IR 05000295/1989008

Insp Repts 50-295/89-08 & 50-304/89-08 on 890210-0323. Violations Noted.Major Areas Inspected:Licensee Action on Previous Insp Findings,Summary Operations & 890219 Shutdown of Unit 2 to Repair Failed Control Rod

ML20244C632
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	04/10/1989
From:	Hinds J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20244C626	List: IR 05000295/1989008 ML20244C623 ML20244C628
References
50-295-89-08, 50-295-89-8, 50-304-89-08, 50-304-89-8, NUDOCS 8904200307
Download: ML20244C632 (13)

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V.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report Nos. 50-295/89008(DRP); 50-304/89008(DRP)

Docket Nos. 50-295; 50-304 License Nos. DPR-39; DPR-48 Licensee: Commonwealth Edison Company P. O. Box 767 Chicago, IL 60690 Facility Name: Zion Nuclear Power Station, Units 1 and 2 Inspection At: Zion,-IL Inspection Conducted: February 10'though March 23, 1989 Inspectors: M. M. Holzmer ,

P. L. Eng

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nJ l 6 Approved B : . M. Ili n'd s , J r. , C i ef 4-io . 69 l

! eactor Projec ection IA Date l t

Inspection Summary ,

Inspection from February 10 through March 23, 1989 (Inspection Report

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' Nos. 50-295/890.08(ORF); 50-304/89008(DRP))

Areas Inspected: Routine, unannounced resident inspection of licensee action on previous inspection findings; summary of operations; February 19, 1989 Unit 2 reactor shutdown to repair pressurizer spray valve packing leakage; March 8,L1989. Unit I reactor shutdown to repair failed control rod individual rod position indication (IRPI) power supply transformer; operational safety i verification and engineered safety feature.(ESF) system walkdown; maintenance and surveillance observation; licensee event reports (LERs); training; safety assessment and quality verification; F6ruary 22,1989 OSHA site visit; )

February 27 through March 10, 1989 INF visi ;

p Results: Of the 10 areas inspected,t a violations or deviations were identified L in 9 areas, and one violation was identified in the remaining area (QA and QC personnel failing to detect an error during a hold point inspection -

paragraph 7). In addition, several observations were noted in the maintenance area pertaining to mechanical maintenance staff duties and training. An apparent violation, identified in paragraph 6, documents the failure of the licensee to recognize that the containment spray train 1A was on a Technical Specification clock when valve 1 MOV-CS 0049 was declared inoperable. This l L event appears to be caused by longstanding difficulties in retrieving design basis information at the station, thus making it difficult for operators to arrive at the correct operability decisio "

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DETAILS Persons Contacted

• T. Joyce, Station Manager

• W. Kurth, Superintendent, Production T. Rieck,' Superintendent, Services P. LeBlond, Assistant Station Superintendent, Operations R. Johnson, Assistant Station Superintendent, Maintenance J. Gilmore, Assistant Station Superintendent, Planning R. Budowle, Assistant Station Superintendent, Technical Services N. Valos, Unit 2 Operating Engineer M. Carnahan, Unit 1 Operating Engineer

• E. Broccolo, Jr. , Operating Engireer R. Cascarano, Technical Staff Supervisor A. Ockert, Training Supervisor

• T. Vandevoort, Quality Assurance Supervisor V. Williams, Station Health Physicist G. Kassner, Lead Health Physicist C. Schultz, Quality Control Supervisor W. Stone, Regulatory Assurance Supervisor

• T'Niemi, Master Mechanic A. Bless, Regulatory Assurance Engineer

• J. Yost, Quality Control Inspector In addition to the above, the inspectors interviewed operators, mechanics, quality assurance and quality control inspectors, and other plant personne ..

