IR 05000445/1988022

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Insp Repts 50-445/88-22 & 50-446/88-19 on 880302-0405.No Violations Noted.Weaknesses in Training Programs Identified. Major Areas Inspected:Nrc Bulletin Followup,Monthly Maint Observation,Fuel Receipt & Storage & Reg Guide 1.97 QA
ML20151N793
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 04/20/1988
From: Bitter S, Burris S, Joel Wiebe
NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20151N791 List:
References
RTR-REGGD-01.097, RTR-REGGD-1.097 50-445-88-22, 50-446-88-19, IEB-84-03, IEB-84-3, NUDOCS 8804260016
Download: ML20151N793 (15)


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4 U '. S. NUCLEAR' REGULATORY COMMISSION OFFICE OF SPECIAL-PROJECTS NRC Inspection Report: 50-445/8b-22 Permits: CPPR-126 50-446/88-19 CPPR-127 Dockets: 50-445 Category: A2 50-446 Construction Permit Expiration Date:

Unit 1: August 1, 1988 Unit 2: Extension request submitte ~ App'licant : TU Electric Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name: Comanche Peak Steam Electric Station (CPSES),

Units 1 and 2 Inspection At: Comanche Peak Site, Glen Rose, Texas Inspection Conducted: March 2 through April 5, 1988 Inspector: . !- Sk 4/10f99 D. Bitter, Resident Inspector, Date Operations Inspector: Ulkt0 ho

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S. P. Burris, Resident Inspector, Preoperational Testing Reviewed:by: M AO d , S. Wiebe, Lead Project Inspector '/Uatp

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8804260016 880420 PDR ADOCK 05000445 Q DCD

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Inspection Summary Inspection Conducted: March 2 through April 5, 1988 (Report 50-445/88-22; 50-446/88-19)

Areas Inspected: Unannounced resident. safety inspection of applicant's action on previous open and unresolved items, applicant's action on previous violations and deviations, NRC bulletin follow-up, monthly maintenance observation, fuel receipt and storage, Regulatory Guide 1.97 quality assurance commitments, preoperational testing program, plant tours, and FSAR Amendment 67 revie Results: Two applicant-identified violations in the fuel receipt and storage area indicate a weakness in the. training programs for reactor engineers and for radiological controls (paragraph 6).

These are identified as unresolved items pending NRC review of corrective actions. During inspection tours, two other unresolved issues were identified (paragraph 9). The first concerned the use of snubbers and sensing lines for climbing and is of moderate safety significance, because snubbers may have been rendered inoperable. The second concerned the existence of inaccurate equipment lists that could be used for maintenance planning and is of minor safety significanc *

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I DETAILS Persons Contacted

  • R. W. Ackley, Project Manager, Stone & Webster-Engineering Corporation (SWEC)
  • R. P. Baker, Licensing Compliance Manager, TU Electric
  • D. N. Bize, Licensing Compliance Supervisor, TU Electric
  • M. R. Blevins, Manager, Technical Support, TU Electric
  • J. T. Conly, Lead Licensing Engineer, SWEC
  • W. G. Counsil, Executive Vice President, TU Electric
  • C. G. Creamer, Instrumentation & Control (I&C) Engineering Manager, TU Electric
  • G. G. Davis, Nuclear Operations Inspection Report Item Coordinator, TU Electric
  • R. D. Delano, Licensing Engineer, TU Electric J. W. Donahue, Operations Manager, TU Electric
  • M. D. Gaden, CPRT, IT Corporation
  • P. E. Halstead, Manager, Quality Control (QC), TU Electric
  • L. Heatherly, Licensing Compliance Engineer, TU Electric
  • T. Jenkins, Manager, Mechanical Engineering, TU Electric
  • J. Kelley, Manager, Plant Operations, TU Electric
  • J. LaMarca, Electrical Engineering Manager, TU Electric
  • W. Lowe, Director of Engineering, TU Electric
  • M. McAfee, Manager, Quality Assurance (QA) TU Electric
  • W. Muffett, Manager of Civil Engineering, TU Electric
  • D. Nace, Vice President, Engineering & Construction, TU Electric '
  • E. Noss, QA Issue Interface Coordinator, TU Electric
  • M. Reynerson, Director of Construction, TU Electric
  • M. Riggs, Plant Evaluation Manager, Operations, TU Electric
  • Scott, Vice President, Nuclear Operations, TU Electric
  • Scott, Manager, Startup, TU Electric
  • Smith, Plant Operations Staff, TU Electric
  • M. Steelman, CPRT, TU Electric
  • J. Streeter, Director, QA, TU Electric
  • T. G. Tyler, Director of Projects, TU Electric
  • R. D. Walker, Manager of Nuclear Licensing, TU Electric

