IR 05000482/1984043
| ML20127D544 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 06/18/1985 |
| From: | Denise R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Koester G KANSAS GAS & ELECTRIC CO. |
| References | |
| NUDOCS 8506240261 | |
| Download: ML20127D544 (3) | |
Text
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, , In Reply Refer To: Docket: STN 50-482/84-43 M 181985 Kansas Gas and Electric Company ATTN: Glenn L. Koester Vice President - Nuclear O P. O. Box 208 Wichita, Kansas 67201 Gentlemen: A copy of the enclosed draft inspection report was given to a member of your staff on January 18, 1985. With the exception of minor editorial changes, the final version of this report issued on January 18, 1985, is the same as the enclosed draft inspection report.
NRC policy requires that released drafts be placed in the public document room and be retained and made a part of NRC official files. Therefore, a copy of this letter and the enclosed draft inspection report will be placed in the NRC Public Document Room.
Sincerely, /s/ R. P. Denise. Director Division of Reactor Safety and Projects
Enclosure:
Draf t NRC Inspection Report 50-482/84-43
REGION III== NRC Inspection Report: 50-482/84-43 CP: CPPR-147 Docket: 50-482 Category: A2 Licensee: Kansas Gas and Electric Company (KG&E) ' Post Office Box 208 Wichita, Kansas 67201 - Facility Name: Wolf Creek Generating Station (WCGS) Inspection At: Wolf Creek Site, Coffey County, Burlington, Kansas - Inspection Conducted: October 1-31 and November 1-30, 1984 /7!I4 Inspectors: . Date / - D.
. Wi 11ams /* J/
Date / / M Mc ormick-Barger /* f9 Date / /2[g4 k W.
. Gu6mond Date / T[.'J/S / Approved By: M. A g Chief Test Programs Section Dat'e ' L. E. Martin, Chief Wolf Creek Task. Force Date R. P. Denise, Director Reactor Safety and Projects Date , ' > n/70n-rn > DJ WL' t' P 7 fd E , /5 , ff
. Inspection Summary Inspection on October I through November 30, 1984, (Report No. 50-482/84-43(DRS)) Areas Inspected: Routine announced inspection of licensee action on previous inspection findings; approved preoperational test procedures; preoperational test performance; approved preoperational test results package evaluations; preoperational test procedure verification; preoperational test results package verification; approved startup test procedures; voiding of completed preoperational tests; preoperational test schedule; technical specification review; and preoperational test content.
The inspection involved a total of 167 inspector-hours onsite and 100 inspector-hours offsite by four NRC inspectors, including 54 inspector-hours onsite during off-shifts.
Results: Of the eleven areas inspected, four items of noncompliar.ce, with multiple examples, were identified, in the area of preoperational test content (paragraph 12).
These items of noncompliance were a topic of an enforcement conference held on December 4,1984.
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- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. .. - . . DETAILS Persons Contacte_d 1.
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- G. L. Koester, Vice President-Nuclear
- C. C. Mason, Director of Nuclear Operations
- F. T. Rhodes, Plant Manager
- 0. L. Maynard, Manager of Licensing i
- H. G. Williams, Superintendent Regulatory and Quality Administrat o
- G. P. Rathbun, Manager, Licensing and Radiological Services
- K. R. Petersen, Licensing Lead Engineer
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- R. M. Grant, Director of Quality
- W. J. Rudolph II, Manager, Quality Assurance
- M. Mathis, Startup Quality Control
- R. L. Hoyt, Emergency Plan Administrator
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- R. B. Glover, Startup Manager R. L. Straight, Licensing F. D. McLaurin, Assistant Startup Manager
- K.R. Ellison, Startup Technical Support Supervisor *W M. Lindsay, Quality Assurance Systems Supervisor
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- W. B. Norton, Reactor Engineering Supervisor 9 1984.
- Denotes those attending the exit interview on November 2,
contacted by Additional plant technical and administrative personnel were i the inspectors during the course of the inspect on.
Licensee Action on Previous Inspection Findings
Safety Injection 2.
_ (Closed) Unresolved Item (482/84-30-01(DRS)): k i mode.
Signal (SIS) override of Feedwater Isolation Valve e erc s a.
This item has been upgraded to an item o h 12.