• Indicates persor,s present at the exit intervie . Licensee Actions on Previous Inspection Findings (92701, 92702)

Open Items listed in the Attachment I to this report have been closed during this inspection period based on a directive by the Division Director, Division of Reactor Safety (DRS), Region III, dated February 3, 1989. The decision to close these items was based on the length of time these items have been open and their limited safety significanc In addition to the above items closed by DRS, Region III, the items listed in Attachment 2 were also closed by the NRC resident inspectors either using the same criteria or because acceptable corrective actions have been complete No violations or deviations were identifie . Summary of Operations Unit 1 The unit began the inspection period in a maintenance outage for the repair of leaking steam generator primary manway gaskets. The unit was l

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taken critical on March 2, 1989 and tied to the grid on March 3, 198 On March 8, the unit was shut down to repair a control rod 1ndividual position indication (IRPI) power supply transformer. The transformer was repaired and the unit was tied to the grid on March 9, 1989. The unit operated at power levels up to 100% for the remainder of the inspection perio Unit 2 The unit began the inspection period in Mode 1 operating at full power anri operated until February 19, 1989 when the unit was shutdown to repair leaking pressurizer spray valve packing leakage. Following repairs the unit was tied to the grid on February 21, 1989. The unit operated at power levels up to 100% for the remainder of the inspection perio No violations or deviations were identifie . February 19, 1989 Unit 2 Shutdown to Repair Leaking pressurizer Spray Valves On February 19, 1989, at approximately 6:00 p.m. (CST), with Unit 2 at 99% power, the reactor operator noticed an increase in pressurizer relief tank (PRT) pressure and level. By 10:00 p.m.' the reactor coolant system (RCS) leak rate was computed to be about 6 gpm. Technical Specifications (TS) permit operations to continue for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if unidentified RCS leakage exceeds 1 gpm. The TS limit for identified leakage is 10 gp After a power reduction to 60% power to permit a containment entry, a-steam plume was found at about 4:30 a.m. on February 20, 1989, coming from a broken valve leakoff bullseye (sightglass) for 2RC-0022, the upstream manual isolation valve for 2PCV RC-06, one of the two pressurizer spray valves. At 9:22 with RCS leak rate about 9.2 gpm,

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the license declared an Unusual Event (UE) for EAL 9A, an item of interest for information only, and commenced a reactor shutdown to isolate the leak. The turbine was taken off line at 11:46 By about 3:30 p.m., initial attempts to isolate the leak by closing the upstream and downstream isolation valves for 2PCV RC-06 had only reduced RCS. leakage to about 5 gpm, after which the licensee shutdown the reactor at 3:52 p.m. At 10:30 p.m. on February 20, 1989, the remaining leakage was reduced by tightening packing for 2PCV RC-06, 2PCV RC-07 (the second pressurizer spray valve), and 2RC-0022 after which RCS leak rate was less than 1 gpm. The licensee terminated the UE at 10:45 The senior resident inspector observed ALARA meetings, initial isolation efforts in the containment, and the reactor shutdown, and was kept informed throughout the event by plant management and operating shift supervisors. The steam plume was verified not to be impinging on any safety related electrical or environmentally qualified (EQ) components, and no potentially damaging condensate was observe Pressurizer spray valve packing leakage from 2PCV RC-06 and 07 forced the licensee to shutdown Unit 2 in October 1987 (see inspection report 295/87026 and 304/87027). At that time the packing material was believed

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to be the cause of the leakage. The. licensee believes that the February

