IR 05000353/1988014

Insp Rept 50-353/88-14 on 880523-0626.No Violations Noted. Major Areas Inspected:Work Activities,Procedures & Records Re Instrumentation,Preoperational Test Procedure Review, Equipment Qualification Program & Engineering & QA

ML20151F980
Person / Time
Site:	Limerick
Issue date:	07/12/1988
From:	Linville J, Williams J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20151F973	List: IR 05000353/1988014 ML20151F970
References
50-353-88-14, NUDOCS 8807280057
Download: ML20151F980 (14)

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U. S. NUCLEAR' REGULATORY COMMISSION

REGION I

Report.No.'88-14 Docket No. 50-353 License No. CPPR-107 Category A/B Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 Facility Name: Limerick Generating Station, Unit 2 Inspection Conducted: May 23, 1988 to June 26, 1988 Inspectors: R. A. Gramm, Senior Resident Inspector, Unit 2

.R. L. Fuhrmeister, Resident Inspector, Unit 2-Reviewed by: Ch / ) Af7/D 'J!;1 J/ 1. iWillia'ms, Pr6 ject Engineer Re ctor Projects Sec ion 2A IDat'e Approved by: 0-of s' C. LinMT1e, Chi

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, Inspection Summary: Report for Inspection Conducted May 23, 1988 to June 26, 1988 (Report No. 50-353/88-14)

Areas Inspected: Routine inspection by the resident inspector of work activities, procedures, and records relative to instrumentation, preoperational test procedure review, equipment qualification program, >

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engineering and assurance of quality. The inspectors reviewed licensee action on previously identified items and performed plant inspection tours. The

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inspection involved 174 hours0.00201 days <br />0.0483 hours <br />2.876984e-4 weeks <br />6.6207e-5 months <br /> by the inspector Results: No violations were identified.

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TABLE OF CONTENTS 1.0 Summary . ............................ 3 2.0 Plant Inspection Tours. . . . . . . . . . . . . . . . . . . . . . 3 3.0 Licensee Action on Previously Identified Items. . . . . . . . . . 5 4.0 Licensee Action on IE Bulletins and Circulars . . . . . . . . . . 7 5.0 Three Mile Island Action Plan Items . . . . . . . . . . . . . . . 5 6.0 Instrumentation . . . . . ................... 5 7.0 Preoperational Test Procedure Revie .............. 10 8.0 Equipment Qualification Program . ................ 11 9.0 Engineering . . ......................... 12 10.0 Assurance of Qualit ...................... 13 11.0 Meeting; with Licensee. . . . . . . . . . . . . . . . . . . . . . 14

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1 DETAILS 1.0 Summary  ;

Twelve NRC open items were reviewed and all were closed (sections 3, 4 and I 5). =The inspector attended the Project Status and Nuclear Review Board ,

meetings (section 2). Numerous instrument calibr&tions were observed and '

a procedural problem related to equipment qualification aspects was corrected (section 6). Five preoperational test procedures were reviewed l with minor comments (section 7). The equipment qualification program  !

specifications were reviewed (section 8), and the Bechtel engineering improvement plan actions were reviewed (section 9).

2.0 Plant Inspection Tours _(334031, 251053, 251063, 235060. 280210, 252053)

l The inspector observed in progress work activities, completed work, and plant status in several areas during inspection tours. Work was examined  :

for defects and compliance with regulatory and licensee requirement i Particular note was taken of the presence of quality control inspectors and quality control evidence such as inspection records, material identification nonconforming material identification, housekeeping and  !

equipment preservation. The inspector interviewed craft supervision, craft and quality control personnel in the work areas. Observations are-

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noted below:

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The inspector observed portions of the cable insulation resistance tests on the 2BG501 diesei generator output cable that was repaire The inspector verified current calibrations for the test equipment, and adherence to specified test duration The inspector ,

independently verified that test results were within acceptable range The inspector observed portions of the electrical testing of the A core spray pump motor, verifying that appropriate data sheets were filled out for the tests performe The inspector observed portions of the uncoupled run of the A core spray pump motor and C residual heat removal (RHR) pump moto The inspector observed the initial motor rotation checks, and the monitoring of vibration, winding and bearing temperatures and running currents during the tes The inspector attended the Project Status Review Meeting held on June 23, 1988. The licensee considered engineering was 96% complete and construction 88.9% complete. Among the topics discussed were Unit 2 Startup/ Unit 1 Second Refueling Outage schedule and coordination, Unit 2/ Unit 1 mechanical interties, component labeling program, startup test program, station security hardware and program changes, Independent Design and Construction Assessment, fire protection issues and technical specification reviews for vital equipment power supplie __