- Improper testing of air (Closed) Open Item (482/84-30-02(DRS)):This item has been b.
operated valves. noncompliance and is discussed in paragraph 1 I l Environmental conditions l (Closed) Open Item (482/84-30-04(DRS)): This item has been upgra for 24 hour diesel generator load test.
d in paragraph 12.
c.
l to an item of noncompliance and is discusse -' Wedge anchor bolt thread ..I (Closed) Open Item (482/84-30-09(DRS)):The inspector J nt was d.
licensee which demonstrated that adequate thread enga ,j engagement.
d provided by engagement of two or three threa sThe deter-Q p{ mined that the analysis was correct, and {{ diameter.
, - - this area.
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Pump start and acceleration (Closed) Open Item (482/84-30-06(DRS)): This item has been capabilities under degraded voltage conditions. upgrad e.
Natural Circulation Startup Procedure (0 pen) (482/84-30-07(DRS)):The procedure wording was modified so th I f.
mapping is used to meet a test objective as specified in the Final comments.
The licensee is continuing to Safety Analysis Report (FSAR). evaluate the inspector's commen the phrase contained in step 6.12, Note b which states, " wide range is approximately equal to core exit thermocouple average T tI8herature".
Administrative controls for (Closed) Open Item (482/84-30-08(DRS)): The inspector reviewed a g.
completed preoperational test packages.
recently issued administrative procedure which pro . The inspector has no further questions in this and accountable.
area.
' Pump start and acceleration (Closed) Open Item (482/84-30-05(DRS)): The licensee capability under 75% nominal voltage conditions.
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provided the inspector with test documentation to show that safety- < related pumps had been factory tested to show their ability to start and accelerate to rated speed under full load at 75% g conditions.
questions in this area.
Preoperational Test Procedure Reviews 3.
Below is a list of preoperational tests for which the inspectors have completed their test procedure review during the inspection period.
Unless otherwise noted, the inspectors have no further questions on l these procedures.
SU3-AB04, Rev. O, " Main Steam System" SU3-BG02, Rev. O, " Seal Injection System" SU3-BG04, Rev. O, " Boron Thermal Regeneration System" SU3-NE01, Rev.1, " Diesel Generator Electrical Test" SU3-NK01, Rev. O, "125 VDC Class IE Electrical System" SU3-EN01, Rev. O, " Containment Spray Nozzle Air Test" SU3-EJ01, Rev. O, " Residual Heat Removal System (Cold)" S03-5B01, Rev. O, " Reactor Protection System" The procedures were reviewed against the Final Safety Analysis ides, (FSAR), Safety Evaluation Report (SER), and applicable Regul . 'r i Standards, and portions of 10 CFR 50.
' comments with respect to the review of: fL - . -. < km hFU -
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.. . SU3-AB04, Rev. O, " Main Steam System" a.
deter-During the review of this preoperational test the inspector ification has been mined that not all testing required for design verThe Wolf Creek-SNUPP o 7.3.7.2 page 25 states "the control sequence for the 10 percent included in the procedure.
i close test would be interrupted in the event of an act The licensee has signal..." had not been incorporated into the procedure.
his design acknowledged this concern and has committed to verify tl function during the retest of SU3-AB03, " Main S (Cold)".
i l discussed in paragraph 12.
l SU3-NK01, Rev.1, "125 VDC Class IE Electrical Test" b.
The Wolf Creek - SNUPPS FSAR Section 8.3 Contrary to tions, record and retain as a permanent plant re d and the . licensee appeared unaware of this commitment.
t t committed to incorporate this requirement into the NK01 re es. This is a failure to meet an FSAR commitment an item of noncompliance and is further discussed in paragraph SU3-NE01, Rev. 1, " Diesel Generator Electrical Test" . The inspector noted that the stated acceptance criteria for c.
s t diesel start time, full load rejection peak voltage and larges 1.
(Essential Service Water Pump) load shed peak voltage iew support the requirements of the most recent proof and rev i l test technical specifications. tion could lead to circumstances t its opera-was accepted but the diesel generator could not meeThe in identified tional requirements. acknowledged the concern and the con l inoperable diesel generator.
issued to change the acceptance criteria to reflect tec specification requirements.
has no further questions in this matter.
llow The method used for the 35 start reliability test did not a between the diesel generator to return to ambient conditionsAm I 2.
in condition under which the diesel would be expected to s successive starts.
Guide the event'of an actuation (in accordance with thod.
, and a TCN was issued to correct the improper test me 1.108).
c' - Failure of the review process to ident "' h -. * *
. j[d= discussed in paragraph 12.