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1989 leakage'was caused by loose packing gland nuts. After tightening the packing to these valves the licensee added a second nut to each pressurizer spray valve packing gland stud to prevent the pa'cking gland nuts from vibrating loose. The 2RC-0022 bullseye leakage was also repaired. The unit was returned to the grid on February 21, 1989 after completion of the repair No violations or deviations were identifie . March 8, 1989, Unit 1 Reactor Shutdown due to Malfunctioning Individual Rod Position Indicators (IRPI) Transformer On March 8, 1989, at approximately 3:05 a.m. (CST), with Units 1 and 2 at approximately 100% power, the Unit 1 IRPI for all control rods dropped from 231 steps to 200 steps. Both the lo and lo lo insertion limit annunciators were received. The licensee entered the LC0 for TS 3.2. which requires that with either more than one rod indicator channel per control group or two rod position indicator channels per control bank inoperable, the unit be taken to hot shutdown within 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> The NSO notified the shift engineer of the event and placed the control rods in manual. Instrument mechanics (IMs), electricians (ems), and members of tech staff were called in to perform troubleshooting. The cause for loss of IRPI was determined to be a malfunctioning SOLA transformer and at approximately 5:05 a.m., unit rampdown by boration was initiated. The. reactor was manually tripped per the shutdown procedure, GOP-4, at 6:49 a.m. and remained in Mode 3 until the IRPI power supply could be restored. All systems responded as designe After repairs to the SOLA transformer, the unit was returned to the grid on March 9, 198 No violations or deviations were identifie . Operational Safety Verification and Engineered Safety Features System Walkdown (41400, 71707 & 71710)

The inspectors observed control room operations, reviewed applicable logs and conducted discussions with control room operators from February 10 through March 17, 1989. During these discussions and observations, the inspectors ascertained that the operators were alert, cognizant of plant conditions, attentive to changes in those conditions, and took prompt action when appropriate. The inspectors verified the operability of selected emergency systems, reviewed tagout records and verified proper return to service of affected components. Tours of the auxiliary and turbine buildings were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks, and excessive vibrations and to verify that maintenance requests had been initiated for equipment in need of maintenance. The inspectors observed plant housekeeping and cleanliness conditions and verified implementation of radiation protection control _ _ - - _ _ _ - _ _ _ - _ _ _ _ _

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The inspectors by observation and direct interview verified that selected physical security activities were being implemented in accordance with I the station security pla These reviews _and observations were conducted to verify that facility operations were in conformance with the requirements established under Technical Specifications, 10 CFR, and administrative procedure FINDINGS'

The resident inspector attended several training sessions which were part of the licensee's Nuclear General Employee Training requalification program. The inspector also attended the licensee's 00 NGET training class held at the licensee's Technical Center in Maywood. The NGET training sessions attended were considered acceptabl The reactor shutdown for the Unit 2 RCS leakage was performed prior to exceeding the TS limit of 10 gpm identified limi In addition, the Unit I shutdown for IRPI power supply transformer failure was performed in accordance with the applicable TS requiremen On March'11, 1989, at about 10:00 p.m., IMOV CS-0049, the 1A train containment spray (CS) header isolation valve from the 1A residual heat removal (RHR) train failed to stroke fully open during periodic test PT-28. The valve was declared inoperable and the licensee evaluated the condition for TS applicability. The licensee concluded that, since IMOV CS-0049 was not mentioned in TS, no action requirement applied, and that no other systems or trains were inoperable. Repairs to IMOV CS-0049 were completed and the

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valve was returned to service on March 18, 198 TS definition 1.27, "0PERABLE - OPERABILITY," states that a train shall be OPERABLE or have OPERABILITY.when it is capable of performing its specified function (s). FSAR section 6.4.2 states that should CS be required during the recirculation phase of the accident, two of the three CS subsystems can be supplied with water from the containment sump via the RHR pumps which deliver water to the discharge lines of the two motor operated CS pumps. FSAR section 14.3.4.4, " Containment Pressure Analysis" states in its assumptions that after the refueling water storage tank is exhausted, CS is continued at a reduced flow rate, and one of two RHR pump trains is used to recirculate and cool water from the containment sump, providing cooled water for CS. With IMOV CS-0049 inoperable, the A CS train was incapable of performing its intended containment pressure reduction function during the recirculation phase of an accident and should have been declared inoperable. This conclusion was reached by the NRC resident inspector and concurred in by the NRC licensing project manager on March 22, 198 TS 3.6.1.C and D require that when one of three CS systems for pressure reduction is made or found to be inoperable, for any reason,

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3 reactor operation is permissible only during the succeeding 48. hours i provided that the remaining CS systems are operable and four reactor containment fan coolers (RCFC) are operable,'otherwise, the reactor shall be brought to the hot shutdown condition within four hour Operation of Unit I from March 11 to March 18, 1989, a period of more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is considered an apnarent violation.