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The NRC inspectors also interviewed other applicant employees and contractors during this inspection perio * Denotes personnel present at the April 5, 1988, exit meetin . Applicant's Action on Previous Open and Unresolved Items (92701)

l During the inspection period the inspectors reviewed the status of NRC open and unresolved item The inspectors reviewed the applicant's documentation to determine the actions taken to resolve each item. Verbal comments on each

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item were provided to ensure that the applicant understood those actions, which in the inspector's opinion, would be necessary to resolve each item. The following items were reviewed: (Open) Open Item (445/8717-0-01): "Administrative Procedural Controls for the Prestart Test Program." This item developed from a concern that adequate procedural controls were not in place to define organizational responsibilities for systems, components, or structure The inspectors reviewed this item to ascertain whether or not the applicant's action provided adequate administrative control The applicant has implemented some changes to Station Administration Manual Procedure STA-80BA, Revision 1,

"Unit 1 Prestart Test Program," to address this issue; however, all of the necessary changes to the affected STAS and incorporation of the new Test Department Administrative procedures (TDAs) into the applicant's administrative program has not been complete This item will remain open pending future NRC revie (closed) Unresolved Item (445/8503-U-01, 446/8502-U-01):

"Refueling Cavity Water Seals." This item was administratively closed; it will be tracked as open bulletin Item 445/IEB 84-03, 446/IEB 84-03, as discussed in paragraph 4 of this repor . Applicant's Action on Previous Violations and Deviations (92702)

During the inspection period the inspectors reviewed the applicant's action on previous violations and deviations. The applicant's documentation was reviewed to ensure that the previously submitted root cause, corrective actions, and actions to prevent recurrence adequately addressed the NRC identified items. The implementation of the corrective actions specified in the applicant's response was reviewed to determine adequacy. The following items were reviewe (Open) Deviation (445/8716-D-01): Failure to have controls to ensure adequate rotesting. The original issue concerned the applicant's failure to adequately <

provide rotesting of systems or design features that have been maintained or modified following preoperational testing and prior to licensing as identified in the FSAR commitment to Regulatory Guide 1.68, Revision 2, 197 The inspectors reviewed all available documentation completed to date. The review determined that Station Administration Manual Procedure, STA-606, had been revised to include the Startup organization in the review cycle of all completed work procedures ensuring

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Regulatory Guide 1.68 retest requirements would be me However, to date the inspectors could not verify that the startup procedures included the controls necessary for the systematic review and closeout of retesting issues resulting from these work. procedures. The applicant committed to provide the necessary documents and any additional changes for the inspectors review during a future inspection perio (Closed) Violation (445/8713-V-01): During completion of hydrostatic test work on the positive displacement charging pump, TBX-CSAPPD-01, as identified in startup work permit (SWP Z-2214), the applicant failed to provide the required vendor bolt retorquing requirement Following the identification of this problem, the applicant issued two nonconformance reports (NCR) which identified this deficiency for each uni Nonconformance Report NCR-PM 87-00576 (Unit 1) addressed the retorquing requirements as identified in the Westinghouse (W) vendor manual (CP-0001-048,Section III). QC acceptance of the completion of the retorque requirements, in accordance with the construction operation traveler (MW87-8061-1-4901) on January 14, 1988, verified that the actual work activities were completed. The inspectors reviewed the final closecut package to ensure that the applicant's post work review had been satisfactorily completed. This item was closed out by the applicant on the 18th of March, 1988. The inspectors consider this close (Closed) Violation (445/8727-V-02): The applicant failed to follow prerequisite Test XCP-EE-9, Revision 6,

"Initial Motor Rotation and Run-In," in that paragraphs 4.15 and 7.7 of the test procedure required the verification of correct termination and rotation of the motor prior to full ru Paragraph 6.0 of the test procedure also required a review of the vendor instruction which specified that the blower fan must be reversed if the leads are reversed. The applicant has retrained testing personnel concerning the necessity of determining proper motor rotatio In addition, Procedure XCP-EE-9 has been changed to require a Test Deficiency Report (TDR) to be generated whenever the rotation of a motor is different from the indication specified by vendor. These TDRs will require a technical review and justification, in accordance with procedural requirements, for changing vendor rotation requirement Based on this specification, this item is considered close .-

