IR 05000029/1993001
| ML20034H208 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 03/08/1993 |
| From: | Eugene Kelly, Norris B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20034H206 | List: |
| References | |
| 50-029-93-01, 50-29-93-1, NUDOCS 9303160178 | |
| Download: ML20034H208 (11) | |
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t U.S. NUCLEAR REGULATORY COMMISSION
REGION I
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DOCKET / REPORT No:
50-29/93-01 LICENSE NO:
DPR-3 j
LICENSEE:
Yankee Atomic Electric Company j
580 Main Street Bolton, Massachusetts 01740-1398 FACILITY NAME:
Yankee Nuclear Power Station
INSPECTION AT:
Rowe, Massachusetts d
DATES:
January 25 - 28, 1993
INSPECTORS:
Barry S. Norris, Project Engineer, DRP Neil S. Perry, Senior Resident Inspector, DRP Morton B. Fairtile, Project Manager, NRR
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SUBMITfED:
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'Barry[jkNorris Date
APPROVED BY:
Mb
Reactor Pr[ojects Section 3,A/
Date Eugene y Kelly, Chief
j AREAS INSPECTED:
i On-site inspection by Region I and NRR staff, consisting of facility tours, observation of work
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- in progress, and review of various licensee programs, procedures, and reports. Emphasis was.
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given to the organization', certified fuel handler training, quality assurance, operations,.
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maintenance and surveillance, fire protection, plant modifications, security,. emergency preparedness, and housekeeping,
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9303160178 930309 gDR ADOCK 05000029 PDR
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EXECUTIVE SUMMARY Yankee Nuclear Power Station j
Report No. 50-29/93-01
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OPERATIONS
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Plant operations were conducted in accordance with license requirements.
Technical Specification requirements were found to be incorporated into the appropriate procedures.
However, controlled copies of the Technical Specifications were not updated properly when amendments were issued.
Plant management initiated immediate corrective action, and enforcement discretion was utilized.
FIRE PROTECTION Many of the fire protection requirements contained in the Technical Specifications were moved to the Fire Protection Technical Requirements Manual. On-going activities were found to include good housekeeping practices, minimizing the potential for fire due to a concentration of combustible materials.
MAINTENANCE AND SURVEILLANCE Equipment required to be operable, either by Technical Specifications or administrative procedures, was appropriately maintained and tested. Two instances were identified where Technical Speci6 cation surveillances were not being completed as required, but had no safety significance since the plant is permanently shutdown and the tests could therefore not practically be performed. Yankee Atomic Electric Co. had not obtained NRC approved relief from the requirement to perform these surveillances, but subsequent to the inspection, the NRC approved an amendment to the Technical Specifications that deleted one of the surveillances. Enforcement discretion was utilized for these instances.
PLANT MODIFICATIONS The licensee's process for conducting plant modifications was found to be in accordance with 10 CFR 50.59 requirements. The process is unchanged from the that used during operations, and Yankee Atomic Electric Co. has incorporated the requirements of the Possession Only License, as related to plant modifications. The safety analyses were found to be comprehensive.
DEFUELED SECURITY PLAN The licensee appears to have properly implemented the Defueled Security Plan. The associated procedures were clearly written and properly derived from the Plan, and training was completed prior to implementation. Security personnel were knowledgeable of the requirements contained within the procedures. A concern with respect to plant lighting, as referenced in the Defueled Security Plan, remained unresolved as of the end of the inspection.
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DEFUELED EMERGENCY PLAN The requirements of the Defueled Emergency Plan were translated into the appropriate procedures, and were being properly implemented.
TRAINING Yankee implemented the NRC approved the Certified Fuel Handler program in July 1992.
However, the licensee implemented the program without developing the appropriate procedures.
This item will remain unresolved. At the beginning of the year, Yankee. downsized and reorganized. However, the organization is not consistent with the description contained in the Yankee Atomic Electric Company Operational Quality Assurance Program Description.
Of specific concern is the confusion associated with the responsibility for the implementation of the Certified Fuel Handler training programs. This item will remain unresolved.
