IR 05000295/1989039
| ML20006E339 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 02/07/1990 |
| From: | Beverly Clayton NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20006E336 | List: |
| References | |
| 50-295-89-39, 50-304-89-35, GL-87-06, GL-87-6, IEIN-89-051, IEIN-89-51, NUDOCS 9002220701 | |
| Download: ML20006E339 (17) | |
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U.S. NUCLEAR REGULATORY COMMISSION l
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REGION III
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Report Nos. 50-295/89039(DRP);50-304/89035(DRP)
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Docket Nos. 50-295; 50-304 License Nos. DPR-39; DPR-48
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Licensee: Commonwealth Edison Company P. O. Box 167 i
Chicago, IL-60690 l
Facility Name: Zion Nuclear Power Station, Units 1 and 2
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i Inspection At:- Zion, IL
Inspection Conducted: December 1, 1989 through January 15, 1990 f
Inspectors:
1, D. Smith R. J. Leemon A. M. Bongiovanni
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Approved By: / Brent Clay n,' Chief e V7/.9
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t Reactor Projects Section IA Date l
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Inspection Summary
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Inspection from December 1.1989 through January 15,.1990(ReportNos.
50-295/89039(DRP): 50-304/89035(DRF))
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Areas Inspected:- Routine, unannounced resident inspection of licensee action f
.on previous inspection findings: Information Notice 89-51, " Potential Loss of Required Shutdown Margin During Refueling Operation " and Generic Letter 87-06, " Periodic Verification of Leak Tight Integrity of Pressure Isolation
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- Valves"; summary (ESF) peration; operational safety verification and engineered of-o
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safety feature system walkdown: Unit 1 seal leaks in 'ncore
. instrumentation thermocouples, Unit One 20 gpm reactor coolant system leak, Unit 1 low forebay level, Unit 2 reactor coolant system leak, and cold weather preparations; surveillance observation: type B and C leak rate testing and q
OB fire pump failure; maintenance observation: Unit 2 delta T and-T average switches in the wrong position, Unit 2 automatic rod insertion, Unit 1 leaking conoseals, and emergency diesel generator failures; engineering and technical support: undersized auxiliary feedwater valve motor operators, procurement /
vendor interface inspection, and followup on modifit.ation testing; safety
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verification and quality assurance: emeroency diesel generator testing frequencies; temporary instructions: TI2815/101 " Loss of Decay Heat Removal" i
and TI2515/104 " Fitness-for-Duty"; training.
-l Results: Of the 10 areas inspected, no violations or deviations were
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Identified. The licensee is requested to respond to the open item identified i
9002220701 900D07 N
PDR ADOCK 05000295
O-PNU
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in paragraph 2b concerning the implementation of their response to Generic Letter 87-06.
The inspection disclosed weaknesses in the licensee's corrective action program as evidenced by continued back leakage in the Unit
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2 safety injection system. Twoexamplesofinstrumentmechanic(IM) error:
the first when poor IM shift turnover failed to return the Unit 2 Delta 7 and r
T-avg switches to the normal position end the second when an IM selected the wrong voltage meter scale.
There was also inadequate design of AFW valve notor operator spring packs and informal guidance on meeting commitnents to a
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1980 Confirmatory Order. The inspection noted strengths in the station
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efforts to improve the procurenent program which the special team stated would probably correct most of the identified weaknesses. Also, after a trip at Quad Cities the licensee on their own initiative verified that similar
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problems did not exist at Zion.
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DETAILS 1.
Persons Contacted
- T. Joyce, Station Manager
- T. Rieck, Superintendent, Services
- W. Kurth, Superintendent, Production
- P. LeBlond, Assistant Station Superintendent, Operations
- R. Johnson, Assistant Station Superintendent, Maintenance
- J. LaFontaine, Assistant Station Superintendent, Planning N. Valos, Unit 2 Operating Engineer W. Deno, Unit 1 Operating Engineer M. Carnahan, Unit 1 Operating Engineer E. Broccolo, Jr., Director of Performance Improvement
- E. Fuerst, Project Manager, ENC T. Vandevoort, Quality Assurance Supervisor C. Schultz, Quality Control Supervisor W. Stone, Regulatory Assurance Supervisor W. T'Niemi Technical Staff Supervisor
- T. Saksefski, Regulatory Assurance
- Indicates persons present at the exit interview.
The inspectors also contacted other licensee personnel including members of the operating, nintenance, security, and engineering staff.
2.
Licensee Actions on Previous Inspection Findings (92701. 92702)
a.
Information Notice 89-51, " Potential Loss of Required Shutdown Margin During Refueling Operation." The resident staff assessed the licensee's evaluation of the concerns raised in this information notice. The licensee's response was adequate, b.
Generic Letter 87-06, " Periodic Verification of Leak Tight Integrity of Pressure Isolation Yalves." On June 11, 1987, the licensee responded to Generic Letter No. 87-06 stating that, "all potentially leaking (pressure isolation) valves were repaired to prevent overpressurization of the lower pressure system and consequently lifting the relief valves." The NRC inspection during September through October 1987 found that two pressure isolation valves were leaking and lifting the relief valves on a lower pressure system since mid 1986 on Unit 2.
Presently, there appears to be back leakage through the check valves on the Unit 2 safety injection system which is pressurizing the safety injection header to approximately 1200 psig.
