IR 05000255/1988026

Insp Rept 50-255/88-26 on 881115-1212.No Violations Noted. Major Areas Inspected:Plant Operations,Radiological Controls,Maint,Surveillance,Security,Reportable Events & Bullentins,Notices & Generic Ltrs

ML18054A469
Person / Time
Site:	Palisades
Issue date:	12/22/1988
From:	Burgess B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML18054A468	List: IR 05000255/1988026 ML18054A467
References
50-255-88-26, GL-83-26, GL-88-17, NUDOCS 8901030328
Download: ML18054A469 (12)

Text

U. S. NUCLEAR REGULATORY COMMISSION REGION I I I Report No. 50-255/88026(DRP) *

Docket No. 50-255 Licensee: Consumers Power.Company 212 West Michigan Avenue Jackson, MI 4S201 Facility Name:

Palisades Nuclear Generating Plant Inspection At:

Palisades Site, Covert, MI Inspection Conducted:

Inspectors:

E. R. Swanson J. K. Heller

~~J.Z~~

Approved By:

B. Burg~s, Chief Reactor Projects Section 2A

~

Inspection Summary License No. DPR-20 Inspection on November 15 thro~h December lf * 1988 (R~P~!lJJ~~

50-255/88026 ( DRP) )--------

Areas Inspected:

Routine unannounced inspection by the resident inspectors of: actions on previously identified items; plant nperations; radiolo~ical contra ls; maintenance; survei 11 ance; security; reportable events; and Bulletins, Notices* and Generic Letter The following Safety Issues Management System (SIMS) item was reviewed: MPA-A-15,diesel generator fuel oi Results:

Of the areas inspected, no violatibns or deviations were identifie The inspection disclosed weaknesses in one of the licensee's surveillance procedures, and control of the quality of diesel fuel oil. The inspection noted strengths in the licensed operators response to a test failure, their general knowledge of plant system conditions, and management's control and oversight of the outage and restart activitie OQ0j0~0~28 881222

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DETAILS Persons Contacted Consumers Power Company * * * * * * * * G. A: Hoffman, Vice President, Nuclear Operations Division Slade, Plant General Manager Orosz, Engineering and Maintenance Manager Rice, Operations Manager Joos, Administrative and-Planning Manager Lewis, Technical Director Tawney~ Mechanical Maintenance Superintendent Cedarquist, Inservice Inspection Engineer Malone, Licensing Analyst Beckman, Radiological Services Manager Kozup, Licensing Engineer McCaleb, Quality Assurance Director Fenech, Operations Superintendent Brunet, Licensing Analyst Nuclear Regulatory Commission (NRC)

C. J. Paperiello, Deputy Regional Administrator, Region III W. L. Axelson, Branch Chief, Project 2

• E. R. Swanson, Senior Resident Inspector

• J. K. Heller, Resident Inspector

• Denotes some of those present at the Management Interview on December 15, 198 Other members of the Plant staff, and members of the Contract Security Force, were-also contacted briefl.

Actions on Previouslr Identified Items (92701, 92702)

(Open) Open Item 255/86035-07(DRP): Prior to startup from the 88 refueling outage, the licensee will have in place a detailed DC Bus or ground is.elation procedur The licensee contends that the open item is resolved by the corrective actions for annunciator Alarm Response Procedure No. 3, "Electrical Jl.uxiliaries and Diesel Generator" at step number 47 and EA-88-SFE198-1 11 DC Troubleshooting Checklist".

They may be sufficient to find/isolate/resolve a DC Ground, but are absent administrative instruction The need for administrative instructions was discussed at the exi (Closed) Open Item 255/86035-21(DRP) arid 255/86035-23(DRP):

Determine if installation of a condenser expansion joint was the source of inleakag The licensee investigation is documented in internal correspondence (ERT 88*013) dated November 9) 198 The licensee initially believed that torquing sequence of the expansion joint hold down clamps or the

condenser design contributed to condenser inleakage a.fter a new joint was installed in 198 Since that time, the licensee has learned that inleakage was caused by a gland steam condenser drain trap operating incorrectl The drain trap was replaced and the leakage decrease The licensee still plans to replace the expansion joint during a 1990 refueling outag The installation procedures have been reviewed and hold down torquing problems have been addresse (Closed) Open Item 255/86035-26(DRP):

Repair cracks in condensate pump bas The pum~ vendor has found that the discharge head radial supports may crack at the rib-to-outer wrapper joint. The vendor recommended changes were made to a spare pump per SC-87-27 The spare pump was installed as P-2A during 1987 under* W0-2470293 Licensee internal correspondence (ERT 88*014) dated November 10, 1988, stated that pump performance has been satisfactory since the modifications were mad (Closed) Open Item 255/86035-27(DRP):

Modify the Air Coolers on P-2A and P-28, 11Condensate Pump Motors".

