ML20236G655

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Insp Rept 50-298/87-12 on 870601-0715.Violation Noted. Major Areas Inspected:Licensee Actions on Previous Insp Findings,Allegations,Offsite Review Committee,Ler Followup, Spent Fuel Shipments & Maint Activities
ML20236G655
Person / Time
Site: Cooper Entergy icon.png
Issue date: 07/27/1987
From: Dubois D, Jaudon J, Plettner E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20236G627 List:
References
50-298-87-12, NUDOCS 8708040338
Download: ML20236G655 (13)


See also: IR 05000298/1987012

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                                                                                                  -APPENDIX B

n, ?W .U. S. NUCLEAR REGULATORY. COMMISSION 3 REGION IV..

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                   '     ,       NRC Inspection Reporti 50-298/87-12-                                                            License:      DPR-46
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                                 Docket:- 50-298                                                                                                                     .
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i  ; Licensee: Nebraska Public Power District (NPPD)

                                                       P.'  O. Box 499
                                                       Columbus,:NE          68601
                                 Facility Name:               Cooper' Nuclear Station (CNS)'                                                                         3
                                .. Inspection At:             Cooper Nuclear Station, Nemaha County. Nebraska

, ~ Inspection. Conducted: ; June 1-July 15,1987

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                                 Inspectors:                 . d'. [f## ,                                                                  7h of g7
                                                           E. A.=Plettner, Resident Inspector, (RI).;                                    Date
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                                                           D.L.DuBois,SeniorResidentInspector,,(SRIT                                     Date
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                                 Approved:                     /                           M
                                                           J( P. Jaudon/ Chief, Project Section A,
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                                                                                                                                        .Date.
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                                   B70B040338 870730
                                   PDR         ADOCK 05000298
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           Inspection Summa'ry
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           Inspection ronducted June 1 through July 15, 1987 (Report 50-298/87-12)
           Areas Inspected:    Routine, unannounced inspection of licensee actions on
           previous inspection findings, allegations, offsite review committee, licensee
           event reports followup, spent fuel shipments, operational safety verification,
           and monthly surveillance and maintenance activities.
           Results: Within the areas inspected, one violation was identified (failure to
           follow SRAB instructions, paragraph 4).
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                                                           DETAILS
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               1.     Persons Contacted                                                                               ,
                    ' Principal Licensee Employ'ees                 ,
                    *G.    R. Horn,-Division Manager of Nuclear Operations
                      J. M. Meacham, Senior Manager, Technical Support
                    *C     R.' Goings-Merrill, Regulatory Compliance Specialist
                      D. R. Robinson,' Supervisor, Operations Quality Assurance
                               .
                      R. D.~ Black, Supervisor, Operations
                      H. A. Jantzen, Supervisor,--Instrument and Control (I&C)
                      M. D. Hamm, Supervisor,. Security
                      G. A. Trevors, Division Manager, Nuclear Support Group.
                     .P. V. Thomason, Manager, Nuclear Program Overview
                      V. L. Wolstenholm, Division Manager, Quality Assurance
                         .
                      D. B.,Muhle, Supervisor, Contract Administration
                      L. J. Cooper, Environmental Manager
                      G. E. Smith, Manager, Quality-Assurance
                                                .
                    *E. M. Mace, Enginee' ring Manager                                                                j
                    *R. Brungardt, Manager,. Operations                                                               -
                    *J. C. ' Ditto, Senior. Quality Assurance Specialist
                         .
                      NRC
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                    *W. R.'      Bennett, Project Inspector
                    *W. M.       McNeill, Project Inspector
                      The NRC inspectors-also interviewed other licensee employees during the
                      course of the inspection.
                    * Denotes those present during exit interview July 20, 1987.
               2.-    Licensee Action on Previous Inspection Findings
                      The following open and unresolved items were reviewed by the NRC                                i
                      inspectors to verify that the licensee's response to the items identified                       l
                      in previous' inspection reports are now in conformance with regulatory
                      requirements.and that corrective measures.were completed in a timely
                      manner.
                  ,
                      (Closed) Open 298/8410-02: Contradictory Action Statements in Table 3.1.1
                      of the CNS' Technical Specification.
                      In Amendment No.108, to the ' facility operating license, dated April 20,
                      1987, Table 3.1.1 of the CNS Technical Specification was revised. That
                      revision eliminated one of two contradictory action statements specified
                      for use when the minimum number of operable APRM channels could not be met
                      for the high flux (flow bias), high flux (15 percent), inoperative,- and
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              downscale reactor trip functions. The previous Technical Specification

