ML20024A681

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IE Insp Rept 50-346/83-05 on 830201-0429.Noncompliance Noted:Administrative Procedures & QA Manual Did Not Include Controls to Prevent Procedures from Becoming Inadequate & Followup LER Not Issued Re Trip Breaker Malfunction
ML20024A681
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 06/06/1983
From: Jackiw I, Peebles T, Rogers W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20024A682 List:
References
TASK-2.B.4, TASK-TM 50-346-83-05, 50-346-83-5, IEB-83-01, IEB-83-04, IEB-83-1, IEB-83-4, NUDOCS 8306220050
Download: ML20024A681 (11)


See also: IR 05000346/1983005

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-346/83-05(DPRP)

-Docket No. 50-346

License No. NPF-3

Licensee: Toledo Edison Company

Edison Plaza

300 Madison Avenue

Toledo, OH 43652

Facility Name: Davis-Besse Nuclear Power Station, Unit 1

Inspection At: Oak Harbor, OH

Inspection Conducted: February 1 through April 29, 1983

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Inspectors: T{ A. Pee es

Senior

sident Inspector

Date

W. G

& - 6 ' 83

Resident Inspector

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Approved By:

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ects ection 2B

. Inspection Summary

Inspection on February 1, through April 29, 1983 (Report No. 50-346/83-05(DPRP))

Areas Inspected: Routine unannounced inspection by resident inspectors of

previous inspection findings; operational safety; maintenance; surveillance;

LER followup; IE Bulletin followup; plant trips; plant operations; onsite-

review committee; TMI Lessons Learned; and independent inspection. The

inspection involved 424 inspector-hours onsite by two inspectors including 82

inspector-hours onsite during off-shifts.

Results: Of the eleven' areas inspected, no items of noncompliance were

identified in nine areas; two items of noncompliance was identified in two

areas (inadequate procedures - Paragraph 2; and inadequate corrective

action - Paragraph 6).

8306220050 930607

pDR ADOCK 0500034

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DETAILS

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Persons Contacted During Inspection

T. Murray, Station Superintendent

B. Beyer, Assistant Station Superintendent

S. Quennoz, Assistant Station Superintendent

P. Carr, Maintenance Engineer

J. Werner, Instrument Engineer

~D. Miller, Operations Engineer

W. O'Connor, Assistant Operations Engineer

D._Briden, Chemist and Health Physicist

R. Peters, Licensing

L. Simon, Operations Supervisor

C. Daft, Quality Assurance Director

J. Faris, Administrative Coordinator

The inspectors also interviewed other licensee employees, including

members of the technical, operations, maintenance, I&C, training, health

physics, and security staff.

Persons at Meeting of March ~30, 1983

L. Young, Nuclear Licensing

T. Murray,sStation Superintendent

R. Peters, Nuclear Licensing

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J. Byrne, Quality Assurance

S. Quennoz, Assistant Station Superintendent

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S. Batch, Technical Section.

J. Stotz, Technical.Section

L. Richter, Technical Section

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W. Rogers, Nuclear Regulatory Commission

I. Jackiw, Nuclear Regulatory Commission

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J. Streeter, Nuclear Regulatory Commission

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T. Peebles, Nuclear Regulatory Commission

~ Persons at Meeting of April 19, 1983

.I. Jackiw, Nuclear Regulatory Commission

W. Shafer, Nuclear Regulatory Commission

T. Peebles, Nuclear Regulatory Commission

W. Rogers, Nuclear Regulatory Commission

L. Grime, Nuclear Safety

A. Zarkesh, Nuclear Safety

P. Carr, Maintenance Engineer

R. Peters, Operational Licensing

D. Poage, Quality Assurance

T. Chowdhary, Quality Assurance

J. Helle, Nuclear Facility Enginerring Manager

R. Berger, Bechtel - Project Administrator

J. Fay, Bechtel, Project Engineer

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M. Calcasuggio, Manager - Engineering Administrator

J. Troknya, Engineering ~ Administrator

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J. Shortt, Nuclear Engineering

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C.'Mekbel, Nuclear Engineering

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.S. Quennoz, Assistant Station Superintendent

J.-Faris, Administrative Coordinator

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2.

