IR 05000461/1986013

Insp Rept 50-461/86-13 on 860224-0313.Violations Noted: Failure to Correct Deficiency Re Recording Battery Specific Gravities & Failure to Preserve safety-related Equipment. Deviation Noted:Security Battery Capacity Not Determined

ML20155D972
Person / Time
Site:	Clinton
Issue date:	04/11/1986
From:	Dupont S, Odwyer G, Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20155D949	List: IR 05000461/1986013 ML20155D945 ML20155D955 ML20155D959
References
50-461-86-13, NUDOCS 8604170473
Download: ML20155D972 (13)

Text

t-

'

C U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-461/86013(DRS)

Docket No. 50-461 License No. CPPR-137 Licensee: Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Narre: Clinton Nuclear Power Station, Unit 1 Inspection At: Clinton Site, Clinton, IL Inspection Conductedi February 24 through March 13, 1986

/ s Inspectors: S. G. DuPont /trd sG. w 9~2We O'Dwyer d Date Approved By:

WfY M. A. Ring, ief f Test Programs Section liite Inspection Sumary Inspection on February _24 thrcughjtar_ch_1_3,_1986_(Report No. 50-461/86013[D_RSJ1

_

~

Areas Inspected: Actions on previous inspectlon findlngs, preoperational test procedurereview(70304;70306), preoperational test witnessing (70442; 70457),

preoperational test result review (70322; 70541), preoperational test result verification (70329), startup test phase procedure review (72500; 72512),

preventive maintenance of station batteries (62705; 61700), startup test phase procedure verification and modification control (37701).

Results : Of the nine areas inspected, no violations or deviations were identified in eight areas. Within the remaining area, two violations and one deviation were identified (deviation from Standard Paragraph 9.a.(7); failure to promptly correct deficiency -Paragraph 9.b.(2); failure to preserve safety-related equipment - Paragraph 9.a.(8)).

8604170473 860411 PDR ADOCK 05000461 Q PDR

- _ _ - - _ - - _ - - _

'

,

s .

DETAILS 1. Persons Contacted

• H. E. Daniels, Project Manager

• J. S. Perry, Manager, Nuclear Programs Coordinator

• J. Greene, Manager, Startup

• J. W. Wilson, Plant Manager

• W. Connell, Manager, Quality Assurance

• J. Greenwood, Manager, Power Supply (Soyland/WIPCo)

• J. E. Loomis, Construction Manager

• D. E. Shelton, Manager, Nuclear Station Engineering

• G. W. Bell, Special Assistant

• F. Schaller, Director, Nuclear Training

• J. D. Palmer, Director, Configuration Management

• J. A. Brownell, Licensing Specialist D. Holesinger, Director, Startup Testing The inspector also interviewed other licensee employees, including members of the quality assurance, startup, maintenance, and operating staff * Denotes those attending the exit interview on March 13, 198 . Actions on Previous Inspection Findings (Closed) Open Item (461/85005-13): The Clinton Safety Evaluation Report (SER), Paragraph 8.3.1, required review of the division 3 diesel generator preoperational test result The inspector reviewed the test results for preoperational test PTP-DG/D0-03 and found that the results demonstrated reliable starting and operation of the High Pressure Core Spray (HPCS)

diesel generator. The inspector verified that the preoperational testing was similar to prototype qualification testing and that the requirements of Regulatory Guide 1.108 were me The inspector also verified that the diesel generator will automatically revert from the test mode to the emergency mode given a Loss of Coolant Accident (LOCA) or a loss-of-offsite power signa (Closed) Unresolved Item (461/85036-04): The licensee was to implement a program to ensure that the startup test engineer (STE) for a given preoperational test was aware of temporary alterations made by another STE authorized by a second preoperational test to avoid invalidation of completed testing. The inspector reviewed the revision to startup administrative Procedure SAP-8, " Control of Temporary Alterations," and verified that the following requirements had been implemented: (1) A retest evaluation is required for each alteration, to consider potential effects on interfacing system (2) The testing engineer is required to contact the System Engineer for the interfacing systems and determine the need for retestin The inspector also verified that Procedure SAP-5,

" Test Procedure Results Review and Approval," incorporated these requirements. The inspector has no further concern r s .

