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U. S. NUCLEAR' REGULATORY COMMISSIONREGION I

Report.No.'88-14

Docket No. 50-353

License No. CPPR-107 Category A/B

Licensee: Philadelphia Electric Company2301 Market StreetPhiladelphia, PA 19101

Facility Name: Limerick Generating Station, Unit 2

Inspection Conducted: May 23, 1988 to June 26, 1988

Inspectors: R. A. Gramm, Senior Resident Inspector, Unit 2.R. L. Fuhrmeister, Resident Inspector, Unit 2-

) Af7/D 'J!;1Reviewed by: Ch /J/ 1. iWillia'ms, Pr6 ject Engineer IDat'eRe ctor Projects Sec ion 2A

O 7A7/r0-of ''Approved by:

s' C. LinMT1e, Chi 'Dafe'

actor Projects Sect A

Inspection Summary: Report for Inspection Conducted May 23, 1988 to June 26,,

1988 (Report No. 50-353/88-14)

Areas Inspected: Routine inspection by the resident inspector of workactivities, procedures, and records relative to instrumentation,preoperational test procedure review, equipment qualification program, >

engineering and assurance of quality. The inspectors reviewed licensee action'

on previously identified items and performed plant inspection tours. Theinspection involved 174 hours by the inspectors.

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Results: No violations were identified.

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TABLE OF CONTENTS

1.0 Summary . 3............................

2.0 Plant Inspection Tours. . . . . . . . . . . . . . . . . . . . . . 3

3.0 Licensee Action on Previously Identified Items. . . . . . . . . . 5

4.0 Licensee Action on IE Bulletins and Circulars . . . . . . . . . . 7

5.0 Three Mile Island Action Plan Items . . . . . . . . . . . . . . . 5

6.0 Instrumentation . . . . . 5...................

7.0 Preoperational Test Procedure Review. 10..............

8.0 Equipment Qualification Program . 11................

9.0 Engineering . . 12.........................

10.0 Assurance of Quality. 13......................

11.0 Meeting; with Licensee. . . . . . . . . . . . . . . . . . . . . . 14

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DETAILS

1.0 Summary;

ITwelve NRC open items were reviewed and all were closed (sections 3, 4 and5). =The inspector attended the Project Status and Nuclear Review Board ,

meetings (section 2). Numerous instrument calibr&tions were observed and '

a procedural problem related to equipment qualification aspects wascorrected (section 6). Five preoperational test procedures were reviewed |with minor comments (section 7). The equipment qualification program !

specifications were reviewed (section 8), and the Bechtel engineeringimprovement plan actions were reviewed (section 9).

2.0 Plant Inspection Tours _(334031, 251053, 251063, 235060. 280210, 252053) |The inspector observed in progress work activities, completed work, andplant status in several areas during inspection tours. Work was examined :for defects and compliance with regulatory and licensee requirements. i

Particular note was taken of the presence of quality control inspectorsand quality control evidence such as inspection records, materialidentification nonconforming material identification, housekeeping and !

equipment preservation. The inspector interviewed craft supervision,.

craft and quality control personnel in the work areas. Observations are- '

noted below:

The inspector observed portions of the cable insulation resistance-

tests on the 2BG501 diesei generator output cable that was repaired.The inspector verified current calibrations for the test equipment,and adherence to specified test durations. The inspector

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independently verified that test results were within acceptableranges.

The inspector observed portions of the electrical testing of the A-

core spray pump motor, verifying that appropriate data sheets werefilled out for the tests performed.

The inspector observed portions of the uncoupled run of the A core-

spray pump motor and C residual heat removal (RHR) pump motor.The inspector observed the initial motor rotation checks, and themonitoring of vibration, winding and bearing temperatures andrunning currents during the test.