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The Nuclear Review Board (NRB) met at the Limerick Generating Station on June 2, 1988 to discuss issues relating to Peach Bottom and Limerick I operation, and Limerick 2 construction and testing

. activities. The inspect:r attended those portions which dealt with Unit The NRB had requested,.at a prev'ious meeting, a detailed description of how the Unit 2 preoperational test program met the requirements of NRC Regulatory Guide 1.68. The Unit 2 Startup Manager presented a. report on the preoperational test program, describing procedure generation, testing and results review. The report also described Blue Tag Testing, test personnel qualification requirements, QA/QC support of testing, the composition and functions of the Test Review Board and the Technical Specification surveillance test progra A second report presented to'the NRB dealt with the recommendations contained in NUREG 1275 regarding new plant startup experience The report listed the recommendations and how they are being implemented in the Unit 2 testing program. The NRB additionally questioned the Unit 2/ Unit 1 tie-in program, and NUREG 1275 Volume 2 regarding air system problem The inspector observed the uncoupled run of RHR A pump motor. The motor was instrumented with vibration monitoring equipment and temperature monitors for motor windings and bearing temperatur A bearing instability problem was noted by the licensee and the motor was subsequently disassembled. The inspector reviewed QCIR 2A0202-48-9 and modification / rework package 1AD202-25 for removal and replacement of the upper guide bearing and cleaning of the thrust bearing due to internal contaminatio Portions of the mechanical disassembly were monitore The inspector discussed the chemisal treatments added to the cooling tower basin. The additives include an acrylic polymer which acts as a dispersant to keep particles suspended, polysilica to provide additional corrosion protection for mild steel and an agent which forms a corrosion inhibiting film on copper alloys. A zine solution has been added to reduce the corrosion rate by a factor of fou Due to leaks in the cooling tower basin, some of these diluted chemicals were released via the storm drain system to Possum Hollo The inspector was informed that the appropriate permit documentation would be amended to reflect the Possum Hollow release poin The inspectar reviewed General Electric core spray elementary 791E4191TR sheet 11, modification 5032, training plan LOT-350 and the associated wiring diagrams. The concern related to the operation of the isolation valve wiring has been made an NRC unresolved item in NRC Inspection Report 88-1 No violations were identifie . _ - _ _ - _ _ - _

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3.0 Licensee Action on Previously Identified items (92700, 92701, 92702) (Closed) Construction Deficiency Report (77-00-01): Cracks in structural steel members. The licensee instituted the following actions:

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~ Visual and nondestructive examinations were performed to determine the extent and cause of-the crack The deficiencies were ~found to have been caused by improper flame cutting' operations at the vandor sho The vendor quality programs were enhance Revised fabrication methods were instituted to prevent creation of crack initiators during the flame cutting proces Bechtel shop inspection coverage was increase Analytical studies were performed to assess the affect of the beam / deficiencies upon the load carrying capabilit All plate girder web defects were repaire Rolled beam cope defects were found acceptable by finite  ;

element analysi !

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. The undersized clip angles and welds were found structurally adequat .

Based upon the beam repairs, analysis, inspections and correction of the vendor shop practices this item is considered closed, (Closed) Construction Deficiency Report (82-00-01): Potential for Robertshaw thermostatic valves (Model 1284 and 1285 in five inch and t six inch sizes) to fail in the full cooling position. This item was reported by Colt Industries on May 25, 1982 to the USNRC and by PECo, pursuant to 10 CFR 50.55(e) on August 3, 1982. The inspector >

reviewed the following documents relating to this item:

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Colt Industries letter, J. M. Moriarity to James G. Keppler, dated May 25, 1982 >

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Colt Industries letter, J. M. Moriarity to James G. Keppler, dated June 28, 1982

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Robertshaw Controls Company letter, T. T Howell to Peter Vander Vennett, dated May 13, 1982

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PECo letter, John S. Kemper to Ronald C. Haynes, dated August '

3, 1982

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Robertshaw Controls Company letter, Teena York to Peter Vander Venr.ett, aated August 11, 1982

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PECo letter, R. A. Mulford to W. C. McDaniel, dated June 1, 1983 with enclosure ,