3. Preoperational Test Procedure Review The inspector reviewed the following preoperational procedures for compliance with the SER, Regulatory Guide 1.68, and the Startup Manua The inspector determined that the procedures were satisfactory and that the acceptance criteria were in compliance with the required design document PTP-LE-01, " Loss of Offsite Power" PTP-VP-01, "Drywell Cooling" No violations, deviations or unresolved items were identifie . Preoperational Test Witnessing The inspector witnessed the following preoperational testing to ascertain through observation and record review that testing was conducted in accordance with approved procedures and the requirements of the Startup Manual. The tests were found to be satisfactor PTP-RI-01, " Reactor Core Isolation Cooling (RCIC)"

PTP-HI-01, " Hydrogen Ignition" The inspector witnessed Sections 7.2.4, "RCIC Storage Tank Suction Valve 1E51-F010," and 7.2.8, " Suppression Pool Suction Valve 1E51-F031,"

and verified by direct observation the valve logic between the valves 1E51-F010 and 1E51-F031 functioned as designed. The design requires that with the suppression pool suction valve open (F031), the RCIC storage tank suction valve (F010) will close and will not operate open while F031 is open. The valve interlock logic is to prevent inadvertent loss of suppression pool inventory to the RCIC storage tank after the storage tank inventory has been used and the RCIC suction lineup has been redirected to the suppression pool. The inspector also verified the automatic suction switchover from the RCIC storage tank to the suppression pool on a low storage tank level signal. Preoperational Test PTP-RI-01 demonstrated that the RCIC suction valves' logic meets the requirements of NUREG-0737,

" Clarification of TMI Action Plan Requirements," Item II.K.3.22 for automatic switchover of RCIC suctio The inspector witnessed Sections 7.2.1 through 7.2.40, " Division 2 Hydrogen Ignitors," of preoperational test procedure PTP-HI-01. The inspector verified by direct observation that all Division 2 hydrogen ignitor glow plugs met the acceptance criteria. The acceptance criteria requires that the glow plugs attain a temperature of 1700 F or greater after a one minute warmup period. The temperatures were measured by Tempilstiks which are certified at a given temperature plus or minus one percent (i 1%). The test engineer utilized a 1750* F i 1% Tempilstik. All glow plugs indicated greater, than 1750 F which met the 1700* F acceptanc The inspector also reviewed the Tempilstik certifications and found them satisfactor No violations, deviations or unresolved items were identifie l

• .

q l Preoperational Test Result Review The inspector reviewed the following preoperational test results for acceptance and completion of test objectives in accordance with the FSAR and SE The licensee's test result evaluations were also reviewed for adequacy and found satisfactor PTP-AX/AY-01, " Auxiliary Power" PTP-DG/00-03, " Division III Diesel Generator" PTP-SX-02, " Service Water Vortex Test" l

~No violations, deviations or unresolved items were identifie . Preoperational Test Results Verification .

.

The inspector verified that the following acceptance (ATP) and l preoperational (PTP) test results were reviewed and accepted by the l licensee in accordance with the Startup Manual and were found to be satisfactory:

ATP-CP-01, " Condensate Polishing" ATP-DM-01, "fcreenhouse and Makeup Water" l ATP-PS-01, " Process Sampling" PTP-EM-01, " Environmental Monitoring" PTP-RE-01, " Auxiliary and Fuel Building Equipment" PTP-SV-01, " Safety Relief Valve Monitoring" PTP-VD-01, " Diesel Generator Room HVAC" l PTP-WE-01, "Radwaste Reprocessing" l No violations, deviations or unresolved items were identifie . Startup Test Phase Procedure Review

!

The inspector reviewed the following startup test phase procedures for compliance with the FSAR, Regulatory Guide 1.68, Draft Technical

'

Specifications, and the Startup Manual:

STP-03-0, " Fuel Loading" STP-30A-3, " Trip of One Recirculation Pump" STP-308-3, "RPT Trip of Two Pumps STP-30C-1 through STP-30C-6, " Recirculation Performance" The inspector determined that the procedures were technically adequate; l however, the prerequisites for fuel loading, as contained in Regulatory i Guide 1.68, were not clearly defined in procedure STP-03-0. The inspector was unable to locate the following Regulatory Guide 1.68, Appendix C prerequisites:

2.a(1),'"The composition, duties, and emergency procedure i

responsibilities of the fuel handling crew should be specified."

i The procedure STP-03-0 only specified the responsibilities of the

!

SR0/ fuel handling SRO and did not reference the minimum crew l

l l

l 4

!