SAFETY ASSESSMENT AND QUALITY VERIFICATION The Quality Assurance Plan for Yankee Rowe Possession Only License Phase details the activities proposed to verify that program and license requirements are met. The on-site QA group is supported by the Yankee Atomic Corporate QA Department for the conduct of audits, surveillances, and QC inspections. The audit / surveillance schedules for 1992 (and 1993) were (and are) focused on safety significant issues and ongoing activities, ii
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TABLE OF CONTENTS EXECUTIVE SUMMARY......................................
i TABLE OF CONTENTS.......................................iii 1.0 FACILITY STATUS
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2.0 OPERATIONS (42700, 54834, 71707, 86700)......................
2.1 Conduct of Operations I
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2.2 Plant Equipment Lay-up Program
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3.0 FIRE PROTECTION (64704)................................ 2 4.0 MAINTENANCE AND SURVEILLANCE (61726, 62703).............. 2 5.0 PLANT MODIFICATIONS (37700)............................ 4 6.0 DEFUELED SECURITY PLAN (81700)
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7.0 DEFUELED EMERGENCY PLAN (82301)...........,........... 5 8.0 TRAINING (41500)...................................... 5 8.1 Certified Fuel Handler Program
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8.2 Organization.....................................
9.0 SAFETY ASSESSMENT AND QUALITY VERIFICATION (40500,71707)...
10.0 M ANAGEMENT MEETINGS (30702, 30703)...................... 7
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The NRC inspection procedures that the inspectors used as guidance are parenthetically listed for each report section, as applicable.
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DETAILS 1.0 FACILITY STATUS The Yankee Nuclear Power Station (Yankee) has been shut down since October 1,1991. The reactor was defueled as of February 15, 1992, with all spent fuel assemblies stored in the spent fuel pool. The reactor vessel head and internals are stored in place. A Possession Only License (POL) was issued in August 1992. Yankee Atomic Electric Co. (YAEC) implemented the NRC approved Certified Fuel Handler program in July 1992, replacing the licensed operator program.
The Defueled Security Plan and Defueled Emergency Plan were implemented in December 1992, after the appropriate procedures were developed and the requisite training was completed. On January 1,1993, permanent plant staffing was reduced to 59 employees; down from over 200
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personnel last year. No further reductions are anticipated throughout 1993.
2.0 O PER ATIONS (42700, 54834, 71707, 86700)
i 2.1 Conduct of Operations The inspectors verified that plant operations were conducted in accordance with license requirements. S~cifically, Technical Specification (TS) requirements were incorporated into the operators' dauy logs. Station procedure AP-2028, YNPS Equipment Operator Log, Revision 1, was reviewed and found to include sufficient guidance for the operators. However, the procedure contained minor typographical errors, referenced several TS that no longer existed, and did not reference an appropriate TS table. A Special Order from the Operations Support Manager, dated December 7,1992, listed all of the TS which were deleted, including the ones referenced by AP-2028. This Special Order was in the control room.
Errors were identified with the controlled :opy of TS located in the control room. Several specifications related to Radiological Effluents, deleted by License Amendment No.146 (November 5,1992), were still in the control room copy of TS. Amendment No.146 moved
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the Radiological Effluent requirements from the TS to the Offsite Dose Calculation Manual.
Several opportunities existed for plant personnel to identify the discrepancies: (1) the initial update directions were correct; (2) the December 1992 Special Order, identified the deleted Technical Specifications; and (3) in November 1992, quality assurance personnel performed a surveillance wi-h included a review of Technical Specifications.
To correct the problem, plant management required a page-by-page verification of all controlled copics of Technical Specifications at the plant. Copies at the corporate offices were also verified. The verification identified discrepancies in the control room copy, the Technical Support Section copy, and the maintenance copy. The Plant Superintendent's and Assistant Plant Superintendent's copies were correct; the status of the other controlled copies was being reviewed by the licensee at the end of the inspection. Additionally, there were several licensee issued TS Clarifications which should have been deleted.
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l The failure of Yankee to properly update and maintain the Technical Specifications is considered a violation of 10 CFR 50, Appendix B, Criterion VI, Document Control. Based on the low -
safety significance and the comprehensive corrective action, this violation met the requirements
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of the NRC's Enforcement Policy in 10 CFR 2, Appendix C, Section VII.B.1, for enforcement
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discretion.