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4. NRC Bulletin Follow-up (92703)

(Open) IEB 84-03, (445/IEB 84-03, 446/IEB 84-03): "Refueling Water Cavity Seals." The NRC inspectors reviewed the applicant's file for IE3 84-03 to verify that the applicant has taken the actions required by the bulleti The response (addressed in detail in NRC Inspection Report 50-445/85-03, 50-446/85-02) explains the CPSES reactor cavity water seal design and commits the applicant to revise procedures in two_ areas:

. Alarm procedures will be revised to address the possibility of a refueling cavity seal lea . Refueling procedures will be revised to include the requirement for a visual check for seal leakage after filling the refueling cavit The applicant has generated revised alarm and refueling procedures for Unit 1. After these procedures are approved, they will be reviewed during a future inspection. This item remains open pending review of the document No items of concern were note . Monthly Maintenance observation (62703)

During this inspection period, the inspector observed portions of selected maintenance activities. The inspector reviewed clearances, examined work packages, and observed electrical and mechanical trouble-shooting for two maintenance activities:

. Unit 1, Train B Residual Heat Removal (RHR) pump motor lower bearing modificatio . Unit 1, Train B Auxiliary Feed Water (AFW) I cmp motor-trouble-shooting for the cause of spurious trippin In each case, no violations were identified. However, upon attempting to install a nut and locking tab washer on the rotor of the RHR pump motor, Electrical Maintenance discovered that the lock washer provided would not fit without being machined. Because no documentation concerning the machining has been provided to electrical maintenance, the reinstallation of the RHR pump motor has been deferred by the applicant pending further review. This item remains open pending review during a subsequent inspectio (445/8822-0-01), "Nonconforming Lock Washer."

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i 7 Fuel Receipt and Storage (60501)

During this inspection. period, the inspectors reviewed the Special Nuclear Material (SNM) license for compliance with license conditions, performed a walkdown of the fuel building, and witnessed a semi-annual surveillance (partial inventory)

of unirradiated SNM in storag . A spot check of several SNM license conditions revealed that the applicant is in complianc . The fuel building walkdown revealed that access control, radiological controls, and cleanliness were adequat . Witnessing the semi-annual surveillance of unirradiated SNM in storage revealed no discrepancies in the storage of fuel and excore neutron detectors. However, the applicant noted that prior to the surveillance team entering the new fuel storage vault, a security officer entered the vault. In doing so, he violated Station Administration Manual Procedure STA-803, Section 6. and STA-656, Section 6.1.2. Section 6.2.2 of STA-803 states that a blue-striped badge is required for access to areas where new fuel is store Section 6.1.2 of STA-656 states that all routine entries into a radiation controlled area require a General Access permit (GAP) or a Radiation Work Permit (RWP). The security officer did not have a blue-striped badge and was not covered under a GAP or RWP. This item remains unresolved pending NFC review of the applicant's corrective action (445/8822-U-02), "Violation of Radiological and SNM Access Requirements."

Although, no deviations or violations were identified by the inspectors during their inspection of fuel stcrage and accountability, the applicant did identify a violation of their SNM licens In a letter dated January 25, 1988, (Log TXX 88139), the applicant explained that the violation was discovered during a

' review of fuel receipt documentatio Specifically, the violation occurred during shipments 15 and 16 of fuel, received on January 11 and 17, respectively, 1984. The SNM license limits the size of fuel shipments to 12 fuel assemblies per shipmen However, shipments 15 and 16 consisted of 14 and 13 fuel assemblies, respectively. The applicant's review of the violation (addressed in a follow-up letter dated February 26, 1988; Log TXX 88245) indicates that there was no nuclear safety significance and that no violation t of intent occurred. The intent of limiting the size of l each shipment was to limit the maximum number of fuel

! assemblics that could be loaded into the spent fuel pool

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prior to verifying the loading patter In.the case of shipraents 15 and 16, the assemblies were loaded into the new fuel storage vaul This violation occurred because, when the vendor increased the maximum permissible fuel shipment size from 12 to 14 fuel assemblies, the applicant failed to note that the increase violated one of the conditions of the SNM licens The applicant's response commits to taking steps to prevent future occurrences by paying closer attention to license conditions. Furthermore, the application for the CPSES Unit 2 SNM license (letter dated January 29, 1988; Log TXX 88089) specifies that the shipment size of Unit 2 new fuel will not exceed 14 fuel assemblies per shipment. This item remains unresolved pending NRC revier of the applicant's corrective actions (445/8822-U-03), "Violation of Special Nuclear Material License."