, . , - _ , . - - . .. - - . . -. . - . , . , , - -. ., . . - - . . - - -,-

- o compositio The licensee stated that the crew composition and duties should be contained in the Technical Specifications and that emergency responsiblities are specified in the emergency procedure .a(3), "The status of all systems required for fuel loading should be specified." The licensee stated that the system status will be contained in either the letter from the Manager-CPS on system readiness or the Mode 5/4 check list However, STP-03-0 does not reference the Technical Specifications or any of the other documents that may contain these prerequisites. Additionally, the inspector did not find all of the limitations and actions prescribed by the regulatory guid STP-03-0 appaars not to contain Paragraph 2.c(2).. " Criteria for emergency boron injection (Standby Liquid Control),"

or 2.c(5), " actions to be followed or approvals to be obtained before routine loading may resume . . . should be listed." STP-03-0 did contain the actions required to resume fuel loading, but did not prescribe any requirements for approval. Since these requirements of the regulatory guide were not clearly contained in the fuel loading procedure and their location may be found within various other procedures or documents, this is an unresolved inspection item (461/86013-01) until the licensee's startup test phase program establishes the requirements of the regulatory guid No violations, deviations or other unresolved items were identifie . Startup Test Phase Procedure Verification The inspector verified that the following startup test phase procedures were approved as required by the FSAR and the Startup Manual:

STP-14-H, "RCIC System Startup Test" STP-14-1, "RCIC System Startup Test" fTP-14-2, "RCIC System Startup Test" STP-31-1, " Loss of Auxiliary Power" STP-33A-1, " Steady State Vibration Test" STP-33A-2, " Steady State Vibration Test" STP-33A-3, " Steady State Vibration Test" STP-33A-5, " Steady State Vibration Test" i STP-33A-6, " Steady State Vibration Test" STP-33B-H, " Transient Vibration Test" STP-33B-1, " Transient Vibration Test" STP-33B-2, " Transient Vibration Test" STP-33B-3, " Transient Vibration Test" STP-338-5, " Transient Vibration Test" STP-338-6, " Transient Vibration Test" No violations, deviations or unresolved items were identifie . Preventive Maintenance of Station Batteries The inspector toured the battery rooms to ascertain the conditions of the batteries maintained by plant staff after turnove The inspector found

,

'

, lo that in all cases, the licensee was not maintaining the batteries as reconsnended by the vendor manual 12-800, "C and D Stationary Battery ,

Installation" or as required by the Institute of Electrical and Electronics Engineers (IEEE) Standard 450-1980, "IEEE Recommended Practice for Maintenance, Testing, and Replacement of Large Lead Storage '

Batteries for Generating Stations and Substations." The _ inspector also reviewed the documentation of battery surveillances maintained by Plant Staff Maintenance Department. The inspector's findings are listed as follows: . General Maintenance (1) Division 1, safety related battery (10C01E). The inspector-found free standing electrolyt t en cells and between interconnecting terminals. This condition can cause trace electrical shorts between the current carrying ccmponents toch as, interconnecting terminals and terminal plates. Additic_nally, the inspector found evidence of corrosion on terminals to cells 24, 49, 51 and 5 (2)' Division 2, safety related battery (IDC02E). The inspector found, in addition to electrolyte spills and excessive dust.on the cells, the terminal plate for cell 4 had evidence of at~s The terminal plate was warped with a gap of 1/8 inches. Since the plate is a current carrying component and the licensee, as a practice, does not clean electrolyte spills or terminal corrosion, this plate could have corroded and limited the cell's capacit This deficiency had not been identified by the licensee as required by procedure CPS 1016.0 (3) Division 3, safety-related battery (IDC03E). The inspector found electrolyte spills and residue. Additionally, a large plastic sheet was found in the battery room. This sheet had apparently been used to cover the cells. The location of the plastic sheet as either debris or a cover is a fire hazard that could result in the loss of the safety-related batter (4) Division 4, safety-related battery (10C04E). The inspector found excessive electrolyte residuc, even on the room's floor and storage racks, and crystallization of sulfuric acid from the electrolyte. Terminals for cells 11 and 53 had evidence of corrosion while cells 33 and 56 had excessive crystallization on the terminal plates. Additionally, the battery room was being used to store equipment, tools and debris for other maintenance activitie The inspector also finds that the physical conditions noted in Paragraph 9.a(1) through 9.a(4) for safety-related batteries constituteavioletion(461/86013-02)of10CFR50,AppendixB, Criteria XIII, which requires that measures shall be established to control cleaning and preservation of safety-related equipment

._- - _ -________--_- -_- - _-___ _ _____-_-_-___-

{ , .

to prevent damage or deterioration. Additionally, these conditions violate the American National Standards Institute (ANSI) N45.2.3 and IEEE Standard 450-1975 which states, "when excessive dirt is noted on cells or connectors, wipe with water-moistened clean wiper. Remove electrolyte spillage on cell covers and containers."