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NCR 6141, dated September 20, 1982 The inspector determined that the potential for failure was due i

to some valve asemblies shipped without the retaining nut i having been soldered in position. The valve internals for the ,

Unit 2 diesels have been replaced with a newer design utilizing l I

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a castellated nut and cotter pin . The inspector had no further questions. This item is close (Closed) Unresolved Item (86-21-01): Drawing errors introduced-during drawing translation utilizing the Computer Aided Drafting-System. 1The inspector reviewed Quality Action Request F-562. The licensee identified several hundred informal memoranda that had been utilized to identify errors in Quality Assurance Diagrams (QADs) or Piping and Instrument Diagrams (P& ids). Bechtel project engineering reviewed other correspondence and found no additional examples where design change related information was transmitted in a informal manner. Construction engineering reviewed the informal memorandum again with respect to the revised engineering diagrams and discrepancies were documented on a formal change document. Site personnel were retrained on the requirements to issue Field Change Requests and Field Change Notices. This problem was reported in accordance with 10CFR50.55(e) and the resolution of the drawing errors will be reviewed at a later date in conjunction with NRC open item 87-00-0 (Closed) Violation (87-11-04): Review of Significant

" Deficiency Report (SDR) 159 for reportability evaluation under 10CFR50.55(e). The SDR identified a design concern with respect to the potential adverse interaction between the standby diesel generators and the associated fire protection flow trip switche On October 22, 1987 an Enforcement Conference was convened at Region Based upon fnformation previded by the licensee, the problem was determined not to meet the reportability criteria of 10CFR50.55(e).

The trip switches were removed from service as discussed in NRC Inspection Report 87-11. The common mode failure of the trip switch circuits under postulated fire conditions in the service water pipe tunnel will be reviewed during followup to NRC open item 87-00-0 This item is close (Closed) Construction Deficiency Report (88-00-05): Westinghouse type DS fused disconnect switch mechanical lugs. This deficiency involved inadequate securing of No. 6AWG and smaller conductors by mechanical connectors using setscrews. The inspector reviewed the following associated documents:

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PECo Reportability Evaluation No. SDR 232-2, dated April 15, 1988

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PEco Interim Report, SDR No. 232-2, dated May 13, 1988

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Startup Nonconformance Report No. 5-1-E, dated January 26, 1988

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Nonconformance Report No. 12991, dated February 1, 1988 The lugs were associated with fused disconnect switches in DC electrical panels supplied by B. K. Electri Some of the connectors had insufficient thread depth to ensure adequate contact with conductors up to size No, 6AWG (adequate contact was obtained

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for pairs of conductors sized No. 8AWG). All DC Power Panels supplied by BK Electric were subsequently inspected, and single conductor connections No. 6AWG and smaller were terminated again using compression lugs. This item is close .,-

4.0 Licensee Action on Bulletins and Circulers (92701, 92703)

The inspector reviewed licensee records related to the Bulletins and Circulars identified below to verify that: the Bulletin or Circular was received and reviewed for applicability; a written response was provided if required; and the corrective action taken was adequat The following Bulletins and Circulars were reviewed: (Closed) Bulletin (77-05): Electrical connector assemblie This bulletin identified the failure of pin-and-socket electrical connecters during exposure to LOCA conditions in tests conducted by

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Sandia Labs. The inspector examined the following documents with l regard to this issue:

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IE Bulletin 77-05, dated November 8, 1977

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IE Bulletin 77-05a, dated November 15, 1977

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GE letter PEco-1973, H. G. DeVoss to R. A. Mulford, dated January 3,1978

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PEco letter, V. S. Boyer to Boyce H. Grier (USNRC), dated March 1, 1978

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GE letter PE-1981, H. G. DeVoss to R. A. Mulford, dated January 24, 1978

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Bechtel interof fice merao F313561, W. E.Mourer to M. Solyes, dated April 27, 1988

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GE letter PE-3684, J. J. Millard to D. B. Fetters, dated May 13, 1988 The licensee found that no safety related connectors are located in areas affected by adverse environmental conditions. This item is closed, (Closed) Bulletin (77-08): Assurance of safety and safeguards during an emergency-locking systems. The licensee reviewed the plant design and found that under emergency conditions that prompt ingress is assured into safety related areas by: transfer of electrical power to an auxiliary source; locking devices that can be opened by operations or security personnel upon failure of primary and secondary power; locking systems and mechanical overrides are tested weekly; preventive maintenance and calibration is performed on the security inverter at 18 month intervals which includes transferring the security inverter from primary to alternate power supplies. The inspector reviewed the conceptual design review package for modification 5819. This will relocate the alternate power supply within the vital area and will include backup power from a Class 1E standby diesel generator. The licensee found that

