations, no violations or deviations were noted.
5.
Exit Interview l
The inspector met with the licensee representatives, denoted in paragraph 1 on September 25, 1987, and summarized the scope and findings of the inspection activities.
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