IR 05000416/1988012

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Insp Repts 50-416/88-12 & 50-417/88-01 on 880521-0624.No Violations or Deviations Noted.Major Areas Inspected: Licensee Action on Previous Enforcement Matters,Operational Safety Verification & Surveillance & Maint Observation
ML20151E641
Person / Time
Site: Grand Gulf  Entergy icon.png
Issue date: 07/05/1988
From: Butcher R, Dance H, Mathis J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20151E633 List:
References
50-416-88-12, 50-417-88-01, 50-417-88-1, NUDOCS 8807260155
Download: ML20151E641 (13)


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UNITED STATES

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Report Nos.: 50-416/88-12 and 50-417/88-01 Licensee: System Energy Resources, In Jackson, MS 39205 Docket Nos.: 50-416 and 50-417 License Nos.: NPF-29 and CPPR-119 Facility Name: Grand Gulf Nuclear Station Inspection Condu ted: May 21 - J ne 24, 1988 Inspectors: C h R. C Butcher, Seniof Resident Inspector 7kkf

/ Da'te Signed Nc k-/9~ Mathis,\Residerit Inspector kb' Da'te Signed Approved by: W 7 H. C. Dance,\Section. Chief 'Datt Signed Division of Reactor Projects SUMMARY Scope: This routine inspection was conducted by the resident inspectors at the site in the areas of Licensee Action on Previous Enforcement Mattec. Operational Safety Verification, Maintenance Observation, Surve111c'ce Observatica, ESF System Walkdown, Reportable Occurrences, Operating Reactor Events, Inspector Followup and Unresolved Items, and Review of Quality Assurance for Unit 2 Extended Construction Delay. All areas except for Unit 2 extended construction delay applies only to Utit Results: One unresolved item was identified involving inadvertent auxiliary lube oil pump starts on the Division 2 diesel generator, paragraph PDR ADOCK 05000416 0 PDC {

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w REPORT DETAILS 1, Persons Contacted Licensee Employees

  • J. G. Cesare, Director, Nuclear Licensing D. G. Cupstid, Start-up Supervisor
  • L. F. Daughtery, Compliance Supervi,sor J. P. Dimmette, Manager, Plant Maintenance
  • S. M. Feith, Director, Quality Programs
  • C, R. Hutchinson, GGNS General Manager
  • R. H..McAnulty, Electrical Superintendent A. S. McCurdy, Technical Assistant, Plant Operations Manager L. B. Moulder, Operations Superintendent J. H. Mueller, Mechanical Superintendent J. V. Parrish, Chemistry /Radiatior, Control Superintendent J L. Robertson, Superintendent, Plant Licensing

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R. F. Rogers, Manager, Special Projects

  • S. F. Tanner, Manager, Quality Services
  • L. G. Temple, I&C Superintendent F. W. Titus, Director, Nuclear Plant Engineering
  • M. J. Wright, Manager, Plant Support
  • J. W. Yelverton, Manager, Plant Operations
  • R. I. Dewitt, Unit 2 Construction Other licensee employees contacted included technicians, operators, security force members. and office personne * Attended exit interview Licensee Action on Previous Enforcement Matters (92702)

(Closed) Violation 416/84-24-0 The licensee modified the Standby Service Water system by Design Change Package OCP 84/5006 to install a siphon line between the basin The licensee's reaction to potential deficiencies has been very good and the NRC has been kept informed. No further action is require (Closed) Violation 416/84-24-02. The licensee's actions to resolve violation 416/84-24-01 resolved this issue also. No further action is require . Operational Safety, Radiological Protection and Physical Security Verifi-cation (71707, 71709 and 71881)

The inspectors kept themselves informed on a daily basis of the overall plant status and any significant safety matters related to plant opera-tions. Daily discussions were held with plant management and various members of the plcnt operating staf _ _ . . _ _ _ . . _ . _ . _ _ . _ . ~ . _ _ . . _ _ _ _ , _ _ _