Licensee internal correspondence (SRO 88*015) dated July 18, 1988, addressed this item and concluded that modifi cations are not necessary. *A 1 so, the stator* winding temperatures were observed during the hot weather of 1988 and found to be acceptabl (Closed) Open Item 255/86035-36(DRP) and 255/86035-37(DRP):

Determine if Control Rod Drive Thermocouples should b.e replaced and exposed terminal blocks coate The licensee evaluation (DMK 88*008) dated November 22, 1988, concluded that replacement or coating is not justified 'because of the low number and type of thermocouple failure *

(Closed) Open Item 255/86035-42(DRP): *Replace/modify that portion of CVCS containing CV-2056 (three way valve) to eliminate leakage and facilitate maintenanc Specification Change 88-171 and W0-24800214 installed a soft seat desig (Closed) Open Item 255/86035-59(DRP):

Develop a plan to provide alternate shutdown cooling to allow repair/replacement of Low Pressure Safety Injection shutdown cooling heat exchanger Inlet, Bypass, and Crossover valves CV-3006, CV-3025 and CV-305 These valves were repaired while the vessel was defueled, which eliminated the requirement for shutdown coolin (Closed) Open Item 255/86035-8l(DRP):

Ensure sufficient spare parts are available for Ferris Relief valve Licensee investigations (PDF 88*008 dated November 4, 1988) concluded that drawing errors, material changes and part interchangeability contributed to the problem To correct these problems, procurement documents have been revised to reflect the material changes, drawing revisions were made to correct the drawing errors, and Specification Changes were made to correct material discrepancie (Closed) Open Item 255/86035-84(DRP):

Identify and repair non EEQ solenoid valves with field wiring terminated inside the solenoid valve body housin Inspection and Enforcement Information Notice (IEIN) 84-68 identified that temperatures in the housing could reach temperatures of 288 degrees Fahrenheit, which may exceed the wire insulation ratin During the 88 refueling outage 95 solenoid valves were inspected and none of the problems discussed in IEIN 84-68 were identifie (Closed) Open Item 255/86035-115(DRP):

Rebuild all Bettis actuators on Service Water System Valve Licensee internal correspondence (DOC 88*012) dated Novemb~r 18, 1988, stated that some activators were rebuilt during the 1986 maintenance outage and the remainder during the 1988 refueling outag (Closed) Open Item 255/86035-118(DRP):

Evaluate so~rces of service water pump vibration using signature analysi During th~ 1988 refueling outage, an expert in pump vibration analysis performed an analysis of the service water pump His analysis and steps to implement his suggestions are being consid~red..

(Closed) Open Item 255/86035-120(DRP):

Implement a program to inspect all service water heat exchangers cool~d by the service water syste The licensee investigation (DOC 88*014 dated November 18, 1988-and DOC 88*019 dated November 21, 1988) documented that most heat exchangers were already on PPAC activities or part of the Turbine-Generator Maintenance Progra The heat exchangers that were not part of a existing program were added to -the PPAC progra (Closed) Open Item 255/86035-12l(DRP):

Place critical service water service equipment and serviced components in the preventative maintenance progra The system engineers review and components placed in th preventative maintenance program are documented in Internal Correspondence (DOC 88*017) dated November 21, 198 (Closed) Open Item 255/86035-123(DRP):

Repair generator end bell hydrogen lea The generator end bells were removed and machined during the 1988 refueling outag The machining removed a low spot which had been the source of the hydrogen leakag At the completion of the repair, a generator pressure drop test was performed on November 21, 1988; the results were satisfactor (Closed) Open Item 255/86035-133(DRP):

Evaluate the feasibility of modifying individual Engineer Safeguards room cOolers to allow isolation during power operations to facilitate maintenanc The licensee investigation (DOC 88*015, dated November 18, 1988) determined that there is no feasible way to implement this suggestion, because removal from service of a cooling coil makes the train of safeguards equipment located in that room inoperable; a condition prohibited by the Technical Specification during power operation No violations, deviations, unresolved or open items were identifie.