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(295/89008-01)'.

The licensee agreed that with IMOV CS-0049 inoperable, a system function was lost, but asserted that the time clock for the RHR system (7 days)

would be more appropriate. The licensee also pointed out that there was

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a previous Open Item (295/86022-02; 304/86020-01) which was initiated to compile a descriptive listing of'all pertinent FSAR parameters, assumptions, and analytic methodologies. The licensee committed to review the status of this project in order to provide operating shifts and other plant personnel a better tool .for making decisions without inadvertently exceeding design basis parameters and assumption One apparent violation and co deviations were identifie . Month 1.v Maintenance and Surveillance Observations (62703 & 61726)

Station maintenance activities on safety related systems and components I were observed or reviewed to ascertain whether they were. conducted in accordance with approved procedures, regulatory guides industry codes or standards and in conformance with Technical Specifications. Consideration was given to: the limiting conditions for operation while components or systems were removed from service; approvals prior to initiating the work; use of approved procedures; functional testing' and/or calibrations prior to returning components or systems to service; quality control records; personnel qualifications and training; certification of parts

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and materials; radiological and fire prevention control In addition, work requests were reviewed to determine status of outstanding jobs and to assure that priority is assigned to safety related equipment maintenance which may affect system performanc Technical Specifications required surveillance testing on the reactor ventilation and containment isolation systems were reviewed or observe Consideration was given to: procedures; calibration of test instrumen-tation; limiting conditions for operation during testing; removal and restoration of the affected components; whether test results conformed with technical specifications and procedure requirements; review of test results by personnel other than the individual directing the test; and correction of any deficiencies identified during the testin PT-21, " Reactor Coolant System Leakage Surveillance" was reviewed and no problems were note The inspector also reviewed the work request package preparation process and selected maintenance procedures. Following interviews with members ,

of the MM staff, the inspector made the following observations: l

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'i * The licensee does not validate new or revised procedures or work instructions in work _ packages prior to use in the field. This ,

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became. evident after review of mechanical maintenance (MM) procedure P/M003-7N,." Disassembly, Inspection,-Reconditioning, Re-Assembly and/or Adjustment of Copes-Vulcan Air Operated Control Valves." The licensee subsequently conducted an indepth review of P/M003-7N, and

. plans to revise the procedur A number of work requests were "on hold" awaiting guidance and/or work instructions from members of the technical staff. Also several work requests did not contain sufficient detail in the " problem / work requested" block to allow timely work package preparation. The

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licensee stated that efforts to improve both work request problem i descriptions and communications between maintenance and the technical staff were being pursued which include increasing the number of work analyst The job description for the work analyst (WA) position had not been ;

updated since 1980. Discussions with several of the work analysts revealed that all the WAs generally knew their assigned tasks; however, description of specific job tasks among WAs were inconsisten l

. Training.and qualification requirements for the WA position were not defined. WA stated that'they had been trained on, Zion Administrative Procedures (ZAPS) and had received general employee training; however, most of their task related training had been from their peer The licensee stated that the current WA position would be reviewe !

Despite the fact that WAs prepare detailed work instructions for.the

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repair, adjustment and troubleshooting of plant equipment, neither the WAs nor their supervisor had received MM equipment trainin The licensee acknowledged the inspectors comments and stated that the 2 week MM training for all work analysts would be completed in the second quarter of 198 Clarification of the job description, identification of required training and training completion for current work analyst personnel is considered to be an Unresolved Item (295/89008-02; 304/89008-01).