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The inspectors made frequ]nt visits to the control room such that it was visited at least daily when an inspector was on site. Observations included instrument readings, setpoints and recordings, status of opera-ting systems, tags and clearances on equipment controls and switches, annunciator alarms, adherence to limiting conditions for operation, temporary alterations in effect, daily journals and data sheet entries, control room manning, and access control This inspection activity included numerous informal discussions with operators and their supervisor Weekly, when the inspectors were onsite, selected Engineered Safety Feature (ESF) systems were confirmed operable. The confirmation is made by verifying the following: accessible valve flow path alignment, power supply breaker and fuse status, major component leakage, lubrication, cooling and general condition, and instrumentatio General plant tours were conducted on at least a biweekly basis. Portions of the control building, turbine building, auxiliary building and outside areas were visited. Observations included safety related tagout verifica-tions, shift turnover, sampling program, housekeeping and general plant conditions, fire protection equipment, control of activities in pro'gress, problem identification systems, and containment isolation. The licensee's onsite emergency response facilities were toured to determine facility readines The inspectors reviewed at least ore Radiation Work Permit (RWP), observed

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health physics management involvement and awareness of significant plant activities, and observed plant radi& tion controls. The inspectors verified licensee compliance with physical security manning and access control requirement Periodically the inspectors verified the adequacy of physical security detection and assessment aid The inspector reviewed the radiation monitoring instrumentation used

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to satisfy T.S. Table 3.3.7.1-1, Radiation Monitoring Instrumentatic Technical Specification Position Statement (TSPS) 069 provides a list of instrumentation used to satisfy items one thru nine of Table 3.3.7.1- It was found that instruments D17-RITS-K621A, K609A, K617A and K618A on control panel 1H13-P669 and -instruments D17-RITS-K621C, K609C, K617C and K618C on control panel 1H13-P671 did not have the instrument number listed for identification. Only a descriptive name was provided. The addition of identifying numbers to the above instruments will be tracked as Inspector Followup Item 416/88-12-0 Material Nonconformance Report (MNCR)-0094-88 was originated on April 11, 1988, to provide for the evaluation of the Low Pressure Core Spray (LPCS)/

Residual Heat Removal A (RHR A) Differential Pressure (DP) line break instrumentation. As previously described in Inspection Report 416/87-40, the LPCS/RHR A DP line break annunciator alarmed at approximately 80 percent power during startup from the second refueling outag After evaluation of MNCR 0015-88, which was originated at that time, the s

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LPCS/RHR A DP setpoint was revised to reflect the normal indicated OP at'that tim The setpoints determined at that time were documented in surveillance procedure 06-IC-1E31-R-0021. The high DP alarm was- set at 2.7 psid and the low OP alarm was set at 0.9 psid. Subsequently, the indicated LPCS/RHP. A OP has slowly decreased until the low alarm trippe The licensee has verified the calibration of the transmitters and trip unit The sensing lines were backfilled and vented and the licensee concluded that the instrumentation is working correctly. .New data taken '

during. power changes down to 75% power indicate that the LPCS line is not broken. Data now indicates that the downward trend in the LPCS/RHR A DP has stabilized and new setpoints were determined. By assuming a new normal range of 0.6 to 0.9 psid and using TS 4.5.1.c.2(b) tolerance of 1.2 psid, the new setpoints were determined as follows:

0.6 psid + 1.2 psid = 1.8 psid high alarn 0.9 psid - 1.2 psid = 0.3 psid low alarm On June 3,1988, the licensee revised the LPCS/RHR A DP instrumentation setpoints and cleared the line break annunciator. The licensee could not define the cause of the DP drif t downward but concluded that further changes in DP will require evaluation to ensure that a line break has not occurre On May 27, 1988, a HP technician entered the cask washdown pit area on the 208 foot elevation of the auxiliary building. The technician was. wearing double PCs and a respirator as required by RWP 88-05-001. When he entered the PCM-1 radiation monitor at the 93 foot level of the control building, he received an alarm on the face detector. A careful survey of his face showed no contamination and he subsequently re-entered the PCM-1 and passed. At 11:20 a.m. , the same day, af ter exiting the chemistry labora-

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tory, he entered the PCM-1 at the entrance to the water treatment building and received an alarm. A particle was lifted off the skin with a piece of adhesive tape by HP technician and then the particle was surveyed with a frisker and showed 3800 CPM on contact with the frisker probe, and 2800 CPM at approximately 1 CM from the probe. IE Information Notices (IENs)