L required the licensee to make a determination as to which of the.two

              statements was appropriate to a specific situation. The amendment

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              eliminated the choice and clarified the applicable action statements.
              This item is~ closed.
              (Closed) Unresolved 298/8611-02:      Inspection of Contracts and Service.
              This item involved the official file for Purchase Contract 84-40A.      The
              file did not contain documentation of the Quality Assurance Review (QAR)
              of two amendments to the contract. Also, a third required amendment was
              not in the official file.     The NRC inspector reviewed the official file
              for Purchase Contract 84-40A to verify that the three amendments were
              contained in the file and that each file contained a documented QAR.
              This item is closed.
           3. Allegations
              (Closed) Allegation 4-86-A-126: This item involved the Electrometrics
              Company and Data Precision Model 3503 Multimeters used to calibrate test
              instruments at Cooper Nuclear Station (CNS).
              On December 16, 1986, J. M. Pilant (NPPD) was notifie-d by the NRC
              Region IV office of possible deficiencies existing in the calibration
              frequencies and maintenance of Data Precision Model 3500 Multimeters used
              by Electrometrics Company to calibrate CNS test instruments. The
              following is a summarization of the actions taken by NPPD to determine if
              deficiencies did exist, and the results of those actions:
              .      On December 17, 1986, CNS test instrument calibration records were
                     researched to determine to what extent the Data Precision Model 3500
                     Multimeters were used by Electrometric for calibration of CNS test
                     instruments. Results of the audit identified 85 different test
                     instruments in the Instrument and Control (I&C) and Electrical Shops
                    which were calibrated using the subject Model 3500 Multimeters. Only
                     two Model 3500 Multimeters (Serial Numbers 5818 and 1008) had been
                     used by Electrometrics to calibrate CNS test instruments during the
                     period January 1, 1984, through November 31, 1986.
              .      On December 18, 1986, an audit specific to the calibration and
                     maintenance of the Data Precision Model 3500 Multimeters was
                     conducted at the Electrometrics Company facilities. Calibration and
                     maintenance records for multimeters SN 5818 and SN 1008 revealed that
                     both instruments were being calibrated on a 1 year frequency in
                     accordance with recommendations from Data Precision Company, the
                     manufacturer of the instrument. Certification of the calibration
                     standards used were traceable to the National Bureau of Standards.
                     Electrometric's records indicated that multimeter SN 1008 had been
                     removed from service and disassembled since November 1984. Rev..w of
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                  CNS. test _ equipment calibration records confirmed the findings at                             j
                  Electrometric. No record 'of instrument' repair to SN 1008 prior to                             i
                  November 1984,'was recorded on the instrument history card. No record
                  of instrument repair for SN 5818 between calibrations was recorded on
                  the instrument history card.
             .   'NPPD audite'd QA records from Electrometrics Company dated
                  September 25, 1985,'and June 5, 1986. The results of the audit-
                  indicated that calibration records for Data Precision Model 3500
                  Multimeter SN 5818 were in order.
             .    Proficiency of technicians who performed repairs and calibrations on
                  CNS, test' instruments was discussed with Electrometric Company
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                  management'on' December 18, 1986.- Management indicated that at least
                  one'of the technicians had been terminated'by the company during the
                  period January 1,1984, 'through November. 31,'1986. Management stated
                  that none of the terminations had occured because of substandard
                  proficiency or ability.
             In conclusion, the results obtained from the above audits and interviews
            performed by NPPD and reviewed by the RI did not indicate-that sny
            deficiencies existed in the calibration frequencies or the maintenance of
            the Data Precision Model 3500 Multimeters used by Electrometrics' Company
            to calibrate CNS test instruments.      Thus, all test instruments
            calibrations were valid.
            This allegation is closed.
        4.  Offsite Review Committee
            The inspection was performed to determine.if the offsite review committee
           : was performing its functions in.accordance with regulatory requirements.
            The offsite review committee was referred.to as the Safety Review and
            Audit Board (SRAB). .The RI reviewed the ' updated Safety Analysis
            Report (USAR), Technical Specification, Quali_ty Assurance Plan (QAP) 2200
            for SRAB and SORC' activities, Revision 1, dated March 6, 1985, and the
            SRAB Instructions and Guidelines, Revision 2, dated December 5, 1986.
            The RI reviewed the SRAB meeting minutes listed below, the documents that
            the SRAB reviewed also listed below and attended SRAB Meeting No. 119 on
            June 17, 1987. Discussions were also held with the SRAB administrator and