Operational Safety Verification (71707, 71710, 71711, 42700)

Routine facility operating activities were observed as conducted in the plant and from the main control room Plant startup, steady power operation, plant shutdown, and system(s) lineup and operation were observed as applicabl **

The performance of licensed Reactor Operators and Senior Rea~trir Operators, Shift Engineers, and auxiliary equipment operators was observed and evaluated including procedure use and adherence, records and logs, communications, shift/duty turnover, and the ~egree of professionalism of control room activities..

Evaluation, corrective action, and response for off normal conditions or events, if any, were examine This included compliance to any reporting requirement Observations of the control room monitors, indicators, and recorders were made to verify the operability of emergency systems, radiation monitoring systems and nuclear reactor protection systems, as applicabl Reviews of surveillance, equipment. condition, and tagout logs were conducte Proper return to service of selected components was verifie The unit began this reporting period in a refueling outage that was compl~ted on November 2 After completion of startup testing the unit commenced power operation on November 2 An increase in primary-to~secondary leakage forced a unit shutdown on December The outage is expected ~o last approximately three week Consumers Power Vice Pre~ident for nuclear operations and the Palisades Plant Manager conducted a plant tour on November 21 for the Region III Deputy Regional administrator, the Chief of Projects Branch 2 and the Senior Resident Inspector. Areas toured included t.he control room, auxiliary building and the containment building for a preoperational cleanliness inspectio All areas inspected appeared satisfactor During th~ plant pressurizatio~ following the 1988 refueling outage, the 11C 11 reactor coolant pump upper mechanical thermal barrier seal failed to stage properl The pump consists of four mechanical seals. Three seals are designed to accept full operating system pressure but normally operate at one-third system pressure, the fourth is a vapor seal. Plant operation is permitted with one full pressure seal not staging properl The inspector discussed this item with several of the operations crews and determined that they had sufficient knowledge of syste design and plant procedures to determine which seal had not staged, what parameters would indicate trouble with a second stage and what actions are required if a second stage would fai The inspector also discussed this item with station management, and found that plant operations would continue with the upper seal not staging until the next cold shutdown outage of sufficient lengt The inspector observed the operators response to information obtained by Q0-11, 11 Containment Isolation Valve Test Procedure

• The test is written to verify the integrity of containment isolation check valves that are in series with a automatic containment isolation valv In this case, the test results indicated that

• Check Valve CK-408, 11 Clean Waste Receiver Tank Recirculation 11 was leaking b Additional evaluation determined that Containment Isolation Valve CV-1037, was leakin The test result indicated that the maximum allowable containment leakrate (~a) may have been exceede When the crew confirmed these results, Technical Specification 3.0.3 was invoked and preparations for a shutdown were made in parallel with attempts to repair the valv Prior to initiation of the shutdown the valve seat was cleaned by flushing with water, Q0-11 completed satisfactory and the valve deactivated in the closed position. All actions performed by the operators appeared correct. See paragraph 6.d (Surveillance) for a discussion of the tes The inspector recalculated six randomly selected primary coolant leakrate calculations performed between November 30 and December 4 using NUREG 1107, 11 RCSLK9: Reactor Coolant System Leak Rate Determin~tion for PWRs

• The inspector's unidentified leakrate calculations were in agreement with the litensee calculation During startup testing of the auxiliary feedwater (AFW) system, several problems were identified and dispositione The nitrogen backup system to the air operated valves was found to be leaking excessively during test T-232 11 Backup Nitrogen Supply Test For Auxiliary Feedwater System