86-23 and 87-39 provided information on events involving excessive skin exposures resulting from skin contamination by small, highly radioactive particles with high specific activity (Hot Particle). The licensee was cognizant of the IE Notices. The chemistry department performed a nuclide identification of the particle. The results showed that the only nuclide present was Ruthenium (RH)-106. Ruthenium has never been identified in isotopics performed on smear surveys at Grand Gul The licensee has concluded that this particle originated at Waterford Nuclear Plant and survived the laundering process at Incerstate Nuclear Services (INS). Routine receipt inspection performed approximately one week later on incoming laundry from INS re.ealed through surveys hot particle existed on the laundry. The particles were removed by tape and

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analyzed through isotopic analysi The licensee contacted INS of the hot particle and plan to survey 100% of all incoming laundry in the futur NRC Region II was notified by the licensee of their finding No. violations or deviations were identifie . Maintenance Observation (62703)

' During the -report period, the inspectors observed portions of the. main-( tenance activities listed below. The observations included a review of the Maintenance Work Orders (MW0s) and other related documents for adequacy, adherence to procedure, proper tagouts, adherence to technical

' specifications, radiological -controls, observation of all or part of the actual work and/or retesting in progress, specified retest requirements, and adherence to the aopropriate quality control MWO ME4486 Clean PSW Side of CCW Heat Exchanger MWO ME3154 Lube Oil Heater Pump Flexible Coupling Lubrication-MW0 M82183 Retorque Air Start Valve Capscrews at Approximately 1969 Engine Run Hours MWO IND600 Install / Remove Annubar in Accordance with Operation Instruction For 0rywell Purge Compressor Cocier Flow MWO M76046 Refurbish Spare MSIV Actuator per WI&IR MW0 182716 Rework CRD Auxiliary 011 Pressure Svicch MWO M30649 SSW Cooling Tower Fan 52-16506 (Q1P41C003D)

MWO M82041 Disassemble. Rework Valve Internals for RCIC Steam Supply *

Isolation Valve MW0 L82874 Clean SSW Basin A Floor per WI&IR No violations or deviations were identifie . Surveillance Observation (61726)

The inspectors observed the performance of portions of the surveillances listed below. The observation included a review of the procedure for technical adequacy, conformance to technical specifications, verification of test instrument calibration, observation of all or part of. the actual surveillances, removal from service and return to service of the system or components affected, and review of the data for acceptability based upon the acceptance criteria.

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06-IC-1E31-M-0023 Revision 28, RCIC/RHR and RCIC Steam Line High Flow Functional Test 06-IC-1C71-M-0001 Revision 25, Drywell High Pressure Functional Test (RPS/PCIS)

06-IC-1C71-M-1003 - Revision 23, Turbine Control Valve Fast Closure (RPT/EOC RPT) Functional Test-06-IC-1E12-M-0001 Revision 23, LPIC System C Discharge Line High/ Low'

Pressure Functional Test 06-0P-1P41-Q-0005 Revision 26, SSW Water Loop B Valve and Pump Opera-bility Test 06-EL-1E30-M-0001 Revision 21, Suppression Pool Makeup Time Delay Relay Calibration and Finctional Test No violations or deviations were identifie . Engineered Safety Features System Walkdown (71710)

A. complete walkdown was conducted on the accessible portions of the Control Room HVAC Syste The walkdown consisted of an inspection and verification, where possible, of the required system valve alignment, including valve power available and valve locking where required, instru-mentation valved- in and functioning; electrical -and instrumentation cabinets free from debris, loose materials, jumpers and evidence of rodents, and system free from other degrading condition The following minor discrepancies were noted, Valve Z51-F039A, A/C unit A level connection, was not labeled, A fire protection water line is not shown between charcoal and HEPA filter en P&ID drawing M-004 Relief valve line drain isolation valves, Z51-F078 and Z51-F077, are not differentiated by designation of A or B for the appropriate syste The actual configuration of flow switch FSN-033 out in the field is different that depicted on drawing M-004 The flow switch in the field has only one sensor connection versus two shown on the drawin Correction of the minor discrepancies identified above will be tracked as I Inspector Followup Item 416/88-12-0 No violations or deviations were identifie . .