            some SRAB members.     The instructions and guidelines that prescribed SRAB
            activities and the functions performed by SRAB appeared to meet Technical
            Specification Section 6.2.1.8 requirements. The NRC inspectors noted that
            while the guidelines allowed for the use of an outside consultant as a
            voting member of SRAB, none had been used in that capacity for the period
            January 1,1986, through June 17, 1987.
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   The following SRAB meeting minutes were reviewed:
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           Meeting No.             Date                                                                            I
               105               03/21/86                                                                          l
               106               04/25/86                                                                          l
               107               05/30/86                                                                          l
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               108               06/13/86
               109               07/24/86                                                                          l
               110               08/22/86                                                                          j
               111               09/19/86
               112               10/10/86
               113               11/14/86                                                                          f
               114               12/19/86
               115               01/16/87
               116               02/20/87
               117               04/14/87
               118               05/27/87
   The following documents were reviewed:                                                                          <
   .    Licensee Event Report 87-10: Automatic Starting of Diesel Generators
        Upon Loss of the Emergency Transformer Due to Inclement Weather
   .    SORC Meeting Minutes:    S87-43 and S87-044
   .    Emergency Plan and Implementing Procedures (EPIP) 5.7.7, Revision 7,
        General Emergency Implementing Procedure
   .    Equipment Specification Change 86-33, RW Exhaust Fan Damper AD-1017
        A/B Replacement
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   .    Special Test /Special Procedure 87-008, Rod Worth Minimizer
        Operability
   .     Proposed USAR Revision No. 5, dated July 22, 1987
   .    QA audit in progress S87-25, Limitorque Corporation
   The USAR Section 13, paragraph 9.5, dealing with.the SRAB, states:
         "All of the Board members have degrees . . . ."
   The SRAB Instructions and Guidelines, Section 1.2 states, "They shall have
   a B.S. degree . . . or equivalent experience."
   The above SRAB Instructions and Guidelines statement was in conflict with
   the USAR requirement also stated above. The RI informed the licensee of
   the conflicting statements. This was of concern to the RI because three
   individuals currently serving on the SRAB do not have a Bachelor of                                              s
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                           Science degree.    Also, no documentation of acceptance criteria used to
                           determine equivalent experience for the three individuals was available.
                           In discussions with the licensee, they agreed to make a change to the USAR
                           under 10 CFR 50.59 to correct the conflicting statements. This item will
                           be tracked as an open item pending review of the licensee's corrective
                           action when completed.     (298/8712-01)
                           According to the SRAB Instructions and Guidelines, dated March 11, 1986,
                           each SRAB member shall receive a minimum of 20 hours training each calendar
                           year. This training can be by formal classroom instruction, by seminar
                           attendance, by participation in audits, or by a combination of the
                           foregoing. The SRAB administrator is tasked to maintain the records of
                           training for the SRAB members. The NRC inspector interviewed several SGAB
                           members. These SRAB members believed that they had completed the reacisite
                           training for calendar year 1986. The SRAB administrators records, however,
                           did not indicate completion of the required training for calendar year 1986.
                           The NRC inspector noted that one former SRAB member, who was not
                           interviewed because he had retired, had only 2 hours of recorded training
                           for 1986. Although the NRC inspector had questions as to whether or not
                           the minimum training had been completed, the lack of records to
                           substantiate the training of SRAB members was an apparent violation.
                           (298/8712-02)
                           The_NRC inspector also noted that the SRAB Instructions and Guidelines
                           stated that each member of SRAB should visit the site at least three times
                           each year. This was not a requirement. SRAB records indicated that three
                           members of SRAB had not made the recommended number of visits for 1986.
                  5.       Licensee Event Reports Followup
                           The following licensee event reports (LERs) were closed on the basis of the
                           SRI's inoffice reviews, reviews of licensee documentation, and discussions
                           with licensee personnel:
                           86-027, Supplement 1, Safety-Related Instr.ument Rack Seismic Deficiencies
                           86-033, Supplement 1, Residual Heat Removal and Core Spray Pump Motor