The inspector attended the Project Status Review Meeting held on-

June 23, 1988. The licensee considered engineering was 96% completeand construction 88.9% complete. Among the topics discussed wereUnit 2 Startup/ Unit 1 Second Refueling Outage schedule andcoordination, Unit 2/ Unit 1 mechanical interties, component labelingprogram, startup test program, station security hardware and programchanges, Independent Design and Construction Assessment, fireprotection issues and technical specification reviews for vitalequipment power supplies.

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The Nuclear Review Board (NRB) met at the Limerick Generating-

Station on June 2, 1988 to discuss issues relating to Peach Bottomand Limerick I operation, and Limerick 2 construction and testing. activities. The inspect:r attended those portions which dealt withUnit 2.

The NRB had requested,.at a prev'ious meeting, a detailed descriptionof how the Unit 2 preoperational test program met the requirementsof NRC Regulatory Guide 1.68. The Unit 2 Startup Manager presenteda. report on the preoperational test program, describing proceduregeneration, testing and results review. The report also describedBlue Tag Testing, test personnel qualification requirements, QA/QCsupport of testing, the composition and functions of the Test ReviewBoard and the Technical Specification surveillance test program.

A second report presented to'the NRB dealt with the recommendationscontained in NUREG 1275 regarding new plant startup experiences.The report listed the recommendations and how they are beingimplemented in the Unit 2 testing program. The NRB additionallyquestioned the Unit 2/ Unit 1 tie-in program, and NUREG 1275 Volume 2regarding air system problems.

The inspector observed the uncoupled run of RHR A pump motor. The-

motor was instrumented with vibration monitoring equipment andtemperature monitors for motor windings and bearing temperature.A bearing instability problem was noted by the licensee and themotor was subsequently disassembled. The inspector reviewed QCIR2A0202-48-9 and modification / rework package 1AD202-25 for removaland replacement of the upper guide bearing and cleaning of thethrust bearing due to internal contamination. Portions of themechanical disassembly were monitored.

The inspector discussed the chemisal treatments added to the cooling-

tower basin. The additives include an acrylic polymer which acts asa dispersant to keep particles suspended, polysilica to provideadditional corrosion protection for mild steel and an agent whichforms a corrosion inhibiting film on copper alloys. A zine solutionhas been added to reduce the corrosion rate by a factor of four.Due to leaks in the cooling tower basin, some of these dilutedchemicals were released via the storm drain system to Possum Hollow.The inspector was informed that the appropriate permit documentationwould be amended to reflect the Possum Hollow release point.

The inspectar reviewed General Electric core spray elementary-

791E4191TR sheet 11, modification 5032, training plan LOT-350 andthe associated wiring diagrams. The concern related to theoperation of the isolation valve wiring has been made an NRCunresolved item in NRC Inspection Report 88-15.

No violations were identified.

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3.0 Licensee Action on Previously Identified items (92700, 92701, 92702)

a. (Closed) Construction Deficiency Report (77-00-01): Cracks instructural steel members. The licensee instituted the followingactions:

~ Visual and nondestructive examinations were performed to-

determine the extent and cause of-the cracks.- - The deficiencies were ~found to have been caused by improper

flame cutting' operations at the vandor shop.The vendor quality programs were enhanced.--

Revised fabrication methods were instituted to prevent creation-

of crack initiators during the flame cutting process.Bechtel shop inspection coverage was increased.-

Analytical studies were performed to assess the affect of the-

beam / deficiencies upon the load carrying capability.All plate girder web defects were repaired.-

Rolled beam cope defects were found acceptable by finite-;

element analysis. !. The undersized clip angles and welds were found structurally-

adequate..