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6 Reportable Occurrences (90712 and 92700)

The below listed event reports were reviewed to determine if the infor-mation provided met the NRC reporting requirement The determination included adequacy of event description and corrective action taken or planned, existence of potential generic problems and the relative safety significance of each event. Additional inplant reviews and discussions with plant personnel as appropriate were conducted for the reports indicated by an asterisk. The event reports were reviewed using the guidance of the general policy and procedure for NRC enforcement actions, regarding licensee identified violation The following License Event Reports (LERs) are closed:

LER N Event Date Event

  • 88-004 January 12, 1988 RWCU System Isolation due to Procedural Deficiency
  • 88-009 February 27, 1988 Hydrogen Ignition in the Offgas System
  • 88-011 March 17, 1988 Inadvertent RHR Pump Start due to Personnel Error The event of LER 88-009 was discussed in Inspection Reports 416/88-05 and 416/88-0 The event of LER 88-011 was discussed in Inspection Report 416/88-0 No violations or deviations were identifie . Operating Reactor Events (93702)

The inspectors reviewed activities associated with the below listed reactor event The review included determination of cause, safety significance, performince of personnel and systems, and corrective actio The inspectors examined instrument recordings, computer printouts, opera-tions journal entries, scram reports and had discussions with operations, maintenance and engineering support personnel as appropriat On May 26, 1988, during a Division 2 diesel generator surveillance run per surveillance procedure 06-0P-1P75-M-0002, the auxiliary lube oil pump inadvertently started when the diesel generator was starte The operator, following instructions per 06-0P-1P75-M-0002, then secured the auxiliary lube oil pump and made comment to that effect on the surveillance shee Similar events had previously occurred on March 2, 1988 and March 30, 1988, except at that time when the auxiliary lube oil pump was secured the diesel had trippe These previous events were reported to the NRC in Special Reports88-001 dated March 29, 1988, and 88-001/1 dated April 5,

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y, 7 198 Based on the March events the cognizant maintenance engineer discussed with the diesel manufacturer, IMO-Delcual, the issue of the auxiliary lube oil pump automatically starting when the diesel generator is' started. IMO-Delaval indicated verbally that due to the many variables which control the. automatic starting of the auxiliary lube oil pump, its automatic start during a diesel generator start is not considered an abnormal event and is not detrimental. to the diesel _ engine or its oil system. As noted in the referenced special reports the auxiliary lube oil 4 pump functions as a backup to the engine driven lube oil pump and starts on low lube oil pressure if diesel speed is greater than 425 RP The auxiliary lube oil pump does not normally start during a diesel star Based on discussion with the diesel manufacturer the licensee modified the monthly functional surveillance procedures, 06-0P-1P75-M-001/-002 and the diesel operating instruction, 04-1-01-P75-1 to define conditions required to be met prior to shutting down the auxiliary lube oil pump in case of a inadvertent start. The Updated Final Safety Analysis Report (UFSAR)

paragraph 9.5.7.2.1, Standby Diesel Generator Lubr.' cation System, states that each standby diesel engine is provided with two 100 percent capacity pumps. One pump is engine driven and a second pump is AC motor drive During normal operation, the engine driven pump provides fuel oil flow ~.

In the event of a failure in the engine driven pump, the rcdundant AC motor driven pump would provide full oil flow to the ' diesel engine, buring engine operation both pumps provide a pressurized, filtered, and cooled oil supply to the engine lube oil headers. The changes to the licensee's procedures for operation of the diesel generators appear to meet the criteria of 10 CFR 50.59 which permit changes to che facility and procedures as described in the safety analysis report but which must include a written safety evaluation which provides the basis for the determination that the change, test or experir.ent does not involve an unreviewed safety questio The licensee did accomplish a 10 CFR 50.59 safety evaluation applicability review and answered no to the question of does the procedural revisions constitute a change to the facility or a change to procedures as described in the FSAR. No written safety evalua-tion was performe Subsequently, oon June 8, 1988, when starting the Division 2 diesel generator following maintenance, the auxiliary lube oil pump again started inadvertently. The operators checked the criteria for shutting down the auxiliary lube oil pump and verified the criteria was met. When the auxiliary lube oil pump was shut down the diesel tripped on low turbocharger oil pressur The licensee determined that a loose fitting on the oil supply line to the low turbocharger lube oil pressure switch contributed to a false low turbocnarger lube oil pressure signal which initiated the diesel generator trip. Following the tightening of the lube oil pressure switch fittings, the Division 2 DG was started twice and the auxiliary lube oil pump did not start either time. The criteria for preventing auxiliary lube oil pump start is that the main lube oil pump must produce 30 psig by the time the diesel reaches 425 rp The Division 1 and Division 2 diesel generators were then instrumented to determine lube oil pressure and diesel rpm during startu During subsequent diesel generator starts the auxiliary lube oil pump inadver-tently started again. A telecon was held on June 23, 1988, between the t