l Deficiencies Believed to be Caused by High Cycle Fatigue Loading  ! l Which Were Discovered During Inspection

                           87-001, Reactor Scrams While Performing a Reactor Coolant System In-Service
                                     Leak Test Due to a Procedural Inadequacy                           i
                           87-002, Reactor Scram During Startup Caused by Rapid Injection of Feedwater
                                    Due to Operator Valving Error
                           87-003, Reactor Scram and Group Isolations Due to Low Reactor Vessel Level   .
                                    During Troubleshooting of Apparent Reversed Leads to the Steam and  i
                                    Feed Flow Recorder                                                  ,

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                       87-004, Excessive Primary Containment Leakage Discovered During Local Leak
                                Rate Testing
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                       87-005, Reactor Scram Due to Main Steam Isolation Valve Closure as a Result
                                of Reduced Primary Containment Pneumatic Header Pressure During
                                Containment Inerting
                       87-006, Low Reactor Vessel Water Level Scram and Group Isolations Due to
                                Loss of Water Inventory Upon Reopening the Main Steam Isolation
                                Valves
                       87-007, Unanticipated Isolation of Reactor Water Cleanup System Due to High
                                Flow When Restoring the System to Operation
                    6. Spent Fuel Shipment
                       The RI inspected the licensee's activities associated with two shipments of
                       spent fuel from CNS. ' Included in that inspection were observations and     -
                       reviews of applicable licensee procedures, records, surveys, inspections,    I
                       and shipping document preparation.
                       The RI verified by review of licensee documentation, through discussions
                       with responsible personnel, and by independent inspection that the licensee
                       completed the following:
                       .     Receiving inspection of railcars and shipping casks-
                       .     Shipping documents
                       .     Advance notification of and approval by affected state and federal
                             agencies
                       .     Proper placarding of the transport vehicles
                       .     Appropriate labeling of the spent fuel shipping casks
                       .     Establishment of provisions for response by escorts and local law
                             enforcement agencies
                       .     Training of escort personnel
                       .     Testing of communications systems
                       .     Continual manning of the licensee's communications center (Movement
                             Control)
                       .     Testing of fuel and cask handling cranes, hoists, and tools
                       .     Proper loading and sealing of the spent fuel shipping casks

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l . Surveillance of area radiation monitors. ventilation systems, and

                 spent fuel pool water level and chemistry
           ..    Update of fuel location and accountability records                                                    ,
           .    Applicable quality assurance audits and inspections
           .     U.S. Department of Energy and U.S. NRC, " Nuclear Material Transaction
                 Report," DOE /NRC Form 741
           .     Bill of Lading