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. . O. " Reactor Protection System" - 5U3-5801, Rev.
d.
Several errors were noted in switch operations of the Nuclear Instrument system during its use as a signal input to the pro 1.
These errors would have been self-identifying and td the test could not have proceeded until they were correc e. tion system.
Although the function was tested, no accep 2.
trip the reactor.
An error in the setup and operation of the switched decade T and resistors would have prevented the Overpower Delta t 3.
Overtemperature Delta T sections from being completed as written.
Appendices AH and AI, which identified where test instr blank.
tion connections were to be made, were left completely 4.
The The low flow reactor trip requires two of four coincidence.
- hich test setup started with two low flow signals present, w S.
t and would would not have allowed the protection system to rese, have prevented the test from proceeding as written.
cies.
The inspector met with licensee staff to discuss these discrep The inspector Major TCNs were issued to correct these problems.
in this area.
reviewed these TCNs and has no further questions Preoperational Test Witnessing following 4.
The inspectors witnessed the performance of portions of the l preoperational tests during this inspection per o : - i~ id SU3-NE01, Rev. O, " Diesel Generator Electrical" Rev. O, " Reactor Protection System" SU3-kJ01, Rev. O, " Diesel Generator Mechani S03-5801, it was conducted The inspectors witnessed test performance to assure thatipment w in accordance with approved procedures, that te l that the adequate, that ability of licensee personnel conducting the test t test changes were processed in an approved manner.
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- $U3-NF01, Rev. 1, " Load Shedding and Load Sequencer" , - rn that During the conduct of this test the inspector expressed conce
i completed.
not all FSAR commitments had been demons > during testing, k} ting." The preopera-the automatic actuation circuitry will override tesfeature by injecting a tional proceddre attempted to verify this design t the actuation by w_ m
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l . . The inspector believed that the opposite initiating the test circuitry.
The test circuitry approach would have better demonstrated this feature.sho l , The licensee to verify that this signal overrides the test circuitry.
acknowledged the concern and wrote a TCN to prove the design feature.
l This is considered an item of noncompliance and is further discussed in l paragraph 12.
Preoperational Test Results Packaaes Evaluations 5.
The inspectors completed review of the following preoperational test results packages during this inspection period: SU3-AB04, Rev. O, " Main Steam System" ., SU3-BG02, Rev. O, " Seal Injection System" SU3-BG04, Rev. O. " Boron Thermal Regeneration System" SU3-EJ01, Rev. 1, " Residual Heat Removal System (Cold)" , SU3-EN02, Rev. O, " Containment Spray Nozzle Air Test" SU3-NB01, Rev. O, "4160 VAC Class IE Electrical System" , The packages were reviewed to assure that test results are being i i adequately evaluated, test data meets acceptance criteria, dev at ons i are properly identified and resolved, review procedures are be ng , followed, and administrative practices are adequate with respe
execution and data evaluation.
with respect to the review of: ] SU3-AB04, Rev. O, " Main Steam System" a.
During the review of the results package it became evident that l tion problems had existed with the operation of the Main Steam Iso a The f'irst attempt at . Valves (MSIV) during the fast closure testing.
I For some valves fast closure timing resulted in excessive times. Successive tests show ' this exceeded two minutes.
Further testing
still outside the acceptance criteria limits.
' ' resulted in the valves meeting acceptance criteria and this test was When questioned by the inspector, the lic-(1) the valves considered acceptable.
ensee presented two possible causes of these problems:
had been repacked and this was the first time that they had been { i stroked, (2) the startup testing engineer felt th f]* to nominal pressure before actuation.
t l explanations, no supporting data is available except for l ~; t able fast closure time.further demonstrate the acceptable operati However, at this s.4 i would be no further concern by the inspector. time,
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~{* acceptance criteria timing limits. Based on this issue and the major main-j l in concern to the licensee.tenance activities on the actuator systems .; lfing on . h {' "*1 progress, the inspector has requested a justification for re N the recorded times.
pending further evaluation by the licensee and the inspector.
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SU3-BG02, Rev. O, Seal Injection System 1.
Failure mode testing of system air operated valves did not check valve position af ter loss of electrical power to the solenoid operated air valve.
This is an item of noncompliance and is discussed further in paragraph 12.
From the data on data sheet 8.2 it would appear that one of the 2.
check valves in the seal injection line for Reactor Coolant Pump B is not opening fully or that the line is plugged.