Action on Previous Inspection Findinas

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(Closed) Unresolved Item (346/83-01-05): During the January inspection,

the inspector found several inadequate procedures due to an excessive

. number of. attached temporary modifications. The inspector also found

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-that.the administrative procedures an'd Quality. Assurance Manual did not

include adequate controls to prevent procedures from becoming inadequate.

It has since been found that the previously addressed procedures were

not isolated instances but were exarples of. procedures which have become

difficult to use and understand. This is due to priorities not having

been established for timely incorporation of temporary modifications.

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This is considered an item of noncompliance (346/83-05-01).

3.

' Operational Safety Verificatica

Theinspectorobservedcontrolroomoperatkoas,reviewedapplicablelogs

and conducted discussions with control room operators during the months

of February, March and April. The inspector verified the operability of

selected emergency systems, reviewed tagout records.and verified proper

return to service of affected components. Tours of auxiliary building

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reactor building and turbine building were conducted to observe plant .

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equipment conditions, including potential fire hazards, fluid leaks, and

excessive vibrations and to verify that maintenance requests had been

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initiated for equipment in need of maintenance. The inspector by

observation and direct interview verified that the physical security

plan was being implemented in accordance with the station security plan.

The inspector noted two apparent discrepancies (Paragraph 15).

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The inspector observed plant housekeeping / cleanliness conditions and

verified implementation of radiation protection controls. During the

month'of February,-. March and April, the inspector walked down the

accessible-portions of the service water, high pressure injection and

decay heat syste.as'to verify operability. The inspector also witnessed

portions of the radioactive waste system controls associated with

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radwaste shipments and barreling.

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These reviews and observations were conducted to verify that facility

~ operations were in conformance with the requirements established under

l technical specifications, 10 CFR, and administrative procedures.

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4.

Monthly Maintenance Observation

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Station maintenance activities of safety related systems'and components

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listed below were observed / reviewed to ascertain that they were conducted

in accordance with approved procedures, regulatory guides and industry

codes or standards and in conformance with technical specifications.

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The.following items were considered during this review: the limiting

conditions for' operation were met while components or systems were

removed from service; approvals were obtained prior to initiating the

work; activities were accomplished using approved procedures and were

inspected as applicable; functional testing and/or calibrations were

performed prior to returning components or systems to service; quality

control records were maintained; activities were~ accomplished by

qualified personnel; parts and materials used were properly certified;

radiological controls were implemented; and, fire prevention controls

were implemented.

Work requests were reviewed to determine status of outstanding jobs

and to assure that priority is assigned to safety related equipment

maintenance'which may affect system performance.

The following maintenance activities were observed / reviewed:

Diesel Generator Electronic Governor

Rad Waste Fan Rework

Turbine-Trip Solenoid Replacement

Steam Generator Level Transmitter Replacement

Security Systems

Following completion of maintenance on the Emergency Diesel Generator

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and SFRCS Power Supply Replacement, the inspector verified that these

systems had been returned to service properly.

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No items of noncompliance or deviations were identified.

.5.

Monthly-Surveillance Observation -

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The inspector observed technical specifications required surveillance

testing.on. the Moderator Temperature Coefficient, Service Water Pumps

and Auxiliary Feedwater System and verified that testing was performed

in accordance with adequate procedures, that test instrumentation was

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calibrated, that limiting conditions for operation were met, that

removal and restoration of the affected components were accomplished,

that' test.results conformed with technical specifications and procedure

. requirements and were reviewed by personnel other than the individual

directing the test, and that any deficiencies identified during the

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testing were properly reviewed and resolved by appropriate management

personnel.

The inspector also witnessed portions of the following test activities:

HPI Pump Runs, CS Pump Runs, DH Pump Runs, RPS Logic, miscellaneous

-valve verification, and EVS Operation.