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licensee,.the resident inspectors and NRC headquarters personnel to discuss the . licensee's investigation findings and proposed actions

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rsgarding the diesel generator operational problems. The licensee has determined -that 'the reason for the occasional low oil pressure and resultant start of the auxiliary lube oil pump was due to a deteriorated foot valve in the lube oil intake system. This finding was documented on-Incident Report 88-6- The deteriorated foot valve permitted the lube oil line to drain down when not operationa Some of the licensee's proposed actions were:

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Review the material used as a sof t seat in the foot valv Develop an improved test for the foot valve to cisclose deterioratio Evaluate disassembling the foot valve for. more detailed inspection whenever maintenance is accomplished in the diesel sum Review past diesel generator surveillance runs to catch any unusual comment The -licensee will report the latest DG event by special report and was requested to include their proposed corrective actions as discussed in the telecon. The licensee is also reviewing this finding to determine if a 10 CFR 21 report is applicable, The inspectors are concerned with_the adequacy of the licensee's initial investigation of the inadvertent start of the auxiliary lube oil pump on the Division 2 diesel generator. It appears that procedures were revised to permit securing the auxiliary lube oil pump without requiring adequate investigation to determine the root cause for the inadvertent start Also, the inspectors _ feel that a written safety evaluation per 10 CFR 50.59 should have been performed prior to revising procedure Resolution of the inspectors concerns and followup of the licensee's corrective actions will be Unresolved Item *

416/88-12-0 Control rod 40-41 scrammed from the full out position (step 48) on June 22, 1988, at 1:37 a.m., a Division 1 fuse supplying power to the scram solenoid valve for rod 40-41 had blown. No indication exists to alert operators that power to solenoid valves has been interrupted. While performing a surveillance, power to the B trip system was deenergized resulting in actuations of both the A and B trip systems. This resulted in control rod 40-41 scrammir.g. Reactor power was reduced to 90 percent to verify fuel preconditioning limits had not been exceeded. Chemistry sampled the reactor coolant to verify no fuel damag The licensee initiated Incident

"Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or devia-tion \

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Report (IR)' 88-6-8 to document this event. Plans to recover rod 40-41 is scheduled during the next rod sequence exchange. The licensee plans to monitor thermal limits to verify that they are not violate No violations or deviations were identifie . Inspector Followup and Unresolved Items (92701)

(Closed) Inspector Followup Item 416/86-39-02. Piping and Instrument Diagram M-1077C was revised to reflect the as built condition of. using a 3/4 inch by 2 inch reducing tee from the booster compressor to check valves B21-F130A and B21-F130B. Also, Surveillance Procedure 06-0P-1821-C-0003 was revised to delete valves B21-F082A,B,C,E,G,K,L,M and N. Valve B21-F082T was adde No further action is require (Closed) Inspector Followup Item 416/86-39-06. Procedure 04-1-01-P53-1, Instrument Air System, Revision 31 has valve IP53-FA001 located in area 9 on elevation 139. This item is close (Closed) Inspector Followup Item 416/86-21-01. The licensee has revised System Operating Instruction 04-1-01-C41-1 and Piping and ' Instrument Diagram M-108? to show valve C41-F151 as locked close. Also, 04-1-01-C41-1 was revised to required valve C41-F006 to be locked open. This item is close (0 pen) Inspector Followup Item 416/88-08-02. In Inspection Report 416/88-08, the licensee evaluation of a potential loose part in recirculation loop B was discusse At that time the licensee had developed. data to justify operation of the reactor for a period of op to 90 days beyond April 7,198 Subsequently, by a letter dated May 26, 1988, GE documented to the licensee their evaluation which justified continued plant operation up to the beginning of the third refueling outage under the following condition Monitoring of loop B noise levels will be performed at least every other day to detect any potential increase 1,n noise levels during lengthy periods when the flow control valve is set at one positio Significant increases (approximately 50'. or more) of impulsive forces or "g" levels with the FCV set at one position are identified and will be further evaluate The licensee's Engineering Department dispositioned Material Nonconfor-mance Report (MNCR) on an interim basis requesting monitoring of noise levels as recommended by GE. Other actions, such as adding additional noise monitors to the B recirculation loop is being studied.