• After corrective maintenance on a valve bonnet, the retest was acceptabl On November 21, 1988, during performance of test T~203, AFW pump starts caused valves CV-0727 and CV-0749 to ope Investigation by the licensee*

determined that air was trapped above the 11 balanced 11 plug which allowed it to open while the pilot valve was close In this condition the water pressure was sufficient to unseat the valv Corrective action was taken to clear and vent the lines of any ai Operating procedures will be revised to ensure all air is removed following maintenanc The licensee has also become aware of some flow instability of pump P-8C, which occurs during recirculation flo This has apparently existed since the safety injection pump was converted to an AFW pum Resolution of this issue will be tracked as an open item (Open Item 255/88026-0l(DRP)). During the cooldown for the December 6 outage, the inspector observed control room activities as they apply to: calculation of boron concentration per SOP 2A and EM-04-08; blocking of SIAS as required by GOP 9; and confirmed the cooldown plots as required by GOP 9 and SOP Half loop operations were preceeded by additional training and implementation of the interim controls required by Generic Letter 88-1 During the 88 refueling outage the licensee found and repaired leaking tubes in the 118 11 steam generator, defueled and conducted extensive valve refurbishment, installed a new thermal margin/low pressure calculator(RPS), replaced OBA sequencers, replaced coolant pump seals, performed core cooling instrumentation modifications, replaced the main voltage regulator, inspected and repaired the main

generator/exciter, repaired the HP turbine casing and gland seals, inspected and repaired the SIRW tank, performed acoustic leak testing of the main steam lines and other systems, and performed a containment integrated leak rate tes The outage was completed in 113 days which was one day shorter than originally schedule The inspector reviewed significant changes to the administrative controls which occurred during the outage. Administrative Procedure 5.01, "Procedure on Procedures was revised to incorporate a page revision method which should reduce the number of inappropriate temporary changes made, and improved the quality of the adminis-trative controls. Standing Orders and operating procedures were changed to reflect controls required to assure that only doors into the control robm HVAC envelope with v~stibules would be utilized during an accident. This is part of other interim measures taken as a result of the discovery of HVAC system design input deficiencies. Selected procedure changes resulting from plant modifications were also reviewe The licensee again utilized a reviewed and approved restart plan for the heatup and power escalation. This plan assured the involvement of management in the review of critical activities pri-0r to startup and at key points during the power escalation testin Portions of the auxiliary feedwater system and the emergency power systems (AC and DC) were walked down. Discrepancies noted w~re minor in nature and were turned over to the license Core physics testing was conducted in accordance with approved procedures which met the requirements of the Technical Specification Portions of the low power testing and 35% testing were observe Discrepancies identified were resolved with the fuel vendor in an appropriate manne One open item; no violations, deviations, or unresolved items were identifie.

Radiological Contro]~ (71707)

During routine tours of radiologically controlled plant facilities or areas, the inspector observed occupational radiation safety practices by the radiation protection staff and other worker Effluent releases w~re routinely checked, including examination of on-line recorder traces and proper operation of automatic monitoring equipmen Independent surveys were performed in various radiologically controlled area A meeting was held in Region III to discuss the large numb~r of personnel contaminations that occurred in calendar year 8 Additional discussions of this issue is contained in report 255/8802 **

• The inspectors observed that considerable post outage manpower was dedicated to reducing the contamination area in the auxiliary buildin One area that showed considerable improvement was the east and west safeguards roo General housekeeping has been steadily improving since the end of the outage on November 2 No violations, deviations, unresolved or open items were identifie.

Maintenance (62703, 42700)

Maintenance activities in the plant were routinely inspected, including both corrective maintenance (repair~) and preventive maintenanc Mechanical, electrical, and instrument and control group *maintenance activities were included as availabl The focus of the inspection was to assure the maintenance activities reviewed were conducted in accordance with approved procedures, regulatory guides and industry codes or standards and in conformance with

• Technical Specifications. The following items were considered during this review~ the Limiting Conditions for Operation were met while components or systems were.removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures; and post maintenance testing was performed as applicabl The following activities were inspected: Calibrate Level ( EPS 24807067)

Transmitter LT~l416 per PPAC EPS 014 Calibrate Level Transmitter MV-6556 DE per PPAC EPS 015 (EPS 24807068) Rebuild and repair of Service Water pump P-7C (SWS 24806332, SC-88-324-RI) Rebuild of P-7C (SWS 24867158)

No violations, deviations, unresolved or open items were identifie.

