IR 05000387/1980010

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IE Insp Repts 50-387/80-10 & 50-388/80-06 on 800421-0516 & 27-30.No Noncompliance Noted.Major Areas Inspected: Installation & Welding of RCPB & Other Piping & Installation of safety-related Components
ML17138B477
Person / Time
Site: Susquehanna  
Issue date: 06/30/1980
From: Gallo R, Mcgaughy R, Rhoads G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17138B476 List:
References
50-387-80-10, 50-388-80-06, 50-388-80-6, NUDOCS 8009190241
Download: ML17138B477 (20)


Text

U.S.

NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I e

. 50-387/80-10 Report No.. 50-388 80-06 50-387 Oocket No.

50-388 CPPR-101 License No. CPPR-102 Prior ity Category Licensee:

Penns lvania Power 8 Li ht Com an B ~-

2 North Ninth Street Allentown, Penns 1 vania 18101 Facility Name:

Sus uehanna Steam Electric Station Inspection at:

Salem Township, Pennsylvania and Allentown, Pennsylvania Inspection conducte April 21 - flay 16 and May 27 - 30, 1980 Inspectors:

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en>or esi en nspector Re.

oa s, ess en nspec or C IB date signed 8 8'o ate igned Cfnef,"

Eggi eerin Suppor, Section No.

Approved by:

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ection RC8ES Branch date signed date signed Ins ection Summar:

'Unitins ection'on'A ril'21'-Ma16;'1980 and'Ma27'-30;'980 Re ort'No.'50-387 80-10

Areas'ns'ected:

Routine inspection by the. Resident Inspectors of:

1nsta ation and welding of reactor coolant pressure boundary and other piping; installation of safety-related components; ACR/PGCC configuration control; Pre-operational testing and procedures. The inspector s also performed plant tours and reviewed licensee actions on previously identified items.

The inspection involved 72 resident inspector-hours, including 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> during off shift, by the NRC,Resident Inspectors and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> by a regional based section chief.

Region I Form 12 (Rev. April 77)

8009xso Z-P

Results:

No items of noncompliance were identified.

Unit 2'ns ection'on'A ril'21'throu'h'Ma '161980'and a

'-','

Re ort No.

0-'3 8/ 0-06 Areas'ns ected:

Routine inspection by the Resident Inspectors of:

nsta at>on and welding of reactor coolant pressure boundary and other piping.

The inspectors also performed plant tours and reviewed licensee actions on previously identified items.

The inspection involved 13 inspector-hours,.including 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> during off shift, by the NRC Resident Inspectors:and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> by a regional based section chief.

Results:

No items of noncompliance were identifie DETAILS Persons Contacted Penns lvania Power and Li ht Com an Note W.

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Barberich, Nuclear, Licensing Group Supervisor Beckley, Site QAE Bragger, Nuclear Design Project Engineer G. Byram, Plant Supervisor of Maintenance Capotosto, Site QAE Clymer, Site QAE L. Denson, Project Construction Manager Eichlin, Senior Project Engineer, Construction D. Everett, ISG Quality Engineer H. Featenby, Assistant Project Director J. Gorski, Plant Quality Supervisor Gorski, Resident Engineer Kenny, Coordinator, Projects 5 Contracts Lazarowitz, Resident Engineer Male, Assistant Manager, Nuclear Plant Engineer Murray, Construction Project Engineer F. Oldenhage, Resident Engineer R. Sabol,'Manager, Nuclear Quality Assurance

'.

Schwarz, Senior Project Engineer, Construction Wetzel, Project Engineer, NQA

1,

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3, 4 3, 4 Bechtel Cor oration A.

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Acasio, Bechtel SFHO Engineering Bisesti, Manager, ACR/PGCC-NSSS Completion Cranston, Resident Project Engineer A. Drucker, Electrical QAE W. Figard, Assistant ISG Supervisor Gelinas, QC Lead Engineer Piping/Mechanical Headrick, Assistant Project Field QCE Khandar, Mechanical QAE Konjura, Mechanical QAE Lilligh, Project QAE Minor, Project Field Engineer Morey, Bechtel Engineer, Project Change Control O'ullivan, Assistant Project Field Engineer Peterson, Assistant Project Manager Quattrociocchi, Bechtel Gaithersburg Stout, Project Field QCE Trickovic, Bechtel Gaither sburg Turnbow, Field Construction Manager Engineer 1,

1,. 3

2 3, 4

'2

3 7

1

General Electric Com an -Nuclear Ener Business Grou NEBG Note E. A. Gustafson, Site Manager T.