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Work requests were reviewed to determine status of outstanding jobs and to assure that priority is assigned to safety related equipment i maintenance which may affect system performanc The following maintenance activities were observed or reviewed:

275484 Removal of Block for PORV 1 PCV-456 278524 Block PORV 1 PCV-456 '

269530 Containment Air Sampling Isolation Valve IS0V-PR-25D 278189 Low Pressure Letdown Relief Valve 1 VC-8119 !

278896 Bypass Valve for Pressure Control Valve 1 VC-8409 Z78368 1A AFW Pump Cooling Water Line Relief Valve 1 FWO186

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Z79318 1A AFW Pump Cooling Water Line Ralief Valve 1 FW0186 7 .

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Z79600' 1A AFW Pump Cooling Water Pressure Control Valve 1 PCV-FW541 Z79651 Unit 1 Rod Position Indicator Line Voltage Regulator L Findings: As a result of the failure of the Unit 2 power operated relief valve (PORV) block (See IR 295/88019; 304/88019), the licensee designed a new valve block. Work request Z 75484 was subsequently written to remove and destroy the Unit 1 PORV valve blocks which were the same as those which failed on Unit Urit 1 was brought to cold shutdown on February 6,1989, to repair

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leaking steam generator manways. Work request Z 78524 was written to block the PORVs open during mid icop operations. Work request 78524 was performed before work request Z 75484, therefore the PORV was blocked open with the wrong block design. This was identified when the Unit 1 PORV block broke while installed. The new PORV valve block design was then installe When attempting to return the Unit 1 PORVs to service, operators could not stroke the PORVs. Investigation revealed that the MM crew assigned to remove the PORV block were not aware that the valve block design had been change Consequently, when the mms went to the PORVs, they did not see the old valve block design and concluded that the block had already been remove The licensee stated that review and issuance of ZAP 3-51-4A, " Valve Block Design and Documentation," was in progress; however, a generic work request traveller is being prepared which requires the review of valve block design for each valve to be blocked until the ZAP is

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issue One example of untimely procurement of spare parts was identifie Work request Z 69530 was initiated on April 12, 1988, to repair valve 150V PR-25D, a containment air sampling isolation valve. The work was not performed during the last Unit I refueling outage due to an 18 week lead time to obtain replacement valve parts, so the work request was "on hold, pending receipt of parts." On February 14, 1989, the inspector discovered that parts for 150V PR-250 had not yet been ordered. The licensee subsequently ordered the valve parts and verified that the order had been received by the manufacture Work request Z 78896 was initiated to repair or replace manual valve 1 VC-8409 which was leaking at the downstream pipe to valve wel The repair required prefabricating a short pipe section, including a replacement valve, in the machine shop and subsequent welding of the pipe section to existing pipe in the field. The inspector had the following observations:

Weld 4 data was recorded as weld 3 in the work package. This error was identified by a second welder who noted that although the work package indicated that weld 3 had been performed, weld 4 had actually been done. The weld map explicitly identified each weld

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L' and direction of flow. The work package required ' weld fit up and alignment hold points for weld 3 by both-Quality Control (QC) and Quality Assurance (QA)- Both-hold points had been signed.off as

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acceptable prior .to identification by the second welde i Piping' design table references were not updated to reflect changes resulting from recording the wrong weld data'on the wrong page until 2 days after the error was mad Review of the work and. associated procedures. revealed that piping system capability would not be compromise Although both QC and QA had required hcid points for weld 3, neither QC nor QA had noted that the welder was working on the wrong wel The licensee's Quality Assurance Manual Procedure (QP) 10-51,

" Inspection for Operations - Maintenance," requires that quality control surveillance of in process welding. include inspection of fitup. Also, QP 18-52, " Audit and Surveillance of Maintenance, Spare Parts and. Inservice Inspection Activities," also requires that 1 QA personnel review QC performance of inspection point !

10 CFR 50, Appendix B, Criterion V requires that the licensee follow l procedures which govern activities affecting quality. Contrary to !

this, the' licensee failed to comply with QP 10-51 and 18-52, in that I on February 25, 1989, weld 4 as specified in work request Z 78896 was performed and erroneously recorded as weld 3, and this error was signed off as acceptable by both QC and QA. Failure to identify

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this errcr is considered to be a violation. (295/89008-03). i

The licensee subsequently identified that the prefabricated pipe section was 1 and 1/2 inches too short for field. installation. Due j to the length of time required to modify the existing prefabricated !