Surveillance (61726, 42700)

The inspector reviewed Technical Specifications required surveillance testing as described below and verified that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, thGt Limiting Conditions for Operation were met, that removal and restoration of the affected components were properly accomplished, that te~t results conformed with Technical Specifications and procedure requirements and were reviewed by personnel other than the individual directing the test, and that deficiencies identified during the testing were properly reviewed and resolved by appropriate management personne The following activities were inspected: DW0-1 SH0-1 T-232 Daily Control Room Surveillanc Operators Shift Surveillance.

Backup nitrogen supply test for Auxiliary Feedwater Syste ** * Q0-11 Crintainment Isolation Valve Test Procedur The inspector did not observe this test, but did review the test

{Revision 9, dated 7/11/88) and the basis document (Revision 4, dated 5/13/88) after a December 2, test failed the acceptance criteria. A discussion of the operator response is contairied in paragraph The,test verified the ability of containment isolation check valves to close when a reverse differential pressure is applied across the valve seat. This is accomplished-by installation of the local leakrate test (LLRT) rig to a test connection located between the check valve and a containment isolation valve. *This configuration is pressurized and the sealing confirmed by monitoring the pressure deca The. inspector questioned whether performance of the test puts the plant in an LCO that is not identifie For example, the test performed on penetration 67, 11 Clean Waste Receiver Tank Recirculation" at paragraph 5.5:requires removal of the test connection cap which may degrade that penetration boundar The test, at a note to paragraph 5.0 states:

11 During performance of test, containment isolation valves may be inoperable provided the affected penetration is isolated by at least on automatic valve within four hours

• This implies that no LCO is entered as long as the automatic valve is isolated or.in this case closed as required to perform the tes The inspector has asked the licensee to review this item and verify if the procedure implements a June 2, 1982 letter from Consumers Power (B. D. Johnson, Senior Licensing Engineer)

to Nuclear Reactor Regulation (D. M. Crutchfield, Chief of Operating Reactors Branch 5). This letter does reference Q0-11 and stated in the second to last paragraph, "Allow unrestricted testing of containment isolation valves by permitting containment isolation valves to be inoperable provided the affected penetration is isolated by deactivating at least one automatic valve in the closed position within four hours".

The acceptance criteria at paragraph 6.3 allows a retest to confirm the results and requires tnitiation of a deviation report and performance of a LLRT at the next cold shutdown if the LLRT guidelines for the applicable penetration are exceede That acceptance criteria is acceptable if total containment leakage is less than 0.6 L However, if total leakage is greater than 0.6 La but less than La then the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> time limit of Technical Specification 4.5.2.c applies or if La is exceeded then the time limits of Technical Specification 3.0.3 applie This matter will be reviewed when the LER is issue No violations, deviations, unresolved or open items were identifie Fire Protection (71707, 64704)

Fire protection program activities, including fire prevention and other activities associated with maintaining capability for early detection and suppres~ion of postulated fires, were examine Plant cleanliness, with a focus on control of combustibles and on maintaining continuous ready

access to fire fighting equipment and materials, was included in the items evaluate Inspection determined that the licensee has established a policy of only allowing pressure treated fire retardent lumber on site. This is an improvement ov~r the previous policy of allowing surface coated lumber on sit No violations, deviations, unresolved or open items were identifie.

Security (71707)

Routine facility security measures, including control of access for vehicles, packages and personnel, were observe Performance of dedicated_ physical security equipment was verified during inspections in various plant area The activities of the professional security force in maintaining facility security protection were occasionally examined or reviewed, and interviews were occasionally conducted with security force member No violations, deviations, unresolved or open items were identifie.

Reportable Events (92700, 92720)

The inspector reviewed the following Licensee Event Reports (LERs) by means of direct observation, discussions with licensee personnel, and review of record The review addressed compliance to reporting requirements and, as applicable, that immediate corrective action and appropriate action to prevent recurrence had been accomplishe (Open) LER 255/88020:

Pressurizer safety valve RV-1039 failed to meet it's Technical Specification acceptance ban It was found to lift at 2760 psig, above the Technical Specification limits of 2460 to 259 RV-1040 was also found below it's desired setpoint tolerance of+/- 1 percent, but within the Technical Specification limits. Valve RV-1039 required repair and both were adjusted and tested satisfactorily. A cause for the setpoint drift has not been determined and the licensee noted that the three previous lift tests of RV-1039 found the lift setpoint above the allowable tolerance. This item will remain open pending cause determination and corrective action by the license No violations, deviations, unresolved or opeh items were identifie.