(5) Balance of plant, non safety-related battery (10C05E). In addition to evidence of electrolyte spills and crystallization, two fill caps were missing for cells 14 and 4 (6) Security batter The inspector found that the battery was, in general, maintained with only minimal electrolyte spillag However, one of interconnecting terminals showed unusual abus The terminal had inadvertently been struck by a welding rod resulting in damage and the loss of the upper quarter of the pos (a) The inspector reviewed the licensee's letter B76-83(06-06)6, June 6, 1983, which contained a disposition supplied by the Nuclear Station Engineering Department (NSED) for continued use as follows:

• "The present damage to the cell does not appear to be of significant concern at this time."

• "While the vendor does recommend replacement, this recommendation was based upon the new exposed surfaces l

accumulating corrosion and subsequent failures; thus, it will not be a sudden development, but rather a slow process."

• " Current maintenance procedures require periodic inspection of all battery cells and any visual degradation can be found i at that time."

• ". . . the present condition of the cell will be determined by the startup test procedure."

• "NSED thus recommends that unless the cell is unable to perform per rpecifications, that it be left in service."

• "If failure should occur at a later date, the cell can be replaced at that time. This will delay the expenditure of money till absolutely necessary and allow for the use of whatever the life of the cell is before its replacement."

(b) The inspector finds this disposition inadequate as follows:

• NSED's evaluation that the failure "will not be sudden, but, rather a slow process" is generally tru However, the assumption that current maintenance procedures will

s .

detect and identify "any visual degradation" is not supported by IP Plant Staff's actual practices as documented in Paragraphs 9.a(1) through 9.a(5) of this repor The vendor manual stresses in Section 6.11,

" Checking Connections," that " maintenance of connictions is one of the most important tasks for which the user is responsible. A loose or corroded connection can often develop a high resistance circui If a high current load is suddenly required from the battery an extremely large amount of power can be dissipated at the connection, often leading to a melt-down of the post and possible ignition of the cover of the cell or other neighboring parts." A failure of this type could render the battery unable to perform its intended functio * The NSED's assumption that "the present condition of the cell will be determined by the startup test procedure" is not valid as follows. The acceptance test procedure for this battery required a discharge test to be performed by procedure STP-SS-0 However, this test did not determine the capacity of the battery as required by IEEE Standard 450-198 The Standard requires that a capacity test is initially performed to determine whether the battery meets its specification end periodically reperformed to determine degrading of its ratin Acceptance is based upon the percentage of the design rating. The initial capacity acceptance is 90 percent. Degradation is also indicated by a capacity drop of more than 10 percent from previous capacity tests or 85 percent of the rated capacit For the security battery, the initial capacity was not determined and periodic testing is not scheduled by i plant staff to be performe The vendor manual also addresses capacity testing in Section 9.1 and endorses the standard. This is a deviation from the IEEE Standard 450-1980 (461/86013-03) in that requirements for capacity tests had not been met for the security batter * The NSED assumption that "if failure should occur at a later Jate, the cell can be replaced at that time",

does not consider delay times for availability of a replacement or the impact on the system of a failed cel Since an initial determination of the battery capacity has not been made and periodic capacity verifications were not planned, the failure could rot be detected as a slow developmen * Finally, NSED's consideration for delaying "the expenditure of money till whatever the life of the cell" does not indicate that the intended function of the battery was evaluated as follows:

,

t- .