2.2 Plant Equipment Lay-up Program
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The inspectors reviewed AP-1902, Plant Lay-up Program, Revision 3, with regard to the "in
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service" tags noted in the plant. These tags are used by the Operations Department to identify
systems and components required to remain in service. The tagging and control of equipment
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is controlled under existing programs, such as procedure AP-0017, Switching and Tagging of Plant Equipment, Revision 22. AP-0017 was recently revised to incorporate the use of "in
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service" tags. Through review of the procedures and discussions with operetors, the inspectors i
determined that there is no conflict or confusion when the equipment must be tagged out for maintenance or other work; the program allows for both tags to be hung on the equipment. The
"in service" tags are intended only as a means of identifying systems and components required for plant operation in the permanently defueled condition. The inspectors determined that both
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procedures adequately provided direction for use of the tags.
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3.0 FIRE PROTECTION (64704)
In September 1992, certain fire protection requirements were removed from TS and placed in i
the Fire Protection Technical Requirements Manual.
The Fire Protection Technical Requirements Manual is a controlled document, and changes require approval by the Plant Operation Review Committee (PORC) prior to implementation. Only one change has occuned, involving a decrease in the fire brigade from 5 to 3 persons. The inspectors reviewed the safety.
evaluation for this change and found it to be appropriate.
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During a tour of the Vapor Container, the inspectors identified a portable, water-filled fire extinguisher with its indicated pressure below the acceptable level. Plant personnel indicated that the indicated pressure was probably low due to the low area temperature; the building is not heated at all times. The licensee stated that water-filled fire extinguishers were not required in
that area and would be removed. In general, the inspectors noted that on-going activities incorporated good housekeeping practices, minimizing the potential for fire due to a
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concentration of flammable materials.
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4.0 MAINTENANCE AND SURVEILLANCE (61726,62703)
The inspectors verified that equipment required to be operable, either by Technical Specifications
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or administrative procedures, was being maintained and tested, as required. The following systems and coroponents were verified as having the necessary surveillances scheduled and/or completed:
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Spent fuel pool and vapor container area radiation monitors - channel checks and o
channel functional tests Metcorological tower (wind speed, wind di:ection, and differential air temperature) -
o channel check and channel calibration Spent fuel pool level - channel calibrations a
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Fire pumps, fire hose stations, and fire extinguishers - functional tests o
Two instances were identified where Technical Specification surveillances were not being completed as required. Technical Specification surveillance 4.4.6 requires the main coolant system chemistry to be determined within certain limits at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. On August 12,1992, the main coolant system was drained of all water except that remaining in the reactor vessel below the loop penetrations; sampling of the main coolant system was cea:,ed at that time since there was no way to get a sample. On September 16,1992, Yankee submitted to the NRC a Technical Specification change request, which would delete the main coolant system chemistry requirements. A memorandum from the Operations Support group (dated November 12, 1992)
recommended that the applicable Technical Specification action statement be entered. The action statement requires performance of an engineering evaluation to determine the effects on the structural integrity of the main coolant system, and if the main coolant system will remain acceptable for continued operations. There is no safety significance to the missed surveillance, since the plant is permanently shutdown; however, no NRC approved relief from the Technical Specification was received as of the inspection. Subsequent to the inspection, the NRC approved an amendment to the Yankee Technical Specifications on February 19,1993, which deleted TS surveillance 4.4.6.
In the second instance, Technical Specification 4.7.2.1 states that when the temperature of the secondary coolant is <70 F, secondary coolant pressure must be determined at least once per hour to be <200 psig. The applicable action statement requires the plant to "... reduce the steam
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generator pressure or temperature to within the limits within 30 minutes." The surveillance requirement and requisite action statement were not met during late 1992, when the vapor container ambient temperature was low enough such that the 70*F limit was exceeded. The inspectors noted that the secondary coolant temperature cannot be directly measured. The situation was previously evaluated by YAEC, as documented in an internal memorandum dated November 12,1992. The failure to maintain the secondary coolant temperature above 70*F has no safety significance, since the steam generators will never again be used. Also, the main and the secondary coolant systems were drained for part of the year. However, the NRC was never informed, and the commitment was not changed.