Two violations were identified; both, by the applican The violation concerning the SNM license is of minor safety significance. The violation of the SNM and radiological access requirements is also of minor safety significance. These violations indicate weaknesses in the training of reactor engineers concerning SNM license conditions and security personnel concerning the requirements for access to the SNM are . Regulatory Guide 1.97 Quality Assurance Commitments (92701)

The inspectors reviewed accident monitoring instrumentation and related documents to determine if Regulatory Guide 1.97,

"Instrumentation for Light-Water-Cooled Nuclear Power Plants to Access Plant and Environs Conditions During and Following an Accident," quality assurance commitments have been properly implemented at the CPSE (This item was identified as ID ;

Recommendation 66 in Enclosure 1 of the Stello memorandum,

"Implementation of Recommendations of Comanche Peak Report Review Group," dated April 14, 1987.) This review had not yet been conducted at CPSE The Final Safety Analysis Report (FSAR) states in Appendix 1A(B) that a plant specific analysis of the information system requirements was conducted using the guidance in Regulatory Guide 1.97, Revision 2, dated December 198 In the response to FSAR Question 032.110, the applicant states that the accident monitoring design meets the intent of Regulatory Guide 1.97, Revision 2. Deviations from the Regulatory Guide are identified in Tables 032.110-4 through 032.110- The following categories were reviewe _ _ - .

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a. Quality Assurance Commitment for Category 1 Variables Regulatory Guide 1.97, Revision 2, dated December 1980, states in Section C, "Regulatory Position,"

paragraph 1.3.1.e, that the quality assurance recommendations of specific regulatory guides (listed in the same paragraph) should be followed for Category 1 variable In the response to FSAR Question 032.110, Table 032.110-6 indicates that the applicant intends to deviate from this specific list of regulatory guides and follow the CPSES quality assurance program and the applicable regulatory guides as addressed in the FSA The inspector verified that the FSAR, in Appendices lA(N)

and 1A(b), addresses the applicant's commitment to each of the regulatory guides specified in Regulatory Guide 1.9 The adequacy of the applicant's commitment to each of the specified regulatory guides is outside the scope of the inspection, since it is under review as part of the CPSES operating license review. The inspectors note that the NRC "Safety Evaluation Report," NUREG-0797, paragraph 17.4 concludes that the applicant's description of the quality assurance program is in compliance with applicable NRC regulation The inspectors verified implementation of the above commitment by verifying that Design Basis Document DBD-EE-004, "Accident Monitoring Instrumentation,"

Revision 1, dated January 18, 1988, paragraph 4.3. requires that Category 1 instrumentation be subject to the QA requirements of 10 CFR 50, Appendix B. The inspector further verified implementation of this

commitment by verifying that a sample of the Category 1 variables were listed as being quality related on the applicant's Master Equipment List Index (MELI). It was noted that the corc exit thermocouples were not on the

"MELI." This by itself does not indicate that the 4 quality assurance requirements were not implemente Station Administration Manual Procedure STA-403, Revision 5, dated June 16, 1987, paragraph 4.2, states that the MELI is not a complete listing of all plant component If a component is not found on the MELI, a Form STA-403-2, "Item Classification Request" is sent to Comanche Peak Engineering (CPE) who will evaluate the item to determine if the item is quality-relate In response to the inspectors questions, CPE evaluated the core exit thermocouples and determined that they are quality related. Paragraph 4.1 of STA-403 states that if the component is on the MELI and listed as quality-related, thon'the "Q-List" report is reviewed to determine quality assurance requirements. The inspectors reviewed the "Q-List" for the above sample of instruments and verified that the "Q-Liut" specified the appropriate

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quality assurance requirement No deviations were foun To provide additional assurance that the Regulatory Guide 1.97 quality assurance requirements were implemented for the core exit thermocouples, the inspectors reviewed DBD-EE-004, Revision 1, dated January 14, 1988, and Drawings 2323-El-0097, 0098, 0136, and 0137. The drawings were marked as safety related and DBD-EE-004 specified that the core exit thermocouples required quality assuranc The inspectors, therefore, concluded that the applicant's Regulatory Guide 1.'97 quality assurance requirements have been properly implemented for Category 1 variable Quality Assurance Commitment for Category 2 Variables ,