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pipe assembly, the licensee opted to fabricate and install another assembly, Both work requests Z 78368 and Z 79318 requested repair of the i cooling water relief valve, 1 FWD 186 for the Unit 1 turbine driven ;

auxiliary feedwater pump (TDAFP). 1FW0186 is installed in the line !

which directs a portion of TDAFP flow back to the pump suction and l is set to relieve to the pump bed plate at a nominal lift pressure !

of 125 psi. Investigation revealed that 1FWO186 was relieving 3 whenever the TDAFP was running. The licensee replaced the relief i valve with a spare on March 2, 1989 under work request Z 7836 j Operators subsequently discovered that 1FW0186 was still lifting I with the TDAFP was running and work request Z 79318 was initiate !

Investigations revealed that the pressure reducing orifice j immediately upstream of the relief valve was also leaking. The '

licensee disassembled the orifice and checked the setting of IFW0186 l under work request Z 79318. It also adjusted the pressure control i valve IPCV-FW541 under work request Z 79600. This work was I completed on March 16, 198 l

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• On March 20, 1989, the licensee notified the inspector that_despite performance of the above mentioned work requests, 1FW0186 continued to_ relieve with the TDAFP was running. Members of the technical- 3 staff' stated that discrepancies between the piping specifications, 1

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associated drawings and installed piping for the TDAFP cooling water system on both units might be a contributor to the constant lifting of 1FWO186. Review and resolution of these discrepancies is considered to be an_ Unresolved item (295/89008-04; 304/89008-02).

Following completion of maintenance on the auxiliary feedwater system and the Unit 1 control . rod position indicator line voltage regulator, the inspector verified that these systems had been returned to service'

properl One violation, two unresolved items and no deviations were identifie . Licensee Event Reports (LERs) Followup (92700)

Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine that deportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had been accomplished'in accordance with Technical Specifications. The LERs listed below are considered-closed:

UNIT 2 LER N DESCRIPTION 88011' Second Level Undervoltage Contact Not Wired Per Drawing In 480 Volt Transformer Breaker

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Regarding LER 304/88011, second level undervoltage contact not wired per the drawing, this condition was reviewed in NRC Inspection Report 295/89004;304/89004 and was the subject of two violations for post modification and periodic testing. This LER is therefore considered close No violations or deviations were identifie . Quality Program Effectiveness The inspector noted that although valve 1 SOV PR-250 was identified as requiring new parts to reduce seat leakage in April, 1988, the appropriate purchase order was not processed until January, 1989. 1 SOV PR-25D is a containment isolation valve which delayed unit startup following the Unit I shutdown on January 27, 1989. The delay appears to stem from a failure to verify that appropriate valve parts had been ordered. A similar incident of untimely ordering of parts for deficient pressure isolation check valves occurred in 1986. Commonwealth Edison is investigating purchasing practices from a corporate standpoint; however, a review at the station level may also be neede = - - _ _ - _ _ _ _

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3-i The inspectors also note that repairs to the TDAFP cooling water relief valve have not identified why IFW0186 lifts whenever the pump is ru It appears that.the licensee has failed to identify and correct this problem during earlier cycles. The inspector will continue to follow the licensee's progress and diagnosis for this proble The inspectors have identified two instances where deficiencies in mechanical maintenance procedures were not identified prior to us These were the procedure for maintenance on Copes-Vulcan air-operated valves (See paragraph 7) and the procedure for maintenance on Limitorque operators (See Inspection Report Nos. 295/87031; 304/87032 paragraph 6).