Currently, all of the systems in the vapor container are drained, with the exception of the reactor vessel. The inspectors determined that the failure to obtain NRC-approved relief from the above required surveillances had no safety significance.
Therefore, enforcement discretion is
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warranted since these violations of Technical Specifications met the criteria in Section VII.B.1
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This technicality will be resolved by the issuance of the Defueled Technical Specifications, which were submitted for NRC review and approval on i
December 21,1992.
5.0 PLANT MODIFICATIONS (37700)
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The inspectors reviewed recent safety-related plant modifications to verify compliance with
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10 CFR 50.59 and the requirements contained within the POL.
The licensee's plant modification process is controlled in accordance with station procedure AP-0059,10 CFR 50.59 Safety Evaluations, Revision 2.
The methodology in this procedure is unchanged from the process used during reactor operations. However, the current revision had incorporated the requirements of the POL related to plant modifications; i.e.,
not precluding any
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decommissioning options, nor increasing decommissioning costs. Procedure No. AP-0059 was
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found acceptable. Twelve plant modifications have been processed since issuance of the POL.
Two of those changes contain safeguards information and will be reviewed during a future safeguards inspection.
Three plant modifications were reviewed for compliance with 10 CFR 50.59 and AP-0059.
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These were:
Appendix A - Safety Classification of Systems Manual o
1992 Control Rod Removal from the Spent Fuel Pool a
YNPS Auxiliary Service Water Pump o
The safety analyses performed as part of the modification process were found to be comprehensive, with a focus on the safety consequences of the modifications. An example is the Auxiliary Service Water (ASW) Pump. The pump was to be removed from the ASW System, which is no longer needed, and transferred to the Spent Fuel Pool Cooling System. The licensee considered the impacts on the electrical distribution system and the flow characteristics of the pump. The licensee's safety evaluation demonstrated that existing accident analyses remain unchanged, that an accident of a different type wasn't credible, and that the margin of safety, as defined in the TS, was not reduced.
6.0 DEFUELED SECURITY PLAN (81700)
The inspectors verified that the licensee had properly implemented the Defueled Security Plan, as approved by the NRC on November 24,1992. Two security procedures, AP-0425, Routine industrial Area Access and Security Controls, Revision 0, and AP-0445, Operation of Security Alarm Station (SAS), Revision 23, were reviewed for compliance with the security plan.
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Security personnel were interviewed to determine their knowledge of the content of the
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procedures. The inspector determined that the associated procedures were clearly written and
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properly derived from the Plan, and that training was sufficient and completed prior to implementation. Letters of commitment with the Massachusetts State Police were reviewed, and found up to date and adequate in scope.
The YAEC Quality Assurance Department initiated a surveillance of the Defueled Security Plan implementation. This review is scheduled for completion mid-March 1993. The QA Audit Group has also planned an audit of the program for later in the year. It was concluded that the Defueled Security Plan is being properly implemented.
The inspectors raised a concern with respect to plant lighting as referenced in the Defueled
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Security Plan. The requirements of the Plan and the associtM implementation were discussed with the licensee. This issue will be addressed by an NRC security specialist inspection, scheduled for the week of March 8,1993.
7.0 DEFUELED EMERGENCY PLAN (82301)
i The inspector verified that the requirements of the Defueled Emergency Plan (as approved on October 30,1992) were translated into the appropriate procedures. The inspector reviewed emergency plan implementing procedures, a contractual arrangement with a local hospital for treatment of radiological accident victims, and interviewed cognizant plant personnel. The revised plan was implemented on December 18,1992. An exercise of the plan is scheduled for
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the first week of April 1993. Letters of agreement with a local medical doctor, ambulance i
service, hospital, and the Massachusetts Department of Public Health were verified as having been signed prior to plan implementation. Station procedures OP-3300, Classifcation of Emergencies, Revision 11, and OP-3305, Emergency Medical Response Actions, Revision 12, j
followed the plan and provided clear guidance in the event of a medical or radiological emergency. It was concluded that the Defueled Emergency Plan has been properly implemented.
