IR 05000498/1984011

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Intervenor Exhibit I-CCANP-145,consisting of Forwarding Insp Repts 50-498/84-11 & 50-499/84-11 on 840730- 0802 & 0813-16.No Violations Noted.Major Areas Inspected: Followup of Quadrex Rept Findings in NUREG-0948
ML20138J128
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 08/14/1985
From: Johnson E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Operea G, Oprea G
HOUSTON LIGHTING & POWER CO.
References
RTR-NUREG-0948, RTR-NUREG-948 OL-I-CCANP-145, NUDOCS 8510290260
Download: ML20138J128 (14)


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Dockets: 50-498/84-11 C '.G L _ 50-499/84-11 Houston Lighting & Power Company ATTN: G. W. Oprea, J Executive Vice President P.D. Box 1700 Houston, Texas 77001 *

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Gentlemen: This refers to the inspection conducted by Mr. G. L. Madsen of this office during the period July 30-August 2 and August 13-16, 1984, of activities authorized by NRC Construction Permits CPPR-128 and CPPR-129 for South Texas Project, and to the discussion of our findings with Mr. C. Robertson, and other members of your staff at the conclusion of the inspectio Areas examined during the inspection were a followup to the Quadrex Report open items. Within these areas, the inspection consisted of selective examination of procedures and representative records, interviews with personnel, and observations by the inspector. These findings are documented in the enclosed inspection repor Within the scope of the inspection, no violations or deviations were identifie In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Room unless you notify this office, by telephone, within 10 days of the date of this letter, and submit written application to withhold information contained therein within 30 days of the date of this letter. Such application must be consistent with the requirements of 2.790(b)(1).

NCOLLAC r.LSLLATCRY COMfdl5580N f r.ke' N _0 ficid Erh. No-is tbs matt?r of Shif ICENTJIED rg.dicant RECEIVED .-- Interweger RgJLCTED [ ' C::at's Of t'r q Costracter nATE

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tenorter bb 8510290260 850814 PDR ADOCK 05000498 G PDR

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Houston Lighting & Power ~ Company -2-Should you have any questions concerning this inspection, we will be pleased to discuss them with yo

Sincerely, Ort;;i--! sised By E. H. Johr. son E. H. Johnson, Chitif Reactor Project Branch 1

Enclosure:

Appendix - NRC Inspection Report 50-498/84-11 50-499/84-11

REGION IV== NRC Inspection Report: 50-498/84-11 Construction Permit: CPPR-128 50-499/84-11 CPPR-129 Dockets: 50-498 and 50-499 Licensee: Houston Lighting & Power P. O. Box 1700 Houston, Texas 77001 . Facility Name: South Texas Project Inspection At: South Texas Project HL&P/Bechtel, Houston, Texas Inspection conducted: July 30-August 2 and August 13-16, 1984 Inspector: 6

  "G . L. Madsen, Reactor Inspector 9/S!8k Date Project Section A Reactor Project Branch 2

Approved: 7 / / L. E. Martin jChief, Project Section A jfat[ ' Reactor Projist Branch 2 e 4/e  ? Jf

  . [au , Chief. Project Section A      Date (

eacto Project Branch 1 Inspection Stannary Inspection Conducted July 30-August 2 and August 13-16, 1984 (Report 50-498/84-11 and 50-499/84-11) i ! Areas Inspected: Routine, announced inspection of a followup to the Quadrex l Report findings contained in NUREG 0948, (Inspection Report 50-498/82-12 and l 50-499/82-12). The inspection involved 49 inspector hours by one NRC inspector.