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           .     CNS Health Physics Procedure 9.5.3.7, " Cask IF-300 Shipment,"
                 Revision 3, dated December 26, 1985
           .     CNS Nuclear Performance Procedure 10.27. " Cask IF-300 Handling and
                 Shipping," Revision 8, dated June 18, 1987
           .     CNS HP-138, " Contamination Survey - Sample Count Data Sheets"
           .     CNS HP-141, " Contamination Survey - Railroad Car for IF-300 Irradiated
                 Fuel Shipping Cask"
          ..     CNS HP-142, " Contamination Survey of IF-300 Shipping Casks"
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           .     CNS HP-143, " Radiation Survey of IF-300 Shipping Cask"
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           .     CNS HP-608, " Spent Fuel Shipment Checkoff Sheet and Certificate of
                 Compliance of Number 9001 Conditions for Shipping Spent Fuel"
           .     CNS HP-14a, " Radioactive Material Shipment Record"
           The following independent radiation and contamination surveys were
           performed by the RI for the July 1,1987, shipment and verified to be
           satisfactory:
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           .     Contact radiation surveys of the shipping casks
           .     Radiation surveys at a distance of two meters from the cask transport
                 vehicles
            .    Contamination surveys of the shipping casks surfaces
            .    Contamination surveys of the cask transport vehicles
           The spent fuel shipments left the CNS on June 10 and July 1, 1987. Each
           shipment consisted of 2 spent fuel shipping casks and each cask contained
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                      18 spent' fuel bundles.    The shipment was transported to the G.E. Morris
                      Operation Complex, Morris, Illinois. The spent fuel casks identification
                      numbers were:
                      .     IF-301 and IF-304 shipped on June 10, 1987
                      .     IF-301 and IF-304 shipped on July 1,.1987
                     -The observations, reviews, and independent measurements were conducted to
                      verify that spent fuel handling and shipment operations were in conformance
                      with the requirements established in the CNS Operating License.and
                      Technical Specification.
                      No violations or deviations were identified in this area.
                  7.  Operational Safety Verification
                      The NRC ~ inspectors observed control room operations, instrumentation,
                      controls, reviewed plant logs and records, conducted discussions with
                      control room personnel and performed system walk-downs to verify that:
                      .     Minimum shift manning requirements were met.
                      .     Technical Specification requirements were observed.
                      .     Plant operations were conducted using approved procedures.
                      .     Plant logs and records were complete, accurate, and indicative of
                            actual system conditions'and configurations.
                      .     System pumps, valves', control switches, and power supply breakers were
                            properly aligned.
                       .    Licensee systems lineup procedures / checklists, plant drawings, and
                            as-built configurations were in agreement.
                      .     Instrumentation was accurately displaying process variables and
                            protection systet,rtatus was within permissible limits for operation.
                       .    When plant equipmen' was found to be inoperable or when equipment was
                            removed from service for maintenance, it was properly identified and    J
                            redundant equipment was verified to be operable. Also, the NRC          1
                            inspectors verified that applicable limiting conditions for operation
                            were identified and maintained.
                       .    Equipment safety clearance records were complete and indicated that     1
                            affected components were removed from and returned to service in a

l correct and approved manner.

                       .    Maintenance work requests were initiated for equipment discovered to

l require repair or routine preventive upkeep, appropriate priority was 1

                            assigned, and work commenced in a timely manner.

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                            .       The conditions.of the plant and equipment such as' cleanliness, leakage,
                                    lubrication, and cooling water were controlled and adequately
                                    maintained.