Regulatory Guide 1.97, Revision 2, dated December 1980, states in Section C, "Regulatory Position,"

paragraph 1.3.2.d that the quality assurance recommendations for Category 2 variables are the same as those for Category 1 variables. However, it goes on to say that it may not be necessary to apply the same quality assurance measures to all instrumentation in this categor The quality assurance requirements that are implemented should be determined and documented by personnel knowledgeable in the end use of the instrumentation, and should be consistent with the importance to safety of the instrumentatio At CPSES, the quality assurance requirements are specified by the-DB Engineering and Construction Engineering Procedure, ECE-DC-17, "Preparation and Review of Design Basis Documents," Revision 4, dated October 31, 1986, states in Paragraph 1.3 that the section manager is responsible for assuring that individuals who originate or review DBD's are sufficiently qualified and cognizant of their responsibilitie In paragraph 2.1. of ECE-DC-17 the originator is provided a list of documents to review to ensure sufficient knowledge of the design requirement In DBD-EE-004, "Accident Monitoring Instrumentation," Revision 1, dated January 14, 1988, paragraph 4.3.2.1.3 states that the quality assurance requirements for Category 2 instruments are as follows:

(1) Class 1E instrumentation shall be subject to the QA '

requirements defined by 10 CFR 50, Appendix B, and (2) Non-Nuclear safety instrumentation quality assurance requirements depends on any seismic or environmental qualifications imposed on the instrument; otherwise, there is none. From the above, the inspector determined that there is reasonable assurance that the quality

assurance requirements were determined and documented by I

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personnel knowledgeable in the end use of the instrumentation and it was consistent with the importance to safety of the instrumentatio The inspectors further verified implementation of this commitment by verifying that a sample of the Category 2 variables, that were not Class 1E, but had environmental or seismic qualification requirements, were listed as being quality related on the applicant's MEL The Comanche Peak Report Review Group Recommendation 66 is considered closed. No problems were identifie . Preoperational Testing Program (70301)

The inspectors reviewed the applicant's development of the Unit 1 Preoperational Retest Program for the Comanche Peak facilit This inspection included interviews of preoperational test personnel and management to determine the current status of the preoperational test program test matrices (See IR 50-445/88-06) and to obtain the current procedure generation / approval statu From the supplied information the inspectors determined that the applicant is making progress toward identification of those systems and procedures required to conduct the preoperational retest program. The inspectors informed the applicant that they

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(NRC) would continue to monitor the weekly preoperational test status meeting, procedure generation / review / approval activities, and activities associated with the preoperational retest group resolution of previously identified NRC concern No problems were identified in the areas inspecte . Plant Tours (71302)

The applicant's activities were randomly monitored by the inspectors during this inspection period. These inspections included tours during backshifts. During deep backshift hours (tours of at least two hours in length, weekdays between the hours of 10:00 p.m. and 5:00 a.m., or conducted on holidays, or during the weekend hours) tours were conducted on 4 separate occasions. Routine backshift tours (tours of at least two hours in length, at anytime other than regular work hours) were conducted on 6 other occasion During the tours the inspectors performed staff interviews, equipment operability checks, equipment installation verifications, plant as-built verifications, material certification checks, room and area walkdowns, and follow-up on inspection identified issues. These inspections were conducted to provide the inspectors with detailed information as to the current status of construction completion and to

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ascertain Comanche Peak facility readiness for operatio These inspections verified that:

. Documentation was avai'lable to the craft personnel involved in the actual work activities and that these

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documents were the latest revisicn . Ongoing work activities in the field were being controlled by the appropriate approved procedure Administrative procedures which governed the access and control of the documents were being followe . Removal, installation, and applicant's inspection of field equipment were being properly documented and controlle . Personnel involved in the work activities were knowledgeable of the scope and nature of the task being accomplishe . Installed plant equipment was properly reflected on all of the applicant's documentation reviewe . Material storage was maintained in an acceptable and approved manne . Material documentation for the specific items reviewed was available in the appropriate records storage are . Housekeeping activities were being conducted and each inspected area was being maintained to the proper cleanliness level in accordance with site approved procedure During one of the inspection tours on March 18, 1988, the inspectors noted that craft personnel were not following site approved Procedure ECC 2.32, Revision 2, "Plant Housekeeping, Access Control and Equipment Protection,"