, Results: Within the areas inspected, no violations or deviations were identifie s

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     -2-DETAILS Persons Contacted Houston Lighting & Power Company (HL&P)
 "C. Robertson, Licensing Manager
 *J. White, Principal Engineer      ;
 *M. Powell, Lead Engineer      i
 *L. Klements Licensing Engineer Bechtel Power Corporation (Bechtel)
 "F. Lopez, Assistant Project Engineer     l
 *R. Witthauer, Nuclear Staff J. Sche 11ebarger, Group Leader Nuclear Analysis    l J. Laube, Plant Design, Material Group Leader R. Tapia, Plant Design Specialist M. Suharwardy, Equipment Qualification U. Tiwari, Equipment Qualification V. Bhatnagar, HVAC M. Braunstein, Nuclear Licensing Specialist M. Sood Engineering Group Leader R. Metavosian, Mechanical Engineer M. Jante. ECW, Responsible Engineer M. Sansa1, HVAC, Responsible Fngineer A. Gajjar HVAC Engineering Group Leader R. Shields, Responsible Engineer J. Paterson, Group Leader, Model RC8 & IVC
 *D. Ashton, Chief Nuclear Engineer     -
P. Trudel, Nuclear Engineer, Group supervisor
 *D. Getman, Mechanical Licensing Coordinator
" Denotes those attending exit interviews on August 2 or 16, 1984.

i Inspection Findings ! { NUREG 0948 entitled, "Special Inspection Report of Quadrax Corporation Report on Design Review, for the South Texas Project, Units 1 and 2" (NRC-l ' Inspection Report Nos. 50-498/82-12 and 50-499/82-12), was issued on January 7,1983. The report contained findings relating to a NRC staff review of the Quadrex report on the Brown & Root (8&R) engineering effort at the South Texas Project (STP). Appendix A of the report lists items j requiring additional followup or verification by the NRC staff and assigns the items to Region IV or NRR. The following provides inspection / verification findings and status for the Quadrex items assigned to Region I The findings are identified by Quadrex paragraph numbers.

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   -3-Quadre2 No. 3.1(h)

The reliability analysis requirements for the ESF sequencer are addressed in Specification 3N099ZS0071. The specification also indicates that the , method of fault Tree analysis and tallure mode and effects analysis (FMEA)

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shall demonstrate that the equipment, as proposed by the seller, meets the single failure criteria of IEEE-379. This requirement was in the specification at the time of the Quadrex repor NRC questions 430.33N and 430.39N have been answered and entered as FSAR Amendment 29. The answer to 430.33N provides information relative to the emergency diesel start signals. The answer to 430.39N provides additional reliability data for the engineering safety features (ESF) load sequencer Based upo.1 the above, this Quadrex item is considered close Quadren No. 4.1.2.3(j) Plans included questioning of the fuel pool vendor (Westinghouse) with

- regard to the requirements of NRC SRP 3.8.4, Appendix D, for seismic
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design of fuel racks. Amendment 32 to the FSAR was submitted and states that, "HL&P is evaluating long term needs for increased spent fuel storage j through the use of higher density spent fuel racks. If HL&P decides to

! purchase higher density racks, these new racks will comply with Appendix Otherwise, the present racks will be analyzed to Appendix 0."

On the basis of the above, this Quadrex item is considered closed.

l Quadrex No. 4.1.2.4(o) Bechtel performed confirmatory calculations to evaluate the adequacy of containment reinforcing steel concerning design for Tangential Shear. The Bechtel " Option" computer program was utilized. Bechtel concluded that the amount of reinforcing steel provided for the containment building is l sufficient to meet the Tangential Shear criteria of code case N-250 of l ASME. This Quadrex item is considered close Quadrex No. 4.1.2.4(g)

Bechtel proposed reanalysis of duct ring calculations. The duct ring ! calculations were performed with the following conclusions: Ring ducts are adequately designed and no further investigation j is required.

! Return air riser supports were found to be inadequate. Therefore, the design will include parts not included in the B&R calculations.