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                             .    ' Areas o'f the. plant were clean, unobstructed, and free of fire hazards.
                                    Fire suppression systems and emergency equipment were maintained in a
                                    condition of: readiness.
                       . .          Security measures and radiological controls were adequate.
                           The NRC inspectors performed a lineup verification of the following systems:
                    '
                            .       Standby Gas Treatment System (SGT) ..
                            .       Reactor Core Isolation Cooling (RCIC)
                            .       High' Pressure Coolant Injection (HPCI)
                            In preparation for performi' gn the system walkdown of SGT, the RI conducted
                           a review of~and comparison between the following licensee SGT system valve
                           checklist and. applicable as-built drawings:
                            .       System Operating Procedure (S0P) 2.2.73, " Standby Gas treatment
                                    System," Revision 15, dated December 28, 1986, Appendix "A" Valve
                                    Checklist, Revision 11
                             .      As-Built Drawing, Burns & Roe 2037 for SGT System
                            .       As-Built Drawing, Burns & Roe 2020 for SGT System
                            ..      As-Built Drawing, Burns & Roe 2022 for SGT System
                            ..      As-Built Drawing, Burns & Roe 2005 for SGT System
                           The review identified the following deficiencys:
                            .      ' SOP 2.2.73, Appendix "A" Valve Checklist, Revision 11, lists four
                                    air-operated valves and one manual valve which are used to isolate the
                                    loop seal reservoir that were not numbered or labeled on applicable
                                    As-Built Drawing 2037.
             "
                           This deficiency is similar to Violation 298/8614-01 that was documented in
                           NRC Inspection Report 50-298/86-14, paragraph 5; and similar to Open
             '               Items 298/8626-01, 298/8636-04, 298/8706-05', and 298/8709-01 identified in
                           NRC Inspection Reports 50-298/86-26,50-298/86-36,50-298/87-06,and
                           50-298/87-09, respectively. This item will be tracked as an open item                                                                             ,
                            pending review of the licensee's corrective action when completed.
                                                                                                                                                                             <
                             (298/8712-03)
                           The tours, reviews, and observations were conducted to verify that facility
                            operations were performed in accordance with the requirements established                                                                        .
                                                                                                                                                                             '
                             in the CNS Operating License and Technical Specification.
                            No violations or deviations were identified in this area.
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                     8. . Monthly Surveillance Observations
                          The NRC inspectors observed Technical Specification required surveillance
                          tests. Those observations verified that:
                          .    Tests were accomplished by qualified personnel in accordance with
                               approved procedures.
                          .     Procedures conformed to Technical Specification requirements.
                          .    Tests prerequisites were completed including conformance with
                               applicable limiting conditions for operation, required administrative
                               approval, and availability of calibrated test equipment.
                          .    Test data was reviewed for completeness, accuracy, and conformance
                               with established criteria and Tecnnical Specification requirements.
                          .    Deficiencies were corrected in a timely manner.
                          .    The system was returned to service.
                          The RI observed the licensee's performance of the following surveillance
                          tests on the indicated dates:
                          .    June 24, 1987:    Surveillance Procedure (SP) 6.3.3.1, "HPCI Test Mode
                               Surveillance Operation," Revision 25, dated April 2, 1987-
                          .    June 25, 1987: SP 6.3.6.1, "RCIC Test Mode Surveillar.ce Operation,"
                               Revision 16, dated August 21, 1986
                          .    June 29, 1987:    Nuclear Performance Procedure (NPP) 10.5, "LPRM
                               Calibration," Revision 18, dated December 28, 1986
                          .    July 7, 1987: SP 6.3.12.1, " Diesel Generator Operability Test,"
                               Revision 20, dated May 7, 1987
                         The reviews and observations were conducted to verify that facility
                          surveillance operations were performed in accordance with the requirements
                          established in the CNS Operating License and Technical Specification.
                          No violations or deviations were identified in this area.
                     9.  Monthly Maintenance Observation
                         The NRC inspectors observed preventive and corrective maintenance
                          activities.   These observations verified that:
                          .     Limiting conditions for operation were met.
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                             .    . Redundant'equipmentwasopdrable.          '
                             .     Equipmentwasadequatelyisolatedand'safetydagged.
                             .    . Appropriate administrative approvals were obtained prior to
                                   commencement of work' activities.
                             .     Work was performed by qualified personnel;in accordance withiapproved-
                                   procedures.
                             .     Radiological controls, cleanliness practic's,e       and appropriate fire
                                   prevention precautions were implemented and maintained.
                             .    . Quality control checks ar) post-maintenance surveillance testing were .
                                   performed'as required.
                             .     Equipment was properly: returned to service.
                             The RI observed the licensee's performance ~of the following maintenance
                            . tests on the indicated dates:
                             .     July 6, 1987: ' Maintenance Procedure 7.2.26, " General Valve
                                   Maintenance," Revision 6, dated September 12, 1985
                             .     July 6 and 7; 1987:    Maintence Work ' Request 87-440, "A"                                   RHR SWBP
                                   Repair
                             These reviews'and observations were conducted to verify that. facility
                             maintenance operations were performed in accordance with the requirements
                             established in the CNS Operating License and Technical Specification.
                            -No violations ~or deviations were identified in this area.
               .10.          Exit Interviews-
                             Exit' interviews were conducted at the conclusion of each portion of the
                             inspection. ' The NRC inspectors summarized the scope and findings of each
                             inspection segment at those meetings and at a summary exit interview on
                             July 20, 1987.
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