Compared to the three other pumps, only the minimum acceptable flow of 7.5 gallons per minute was obtained with its respective The throttle valve considerably more open than the others.
licensee has committed to conduct a retest of seal injection flow balancing.
Evaluation of this retesting by the licensee and the inspector is an open item (482/84-43-02(DRS)) pending demonstration of satisfactory operation.
SU3-BG04, Rev. O, Boron Thermal Regeneration c.
. Failure mode testing of system air operated valves did not 1.
' check valve position after loss of electrical power to the solenoid air valve.
This is an item of noncompliance which - is discussed further in paragraph 12.
2.
The clamp-on ammeter that was indicated as used in the test was not equivalent to that specified in the procedure.
The range of the instrument used in the test was 100-999 Amps with an , accuracy of i 1% while the specified instrument range was 0-100 - i amps with an accuracy of i 3%. Discussions with the licensee revealed that the instrument was multi-range and.that the wrong . The inspec-i
range was recorded when identifying the instrument.
tor reviewed a corrective entry to the results package and has '
no further questions in this area.
{ Valve BG-UV7056 was identified as exhibiting stroking problems.
o 3.
The solution was to raise control air pressure to 60 psig.
Test entries did not provide justification for this action and did not address any investigation to determine if of.her Discussion with the licensee mechanical problems existed.
revealed that 60 psig was the correct pressure and that control
air pressure was initially low.
The inspector has no further questions in this matter.
d.
SU3-EJ01, Rev.1, '.' Residual Heat Removal (Cold)" ,{ During verification of pump performance, a 0-800 psig gage with j 1.
an accuracy of i 16 psig was used to measure pump suction d,1 pressures ranging from 4.5 to 30 psig.
The inspector met with licensee staff to discuss the validity of the test data and the validity of the test method. The licensee responded that an E u immediate post-test calibration check of both pump suction pressure gages against a 0-1000 psig,la% accuracy test gage i revealed that the gages used in the test were in fact
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. This post test indicating as accurately as the precision gage.
Failure of information was not included in the test package.
the procedure review and test results review process to identify, question, and correct the use of improper test equip-ment is an item of noncompliance and is further discussed in paragraph 12.
The inspector noted a step discontinuity in the pump perform-2.
This discontinuity occurred ance data recorded for both pumps.
during the performance of identical steps in the testing of It was not clear that the review process noted or each pump.
evaluated this discrepancy and the validity of the procedural Evaluation of the step and resulting data is questionable.
step discontinuity by the licensee is an open item (482/84-43-03(ORS)) pending review of that evaluation by the inspector.
Preoperational Test Procedure Verification 6.
. The inspectors reviewed the following preoperational test procedure against the FSAR, SER, proposed technical specifications, Regulatory Unless Guides 1.68, and the licensee's administrative procedures.
otherwise noted, the inspectors had no comments.
SU3-GM01, Rev. O, " Diesel Generator HVAC System" No items of noncompliance or deviations were identified.
Preoperational Test Results Verification 7.
The inspector reviewed the following preoperational test re.sults packages and verified that the test results were reviewed against approved accept- - ance criteria and an evaluation of the test results had been performed in accordance with Regulatory Guide 1.68 and the licensee's administrative
Unless otherwise noted the inspector had no comments.
procedures.
SU3-GM01, Rev. O, " Diesel Generator HVAC System" No items of noncompliance or deviations were identified.
Initial Startup Test Procedure Review ! l 8.
Below is a list of startup test procedures for which the inspectors have ' . -l _ completed their review-SU7-SF03.1, Rev. O, " Rod Drop Time Measurement (Cold, No Flow)" SU7-SF03.2, Rev. O, " Rod Drop Time Measurement (Cold, Full Flow)" SU7-SF03.3, Rev. O, " Rod Drop Time Measurement (Hot, Full Flow)" SU7-SF03.4, Rev. O, " Rod Drop Time Measurement (Hot, No Flow)" . [4
- SU7-0004, Rev. O, " Initial Criticality"
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- SU7-0003, Rev. O, " Inverse Count Rate Ratio Monitoring for Approach to
' Initial Criticality"
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.., _ _... ._. - . . O, " Initial " Denotes procedures incorporated in procedure SU7-5011, Rev.
Criticality and Low Power Test Sequence".