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   -4-As a followup, Bechtel revised the return air riser drawings 3C01-95-1604 through 1607. A review of these drawings indicated proper approvals and a release for construction. This Quadrex item is considered close Quadrex Nos. 4.2.2.1(a). 4.2.2.1(b), and 4.2.2.1(d)

H MP notified the NRC on May 8, 1981 of a potential 10 CFR 50.55(e) ! reportable item relating to computer program verification. On  ! October 14, 1983, HL&P issued a final report on this matter. Bechtel completed a review and acceptance program of B&R computer calculations and computer verification reports (CPVR) in accordance with Engineering Department Procedures 4.36 and 4.3 Because of the design evaluation, a better descripton of as-built conditions, and the need to revise the design to meet new regulatory requirements, Bechtel retained only 6 of 147 related calculations and 45 of 98 CPVRs for project documentation of design calculations performed by B& Tha inspector selected one calculation 3LO99NC728-A and CPVRs CW-527 and EDSLIN for revie The first record packet reviewed contained information for the acceptability of Heating 5 computer program used for B&R heat conduction calculations. Calculations 3LO99NC7248, 726B, 727B, 728A and 729A were identified as similar and each determined temperature distribution in pipe restraints using the Heating 5 code. Calculation 729A was chosen for comparison with results obtained using Bechtel standard computer

, program ME 659. Bechtel concluded that Heating 5 code usage in B&R calculations was acceptable and conforms to Bechtels EDP-4.37. With further review, the inspector determined that calculations 7248, 727B, 728A, and 729A were found acceptable for use by Bechtel. Calculation 7268 was rejected because the modeling was considered unrealistic and incon- :

sistent. Hand calculations of temperatures matched computer output temperatures within a maximum error of 3% for calculation 7248, 7278, 728A, and 729A and the CPVR was accepted in accordance with Bechtel's l procedure EDP-4.3 The CPVR packet for B&R's CW-527 was reviewed by Bechtel. The document package indicated the code is in the public domain, was originated by the Corp of Engineers, appears to have been correctly loaded into the computer by B&R, and B&R hand calculations appear to be correct and acceptabl Bechtel reran a test problem using their HEC-2 program with essentially the same results. This CPVR was accepted in accordance with Bechtel procedure EDP-4.3 ., . (

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    -5-Computer code EDSLIN is an EDS Nuclear Incorporated code. Bechtel had received a listing of all computer codes used by EDS while performing work on the ST EDSLIN was included on this list. EDS also identified sections of the EDS Nuclear Quality Assurance program dealing specifically with computer programs and their handling. Additionally, Bechtel performed quality assurance audits of EDS in the area of computer. app 11-cation. The audit reports concluded there was effective implementation of the EDS QA manual. There was one finding pertinent to upgrading of a controlled copy of the EDS QA manual; however, it was closed during the course of the audit. The NRC inspector's review of the EDS QA manual and Bechtel's EDP-4.37 revealed them to be compatibl The NRC inspector additionally reviewed computer verification packets for STARDYNE, ES-439, CP-244, ES-212, ES-401, and ES-419. These six computer codes were verified by Bechtel hand calculations and/or computer verification utilizing a Bechtel code. Bechtel found each CPVR to be acceptable and the NRC inspector concluded the verification was in accordance with Bechtel's EDP 4.3 On the basis of the above, Quadrex items 4.2.2.1(a), 4.2.2.1(b), and 4.4.2.1(d) are considered close Additionally, the actions taken are considered to be adequate and provides a basis for the closecut of the associated 10 CFR 50.55(e) repor Quadrex No. 4.2.2.1(d)

Amendment 32 updated Appendix 3.8.A of the FSAR. This Quadrex item is considered close ' Quadrex No. 4.3.2.1(a)

 (This finding contained two line items.) This item is also discussed in 4.8.2.1(a). A potential 50.55(e)

report was made on March 16, 1982. DER 82-001 documents the evaluation of this item and concludes that safety of operation is not adversely affected and the final design had not been approved or released for construction. B&R made design changes to eliminate the specific question. A review of all safety-related PI&Ds for application of single criterion to instrument lines lead to the conclusion that the finding is not generic nor is it a safety j issue. The NRC was notified, on April 8,1982, that this item was considered not reportable in accordance with the requirements of 10 CFR 50.55(e). Based on the action taken, this finding is considered closed.