M. LeVasseur, guality Assurance Representative General Electric Com an -Installation and Service IPSE G. Bragan, Site Manager Peabod Testin Com an M. Whalen, NDE Supervisor EGSG Idaho, Inc.

Wendell Banister, Project Manager Notes 1 - Denotes those present at the exit interview April 25, 1980.

2 - Denotes those present at the meeting on May 8, 1980.

3 - Denotes those present at the exit interview May 9, 1980.

4 - Denotes those present at the exit interview May 16, 1980.

The inspectors also interviewed other PP8L employees, as well as employees of Bechtel, Peabody Testing Company and General Electric Company.

Plant Tours - Units 1 and

The inspectors observed work activities in progress, completed work and plant status in several areas of the plant during general inspection of the plant.

The inspectors examined work for any obvious defects or noncompliance with regulatory requirements or license conditions.

Particular note was taken of presence of quality control inspectors and quality control evidence such as inspection records, material identification, nonconforming material identification, housekeeping and equipment preservation.

The inspectors interviewed craft personnel, supervision and quality inspection personnel as such personnel were available in the work areas.

No items of noncompliance were identifie.

Licensee Action on Previousl Identified Items

~

~

(Open) Unresolved Item (387/78-16-03; 388/78-15-01):

Stor age of RHR Heat Exchangers.

The inspector reviewed the licensee's actions relative to the storage condition of the Units 1 and

RHR Heat Exchangers.

The Unit 1 Heat Exchanger was in the process of being flushed as part of the RHR system flush. It is the intention of the Integrated Startup Group System Engineer to maintain the Unit 1 Heat Exchanger full of deminera-lized water when pre-operational testing is not in progress.

The responsible PPSL construction engineer has examined the internal condition of the Unit 2 Heat Exchanger and found that the recent cleaning and sandblasting appears to have been effective in that no severe corrosion was present.

The PPSL construction engineer was advised by the PPSL Engineering Department that consideration was being given to filling the Unit 2 Heat Exchanger with a potassium chromate solution for corrosion prevention.

A final decision on this system or an alternate method of corrosion control had not yet been made.

The inspector reviewed the following documents relative to this matter:

PP8L internal letters:

PLI-7377 PLI-7782 PLI-7865 PL I-7929 b.

This matter remains unresolved pending licensee determination of the corrosion control method to be used and review by the NRC.

(Open)

Unresolved Item (387/78-17-03; 388/78-16-01):

Classification of Crane Rails as Non-Safety Related.

The inspector observed rework of the refueling platform crane rails in progress including the replacement of the rail in accordance with Nonconformance Report No. 5539.

The inspector discussed with site management the contents of a request for additional information in a letter from the NRC to PPSL dated May 20, 1980.

The letter requests that the.licensee provide justification for the classification of

the refueling platform crane rails, clamps and clip plates as non-safety related.

The inspector stated that the installation of these items as non-safety related did not appear to meet the intent of the FSAR Section 9.1.4.

This matter remains unresolved pending the licensee's response to the NRC request for additional information.

c.

(Closed)

Unresolved Item (387/79-01-02):

Reactor Core Isolation Cooling (RCIC)

Pump Coupling Runout.

The inspector reviewed documentation regarding the licensee's evaluation of the RCIC pump coupling rim runout of.003 inches.

The RCIC Pump is a General Electric supplied component and therefore required concurrence from that organization.

Bechtel requested concurrence from GE that the referenced coupling runout reading was not detrimental to the operation of the coupling.

GE provided their concurrence that the runout readings were acceptable.

PP&L provided concurrence with the GE position.