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egress from plant areas can be accomplished under all condition This item is close Closed) Circular (78-03): Packaging greater than Type A quantities o ow specific activity radioactive material for transport. The inspector reviewed procedure HP-713, "General Packaging, Marking and Labeling Requirements for Radioactive Materials for Shipment". The procedure requires that greater than Type A quantities of low specific activity radioactive material be shipped under the 10CFR71 regulations. This item is close d. (Closed) Bulletin (79-07): Seismic stress analysis of safety-related piping. The licensee reviewed the computer codes that had been utilized by Bechtel, General Electric, Colt Industries, Rockwell International and Reactor Control None of the computer codes utilized the deficient algebraic summation methods for horizontal and vertical piping seismic excitations. The inspector reviewed the user manual for Bechtel program ME101,

"Linear Elastic Analysis of Piping Systems" and confirmed that the algebraic summation methodology was not employed. This item is closed, e. (Closed) Circular (80-14): Radioactive contamination of plant demineralized water system and resultant internal contamination of personnel. The licensee reviewed the water systems and found: no temporary connections of the demineralized water system to any contaminated systems; the po+able water system is not connected to any contaminated systems; two pathways between the demineralized water system, and the radwaste evaporators and condensate storage tank. Plant Administration Procedu.e A-7 specifies that demineralized water shall never be used for human consumption and that temporary system cross connections shall only be made in accordance with approved procedures. The potential backflow paths are provided with manual isolation valves, level alarms and a continuously running demineralized water pump that will prevent backflow. This item is close f. (Closedj Circular (81-09): Containment effluents water that bypasses radioactivity monitor. The licensee performed a detailed review of water systems that penetrate containmen The systems that are not provided automatic isolation valves were checked for direct flow paths to the environmen The systems, except recirculation pump cooling, connect to closed systems outside containment. The recirculation pump cooling system com:nunicates with the emergency service water system which is provided with an effluent monitor. This (tem is close '

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S.0 Three Milt Island Action Plan Items (3254018)

M As a result of the Three Mile Island (THI) plant accident, generic reactor enhancements were developed by the NR NUREG 0737 documents the specific action requirements. The licensee has been informed of those issues which require Region I closure prior to fuel-load. The following TMI issue was reviewed:

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-(Cl osed) :!I . F.2: Instrumentation for detection of inadequate core cooling. The inspector reviewed the Limerick FSAR, SER, SSER #2 and

Region I Inspection Report 50-352/84-60. The Limerick reactor water level monitoring system fully conforms with the review requirement As no system modifications were necessary and since periodic inspections have been performed on the reactor water levei instrumentation this item is considered close .0 Instrumentation (252051, 252053, 252055)

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PIS-42-2N690E, reactor pressure enable for core spray (CS) and

, low pressure coolant injection (LPCI)

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LIS-42-2N691C, reactor vessel level 1 initiation signal for CS and LPCI

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LIS-42-2N691B, reactor level 1

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LS-42-2N6928, reactor level 2

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LS-42-2N6938, reactor level 8

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PT-42-2N090E, low reactor pressure

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LT-42-2N091C, reactor level 1,-2 & 8

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LT-42-2N0918, reactor level 1, 2 & 8

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PIS-42-2N6900/PT-42-2N0900, low reactor pressure

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PIS-42-2N6948, high drywell pressure

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PIS-42-2N694E, high drywell pressure

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POISL-51-2N658C, LPCI isolation valve leakage indication

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POSH-52-2N653C, RHR , ,o discharge pressure

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PIS-56-2N656F, HPCI turbine exhaust pressure

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PIS-56-2N657, HPCI pump suction pressure

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During calibration the inspector verified proper use of calibrated measuring and test equipment, proper calibration data recording and procedural adherence with the exception of the equipment qualification (EQ) aspect discussed below, During the calibrations listed above, it was noted that procedure

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steps relating to EQ maintenance were not being performed. When questioned, the instrumentation technicians stated that the EQ maintenance activities were being deferred until the formal commencement of the Unit 2 EQ program, just prior to fuel load. At

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that time, all the steps for EQ would be performed on all of the

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instruments in accordance with computer generated maintenance request Formal documentation of this widely known fact could not be foun PECo has issued interim changes to the instrument