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    -6-i Bechtel has issued Project Engineering Directive (PED) 21 which provides listings of safety-related systems / equipment requiring DiEA and guidance for preparation of FPCA's. This item is considered closed; but Quadrer. finding 4.6.4.1(a), item (2),

remains open. The FEMA analyses will be reviewed by the NRR ' upon completion as part of the licensing review.

t ' On the basis of the above, this Quadrex item is considered closed.

! Quadrex No. 4.3.2.1(d) Bechtel has formalized methodology for verification of adequate separation and single failure criterion by the issuance of the following PE ' , 1) PED-16 entitled, " System Interaction Design Grade Directive," l which includes design guidance for single failure applications. , 2) PED 21 entitled, " Guidance fo- Preparation of FMEA."

' This Quadrex item is considered close Quadrex No. 4.3.2.1(e) Bechtel has issued design criteria for separation and specifications for main control boards such as the main control room benchboards, HVAC and miscellaneous panels, and panel-mounted components. This Quadrex item is considered closed.

l Quadrex No. 4.3.2.1(f) . l . Design Criteria NQ-1000, entitled, " Quality Classification of Structures, i Systems and Components," was issued by Bechtel. This Quadrex item is j considered closed.

i l Quadrex No. 4.3.2.1(1) Bechtel has issued the following PEDS: 1) PED 11 entitled, "ALARA Directive."

2) PED 15 entitled, "Bechtel Procedures for Review of Enviror.mentti and Seismic Equipment Qualification Plan and Procedures, EQ Tests, and EQ Reports."

3) PED 16 entitled, " System Interaction Design Guide Directive."

With the issuance of these documents, this Quadrex item is considered close .- - _ , - , - - _ - . _ - - - _ - -

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Quadrex No. 4.3.2.1(n) Bechtel's issuance of Design Criteria EQ 1009, " Electrical Design 1 Criteria"; and ZQ 1014 " Control System Design," provides designer i guidance on isolation devices of different types. This Quadrex item is

,  considered close i Quadrex No. 4.3.2.1(p)
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Battery load, calculations have been completed by Bechtel for the following: ' Non Class IE 125 V DC plant station batteries for electrical auxiliary and turbine generator buildin i V DC Non Class IE batteries which provide emergency power for l plant annunciator V DC Non-Class IE battery which provides emergency power for turbine generator and steam generator feed pumps during loss of AC powe Size 125V DC Class IE battery which can carry all DC and AC load supplied via inverter DC cable sizin This Quadrex item is considered closed.

- Quadrex No. 4.3.2.4(v) . i B&R's criteria regarding equipment and system monitoring was an item of l concern. Design criteria for plant annunciators and ESF status monitoring I systems have been issued. Additionally, a control room design criteria { report has been submitted to NRR for review. This Quadrex item is i considered closed.

i f Quadrex No. 4.3.2.4(x) ! Bechtel has issued PED 21 which provides Itstings of safety-related ' systems / equipment requiring FMEA and guidance for preparation of FMEA' The FMEA analysis will be reviewed by NRR as part of the licensing process . and a followup of Quadrex No. 4.3.2.1(a). This Quadrex item is considered closed.

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!        i Quadrex No. 4.3.2.5(ce)

l ' The use of PVC was questioned. The usage of PVC was identified and the quantity of PVC utilized was estimated. Bechtel considers that the overall , e quantity used is acceptable. The design will receive additional evaluation  !

in conjunction with NRR's review of Appendix R requirements and followup of l

Quadrex item 4.4.2.4(1). This Quadrex item is considered resolve i I Quadrex No. 4.4.2.1(d) Bechtel has issued PED 16, " System Interaction Design Directive" and design cr teria for the HVAC system and components within the plant. These criteria in :1ude the identification of interfaces with other systems. This Quadrex it m is considered close .