The procedures were reviewed again d the FSAR, ard applicable Regulatory The inspector had the Guides, Standards, and portions of 10 CFR 50.
l folic, wing comments with respect to the review of: SU7-SF03.1, Rev. O, " Rod Drop Time Measurement (Cold, No Flow)" a.
The note at Step 6.0 stated " Rod Position Indication System, (1) SU7-SF04.1 should be done concurrently with this procedure."
Both procedures required that rods be withdrawn a certain number of steps and then stopped so that data could be taken.
Numerous transfers from one procedure to the other would be needed as the procedures were performed because one procedure required that data be taken at 18, 210 and 228 steps (shutdown banks) or at 24 step intervals (control banks) while the other procedure required that data be taken at 48 steps (all banks).
The procedures did not contain statements to coordinate trans-At the time that the inspector , ferring from one to the other.
discussed this with the Reactor Engineering Supervisor, he indicated that he had been considering combining these proce-dures (and possibly an additional procedure) in a manner , similar to the procedures that were combined into 5U7-5011 This is " Initial Criticality and Low Power Test Sequence."
' considered an unresolved item (482/84-43-04(DRS)) pending licensee action to revise the procedures to eliminate any ambiguities related to coordination between the procedures.
the During the conduct of the test this procedure requires .. Step 4.8 .(2) Residual Heat Removal (RHR) pumps to be stopped.
stated "The Residual Heat Removal pumps should not be operated If their operation is deemed absolutely during this test.
necessary to maintain equilibrium cold plant conditions, the
recorder traces for the affected rod drops should be marked ~ ' However, there was no statement
with the RHR flow rate."
within the procedure to identify the Proof and Review Technical Specification 3.4.1.4.1 requirement that, after being deener-Also, gized for one hour, an RHR pump must be restarted.S ment to return the RHR pumps to service when the test was The licensee's Reactor Engineering Supervisor . complete.
indicated that the procedure would be modified to address these concerns; that the Reference Section would be modified to include references to Technical Specification 3/4.4.1, and to & add the procedure that will be used to start the RHR pumps.
- This is considered an open item (482/84-43-05(DRS)) pending ' procedure revision.
SU7-SF03.3, Rev. O, " Rod Drop Time Measurement (Hot, Full Flow)'.' O b.
The note at Step 6.0 stated " Rod Position Indication System, ~ F SU7-SF04.2, should be done concurrently with this procedure."
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____- ___ '- ___ - - . [The details of this comment are the same a kd a.(1) above; resciution of this comment will be trac e via the unresolved item mentioned in a.13 t Prerequisite 5.4 specified that the reactor coolant tempera This was different from the Hot, (2) be between 500*F and 557*F.
i Full Flow Rod Drop surveillance described be The licensee agreed greater than or equal to 551 F.
Technical the procedure to agree with the Proof and ReviewThis Specification.
pending procedure revision.
Flow)" SU7-SF03.4, Rev. O, " Rod Drop Time Measurement (Hot, No Review During the inspector's review, it was noted that Proof and c.
Technical Specification 3/4.10.5, "Special Test Exceptions: i 2.0, Position Indication System-Shutdown", was listed in Sect on " References", and addressed in the body of ' . Step 6.0, 3/4.10.4, "Special Test Exceptions: i d in either also applied directly to this procedure, was not me . of this procedure to address Proof and Review Tec n c location.
3/4.10.4.
O, Rev. O, " Initial Criticality", and SU7-0003, Rev.
. il " Inverse Count Rate Ratio Monitoring for Approach to Init a s 507-0004, d.
Criticality" l boron Regulatory Guide 1.68, Revision 2, states that a critica lies may be noted concentration should be predicted so that any anomaTh , and evaluated.
This is considered an unresolved item this statement.
(482/84-43-08(DRS)) pending procedure revision.
d e listed The inspectors commenced review of the startup ort.
. Power" (This below.
SU-SF08, Rev. O, "RCCA or Bank Worth Measurement at Zero" procedure is incorporated in SU7-5011, Rev. O, Low Power Test Sequence"). id No items of noncompliance or deviations were identif e. i3 Voiding of Completed Preoperational Tests tional tests 9.
f,j{ The inspectors observed that several safety-related preopera i rocedure viola-have recently been voided due to numerous adm d and had ' i proceeded through various levels of the normal rev ewThe in - tions.
' - l i this situa-lack of overview and monitoring by the licensee in a action was initiated.
' - P~' , f i tion to develop.