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1 Review of Quality Assurance for-Unit 2 Extended Construction Delay (92050)

The inspection was conducted to provide a periodic review of Qurlity Assurance.(QA) activities for a construction site under an extended dela The inspection was to deterrnine. whether the '_ licensee had established adequate QA' implementation -plans, instructions and procedures which.are in conformance with the establish QA pla ' A Preventive Maintenance (PM) program for Q-listed, balance of plant and ASME section III~ equipment is the responsibility of Bechtel Power Corporation. Construction Work Plan / Procedure WP/P-1 establishes the Bechtel Construction Department programs for compliance with and imple-mentation of the QA responsibilities assigned to the construction department. Construction Work Plan / Procedures WP/P-14, Material Control, and WP/P-15, Maintenance of Materials and Equipr..ent, are the controlling documents for the PM program during this delay period. Bechtel controls and tracks the frequency of maintenance and inspections of all equipment '

by the ute of their Instorage Maintenance System Bulk Listin The inspector reviewed the applicable procedures, walked tnrough the Unit 2 power block and onsite warehouse to verify that eqm pment is properly maintained as described in WP/P-1 The following components were verified to have received the proper PM:

HPCS Pump Motor E22C001 Inspected 06/22/88 Energized / Check Space Heater Inspected 06/22/88 Visual Standby Service Water Valve P41F122B Inspected 06/22/88 For Visual i Control Rod Drive Valve C11F083 Inspected 06/22/88 For Visual Component Cooling Water Valve P42F200A

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Inspecteo 06/22/88 For Covering Standby Service Water Valve P41F190 i Inspected 06/22/88 Visual Inspected 06/22/88 Humidity RHR A Valve E12F047A Inspected 06/22/88 Visual Inspected 06/22/88 For Covering Suppression Pool Maket.p Valve E30F5:1A Inspected 06/22/88 Visual

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RCIC Pump E51C001 Inspected 06/14/88- Apply -Rust Corrosion Preventive to all Machine Surfaces

' Inspected 06/14/88 Visual Fuel Handling Platform kssembly Bridge ~0 rive Gear Case Inspected 06/03/88 Visual Fuel Pool Pump Motor G41C001A Inspected 05/23/88 Visual Fuel Pool Pump G41C001A Inspected 05/20/88 Rotate Shaft Inspected 05/19/88 Check Dessicant RHR B Pump Motor E12C002B Inspected 04/19/88 Check 011 Inspected 04/01/88 Rotate Shaft Inspected 04/01/88 Megger Inspected 05/27/88 Visual HPCS Metal Clad Switchgear HPCS Transformer 750 KVA Inspected 06/01/88 Visual EMD OSL Engine E22S001 Inspected 06/13/88 Visual Air Exhaust Silencer Inspected 06/13/88 Visual Air Intake Silencer Inspected 06/07/88 Vacuum Surface of D/G and all Equipment on Skid The System Energy Resources, Inc. (SERI) QA organization is required to perform audits of Bechtel to assura compliance with their QA program and to assure that they are acceptably implemented. The inspector reviewed the following QA audits conducted by the SERI QA organization for compli-ance to the QA Manual and had no comments: ,

MAR-87/2-0003 Unit 2 QSA-88/2-0001 Unit 2 No violations or deviations were identifie . Exit Interview (30703)

The inspection scope and findings were summarized on June 24, 1988, with those persons indicated in paragraph 1 above. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio The licensee had no comment on the following inspection findings:

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416/88-12-01, Inspector Followup Item. Addition of identification labels to instruments on panels 1H13-P669 and 1H13-P671 (paragraph 3).

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416/88-12-02, Resolve discrepancies noted during control room HVAC system walkdown (paragraph 6).

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416/88-12-03, Unresolved Ite Corrective actions for inadvertent auxiliary tube oil pump starts on Division 2 diesel generator (paragraph c).