The security battery function is to provide electrical power to various security systems during a loss-of-offsite power (LOOP), including electrical interlocks to security doors throughout the statio During the LOOP, access to safety-related equipment and remote operating stations is vital. Without timely access through security doors, operation of this equipment will be hindered and will add inadvertent complications to the even Because the disposition is inadequate in addressing the intended function of the battery, this is an unresolved item (461/86013-04) until an adequate disposition is made eo and reviewe Safeguards aspects of the security battery issues are treated in Inspection Report No. 50-461/8602 (b) Maintenance Procedures and Documentation The inspector reviewed the recorded data for weekly and monthly surveillances. The inspector found the following:

(1) The inspector had previously identified to the licensee, in Inspection Report No. 85061, the inadequacies of procedure CPS 8433.01, " Generic Procedure for Battery Maintenance," Section 8.2, " Battery Equalizing," for meeting the requirements of IEEE Standard 450-1975. Specifically, the procedure was inadequate in the areas of acceptance criteria for the equalizing charge and the failure to compensate specific gravities for electrolyte levels. During the review of surveillance data for the batteries, the inspector noted a significant drop in recorded specific gravities followed by an equalizing charge. The change in specific gravity data was attributed to compensating for electrolyte levels and the charge was required to restore the gravities to specifications. The inspector also noted that after compensating for level, all of the batteries required an equalizing charge to restore the batteries to specification The inspector was not able to determine if the batteries were out of specification throughout the duration that gravities were not being compensated for level because of a lack of dat However, the need for an equalizing charge immediately after compensating for level does indicate that the batteries were being maintained out of specification (2) In addition to not being able to determine the condition of the batteries before compensating for levels, the inspector also noted that plant staff had not corrected the inadequate practice of not compensating for levels in a timely manner. One battery's gravities were corrected after the inspector had identified the l inadequacy to the licensee while the other batteries were corrected at later date In one case, the licensee continued to record uncompensated data four weeks after correcting for levels on the first batter Since the battery specific gravities were corr?cted l

l 9

-_-__- ___ -__ _- ____ _ _ _ _ _ _ _ _ - - . _ _ _ _ - - _ _ _ _ - _ - _ _ _ . - - _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ -- _ _ - _ - - _ - _ -

- -_;

.. ,

on an individual case basis at intervals of one or more weeks following identification of the improper practice and all batteries were out of specifications after compensating, the inspector finds the licensee's corrective action inadequate. This is a violation (461/86013-05) of 10 CFR 50, Appendix B, Criterion XVI in that prompt actions were not taken to preclude repetition of conditions adverse to quality after identification of improper practic (3) During the review of documentation, the inspector identified that procedure CPS 8433.01 had a note in Section 8.2, " Battery Equalizing," stating that electrolyte level should be adjusted to the full level prior to starting the equalize charge. The inspector determined by interviewing Plant Staff Maintenance

,

Department personnel and visual inspection of the batteries that the licensee does adjust the level to the full mark prior to commencing the charge. This practice is not in agreement with the vendor manual " caution" in Section 4.9, " Adjusting Electrolyte Level and Watering of Battery," which states, " adjust electrolyte levels AFTER complete recharge and while on charge, never before recharge or when a battery is discharged." The reason for the caution is that had the level been adjusted to the high level mark before charging, it is conceivable that upon charging the electrolyte may rise to a point where it could overflow through the vent or be forced up into the flame arrestors thereby causing an additional problem requiring maintenance. The inspector's tour of the battery rooms revealed that electrolyte had overflowed through the vents as evidenced by electrolyte stains on the vents, racks, room floors, and electrolyte residue on the sides of the cells. It was also apparent that no additional maintenance had been performed as a result of electrolyte overflo Plant staff stated that these requirements for water additions were only in the newly distributed 1983 revision of the vendor manual and were not located in the 1976 revision that was used to prepare procedure CPS 8433.01. However, the above stated cautions are also contained in the 1981 revision. The inspector's review of the 1976 revision does not agree with the licensee's statement in that the " Condensed Instructions for Standby Battery Service, Full Float Operation," does contain as Caution 4, " Watering, add approved or distilled water after charging and as required to keep electrolyte level between high and low level lines." It is apparent that plant staff had not familiarized themselves with the refer 6 cc @ caments (IEEE Standard 450 or the vendor manual)

prior to (,repaeing and approving the battery maintenance procedurc ' Both of the inspector's concerns, water addition and ,

specific 9 avity compensation for electrolyte level, were found l l to be coitained in the 1976 vendor manual as Caution 4 and in 1 Section 6.3.5. This is an open inspection item (461/86013-06) l pending licensee review of the plant staff's battery maintenance L

program (provantive and corrective), all related plant staff procedures, and performance of adequate correction Y

,

!