Documentation reviewed by the inspector included:

Bechtel letters to GE:

M-789 dated January 22, 1979 M-1044 dated August 13, 1979 GE letters to Bechtel:

EAG-1024 dated January 29, 1979 EAG-1147 dated April 16, 1979 EAG-1573 dated October 18, 1979 PP8L internal letter:

PLI-8218 dated May 14, 1980 The inspector had no further questions on this matter at this time.

d.

(Closed)

Unresolved Item (387/79-31-07):

High Pressure Coolant Injection (HPCI) System Pump Installation.

The inspector reviewed documentation regarding the rework of the HPCI pump discharge piping.

Nonconformance Report (NCR) No. 4346 was reviewed by the inspector.

Additional documentation reviewed by the inspector included:

FCI-M-178, Revision

PPSL Deficiency Report No.

gCI M 2.20 Revision

gCIR 52.0-Ml-lP-204-1S-211-9-Final cold alignment of the HPCI Pump Bechtel drawings:

EBB-102-1 Vendor sketches EBB-102-1, Spools 1 and

Byron Jackson letter to Bechtel dated January 21, 1980 One administrative discrepancy in the NCR Documentation, regarding the identification of a vendor weld, was corrected during this inspection.'he inspector found that the rework conducted to complete the HPCI piping installation was in compliance with PSAR Appendix D commitments and NRC requirements.

The inspector had no further questions on this matter at this time.

4.

Confi uration Control a.

Documentation Review The inspector reviewed the following,project engineering procedures and field procedures related to the development, approval and change control of engineering drawings:

En ineerin Procedures Manual Section

Section'6 Section

Appendix G

Field Procedures FPG-4 Rev.

FPG-5 Rev.

FPG-18 Rev.

The inspector reviewed a draft of a configuration control document for the power generation control complex/advanced control room (PGCC/ACR).

The objectives of PGCC/ACR configuration control scheme are to establish a baseline for the equipment and develop procedural requirements to maintain currency of the configuration by a rigid

change control system.

The configuration will be documented in a Configuration Control Register.

No items of noncompliance were identified.

b.

~Meetin The licensee conducted a meeting on May 8, 1980 with PP8L, NRC and Bechtel Power Corp. personnel in attendance to discuss the configura-tion control scheme."

The licensee stated:

a.

The plan is still in a development phase and additional data will be incorporated in the register.

'b.

Implementation will probably occur within the next few months.

c.

The applicable Engineering Procedures and Field Procedures will be revised.

d.

PP8L, Bechtel and other personnel will be trained in the use of the configuration control register and applicable pro-cedures.

e.

PP8L and Bechtel quality assurance organizations will audit the implementation of the plan.

No items of noncompliance were identified.

c.

Plant Tour The inspector toured the PGCC/ACR facility.

Considerable craft activity was in process and quality control personnel were in evidence.

It was noted that environmental control of the ACR had been implemented and installation of environmental control equipment was in process in the lower relay room.

No items of noncompliance were identified.

5.

Pre-0 erational Testin a

~

Procedure Review The inspector reviewed preoperational Test Procedures P2.1 and P88.1 for the 125 VDC and 250 VDC systems.

The inspector verified that the preoperational tests as written demonstrated conformance with FSAR commitment The inspector noted two discrepancies in this regard.

FSAR Section 14.2.12.1 Preoperational Test Procedure Abstracts stated in part that one of the "Test Objectives" of the 125 Volt DC System pre-operational tests was to demonstrate that the battery chargers can fully charge their associated batteries from the battery minimum voltage limit while simultaneously providing power to distribution panels for normal station loads.

The battery minimum voltage limit is defined in this same section as that voltage limit which applies during the performance test (test discharge)

of the battery.

FSAR Section 14.2.12.1

"Test Method" describes the method for demon-strating battery charger capability by recharging the battery after completion of the service test on the battery.

Section 8.3. of FSAR also stated that battery charger should be capable of charging the battery from design minimum voltage while maintaining steady state electrical loads.

This design minimum voltage is equated to that voltage after the service test.

The test procedure P2.1 for the 125 VDC test was written to conform to FSAR Section 8.3 and the "Test Method" portion of FSAR Section 14.2. 12. 1.

The discrepancy between recharging after the performance test or the service test was brought to the attention of the Assistant Startup Group Supervisor.