No items ~of noncompliance or deviations ~were identified.

6.

Licensee Event Reports Followup

Through direct [ observations, discussions with licensee personnel, and

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- review'of records, the following event report was reviewed to determine

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that reportability requirements were fulfilled, immediate corrective

action was accomplished, and corrective action to prevent recurrence had

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been accomplished in accordance with technical specifications.

Action

LER Number

Subject

-(OPEN)

81-70

Failure of CRDN Trip Breaker

The inspector's review of the LER identified the following problems:

(a) No followup LER was issued to give the cause of the breaker failure.

(b) The replacement breaker did not have a UV coil and the UV coil from

the failed breaker was used.

(c) The testing which was done on the replacement breaker did'not include-

time response testing or reference to a maintenance procedure.

(d) The NWO to troubleshoot the failed breaker was written one week

after the failure and troubleshooting did not take place until 7/82

and could not be comprehensive as the breaker was not "as found" due

to use of the UV coil in the other breaker.

(e) The GE maintenance advice to change the UV coil setpoint was

received 5/79 and a procedure written 6/79, but the first time the

procedure.or the GE advice was implemented was 7/82.

Failure to take prompt corrective action is considered an item of non-

. compliance (346/85-05-02).

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As a result of discussions with the licensee, they agreed to submit an

updated LER.

On March 9, 1983, an Enforcement Conference was held with the licensee to

discuss recent concerns identified by the NRC in the area of maintenance

controls including inadequate and untimely corrective actions taken re-

garding equipment malfunctions. Following this meeting the licensee

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initiated steps to implement a comprehensive corrective action program to

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address these concerns,

During this inspection the-inspector identified the above example of

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untimely corrective action taken with regard to LER No. 81-70. This

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event occurred prior to the Enforcement Conference. However, in order

to resolve the continuing NRC concerns regarding taking adequate and

prompt corrective actions when equipment malfunctions are identified,

the licensee is being requested to provide the following information:

i.

How will-future updates from the equipment manufacturer be

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expeditiously incorporated in your maintenance program?

11. . How will appropriate maintenance procedures be referenced on the NWO?

iii. How will. troubleshooting be expedited?

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How will the Station Review Board procedures be changed to assure

adequate troubleshooting and appropriate corrective actions are

expeditious and thorough?

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How will the LER procedures be changed to assure'that followup LER

' revisions are generated?

7.

IE Bulletin Followup-

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'For the IE Bulletins listed below the inspector verified that the

Bulletin was received by licensee management and reviewed for its

applicability to the facility.

If the Bulletin was applicable the

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inspector verified that the. written response was within the time period

stated in the Bulletin, that the written response included the informa-

tion required to be reported, that the written response included

adequate corrective action commitments based on information presented

in the Bulletin and the licensee's response, that the licensee manage-

ment' forwarded copies of the written response to the appropriate onsite

management representatives,.that information discussed in the licensee's

written response was accurate, and that corrective action taken by the

licensee was as described in the written response.

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(OPEN) 83-04 Failure of the undervoltage trip function of reactor trip

breakers,

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The inspector reviewed the licensee's response with the following

results:

(a) The trip breakers were tested satisfactorily on March 14, 1983.

This test did not include time response.

(b). The maintenance program is currently in conformance with the latest

, manufacturer's recommendations. The last maintenance was performed

in July of 1982 to these procedures. Time response testing was

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satisfactory.

(c) .All licensed operators-completed the required reading of the

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bulletin.

(d) .The additional breaker malfunctions were all with the output relay

and did not affect breaker operation.

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(e) The.RPS breaker and UV device are treated as safety related.

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Outstanding questions are addressed in Paragraph 6.

The RPS breakers are currently in conformance with bulletin requirements

as-stated'above.

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(Closed) 83-01 Failure of Reactor Trips Breakers (Westinghouse DB-50) to

Open an Automatic Trip Signal.