Based upon the beam repairs, analysis, inspections and correction ofthe vendor shop practices this item is considered closed,

b. (Closed) Construction Deficiency Report (82-00-01): Potential forRobertshaw thermostatic valves (Model 1284 and 1285 in five inch andsix inch sizes) to fail in the full cooling position. This item was t

reported by Colt Industries on May 25, 1982 to the USNRC and byPECo, pursuant to 10 CFR 50.55(e) on August 3, 1982. The inspector >

reviewed the following documents relating to this item:

Colt Industries letter, J. M. Moriarity to James G. Keppler,-

dated May 25, 1982 >

Colt Industries letter, J. M. Moriarity to James G. Keppler,-

dated June 28, 1982Robertshaw Controls Company letter, T. T Howell to Peter R.-

Vander Vennett, dated May 13, 1982PECo letter, John S. Kemper to Ronald C. Haynes, dated August-

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3, 1982Robertshaw Controls Company letter, Teena York to Peter R.-

Vander Venr.ett, aated August 11, 1982PECo letter, R. A. Mulford to W. C. McDaniel, dated June 1,-

1983 with enclosure ,

NCR 6141, dated September 20, 1982-

The inspector determined that the potential for failure was duei to some valve asemblies shipped without the retaining nut i

having been soldered in position. The valve internals for the,

Unit 2 diesels have been replaced with a newer design utilizing |

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a castellated nut and cotter pin . The inspector had no furtherquestions. This item is closed.

c. (Closed) Unresolved Item (86-21-01): Drawing errors introduced-during drawing translation utilizing the Computer Aided Drafting

-System. 1The inspector reviewed Quality Action Request F-562. Thelicensee identified several hundred informal memoranda that hadbeen utilized to identify errors in Quality Assurance Diagrams(QADs) or Piping and Instrument Diagrams (P& ids). Bechtel projectengineering reviewed other correspondence and found no additionalexamples where design change related information was transmitted ina informal manner. Construction engineering reviewed the informalmemorandum again with respect to the revised engineering diagramsand discrepancies were documented on a formal change document. Sitepersonnel were retrained on the requirements to issue Field ChangeRequests and Field Change Notices. This problem was reported inaccordance with 10CFR50.55(e) and the resolution of the drawingerrors will be reviewed at a later date in conjunction with NRC openitem 87-00-01.

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d. (Closed) Violation (87-11-04): Review of SignificantDeficiency Report (SDR) 159 for reportability evaluation under10CFR50.55(e). The SDR identified a design concern with respect tothe potential adverse interaction between the standby dieselgenerators and the associated fire protection flow trip switches.On October 22, 1987 an Enforcement Conference was convened at RegionI. Based upon fnformation previded by the licensee, the problem wasdetermined not to meet the reportability criteria of 10CFR50.55(e).The trip switches were removed from service as discussed in NRCInspection Report 87-11. The common mode failure of the trip switchcircuits under postulated fire conditions in the service water pipetunnel will be reviewed during followup to NRC open item 87-00-07.This item is closed.

e. (Closed) Construction Deficiency Report (88-00-05): Westinghousetype DS fused disconnect switch mechanical lugs. This deficiencyinvolved inadequate securing of No. 6AWG and smaller conductors bymechanical connectors using setscrews. The inspector reviewed thefollowing associated documents:

PECo Reportability Evaluation No. SDR 232-2, dated April 15,-

1988PEco Interim Report, SDR No. 232-2, dated May 13, 1988-

Startup Nonconformance Report No. 5-1-E, dated January 26, 1988-

Nonconformance Report No. 12991, dated February 1, 1988-

The lugs were associated with fused disconnect switches in DCelectrical panels supplied by B. K. Electric. Some of theconnectors had insufficient thread depth to ensure adequate contactwith conductors up to size No, 6AWG (adequate contact was obtained

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for pairs of conductors sized No. 8AWG). All DC Power Panelssupplied by BK Electric were subsequently inspected, and singleconductor connections No. 6AWG and smaller were terminated againusing compression lugs. This item is closed.