  ,quadrex Nos. 4.4.2.1(a) and 4.4.2.1(b)

Bechtel has developed design criteria VQ 1000 through 1033 for the i butidings at STP. All drawings relating to the HVAG redesign are in < j process and about 75% of the drawings have been released for construction.

j Amenhents 30, 31, 32, and 36 contained information for updating of the FSAR to reflect the redesign of the HVAC system. This Quadrex item is

considered close '

The final 10 CFR 50.55(e) report on the HVAC design was issued on i October 20, 1982, and was supplemented on May 17, 1984. The development

of design criteria for buildings, the status of redesign, and issuance of amenhents to the FSAR provide a basis for closure of this 10 CFR 50.55(e)
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! Quadrex No. 4.4.2.1(e) ' Bechtel reexamined the floor drainage system relative to the availability of the ECW system. As a result, a design change has been approved. for the , addition of seismically qualified level alarms, located in the control room, for the MEAB sumps. This Quadrex item is considered close Quadrex No. 4.4.2.1(.f) I j' Bechtel has issued design criteria which provides a basis for design to provide a suitable and safe environment for operating personnel and equipment in locations such as the control room, relay rooms, computer rooms and offices, and for the isolation valve cubicle and pipe restraint area ventilation system This Quadrex item is considered close _ . . . _ . , _ _ _ _ _ . _ _ . _ _ _ _ _ _ . _ _._.___-

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     -9-Quadrex No. 4.5.3.4(ca)

Bechtel reviewed all embeds and structural steel for the pipe whip load design. The pipe restraints outside of containment had not been locate Bechtel eliminated all EDS design for this item, basically for reasons of cost and maintainability. Bechtel has redesigned in accordance with l Bechtel criteria. This Quadrex item is considered close Quadrex No. 4.5.5.3(j) A problem was identified by B&R involving access for ISI on penetrations M46 and M48. A material requisition for replacement of M46 and M48 with integral forgings was issued in December 1982. This Quadrex item is , considered close Quadrex No. 4.5.5.4(1) A Bechtel review of mechanical penetration thermal analysis revealed a variation between interface temperatures used in the vendor's assumptions and Bechtel's .nalysis for the main steam and feedwater penetration The design was modified for these penetrations to include forced coolin The resultant interface temperatures where provided to the vendor and the vendor performed stress analyses which have been reviewed by Bechte < This Quadrex item is considered close Quadrex No. 4.5.5.4(n) During review of stress calculations in the transition region from the CCW pump pipe to fluid head, B&R identified the exclusion of stresses in the pipe to fluid head transition region. The vendors redid the stress  : calculations and submitted the report to Bechtel for review. Following Bechtel's review, the stress report was returned to the vendor for i ssuance. This Quadrex item is considered close Quadrex No. 4.5.5.4(o) The initial contract for the design of the RWST was with Brown Minneapolis. B&R approved the design "for use" in September 1981. In November of 1983, Bechtel closed the purchase order with Brown Minneapolis and awarded the contract to Pittsburg Des Moines Co (PDM). PDM C submitted their design to Bechtel in May 1984. Bechtel commented on the proposed design by PD The actions to-date provide closure of the finding relating to B&R's activities and the design of the RWST is presently in the normal Bechtel design process. Therefore, this Quadrex item is considered closed.

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      -10-Quadrex No. 4.5.5.4(p)

In response to a valve opening and closing rate specifications question, all B&R data sheet information was transferred to Bechtel iata sheets and submitted for review. The actuation / stroke tiac was specified in the miscellaneous section of the process solenoid valve data sheets and in the

 " notes" section of the control valve data sheets. Document review comments were resolved and all data sheets were issued for constructio This Quadrex item is considered close Quadrex No. 4.5.5.4(s)

Discussion revealed that: B&R had analyzed each valve siz In cases where there were no testing reports, an extrapolation to other size valves was use B&R did not actually accept any 2:1 extrapolatio Sechtel accepts a 2:1 extrapolation at the 1/2" valve size. A lesser ratio is permitted for larger size valves. Bechtel has engineering design criteria which covers this matte B&R specifications called for testing unless not practica In those cases analysis was permitte This Quadrex item is considered closed; however, NRR will provide additional evaluation in conjunction with Quadrex item 4.5.5.1(f) Quadrex No. 4.6.4.4(g)