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8.0 TitAINING (41500)
8.1 Certined Fuel Handler Program The NRC approved the Certified Fuel Handler (CFH) program for Yankee on June 16, 1992.
Yankee impicmented the CFH program in July 1992. All of the personnel certified as CFHs were previously licensed as senior reactor operators (SROs), and those persons were
" grandfathered" based on their SRO license. The personnel certified as Equipment Operators (EOs), under the CFH program, were previously licensed reactor operators (RO), or were trained as EOs, in accordance with the CFH program. No deficiencies were identified with the implementation of the CFH program, as related to the ability of the personnel to maintain the fuel in a safe condition.
However, the inspector's review identified that the licensee implemented the program without first developing the appropriate procedures. Yankee personne in the opemtions and training departments stated that the procedures for the implementation of the CFH program were still under review. This item will remain unresolved pending further review (UNR 50-29/93-01-01).
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8.2 Organization As stated earlier in the report, at the beginning of the year, Yankee Atomic Electric Co.
reorganized and recently downsized to 59 full time staff. The inspectors reviewed the new organization, and it appeared to encompass all necessary departments and functions. However,
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J the organization is not consistent with the description contained in the Yankee Atomic Electric Company Operational Quality Assurance Program Description (YOQAP-1-A). Yankee submitted a change request to the YOQAP on October 21,1992; as of the inspection, the change had not
yet been reviewed by the NRC.
Of specific concern is the lack of clear direction as to who is responsible for the implementation of the training programs for the operations depanment and what the reporting relationship is for the on-site Training Coordinator (TC). By the proposed change to the YOQAP, the Operations Department is responsible for the administration of the CFH/EO training program. Two control room supervisors (CFHs) were designated as the individuals responsible for the actual
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implementation of the CFH/EO program. In addition, per the YOQAP, the on-site TC is responsible for coordinating the CFH/EO training program. The problem arises in that the two organizations don't normally communicate with each other, and there is no clear delineation as to which organization is responsible for which function. Examples include tracking of watch standing proficiency, and meintenance of training records. Further confusion was identified in that the TC stated that he. administratively reported to the corporate Training Manager, and received Yankee specific direction from the Assistant Plant Superintendent (APS). The APS believed that the TC reported directly to him, and that technical direction was received from the corporate Training Manager. The submitted change request shows the former arrangement.
Pending clarification of the organization related to training, and development of clear delineation of the duties and responsibilities for implementation of training activities, this item will remain unresolved (UNR 50-29/93-01-02).
9.0 SAFETY ASSESSMENT AND QUALITY VERIFICATION (40500,71707)
The Quality Assurance Planfor Yankee Row Possession Only License Phase, Revision 0, was approved on September 28,1992. The QA Plan details the activities proposed to verify that program and license requirements are met. The on-site QA group consists of two people; however, the Yankee Atomic QA Department is available and routinely utilized for the conduct of audits, surveillances, and QC inspections at the Yankee site.
Numerous audits and
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surveillances have been conducted since the issuance of the POL. The inspector reviewed the
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audit / surveillance schedules for 1992 and 1993, and found them to be focused on safety significant issues and relevant ongoing activities.
The inspector reviewed the following associated audit /::urveillance plans and reports, and found them to be in-depth, concise, and well written.
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Audits 92-06 Aug '92 Maintenance 92-10 Oct '92 Fire Protection and Housekeeping 92-12 Oct '92 Special Nuclear Material Control and Accounting 92-16 May & Dec '92 Corrective Action and Technical Specifications i
Surveillances 92-39 Nov '92 Fire Suppression System Flush
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92-40 Nov '92 Plant Compliance with Technical Specifications, Emergency Plan, Fire Protection Technical Requirements, -
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and Certified Fuel Handler / Equipment Operator Training 92-41 Dec '92 Implementation of Amended Facility Operating License, Amendment No.142 92-42 Dec '92 Volume Reduction Packaging and Shipping of Irradiated
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Hardware 93-01 Jan '93 Plant Compliance with Defueled Security Plan Training
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10.0 MANAGEMENT MEETINGS (30702,30703)
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An exit meeting was held on January 28,1993, at which time the inspectors summarized their preliminary findings to the Plar.t Superintendent and his staff. No proprietary information was l
identified as having been included in this inspection.
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