NRC Compliance Bulletins, Notices and Generic Letters (92703, 71707, 25588)

The inspector reviewed the NRC communications listed below and verified that: the licensee has received the correspondence; the correspondence was reviewed by appropriate management representatives; a written response was submitted if required; and, plant-specific actions were taken as described in the licensee's respons (Closed) TI-2515/93 and TI-2515/100: Quality Assurance (QA)

requirements for diesel generator fuel oil (MPA Item A-15).

By NRC letter dated January 7, 1980 all power reactor licensees were requested to review their QA Program coverage of diesel generator fuel oil, and if it does not, to respond justifying why it should not be include On April 21, 1980, the licensee responded stating that 11 Diesel fuel oil is included in the Palisades Plant QA Program as required by Quality Assurance Program Procedures (QAPP) 2-25, Section 5.2.2

, dated February 15, 198 This particular paragraph addressed spare equipment and consumables in regards to their inclusion on the Q-Lis This section of the procedure was deleted by Temporary Change in January 1982 because the 11Q-List does not include spare equipment and consumables in regards to their inclusi~n on the Q-Lis Fuel oil currently is not Q-Listed, nor is it addressed by the QA Program or FSA S~mpling is performed monthly for viscosity, water content and sediment of the main storage tank (T-10) as required by Technical Specification 4.17.2. This specification is part of the fire pump diesel engine surveillance requirement. Testing of the fuel oil is done offsite and results are received in about a mont Samples of the diesel day tanks are also taken monthly, although this is not specified by procedur This testing does not meet th~

NRC. position as stated in Regulatory Guide 1.137. Specifically, fuel oil is not sampled before adding to the existing supply, nor does routine testing verify specific or API gravity, total insolubles, cloud point, or other properties. Generic Letter 83-26 further clarified the NRC's position on diesel fuel oil testing and forwarded draft Technical Specifications, expecting the*li~ensee to submit Technical Specification incorporating these testing requirement The inspector could not identify any submittal of proposed Technical Specification in response to the Generic Lette Palisade'~ fuel oil system is somewhat unique in that the main storage tank (T-10) inventory turns over about once a month as a result of usage from diesel testing and operation of the plant h~ating boilers. This somewhat ameliorates the concern for maintaining the quality of fuel oil that is in long term storage with respect to biologic growth and oxide formatio Some sludge accumulation was identified during the last tank inspection and cleaning, howeve The licensee is also pursuing conversion of their Technical Specification under the Technical Specification Improvement Progra The target date for a complete submittal is early 199 Responsibility for accepting or resolving the above described discrepancies lies with NRR in the resolution of Multi-Plant Action A-1 In conclusion the following issues require resolution:

(1). The licensee should review RG 1.137 and its referenced standards and document their position for NRC revie (2). The licensee ~hould revise their response to th~ NR~.

• including a clear statement of the QA program applicability to diesel generator fuel oi (3). Proposed Technical Specifications should be submitted by the licensee as requested by Generic Letter 83-2 (4). Plant procedures should be revised according to the results of their revie (Closed) TI-2515/98:

The Temporary Instruction directed review of the Palisades Plant containment temperature monitoring system and evaluation of its adequacy in relation to recording representativ~

temperatures and maintaining equipment qualification (EQ).

The current temperature used for analysis and also for EQ is 145 degrees Fahrenheit. This exceeds the highest temperature ever recorded for*

containment, including instrument accurac The four installed temperature elements do not provide an accurate picture of containment temperature since three of them are.inside ventilated structures (Pressurizer and two steam generator housings) and one in the containment dom Since the licensee is using the most limiting temperature, typically the containment dome,'there does not appear to be any concern with respect to the analysis or E The licensee is conducting further evaluation of the containment temperature profil A Technical Specifications does not exist for containment temperature although it has been recommende No violations, deviations, unresolved or open items were identifie.

Open Items Open.Items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or bot An Open Item disclosed during the inspection is discussed in Paragraph.

Management Interview (30703)

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

on December 15, 1988 to discuss the scope and findings of the inspectio In addition, the inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by th~ inspector during the inspectio The licensee did not identify any such documents/processes as proprietar