'$ 10 l

l

__ _ _ __ __ ___ _ _--______ - __ _ _ f _ _ _ - _ _ _ _ ___O

,

e .-

(c) Battery Inspection Su_nna_ry_

_

Because of the failure to establish adequate measures to assure that the preoperationally tested and accepted batteries (both safety-related and non safety-related) are preserved and because damage or deterioration may exist, the inspector has no confidence that the preoperational test data collected, evaluated and approved is valid. Pending Nuclear Station Engineering Department evaluation of the the completed test data against the current condition of the batteries, the validity of

. the completed preoperational testing is consf5ered an unresolved inspection item (461/86013-07).

No other violations or deviations were identifie . Modification Control During the inspection, the inspector found that the CQ, "Public Address System," had been modified prior to turnover to startup for preoperational testing. Before the system turnover was completed, the Manager, CPS, requested Baldwin Associates (BA) to not build the CQ system as designe BA disabled the page function of the system with the exception of the control room unit. The disposition stated that the acdification was to " improve the effectiveness of the P.A. system for the emergency plan drill." The improvement was to prevent unwanted paging during the drill. Since the system was turned over to Startup with the paging modified, startup wrote a condition report, CR 1-85-12-023, as required by the Startup Manual. As a result, a Plant Staff Field Problem Report (FPR 200064) was written to NSED to initiate a pemanent plant n.odification. Two Field Engineering Change Notices (FECN 22705 and 22812) modified the CQ System from the Sargent and Lundy (S&L) design criteria, DC-CQ-01-CP and the FSAR Section 9.5.2. Additionally, a Plant Staff Modification Control Package (CQ-12) was approved to disable the plant paging capability with the exception of the following:

Main Control Room

Technice.1 Support Center

Operational Support Center

Emergency Operations Facility

Central Alarm Station

'

Shift Supervisors Office ,

'

'

Radwaste Operations Center

Remote Shutdown Panel

Service Building Office Areas

Maintenance Office Areas

Chemistry Office Areas

Various Security Stations In total, only 36 of 158 CQ stations listed in the FSAR will have the

. ability to page throughout the plant. The control room unit will also have the ability to monitor the party line function of the CQ system.

11

- _ _ -

-

a The affect of the current modification, with all paging disabled except the control room, has caused certain problems. IP Quality Assurance noted in a surveillance (Q-02652) that the paging system did not function properly on February 6, 1986, thus delaying the fire brigade response. Additionally, a previous quality finding (0-085-172) noted the inadequacies of the CQ syste Since the modification of the CQ system was perfomed during construction and a pemanent plant modification has been written, this is not a violatio However, plant staff including the Manager, CPS, did not demonstrate adequate control or good engineering practice in not initiating a permanent modificatio The modification CQ-12 was written over two months after the system was changed and turned over to startup. Also, the plant staff had not evaluated the impact on security and fire brigade response, as noted by IP Quality Assurance, prior'to disabling the paging functio In additicn to the above, the inspector reviewed the completed 10 CFR 50.59 Safety Evaluation Reports for Modification CQ-12. The 10 CFR 50.59 Reports are not required to be perfonred until af ter the plant receives an Operating License (0L); however, plant staff has initiated 10 CFR 50.59 reports prior f

to OL as a policy. The inspector found four reports attached to Modification CQ-12. In general, these reports state that no testing as described in the FSAR and that no procedures are affected. However, there is no evidence that the evaluator considered the preoperational test as an FSAR described test or that the Plant Staff operating, emergency or security procedures were reviewe In one case, the evaluation's description of the acdification does not appear to agree with the sumary contained in modification CQ-12. Additionally, the latest evaluation (Log 109 dated February 20,1986), concluded that the modification "will not change any FSAR descriptions" of the CQ syste This evaluation is inadequate because the change does affect the FSAR descriptio Since the 10 CFR 50.59 reports are not required, this is not a violatio However, this mcdification activity did not demonstrate adequate control, evaluation and technical understanding of the impact of modifications on the part of Plant Staf . Open Itens Open itens are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. An open item disclosed during the inspection is discussed in Paragraph 9.b.(3).

12. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of violation or deviations. An unresolved item disclosed during the inspection is discussed in Paragraphs 7, 9.a.(6) and .

_ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ - _ - _ _ _ _

F l 4 -.  !

i 13. Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1) on March 13, 198 The inspector summarized the scope and findings of the inspection. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspectio The licensee did not identify any such documents or processes as proprietary. The licensee acknowledged the statements made by the inspector with respect to the finding