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calibration procedures specifying that the EQ maintenance actions

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. are not applicable to Limerick Unit 2 equipment until the Unit 2 EQ program is implemented at fuel load. These changes assure

, . consistency of the applicable procedure steps with work performed by the technician No violations were identifie .0 Preoperational Test Procedure Review (335301, 370340, 370335, 370337, l 370344, 3703'.1, 370355, 370358)  ;

The inspector reviewed the following preoperational test procedures for technical content, conformance with the FSAR test abstract (Table 14.2-4)

and consistency with the startup administrative manual requirements:

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2P18.1, "Instrument Air System". Additional documents reviewed include FSAR section 9.3.1; Test Review Board (TRB) regulatory review list and TRB meeting minutes; electrical schematic diagram E-570 and the air compressor wiring diagra P25.1, "Primary Containment Instrument Gas". Additional documents '

reviewed include FSAR question 410.73; Administrative Manual A0 regarding system cleanliness; TRB meeting minutes and regulatory review list; FSAR section 9.3.1.3; FSAR tables 9.3-3, 6.2-17 and  :

9.3-4; logic diagram M-59; P&ID M-59; electrical schematic diagrams 1 E-343 E-348, E-357. E-568 and E-622; and vendor prints M-30-2-14BR and M-1-E11-1040-E-04 P66.1, "Reactor Enclosure Unit Coolers". Additional documents reviewed include FSAP. sections 7.3.1.1.15.5, 7.4.2.8.1.2.3.16 and 9.4.2.2; logic diagram M-76F0; P&IO M-11 sheet 5; electrical schematic diagramt. E-471 and E-686. The test procedure was found to properly verify manual unit cooler operations; proper emergency service water valve response; automatic start and stop of the unit-

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cooler depending upon ambient room temperature; and proper operation of the standby unit cooler. An incorrect FSAR statehent was identified in section 7.4.2.8.1.2.3.1.16 which stated the RCIC unit cooler upon automatic initiation would continue to run until manually overriden by an operator. The unit cooler will actually shut down automatically when the pump room temperature drops to 80 degrees F. Licensing Document Change Notice FS-1454 was issued to correct the FSA P-2.1/2.2, DC Safeguard Power System Division I, II, III ad I Additional documents reviewed include FSAR Table 8.3. The battery capacity load profile was more conservative than the FSAR. On page 7-28 of procec.ure IP2.2 a formula was corrected from 692 amp-hours to 678 based upon the inspector's review. On page 7-38 of procedure 2P-2.2 an instruction was corrected to install a digital voltmeter across the charger shunt. With the exception of the FSAR inaccuracy and the correctiers to procedure 2P2.2 no other concerns were identifie _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ __ ___ .__

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.11 2P-83.1 "Main Steam System". In addition, the following documents were reviewed: FSAR Section 5.2.2, FSAR Section 5.4.5, Drawings M1-E32-1050-E-13.2 through 24.1, P&ID M-40 and P&ID M-41. The test procedure was found to adequately demonstrate proper opeiation of the Main Steam Isolation Valves (MSIV), MSIV Leafage Control System, Main Steam Safety / Relief Valves, and Main Steam System Isolation Logic Trains. Several minor typographical errors were identified which will be corrected in the next revisio No violations were identifie .0 Equipment Qualification (37055)

The following documents were reviewed by the inspector that pertain to the equipment environmental'and dynamic qualification program:

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FSAR section 3.10 and tables 3.10-1, 3.10-2 and 3.10-3 section 3.11 and tables 3.11-2

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Bechtel Specifications G-22, "Equipment Qualification Program", Rev. 5 l G-29, "Evalustion and Purchase of Commercial Grade Items for Safety Related Applications", Rev. 4 G-46, "General Requirements for Dynamic Qualification Walkdown",

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G-47, "Environmental Qualificatior Walkdown of Safety Related Equipment", Rev. A The inspectur subsequently held a meeting with cognizant PECo, Bechtel

and General Electric project engineers regarding the Equipment i

Qualification (EQ) Program. The inspector was informed that Unit 2 equipment is generally similar to Unit 1. The licensee intent is to

etilize the existing Unit 1 qualification packages as a bases for the Unit 2 EQ packages, The inspector was informed that equipment specific similarity checklists have been generated to guide the comparison of the equipment to ensure that the Unit 1 packages are appropriately extended for the Unit 2 equipment. The Unit 1 packages will be enhanced by including a more detailed EQ checklist, applicable NRC Eulletins or Notices, and accounting for subsequent plant modifications.