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Bechtel provided NUS with conditions for inclusion in a thermal analysis for the ECP design. The conditions included ECW and CCW heat loads and flows, RCFC heat loads for shutdown and cooldown, spent fuel pool heat loads, ECP seepage, and the normally maintained level of the ECP of

El 24.5 to 25.0 foo On October 19, 1982, the item was reported as a potential 50.55(e) issu The results of the ECP thermal analysis indicated that temperatures were below those previously used to evaluate effects on components serviced by the ECW and the CCW and recommend use as orginally design. On April 11, 1983, HL&P notified NRC that this item was not considered reportable in accordance with 10 CFR 50.55(e).

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The Quadrex and potential 50.55(e) item is considered closed.

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Quadrex No. 4.7.3.1(e) Bechtel issued PED 15, entitled, "Bechtel 'rocedure for Review of Environmental and Seismic Equipment Qualification (EQ) Plan and Procedures, EQ Tests, and EQ Reports. This Quadrex item is considered closed; however, NRR will evaluate this subject further in conjunction with Quadrex item 4.6.2.1 and the review of the equipment qualification repor Quadrex No. 4.8.2.1(a) This item is also discussed in 4.3.2.1(a). A potential 50.55(e) report was made on March 16, 1982. DER 82-001 documents evaluation of the item and concluded that safety of operation is not adversely affected and the final design had not been approved for release for construction. Design changes eliminated the specific question and a review of all safety-related PI&Ds for application of single failure criterion to instrument lines lead to the conclusion that the finding is not generic nor is it a safety issue. The NRC was notified on April 8, 1982, that this item was considered not reportable in accordance with the requirements of 10 CFR 50.55(e). The NRC inspector concurs with this conclusio Based on a review, this Quadrex item is considered close l Quadrex No. 4.8.2.1(d)

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This item relates to computer code verification and is addressed in Quadrex item 4.2.2.1(a) above. This Quadrex item is considered close . Quadrex No. 4.8.2.4(11)

Bechtel reexamined the floor drainage and sump overflow. As a result, a ! design change has been approved for the addition of seismically qualified ' level alarms located in the control room for the MEA 8 sumps. This Quadrex item is considered closed; however, the general subject will receive additional NRR review in conjunction with Quadrex items 4.5.3.4(w) and4.6.4.1(b).

! Quadrex No. 4.9.1(b) i ( Bechtel has issued Specification 44010PSOC7, entitled "Special Problem List." Only one outstanding item is presently on the special problem listing; however, as additional problems are identified, they will be l entered on the problem listing for verification and resolution by the NDE contractor. This Quadrex item is considered close . _ . _ _ _ _ _ . . _ _ _ _ - . ~

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     -12-Quadrex No. 4.9.1(d)

The NRC inspector reviewed drawing MS-9001-HL-5003 and the STP mode Support MS-1001-SS-05 has been redesignated as MS-9001-HL-5003. The redesigned support is of a moveable design and provides additional clearance for ISI. This Quadrex item is considered close Quadrex No. 4.9.2 , Bechtel has provided a redesign of main steam line pipe restraints to provide additional access for RHR heat exchanger tube bundle removal and valve RHR-060B. This Quadrex item is considered close Quadrex No. 4.9.2(m) The NRC inspector's review of drawings and the STP model revealed that there was still some ongoing design activity in the general location of

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valve SI-009C and the valve has not been glued in place on the mode This Quadrex item is considered close . Open Quadrex Items Quadren items 4.1.2.3(m), 4.1.2.4(r), 4.1.2.3(v), 4.3.2.1(m), 4.4.2.1(c), and 4.6.4.4(f) have not been closed by HLAP. These items will be reviewed by Region IV during subsequent inspection . Exit Interview Exit interviews were conducted on August 2 and 16,1984. The finding and status relating to the Quadrex items, assigned to Region IV for ' resolution, were discusse . .

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