The inspector verified that the licensee does not use Westinghouse DB-50

type in the Reactor Protection System. The inspector also verified that

the licensee submitted a negative declaration as required by this bulletin.

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8.

. Plant Trips

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Following the plant trips on April 10, 1983, the. inspector ascertained

the status of the reactor and safety systems by observation of control

room indicators.and discussions with licensee personnel concerning plant

parameters, emergency system status and reactor coolant chemistry. The

inspector verified the establishment of proper communications and

reviewed the corrective actions taken by the licensee.

All systems responded as expected, and the plant was returned to

operation on April 10, 1983.

No items of noncompliance or deviations were identified.

9.

Review of Plant Operations

During the months of January through' April 1983, the inspector reviewed

the following' activities:

a.

Review and Audits

On April 19 and 26, the inspector sat in on portions of safety

review committee meetings. .The inspector verified that provisions

of technical specifications dealing with membership, review process,

frequency, and qualifications were met. The inspector also verified

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that decisions made were reflected in the meeting minutes and that

corrective actions proposed were taken.

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b.

Training

The inspector atter.ded three of the licensee's operator requalifi-

cation lecture series and verified that lesson plan objectives were

met'and that training was in accordance with the approved operator

requalification program schedule and objectives.

The inspector verified by direct questioning of one new, one

existing, and one temporary employee that administrative controls

and procedures, radiological health and safety, industrial safety,

controlled access and security procedures, emergency plan, and

quality assurance training were provided as required by the

licensee's technical specifications.

c.

Security

The inspector observed _that ten individuals achieved acceptable

scores during the conduct of weapons and physical fitness tests.

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-Emergency Preparedness

The inspector visited the Ottawa County Commission and verified that

the agency is familiar with their role in the emergency plan. On

-April 13-14, 1983, Toledo Edison conducted a full scale emergency

drill agencies participating in the drill were local counties, the

state of Ohio and the NRC. The inspector also observed the emergency

drill and verified that the licensee has a program for correcting

identified discrepencies and that equipment disrupted was returned

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to its proper location after the drill.

e.

Licensee Action Concerning Identified Problems

The inspector reviewed corrective actions taken by the licensee

pertaining to recurring failures-and resolution of identified

discrepencies involving safety-related components.

This area has several identified problems, to which the licensee

is currently responding as part of the March Enfotcement Conference

and in response to this inspection report.

10.

Onsite Review Committee

The inspector examined the onsite review functions conducted during

the. period March and April 1983, to verify conformance with technical

specifications and other regulatory . requirements. This review included:

changes since the previous inspection in the charter and/or administra-

tive procedure governing review group activities; review group membership

and qualifications; review group meeting frequency and quorum; and,

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activities ~ reviewed including proposed technical specification changes,

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noncompliance items and corrective action, proposed facility and

procedure changes and proposed tests and experiments conducted per

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10-CFR 50.59, and others required by technical specifications,

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No items of noncompliance or deviations were identified.

11. Meeting With Public Officials

A meeting was held with local public officials on March 9, 1983, in the-

Ottawa County Courthouse, Port Clinton, Ohio. The resident inspectors

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were introduced and a description of the NRC Inspection and Enforcement

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Program was given.

NRC personnel in attendance were:

W. B. Henczer, Regional State Liaison Officer

C. E. Norelius, Director, Division of Projects and Resident Programs

L. Reyes, Project Section Chief

I. N. Jackiv, Project Section Chief

W. G. Rogers, Resident Inspector

T.- A. Peebles, Senior Resident Inspector

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1:2. _ Meetina on 3perability

.A meeting was held at the Davis-Besse site on March 30, 1983, with the

. persons in attendance as noted in Paragraph 1.

The following items were

discussed:

'(a)- SUBJECT: NRC Position on When an Action Statement is Entered as a

. Consequence of Failure to Perform Surveillance Teste

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Action Statements are entered when the Surveillance Requirements

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should have been performed rather than at the time it is discovered

that tests were not performed.