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4.0 Licensee Action on Bulletins and Circulers (92701, 92703)

The inspector reviewed licensee records related to the Bulletins andCirculars identified below to verify that: the Bulletin or Circular wasreceived and reviewed for applicability; a written response was providedif required; and the corrective action taken was adequate. The followingBulletins and Circulars were reviewed:

a. (Closed) Bulletin (77-05): Electrical connector assemblies. Thisbulletin identified the failure of pin-and-socket electricalconnecters during exposure to LOCA conditions in tests conducted bySandia Labs. The inspector examined the following documents with

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l IE Bulletin 77-05, dated November 8, 1977-

IE Bulletin 77-05a, dated November 15, 1977-

GE letter PEco-1973, H. G. DeVoss to R. A. Mulford, dated-

January 3,1978PEco letter, V. S. Boyer to Boyce H. Grier (USNRC), dated March-

1, 1978GE letter PE-1981, H. G. DeVoss to R. A. Mulford, dated January-

24, 1978Bechtel interof fice merao F313561, W. E.Mourer to M. Solyes,-

dated April 27, 1988GE letter PE-3684, J. J. Millard to D. B. Fetters, dated May-

13, 1988

The licensee found that no safety related connectors are located inareas affected by adverse environmental conditions. This item isclosed,

b. (Closed) Bulletin (77-08): Assurance of safety and safeguardsduring an emergency-locking systems. The licensee reviewed theplant design and found that under emergency conditions that promptingress is assured into safety related areas by: transfer ofelectrical power to an auxiliary source; locking devices that can beopened by operations or security personnel upon failure of primaryand secondary power; locking systems and mechanical overrides aretested weekly; preventive maintenance and calibration is performedon the security inverter at 18 month intervals which includestransferring the security inverter from primary to alternate powersupplies. The inspector reviewed the conceptual design reviewpackage for modification 5819. This will relocate the alternatepower supply within the vital area and will include backup powerfrom a Class 1E standby diesel generator. The licensee found that

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egress from plant areas can be accomplished under all conditions.This item is closed.

c. Closed) Circular (78-03): Packaging greater than Type A quantitieso ow specific activity radioactive material for transport. Theinspector reviewed procedure HP-713, "General Packaging, Marking andLabeling Requirements for Radioactive Materials for Shipment". Theprocedure requires that greater than Type A quantities of lowspecific activity radioactive material be shipped under the10CFR71 regulations. This item is closed.

d. (Closed) Bulletin (79-07): Seismic stress analysis ofsafety-related piping. The licensee reviewed the computer codesthat had been utilized by Bechtel, General Electric, ColtIndustries, Rockwell International and Reactor Controls. None ofthe computer codes utilized the deficient algebraic summationmethods for horizontal and vertical piping seismic excitations. Theinspector reviewed the user manual for Bechtel program ME101,"Linear Elastic Analysis of Piping Systems" and confirmed that thealgebraic summation methodology was not employed. This item isclosed,

e. (Closed) Circular (80-14): Radioactive contamination of plantdemineralized water system and resultant internal contamination ofpersonnel. The licensee reviewed the water systems and found: notemporary connections of the demineralized water system to anycontaminated systems; the po+able water system is not connected toany contaminated systems; two pathways between the demineralizedwater system, and the radwaste evaporators and condensate storagetank. Plant Administration Procedu.e A-7 specifies thatdemineralized water shall never be used for human consumption andthat temporary system cross connections shall only be made inaccordance with approved procedures. The potential backflow pathsare provided with manual isolation valves, level alarms and acontinuously running demineralized water pump that will preventbackflow. This item is closed.

f. (Closedj Circular (81-09): Containment effluents water thatbypasses radioactivity monitor. The licensee performed a detailedreview of water systems that penetrate containment. The systemsthat are not provided automatic isolation valves were checked fordirect flow paths to the environment. The systems, exceptrecirculation pump cooling, connect to closed systems outsidecontainment. The recirculation pump cooling system com:nunicateswith the emergency service water system which is provided with aneffluent monitor. This (tem is closed.