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_- . .- . tests that have problems but should indicate more involvement by moni-toring groups within the licensee's organization. The inspectors further indicated that this trend will continue to be evaluated to determine if adequate corrective action has been implemented and to determine the impact on the acceptability of the preoperational test program.
10.
Preoperational Test Scheduling The inspector has again informed the licensee that the published preoperational test completion date, plus the exhibited time frame for licensee review of completed test results packages does not support the proposed fuel load date.
The inspector's concern is that attention to meeting proposed fuel load date may negatively influence the licensee's results review process.
The inspector also indicated that the level of review by qualified people must not decrease due to pressure to meet proposed schedules. The licensee has acknowledged the concerns.
This item is of particular interest due to the recent voiding of completed test packages by the licensee as discussed in paragraph 9.
. 11.
Technical Specifications Review The inspector reviewed the draft proof and review technical specifica-tions in detail in preparation for procedure and results reviews.
No items of noncompliance or deviations were identified.
12.
Preoperational Test Content Review of procedures and test results packages during both this and the previous inspection period revealed deficiencies in the technical content of approved preoperational test procedures.
These deficiencies can be categorized into four areas and are listed below along with examples of these deficiencies.
a.
Failure to provide verification of designed safety features (1) The ability of an SIS or Feedwater Isolation Signal to override the exercise mode of the Main Feedwater Isolation Valves was not verified in SU3-AE01, " Main Feedwater System".
This item was discussed fully in inspection report 50-482/84-30(DRS).
(2) The ability of an SIS to override the slow closure mode of the MSIVs was not verified in SU3-AB04, " Main Steam System". This item is discussed in paragraph 3.a of this report.
(3) The ability of an SIS to override the Automatic Test Insertion sequence in the Load Shed/ Emergency Load Sequencer system was not verified in SU3-NF01, " Load Shedding and Load Sequencer".
This item is discussed in paragraph 4 of this report.
. Failure of preoperational test procedures to verify the proper operation of designed safety functions is considered an item of noncompliance (482/84-43-09(DRS)). . '
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. . b.
Failure to verify an FSAR commitment Preoperational test SU3-NK01, "125 VDC Class 1E Electrical System", did not monitor and record hydrogen concentration during battery operations for retention as a plant permanent record.
This item is discussed in paragraph 3.b of this report.
Failure to verify an FSAR commitment is an item of noncompliance (482/84-43-10(DRS)). c.
Improper test methods (1) Failure mode testing of air operated valves (A0V) did not . verify correct fail position on loss of air and loss of electrical power to the solenoid air valve.
This item was discussed in report 50-482/84-30(DRS) and in paragraphs 5.b and 5.c of this report.
(2) An improper pressure gage was used to record pump performance data for acceptance criteria in SU3-EJ01, " Residual Heat Removal System".
This item is discussed in paragraph 5.d of this report.
. (3) The method used for conducting the 35 start diesel generator reliability test did not provide correct test conditions.
This item is discussed in paragraph 3.c of this report.
Incorporation of improper test methods and failure of the review processes to identify and correct them is an item of noncompliance (482/84-43-11(DRS)). d.
Failure to test equipment in the conditions under which it is expected to operate ~ (1) SU3-NF02, "LOCA Sequencer", did not provide proper environmental conditions for the diesel generator during its 24 hour load test. This item is fully discussed in report 50-482/84-30.
(2) SU3-NF03, " Shutdown Sequencer", did not test the emergency pumps' ability to start and accelerate to full load under degraded voltage conditions. This item was discussed in report 50-482/84-30.
Failure to test equipment in the condition under which it is expected to operate in'the event of an actuation is an item of noncompliance (482/84-43-12(DRS)). These items of noncompliance identified in preoperational test content were discussed at an Enforcement Conference held on December 4, 1984.
Any enforcement action based on these findings will be discussed in inspection report 50-482/84-57.
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Open Items Open items 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, the licensee or both.
Open items disclosed during the inspection are discussed in paragraphs 5.a, 5.b.(2), 5.d.(2), 8.a.(2), 8.b.(2), and 8.c.
14.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompli-ance, or deviations.
Unresolved items disclosed during the inspection are discussed in paragraphs 8.a.(1) and 8.d.
15.
Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1) on November 29, 1984 to discuss the scope and findings of the inspection.
The licensee acknowledged the statements made by the inspectors with ,
respect to items discussed in the report.
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