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The licensee intends to perform in plant walkdown verifications to assur; that the as-built equipment condition is consistent with tiu EQ configuration. The walkdowns will be performed by engineers familiar with the equipment qualification and will be guided by an appropriate

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checklist. Based upon equipment location, either sampling or 100%

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walkdowns are intended. Information will also be obtained for feedback to the GE qualification progra .:

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The' inspector plans to monitor the implementation of the EQ walkdown

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phase. No concerns were identified at this tim .0 Engineering (37055, 35060)

The licensee has developed an engineering improvement plan _that includes Bechtel and General . Electric engineering organizations. The . primary focus of the plan is-to address concerns that were documented within the last NRC Systematic Assessment of Licensee Performance (SALP) for Limerick Unit 2 (Report Number 50-353/87-99). Various elements of the improvement program have been implemented. The inspector reviewed the following documents regarding the improvement plan:

Document Description March 10, 1988 Off project review of component .dentification Report identified an error which was that the "C" & "0" circulating water pumps had been connected to "A" & "B" water box loops. The error was corrected by changing the water box identification to be consistent with the control room and pump configuration. The review was extended to examine the main steam and HPCI systems for similar problems. The RHR, RHRSW and'ESW systems were also examined as discu: sed belo May 16, 1988 Off project review of the RHR, RHR Service Water and Report Emergency Service Water Component identificatio The review encompassed P& ids, electrical, schematic and physical drawings to assure correct piping loop and electrical division relationship Bechtel IOM Construction design interface review report on May 27, 1988 electrical equipment. ;e review included separation, seismic spacing, conduft. installation, junction box design, RPS/ESF contrci panel separation, raceway support spacing criteria. A sample walkdown was performed on installed hardware to ver;fy conformance with design. All installations were found satisfactor Bechtel IOM "Design Process Improvement Program" instituted trial June 6, 1988 use of procedure EDPI 4.65.1 te analyze design weaknesses for trends and root causes and to identify corrective action Input from significant NCRs, Pas 21/50.55(e) reports and corrective action report GE Letter Comments on GE Nuclear Engineering and Bechtel B-2395 interface documen _

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. Survey- FSAR nonconformance survey performed of 301 engineers at Pottstown and San' Francisco. One area of nonconformance was identified that was'not currently being addressed by an LDCN. As a result, two items

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were added to Design Closure Plan for study of control. system failures in response to FSAR questions 421.10 and 421.1 The engineering. overview and improvement processes continue to be performed in a thorough manner. As further elements of the program are implemented, add'tional NRC inspection will be performe .0 Assurance of Quality (35060)

The conduct of equipment vibration monitoring tests was observed (section 2). The licensee has retained an experienced consultant to train PECo maintenance personnel on the Bentley-Nevada vibration monitoring equipment. The monitoring has detected problems with the residual heat removal pump motor bearings and the reactor enclosure cooling water pump motor support structur The Nuclear Review Board continues to conduct in-depth reviews of the Unit 2 startup program (section 2).

During' review of instrument calibration activity (section 6b), the inspector noted that certain procedural steps related to maintenance of equipment qualification (EQ) were not performed. In particular, for Rosemount transducers, the gasket material was not replaced and the cover seal was not torqued. Further review found the EQ baseline maintenance would be performcd before fuel load and tracked on the PECo automated maintenance scheduling progra This would allow startup test activities to be performed, such as opening the transducer cover, without necessi-tating the performance of the EQ work again. While the instruments would ultimately reach the qualified state it appeared to be a poor practice to complete the appro ad procedures that normally guide the calibration activities. The licensee amended the procedures to waive the EQ main-tenance conduct at this tim A further FSAR inaccuracy was identified in section 7.0 to the operation of the RCIC unit cooler The Equipment Qualification Prograr has been planned with extensive site engineering walkdown verifications to ensure that environmental and dynamic qualification parameters have been accommodated by the as-built plant (sectior s).

In-dapth engineering reviews continue by non project personnel in response to concerns identified in the previous NRC Systematic Assessment of Licensee Performance (section 9).

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11.0 _L_icensee Meetings The NRC resident inspector discussed the issues and findings in this report with members of the licensee's staff on a weekly basis, and at an exit meeting held on June 24, 1988. Based on discussions held with licensee representatives on June 24, 1988, it was determined that this report does not contain information subject to 10 CFR 2.790 restrictions.