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;S.0 Three Milt Island Action Plan Items (3254018)

M As a result of the Three Mile Island (THI) plant accident, genericreactor enhancements were developed by the NRC. NUREG 0737 documents thespecific action requirements. The licensee has been informed of thoseissues which require Region I closure prior to fuel-load. The followingTMI issue was reviewed:

-(Cl osed) :!I . F.2: Instrumentation for detection of inadequate core-

cooling. The inspector reviewed the Limerick FSAR, SER, SSER #2 andRegion I Inspection Report 50-352/84-60. The Limerick reactor water4

level monitoring system fully conforms with the review requirements.As no system modifications were necessary and since periodicinspections have been performed on the reactor water leveiinstrumentation this item is considered closed.

6.0 Instrumentation (252051, 252053, 252055)

a. The inspector observed the calibration of the following instruments:-

PIS-42-2N690E, reactor pressure enable for core spray (CS) and--

low pressure coolant injection (LPCI),

LIS-42-2N691C, reactor vessel level 1 initiation signal for CS-

and LPCI'

LIS-42-2N691B, reactor level 1-

LS-42-2N6928, reactor level 2--

LS-42-2N6938, reactor level 8-

PT-42-2N090E, low reactor pressure-

LT-42-2N091C, reactor level 1,-2 & 8-

LT-42-2N0918, reactor level 1, 2 & 8-

PIS-42-2N6900/PT-42-2N0900, low reactor pressure-

PIS-42-2N6948, high drywell pressure-

PIS-42-2N694E, high drywell pressure-.

POISL-51-2N658C, LPCI isolation valve leakage indication-

POSH-52-2N653C, RHR , ,o discharge pressure-

PIS-56-2N656F, HPCI turbine exhaust pressure-

PIS-56-2N657, HPCI pump suction pressure-

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During calibration the inspector verified proper use of calibratedmeasuring and test equipment, proper calibration data recording andprocedural adherence with the exception of the equipmentqualification (EQ) aspect discussed below,

b. During the calibrations listed above, it was noted that proceduresteps relating to EQ maintenance were not being performed. When

' questioned, the instrumentation technicians stated that the EQmaintenance activities were being deferred until the formalcommencement of the Unit 2 EQ program, just prior to fuel load. Atthat time, all the steps for EQ would be performed on all of the

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instruments in accordance with computer generated maintenance>

requests. Formal documentation of this widely known fact could notbe found. PECo has issued interim changes to the instrumentcalibration procedures specifying that the EQ maintenance actions

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. are not applicable to Limerick Unit 2 equipment until the Unit 2 EQprogram is implemented at fuel load. These changes assure

. consistency of the applicable procedure steps with work performed by,

the technicians.

No violations were identified.

7.0 Preoperational Test Procedure Review (335301, 370340, 370335, 370337, |

370344, 3703'.1, 370355, 370358);

The inspector reviewed the following preoperational test procedures fortechnical content, conformance with the FSAR test abstract (Table 14.2-4)and consistency with the startup administrative manual requirements:

2P18.1, "Instrument Air System". Additional documents reviewed-

include FSAR section 9.3.1; Test Review Board (TRB) regulatoryreview list and TRB meeting minutes; electrical schematic diagramE-570 and the air compressor wiring diagram.

2P25.1, "Primary Containment Instrument Gas". Additional documents '-

reviewed include FSAR question 410.73; Administrative Manual A07.1regarding system cleanliness; TRB meeting minutes and regulatoryreview list; FSAR section 9.3.1.3; FSAR tables 9.3-3, 6.2-17 and :9.3-4; logic diagram M-59; P&ID M-59; electrical schematic diagrams 1

E-343 E-348, E-357. E-568 and E-622; and vendor prints M-30-2-14BRand M-1-E11-1040-E-042.