A revision to the FSAR 14.2.12.1

"Test Objectives" has been submitted to state that the recharging requirement applies after the service test.

The second discrepancy noted was in FSAR Section 14.2.12.1 under "Pre-requisites"'f the 125 VDC test.

The "Prerequisites" states that the Hydrogen Monitoring System is to be available and/or in service be-fore performing testing on the 125 VDC system.

However, Susquehanna does not have a Hydrogen Monitoring System.

This discrepancy was brought to the attention of Assistant Startup Group Supervisor and an FSAR revision request was submitted to correct this statement.

The FSAR revisions will be reviewed during a subsequent inspection.

No items of noncompliance were identified.

Test Procedure Acce tance Criteria The inspector inquired if the values found in the Test Procedure acceptance criteria for the 125 VDC battery test were valid for all four batteries.

Acceptance criteria 2. 1(2) originally stated that each 125 Volt DC battery charger, 1D-613, 1D-623, 1D-633 and 1Di643

has the capacity to fully charge its associated battery from design minimum discharge (i.e. after the service test) to 1.210+

.010 Specific Gravity in a period of twelve hours while supplying power (44 + 2 amperes)

to simulate its normal 125 VDC loads.

(FSAR Section 8.3.2.1.1.4)

The inspector inquired how the 44 + 2 amperes was derived as the normal 125 VDC load.

Due to the inquiry Bechtel, San Francisco was contacted and the values were, changed to the following for each charger:

1D-612

-.

42 + 2 Amps 1D-622

-

49 + 2 Amps 1D-632

-

42.+ 2 Amps 1D-642

-

46 + 2 Amps No supporting documentation accompanied this change to the values.

The inspector also observed that Test Change Notices (TCN) had changed the Service Test Acceptance criteria for both P2.1 and P88.1 tests.

TCN number 1 to P88.1 changed Section 2.(6) from:

Each of the 250 Volt DC batteries has sufficient stored energy to supply DC power in accordance with the schedule specified below.

At the end of 240 minutes (four hours),

the voltage of each battery cell will equal or exceed 1.75 volts.

(FSAR Table 8.3-7)

(a)

Schedule:

Division I (1D650)

~ 1045 amperes for 1 minute 570 amperes for 29 minutes 115 amperes for 60 minutes 25 amperes for 150 minutes Total time:

240.0 minutes (b)

Schedule:

Division II (1D660)

1260 amperes for 1 minute 465 amperes for 44 minutes 185 amperes for 195 minutes Total time:

240.0 minutes To the following:

(a)

Schedule:

Division I (1D650)

1046 amperes for 1 minute 567 amperes for 29 minutes 113 amperes for 60 minutes 24 amperes for 150 minutes Total time:

240.0 minutes

(b)

Schedule:

Division II (1D660)

1260 amperes for 1.0 minute 465 amperes for 1.0 minute 365 amperes for 28.0 minutes 323 amperes for -60.0 minutes 185 amperes for'150.0 minutes Total time:

240.0 minutes TCN numbers 1, 2, 3, 4 correspondingly change the service test acceptance criteria in P2.1 Revision 1 Section 2.1(5) from:

Each of the 125 Volt DC batteries has sufficient stored energy to supply DC power in accordance with the schedule specified below.

At the end of 240 minutes (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />),

the voltage of each battery cell equals or exceeds 1.75 volts.

Schedule:

355 amperes for 1.0 minute 115 amperes for 29.0 minutes 105 amperes for'210.0 minutes Total time:

240.0 minutes (FSAR Section 8.3.2.1.1.4)

P To the following:

(a)

Schedule:

Channel A (1D610)

341 amperes for 1.0 minute 122 amperes for 239.0 minutes Total time:

240.0 minutes (b)

Schedule:

Channel 8 (1D620)

340 amperes for 1.0 minute 121 amperes for 239.0 minutes Total time:

240.0 minutes (c)

Schedule:

Channel C (1D630)

339 amperes for 1.0 minute 121 amperes for 239.0 minutes Total time:

240.0 minutes

(d)

Schedule:

Channel D (1D640)

322 amperes for 1.0 minutes 104 amperes for 239.0 minutes Total time:

240.0 minutes These TCN's were incorporated based on correspondence received from Bechtel, San Francisco.