(b)~ SUBJECT: NRC Position on Shutdown Time Allowances When an LCO is

Not Het

It is the NRC position that it is acceptable for a licensee to

' initiate and complete a reduction in operational modes in a shorter

time interval than required by the allowable out-of-service time

specified in an Action Statement and then to add the unused portion

of this allowable out-of-service time to that provided for operation

in a lower operational mode. Furthermore, it is the NRC position

that a stated allowable out-of-service time (frequently 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or

7 days) should be applicable regardless of the operational mode in

which the'inoperability is discovered. However, the times provided

for achieving a recuction in operational modes (e.g., generally 6

hours from Modes 1 or 2_to Mode 3, and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> from Mode 3 to Mode 4)

should notlbe-applicable if the inoperability is discovered in a

lower operation mode.

(c) SUBJECT: NRC Position on Relationship Between Surveillance

Requirements for Inservice Inspection and Operability

Requirements.

Satisfactory performance of the Section XI surveillance program is

necessary to demonstrate operability of components. Failure to

conduct Section XI testing renders affected components inoperable

and requires the invocation of applicable action statements.

(d) The. applicability of Technical Specification 3.03 when an LCO was

exceeded was discussed and the Region will request an interpretation

-from NRR.

(e).'LER 83-07 (Loss of Y1 bus) was discussed and it was determined that

'upon loss of the bus- that the other busses .would be checked for

operability.

(f) LER 83-01 (ECCS Room Coolers) was discussed and the licensee agreed

ito expedite his investigation and to have a report by April 15,

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(The report was sent on April 13).

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(g) Reportability of failed components was discussed and it was agreed

that if the failure was in the " safe" direction and did not cause

entry into the Technical Specification Action Statement that it was

not reportable.

(h) The licensee.was requested to expedite the change to Technical Specification 3.0.3.

The licensee agreed that if required, the

section on 3.0.3 would be separated from the other portions of the

Technical Specification Change Request. -During a subsequent telecon

discussion on May 11, 1983, between N. Jackiw (NRC) and L. Young

(TECo), Mr. Young stated the Technical Specification change is

being expedited. He also stated that he expects to submit the

change to NRR.by July 1, 1983.

13. Meeting for Followup from March Enforcement Conference

A meeting was held at the Davis Besse site on April 19, 1983, with the

personnel in attendance as noted in Paragraph 1.

The licensee presented

the major points of the. corrective actions addressed at the March

Enforcement Conference. The NRC staff requested additional information

which'the licensee stated would be included in the formal response to be

sent by the end.of April.

14. Implementation of TMI Lessons Learned

Item II.B.4. (Closed): Training for Mitigating Core Damage

The Station Superintendent successfully completed the mitigation

of core damage training on March 14-18.

This item is considered closed.

No items of noncompliance or. deviations were identified.

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15.

Independent Inspection Effort

The inspectors routinely attended meetings with licensee management and

various shift turnovers between shift supervisors and licensed /non-

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licensed operators. These meetings and discussions provided a daily

status of plant operating and testing activities as well as discussion

of significant problems or incidents.

On March 21, 1983, high water was experienced in the vicinity of the

plant and the Flood Watch procedures were put into effect. The inspector

reviewed the procedure. No flooding of the site occurred.

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On' April 12, the inspector found that an opening in the protected barrier

fence did not appear to have adequate compensatory measures. On April 26

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and 28, the inspector noted improper card reader use at two doors. The

licensee and the region were informed and the region is following up on

.these. items. Additional information regarding these items is discussed in

. Inspection Report No. 346/83-08.

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16. Exit Interview

The inspector met with licensee representatives (denoted in Paragraph 1)

throughout the months and at the conclusion of the inspection on April 29,

and summarized the scope and findings of the inspection activities. The

licensee acknowledged the noncompliance and other findings.

The licensee was informed that nothing had been initiated to expedite the

technical specification change to Section 3.0.3 which they had committed

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to do on March 30, 1983.

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