2P66.1, "Reactor Enclosure Unit Coolers". Additional documents-

reviewed include FSAP. sections 7.3.1.1.15.5, 7.4.2.8.1.2.3.16 and9.4.2.2; logic diagram M-76F0; P&IO M-11 sheet 5; electricalschematic diagramt. E-471 and E-686. The test procedure was found toproperly verify manual unit cooler operations; proper emergencyservice water valve response; automatic start and stop of the unit-

! cooler depending upon ambient room temperature; and proper operationof the standby unit cooler. An incorrect FSAR statehent wasidentified in section 7.4.2.8.1.2.3.1.16 which stated the RCIC unitcooler upon automatic initiation would continue to run untilmanually overriden by an operator. The unit cooler will actuallyshut down automatically when the pump room temperature drops to 80degrees F. Licensing Document Change Notice FS-1454 was issued tocorrect the FSAR.

2P-2.1/2.2, DC Safeguard Power System Division I, II, III ad IV.-

Additional documents reviewed include FSAR Table 8.3. The batterycapacity load profile was more conservative than the FSAR. On page7-28 of procec.ure IP2.2 a formula was corrected from 692 amp-hoursto 678 based upon the inspector's review. On page 7-38 of procedure2P-2.2 an instruction was corrected to install a digital voltmeteracross the charger shunt. With the exception of the FSAR inaccuracyand the correctiers to procedure 2P2.2 no other concerns wereidentified.

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2P-83.1 "Main Steam System". In addition, the following documentswere reviewed: FSAR Section 5.2.2, FSAR Section 5.4.5, DrawingsM1-E32-1050-E-13.2 through 24.1, P&ID M-40 and P&ID M-41. The testprocedure was found to adequately demonstrate proper opeiation ofthe Main Steam Isolation Valves (MSIV), MSIV Leafage Control System,Main Steam Safety / Relief Valves, and Main Steam System IsolationLogic Trains. Several minor typographical errors were identifiedwhich will be corrected in the next revision.

No violations were identified.

8.0 Equipment Qualification (37055)

The following documents were reviewed by the inspector that pertain to4

the equipment environmental'and dynamic qualification program:

FSAR section 3.10 and tables 3.10-1, 3.10-2 and 3.10-3-

section 3.11 and tables 3.11-2

Bechtel Specifications-

G-22, "Equipment Qualification Program", Rev. 5

| G-29, "Evalustion and Purchase of Commercial Grade Items for SafetyRelated Applications", Rev. 4G-46, "General Requirements for Dynamic Qualification Walkdown",

Rev. A,

G-47, "Environmental Qualificatior Walkdown of Safety RelatedEquipment", Rev. A

The inspectur subsequently held a meeting with cognizant PECo, Bechteland General Electric project engineers regarding the Equipment;

Qualification (EQ) Program. The inspector was informed that Unit 2i

equipment is generally similar to Unit 1. The licensee intent is to; etilize the existing Unit 1 qualification packages as a bases for the

Unit 2 EQ packages, The inspector was informed that equipment specificsimilarity checklists have been generated to guide the comparison of theequipment to ensure that the Unit 1 packages are appropriately extendedfor the Unit 2 equipment. The Unit 1 packages will be enhanced byincluding a more detailed EQ checklist, applicable NRC Eulletins orNotices, and accounting for subsequent plant modifications.

The licensee intends to perform in plant walkdown verifications to assur;' that the as-built equipment condition is consistent with tiu EQ

configuration. The walkdowns will be performed by engineers familiarwith the equipment qualification and will be guided by an appropriatechecklist. Based upon equipment location, either sampling or 100%,

! walkdowns are intended. Information will also be obtained for feedbackto the GE qualification program.

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The' inspector plans to monitor the implementation of the EQ walkdownphase. No concerns were identified at this time.