The FSAR sections referenced above have not been revised nor did correspondence delineate what loads have changed to account for change in acceptance criteria.

The validity of these values will remain unresolved pending investigation by the licensee and review by the NRC.

(387/80-10-01)

~tt flit The inspector observed actual performance of the following portion of P2.1 Revision 1-125 volt DC system test:

Section 7.3.5-Battery 1D-610 service test.

and the following portion of P88.1 Revision 1-250 volt DC systems test:

Section 7.3.1-Battery 1D-650 performance test.

The inspector verified the following for both tests:

(a)

Latest revision of test procedures were available and in use by all crew members.

(b)

Minimum crew requirements were met.

I (c)

Test prerequisites were met.

(d)

Proper plant systems were in service to support test.

(e)

Special test equipment required by procedures were calibrated and in service.

(f)

Tests were performed as required by approved procedures.

(g)

Crew actions were correct and 'timely during performance of tes During verification of special test equipment calibration it was noted, on May 6, 1980, that two hydrometers Serial numbers EM-053 and EM-054 had been calibrated on November 8; 1979 and had a calibra-tion due date of June 8, 1980.

The inspector checked the calibra-tion index cards which listed the calibration frequency as a six month interval, and also listed the calibration due date of these instruments as June 8, 1980.

The calibration due date should have been May 8, 1980.

The inspector brought this discrepancy to the attention of the Assistant Instrument and Control Foreman who had these instruments recalibrated on May 6, 1980.

No items of noncompliance were identified.

d.

Timeliness of Procedure A

royal and NRC Notification Both P2.1 Revision 1 and P88.1 Revision 1 tests had been approved by the Test Review Board on March 25, 1980 and testing started on April 30, 1980, a period of 36 days.

FSAR Sections 3.13.1 and 14.2.7 commit to Regulatory Guide 1.68 Revision 1, January 1977 which states in Paragraph C.4 that approved test procedures should be available for review by NRC personnel from the Office of Inspection and Enforcement at least 60 days prior to their intended use.

The inspector also noted that this item had been discussed with the Assistant ISG Supervisor and Assistant Starting and Testing Co-ordinator as documented in NRC Inspection Report 50-387/79-39 paragraph 1.d.

The inspector made a review of the preoperational and acceptance test matrix Revision 9 dated May 15, 1980 with the following results:

These preoperational tests have been completed to date:

P5. 1A'-'480'Volt'Essential'Load Centers - TRB approved March 25,

- test comp ete prs P17;1 - Instrument AC - TRB approved March 27, 1980 - test comp ete pn

,

P57.1'-Uninterru table AC Power'S stem - TRB approved March 25,

- test comp ete pri

,

19 0 l:

To date no approved preoperational test has been available to the NRC within the 60 days as required above.

This. item will remain un-resolved pending further review by the NRC.

(387/80-10-02)

e.

Commitment to 60 Da Notification guestion 423.8 of the FSAR states:

Your position to have approved test procedures available for NRC review at least 30 days prior to intended use is not acceptable.

Revision 1 to the Standard Review Plan has been revised to, among other items, state that these procedures should be suitable for review at least 60 days prior to their intended use.

Revise Section 14.2.7 to be consistent with this position.

The licensee did revise Section 14.2.7 to be consistent with this policy, but did not change Section 14.2.3 to the FSAR which still commits to a lead time of 30 days between approval and scheduled implementation.

This was brought to the attention of Assistant Startup Supervisor who submitted a

FSAR revision request to update this section.

The FSAR revision will be reviewed during a subsequent inspection.

Ho items of noncompliance were identified.

Trainin Documentation The inspector verified by review of training records of the two Startup Engineers performing this testing that they had received required training.

The inspector noted that one of the engineers had failed to initial for required reading of the guality Assurance Manual/Program.

This was brought to the attention of the Power Production guality Engineer assigned responsibility of the Inte-graded Startup Group who had the engineer correct the discrepancy.

It was also noted that no orientation lecture/discussion was signed off in the training folders, although an orientation is specified as a requirement in AD-10-1-Revision '2 Startup Indoctrination and Training.