Section 6.3, Step 6.3.10, in that the craftsmen were using snubbers and sensing lines as a personal support for climbing and standing. This practice is not allowed by site approved housekeeping requirements which stipulate in Step 6.3.10 that, "Pipe support, snubbers, struts, etc. may appear sturdy. However, they are very fragile. Minor changes in there (sic] structure may cause serious damage or prevent them from performing their function properl It is imperative that such items are not damaged in any way. DO NOT STEP ON, LEAN ON, "TIE-OFF" TO OR USE THEM AS HAND HOLDS." The inspectors discussed this item with site operations and construction management to determine the extent of this unauthorized work practice. The inspectors requested information to determine if the applicant's corrective

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actions to a previously identified housekeeping problem were adequate to prevent recurrence. The applicant stated that previous corrective actions are considered adequate, but are taking time to completely implemen The inspectors.are concerned that during this

"implementation" period, snubbers may be rendered inoperable. Until the applicant can demonstrate otherwise, the inspectors consider the snubbers t inoperable. The inspector informed the applicant that this would be identified as an unresolved item, 445/8822-U-04, "Housekeeping and Equipment Protection Problems" pending NRC review of the applicant's corrective actions and pending the applicant's demonstration that the snubbers are operabl . That the control room was being maintained to adequate standards of conduc The inspectors performed this by conducting interviews with site operations personnel and supervision to verify that the activities were being performed in accordance with site approved procedural controls and that discovered deficiencies were being documente The following items were also inspected during.these tours:

(1) control room and shift foreman logs, (2) operations personnel were cognizant of abnormal conditions, (3) control board walkdowns were performed, and (4) any i out of specification conditions were logge Control room personnel were alert and attentive to their duties and decorum was being maintained. The amount of rework in progress in the control room detracted slightly from the control room decorum.

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. That shift turnovers contained the necessary detail and depth to alert the oncoming watchstander of any abnormal

, or adverse condition which would impact plant safety.

I The inspectors performed field verification of selected permanent plant equipment using the applicant's documentation (Maintenance and Operation Data System "MODS" printout.) The inspectors selected 13 out of 140 items as a random sample of installed flow orifices to verify that the documents reflected the correct size, identification number, heat number, pressure rating, and thickness. During the verification process, the inspectors noted several discrepancies between the actual installed equipment and the "MODS" list, specifically,

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incorrect bore diameters were listed on the "MODS" printou Discussion with the applicant's maintenance and results personnel, found that the procedure which controlled "MODS" had been out of use for several years. Maintenance personnel

stated that they knew that this list was not being maintained and; therefore, it could not be inappropriately used.

. Furthermore, the maintenance and results groups were

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t-implementing a new program to provide the correct information

called Managed Maintenance Computer Program (MMCP). The inspectors expressed concern that the inaccurate MODS list document could be accidentally used in place of the correct information. The inspectors requested a current copy of the MMCP for comparison to the actual field installed equipmen After reviewing the MMCP, it was found that the current'

information on the MMCP was also incorrect for these same flow crifice attributes. The inspectors requested the applicant to determine when and how these changes to the field installed equipment had been accomplished. At the close of the inspection, the applicant was still reviewing the documentation'for this concer The inspectors informed the applicant that this would be identified as an unresolved item, 445/8822-U-05, "Procedures Implementing Maintenance Programs."

Two unresolved issues were identified. The unresolved issue concerning maintenance program procedures is of minor significance and is indicative of configuration control problems which the applicant has already identified. The unresolved issue concerning housekeeping and equipment protection violations is of moderate significance and is indicative of continuing weakness in this are . FSAR Amendment 67 Review The inspectors reviewed portions of the operational and preoperational activities associated with Amendment 67 to the applicant's FSAR. This inspection was performed to verify that the applicant changes would not adversely affect the applicable sections, changes requiring an engineering evaluation had been performed, changes which were not editorial in nature did not affect the designed operability of the finished plant, and changes submitted to clarify a point did, in fact, clarify and not over simplify a required statemen The inspectors did not identify any items which would warrant further review by the on-site inspection force at this particular tim . Open Items ,

open items are matters which have been discussed with the applicant which will be reviewed further by the inspector, and which involve some action on the part of the NRC or applicant or both. One open item disclosed during the inspection is discussed in paragraph ,

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12. Unresolved Items

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Unresolved items are matters about which more information is .

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required in order to ascertain whether-'they are acceptable items, violations or deviations.. Four unresolved items disclosed during the inspection are discussed in paragraphs 6 (two items) and 9 (two items).

13. Exit Meeting (30703)

An exit meeting was conducted on April 5, 1988, with the applicant's representatives identified in paragraph 1 of this report. No written material was provided to the applicant by the inspectors during this reporting period. The applicant did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio During this meeting, the NRC inspectors summarized the scope

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