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9.0 Engineering (37055, 35060)

The licensee has developed an engineering improvement plan _that includesBechtel and General . Electric engineering organizations. The . primaryfocus of the plan is-to address concerns that were documented within thelast NRC Systematic Assessment of Licensee Performance (SALP) forLimerick Unit 2 (Report Number 50-353/87-99). Various elements of theimprovement program have been implemented. The inspector reviewed thefollowing documents regarding the improvement plan:

Document Description

March 10, 1988 Off project review of component .dentificationReport identified an error which was that the "C" & "0"

circulating water pumps had been connected to "A" & "B"water box loops. The error was corrected by changingthe water box identification to be consistent with thecontrol room and pump configuration. The review wasextended to examine the main steam and HPCI systems forsimilar problems. The RHR, RHRSW and'ESW systemswere also examined as discu: sed below.

May 16, 1988 Off project review of the RHR, RHR Service Water andReport Emergency Service Water Component identification.

The review encompassed P& ids, electrical, schematicand physical drawings to assure correct piping loopand electrical division relationships.

Bechtel IOM Construction design interface review report onMay 27, 1988 electrical equipment. '';e review included

separation, seismic spacing, conduft. installation,junction box design, RPS/ESF contrci panelseparation, raceway support spacing criteria. Asample walkdown was performed on installed hardwareto ver;fy conformance with design. All installationswere found satisfactory.

Bechtel IOM "Design Process Improvement Program" instituted trialJune 6, 1988 use of procedure EDPI 4.65.1 te analyze design

weaknesses for trends and root causes and to identifycorrective actions. Input from significant NCRs,Pas 21/50.55(e) reports and corrective actionreports.

GE Letter Comments on GE Nuclear Engineering and BechtelB-2395 interface document.

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. Survey- FSAR nonconformance survey performed of 301 engineersat Pottstown and San' Francisco. One area ofnonconformance was identified that was'not currentlybeing addressed by an LDCN. As a result, two itemswere added to Design Closure Plan for study of

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control. system failures in response to FSAR questions421.10 and 421.11.

The engineering. overview and improvement processes continue to beperformed in a thorough manner. As further elements of the program areimplemented, add'tional NRC inspection will be performed.

10.0 Assurance of Quality (35060)

The conduct of equipment vibration monitoring tests was observed (section2). The licensee has retained an experienced consultant to train PEComaintenance personnel on the Bentley-Nevada vibration monitoringequipment. The monitoring has detected problems with the residual heatremoval pump motor bearings and the reactor enclosure cooling water pumpmotor support structure.

The Nuclear Review Board continues to conduct in-depth reviews of theUnit 2 startup program (section 2).

During' review of instrument calibration activity (section 6b), theinspector noted that certain procedural steps related to maintenance ofequipment qualification (EQ) were not performed. In particular, forRosemount transducers, the gasket material was not replaced and the coverseal was not torqued. Further review found the EQ baseline maintenancewould be performcd before fuel load and tracked on the PECo automatedmaintenance scheduling program. This would allow startup test activitiesto be performed, such as opening the transducer cover, without necessi-tating the performance of the EQ work again. While the instruments wouldultimately reach the qualified state it appeared to be a poor practice tocomplete the appro ad procedures that normally guide the calibrationactivities. The licensee amended the procedures to waive the EQ main-tenance conduct at this time.

A further FSAR inaccuracy was identified in section 7.0 to the operationof the RCIC unit coolers.

The Equipment Qualification Prograr has been planned with extensive siteengineering walkdown verifications to ensure that environmental anddynamic qualification parameters have been accommodated by the as-builtplant (sectior s).

In-dapth engineering reviews continue by non project personnel inresponse to concerns identified in the previous NRC Systematic Assessmentof Licensee Performance (section 9).

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11.0 _L_icensee Meetings

The NRC resident inspector discussed the issues and findings in thisreport with members of the licensee's staff on a weekly basis, and at anexit meeting held on June 24, 1988. Based on discussions held withlicensee representatives on June 24, 1988, it was determined that thisreport does not contain information subject to 10 CFR 2.790 restrictions.