This item was brought to the attention of Assistant ISG Supervisor who incorporated this item into the training records.

Further review of Startup Group Training will be conducted during subsequent NRC inspection.

No items of noncompliance were identified.

6.

Electrical Penetration Cable Dama e

On April 22, 1980, the licensee reported to the NRC the discovery of the apparent deliberate cutting of several electrical cables about one foot from an installed containment electrical penetration, 1W105D.

A Bechtel Condition Report, No.

E-. 1086, was issued to document the condi--

tion and provide a disposition for repair.

The licensee issued a press release on this matter.

The inspector examined the cut cables and re-quested that the licensee notify the NRC of any further occurences of this nature.

7.

Reactor Coolant Pressure Boundar and Safet -Related Pi in (Weldin

)

The following activities were examined to determine that they were being performed in accordance with the ASME Section III and IX Codes, PSAR Appendix D, the Bechtel Quality Assurance Manual Section III, Site Spe-cifications M-204, M-207, drawings M-198 and M-199, G.E. specifications 24A4628, 22A4273 and 22A2693 and G.E.

18SE procedures 160-77E-0154, 11 MU-3, DWP 3004 and WQ-32 and the G.E.

IPSE QA Manual 18XA7005.

Weldin

- Units 1 and

Welding of:

DCA-242-1 FW2 (fitup only)

OBA-101-1 FW22 DCA-103-1 FW50 Jet Pump Riser E to brace arm (Unit 2 Reactor Internals)

The inspector verified selected detailed drawings, welding pro-cedures, base and filler materials as specified, welder qualifi-cation, quality control documentation, weld appearance, welding variables such as gas flow and amperage and nondestructive testing activities as appropriate.

No items of noncompliance were identified.

8.-

Reactor Protection S stem Power Su lies The inspector reviewed the following documents with regard to the Reactor Protecting System (RPS) electrical power:

FSAR Sections 7.2.1.1.1 7.2.1.1.2 FSAR Question Q32.25 G.E.

Design Specification 22A3052-MPL Number A61-4050 PAID - E-157 During this review the inspector noted that G.E. design specification 22A3052 Section 4.3. 1.6 stated for the RPS that:

Power supplies to systems which de-energize to operate (fail-safe power supplies)

require only that separation which is deemed prudent to give

reliability (continuity of operation).

Therefore, the protection system fly-wheel motor generator (MG) sets and load circuit breakers are not required to comply with the separation requirements of this specification for safety reasons even though the load circuits go to separated panels.

FSAR Section 7.2.1.1.2 which was revised due to FSAR Question Q32.25 states in part:

The reactor protection system (RPS) is classified as Safety Class 2,

Seismic Category I, and quality Group B - Electric Safety Class IE with the exception of the motor-generator power supplies which are non-Class IE and the RPS circuits located within the turbine building.

The RPS motor generators 1G201A, and 1G201B supply power to panels 1Y201A and 1Y201B respectfully.

It appears that all power to RPS and other loads off these two panels are installed as non-IE and non-safety related.

These loads include the main steam line radiation monitor panels, part of the-Nuclear Steam Supply Shutoff System.

Therefore these panels are being supplied by non-IE, non-safety related power, and in turn supply safety related components.

It was also noted that although installed as non-IE, and non-safety related, the normal and alternate power supplies to motor/generator 1G201A are from safety related 480 YAC Motor Control Centers 1B217 and 1B227 while the power supplies to 1G201B are from non-safety related Motor Control Centers 1B253 and 1B261.

The inspector inquired if the safety related systems supplied by the non-safety related power supplies had been reviewed to determine if any com-ponents that energized to perform their safety function were supplied power from this source.

This matter is unresolved pending licensee investigation and review by the NRC.

(387/80-10-03)

9.

Unresolved Items Unresolved items are matters about which, more information is required to ascertain whether they are acceptable items, items of noncompliance, or deviation.

Unresolved items disclosed during the inspection are dis-cussed in paragraphs 5.b, 5.d and.. Exit Interviews At periodic intervals during the course of this inspection, meetings were held with facility management (dates and attendees are denoted in Details 1) to discuss inspection scope and findings.