Although the licensee has mockups of various plant equipment used for MM training purposes and MM personnel with pertinent experience, these

. resources are not effectively used in procedure preparation or validatio No violations or deviations were ider.tifie . February 22, 1989 Site Visit By Occupational Health and Safety Administration (OSHA)

On February-22, 1989, five members of the Safety Branch, OSHA Office of Training and Education, toured the Zion Nuclear Power Plant. The purpose-of the tour was to familiarize OSHA staff instructors with nuclear power plant facilities to aid them in preparing training lesson plans and materials for NRC personne The OSHA staff toured portions of the turbine and auxiliary buildings and were escorted by the RIO staf . February 27 - March 10, 1989 Site Inspection By Institute for Nuclear

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Power Operations (INPO)

On February 27, 1989, a two week INPO team visit began, covering the areas of maintenance, operations, training, radiation protection, plant material condition, corrective actions, and SOER response Mr. J. Bishop is the team leade . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance or deviations. Two Unresolved Items disclosed during this inspection are discussed in paragraph . Exit Interview (30703)

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

throughout the inspection period and at the conclusion of the inspection on March 23, 1989, to summarize the scope and findings of the inspection '

activitie The licensee acknowledged the inspectors' comments. The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not identify any such documents or processes as proprietar .

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ATTACHMENT 1

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. DRS ITEMS T0 BE. CLOSED Report N Item Type-295/81011-02' Unresolved .

295/84021-03 Violation (4)

295/85002-03 Open-295/85002-04 -Open 295/85002-05 Open s 295/85011-01 Open 295/85011-02 Open 295/85016-03 Open 295/85032-01 Open

.295/85032-04 Open 295/85043-01 Unresolved 295/86016-02 Open 295/86016-03 Open 295/86030-02 Open-295/87008-LL LER 295/87011-02 'Open 295/87011-03. Open 295/87019-01- Open 295/87038-02' Violation (5)

295/88010-01 Violation (5)

295/86010-02 : Violation (4)

.304/81007-02 Unresolved 304/84020-01 Unresolved ~

304/84022-03 Violation (4)

. 304/85002-03 Open 304/85002-04 Open

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304/85002-05 Open 304/85006-0 Open 304/85012-01 Open 304/85012-02 Open 304/85015-02 -Open 304/85015-03 Open 304/85033-01 Open-304/85033-04 Unresolved 304/85044-01 Unresolved 304/86015-02 Open 304/86015-03 Open 304/86022-02 Open 304/86030-02 Open 304/86031-02 Unresolved

'304/87008-01 Open 304/87014-0 Open 304/87014-03 Open 304/87021-02 Open -

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304/87039-02 Violation (5).

I 304/88011-01 Violation (5)

304/88011-02 Violation (4)

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1* ATTACHMENT 2 DRP ITEMS TO BE CLOSED Report N Item Type 295/84025-04 Open

- 295/85002-02 -Unresolved 295/85028-01. Open 295/85028-02 Open 295/85028-03- Open-295/85036-03 Open-295/86005-94 Open 295/86005-06 Open 295/86013-02 Open 295/86022-04 Open 295/87003-01 Open 295/87003-02 :Open 295/87006-01 Open 295/87006-04 Open 295/87015-01 Violation (4)

295/87015-06- Unresolved

. 295/87015-08 Open 295/87036-01 -Open 295/87036-02 ~Open

. 295/88012 01 . Violation (4)

295/88012-02 ~ Unresolved 295/88019-03- Open 295/88019-07 Violation (4)

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304/85002-02 Unresolved 304/85019-02 Open

- 304/85029-01 :Open 304/85029-02- Open 304/85038-04 Open 304/86005-03 Open 304/86005-05 Open 304/86012-03 Open 304/86020-04 Unresolved

- 304/86020-05 Open 304/86020-06 Open 304/87003-01 Open 304/87003-02 Open 304/87007-03 Open 304/87016-01- Violation (4)

304/87018-01 Violation (4)

304/87027-01 Open 304/87037-01 Open 304/87037-02 Open 304/88013-01 Violation (4)

304/88019-05 Open 304/88019-10 Violation (4',

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