This discrepancy from the commitment
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stated in the licensee's June 11, 1987 response is considered an l
OpenItem(295/89039-01(DRP);304/89035-01(DRP)).
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Summary of Operations:
Unit 1 The unit entered this reporting period in cold shutdown for the
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continuation of the scheduled refueling outage.
The unit left cold i
shutdown and entered hot shutdown on December 16, 1989. Routine i
surveillance tests and a containment tour were conducted in preparation l
for returning the unit on line. On December 19, the unit returned to
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cold shutdown to repair leaks from the reactor vessel head incore instrumentation conoseals. The unit was taken back to hot shutdown l
on January 1,1990. On January 3,1990, an unidentified leak of
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approximately 20 gpm developed. The leak was determined to be from a j
residual heat removal hot leg suction valve. The licensee took the
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plant to cold shutdown to repack the leaking valve. On January 10, J
the unit was placed in mode 7 to conduct required physics testing.
On January 15 at approximately 4:30 a.m., the reactor was taken critical l
for returning the unit on line.
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Unit 2
On December 1,1989, an unusual event was declared due to reactor coolant system (RCS) leakage of 4.0 gpm. The loop D cold leg sample valve had a
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body-to-bonnet leak. The unit was placed in hot standby to resair the i
cold leg sample valve and repack a pressurizer spray valve. 71e unit was returned on line on December 4, and continued operation at approximately 100% power for most of the inspection aeriod. On January 10, 1990, the
licensee noted an increased trend in t1e concentrations of chlorides and
sulfates as detected from the steam generator blowdown samples. On
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Janaary 15, in accordance with abnormal operating procedures, power was
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reduced to 40% to bring the sulfate concentration within vendor speci-fications limits for steam generator secondary chemistry.
Operational Safety Verification and Engineered Safety Features System Walkdown (71707 5 71710)
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The inspectors observed control room operations, reviewed applicable
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logs and conducted discussions with control room operators from
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December 1,1989 through January 15, 1990.
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
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verified the operability of selected emergency systems, reviewed tagout records and verified proper return to service of affected components.
Tours of the Unit I containment, spent fuel pool area, crib house, 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.
l The inspectors by observation and direct interview verified that selected
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physical security activities were being implemented in accordance with j
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The inspectors observen plant housekeeping / cleanliness conditions and i
verified implementatiot, of radiation protection controls. From i
December 1,1989 to January 15, 1990, the inspectors walked down the
accessible portions of the safety injection system, diesel generators,
Unit I containment, battery rooms, service water system, component
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cooling system, and auxiliary feedwater systems to verify operability.
The inspectors also witnessed portions of the radioactive waste system
controls associated with radwaste shipments and barreling.
l These reviews and observations were conducted to verify that facility
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operations were in conformance with the requirements established under l
Technical Specifications, 10 CFR, and administrative procedures.
j a.
Unit 1 Seal Leaks in Incore Instrumentation Thermocouples
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On December 18, 1989, the unit was placed in cold shutdown to repair three leaks in two incore instrumentation thennoccuple seals. This is discussed in the maintenance section of this report, paragraph 6.c.
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b.
Unit One 20 GPM Reactor Coolant System Leak At 10:00 p.m. on January 3,1990, a RCS leak of approximately 20 gpm developed on Unit 1, which was in hot shutdown at the time.
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A containment entry was made and it was determined that the residual heat removal (RHR) hot leg suction valve was the major source of the leakage. The packing on the RHR valve was tightened, however, the leakage continued. The plant was taken to cold
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shutdown to repack the RHR valve.
This valve had been repacked by i
contractor personnel during the refueling outage. The cause of
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the leakage was due to the valve stem not being centered in the stuffing box when it was re)acked. On January 4, the valve was back seated which stopped tae leak. The valve was repacked and successfully (leak tested.DRp)) pending review of the licensee's root cause This is considered an Open Item (295/89039-02 determination.
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c.
Unit 1 Containment Close Out Inspection
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The resident staff, accompanied by the Ifeensee, performed a containment close out inspection to verify the position of containment isolation valves and general material conditions of the containment.
The inspectors noted some debris and loose parts which were promptly removed from containment by the licensee.
The inspectors were well satisfied with the containment status for the close out inspection.
d.
Unit 1 Low Forebay Level On January 8 1990, with the IC circulating water (CW) pump running, onadditionalCWpump(18)wasstartedandacribhouseforebay low-level water alarm was received. The 18 and IC CW pump discharge valves were throttled and the forebay water level was recovered.
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Investigation by a diver revealed that a 10 ft by 20 ft, fishing
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net was blocking some of the flow into the intake structure out in
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the lake, it was also believed that the intake structure had some
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frazzle ice buildup which could have also caused some of the flow
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blackage. The diver removed the net and the operations department
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started conducting ice melting operations of the circulating water system. This appeared to clear the blockage as evidenced by the i
forebay water level remaining constant when the IB and IC CW pump
discharge valves were opened fully.
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Unit Two 1 GPM Reactor Coolant System Leak j_
On December 1, 1989, at 6:45 a.m. an unusual event was declared
due to a reactor coolant system (RCS) leakage greater than 1 gpm i
on Unit 2.
The unit was placed in hot shutdown.
Investi showed that the air operated loop cold leg sample valve, gation
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A0V 25S-93580, had body-to-bonnet leakage. The leak was stopped
by isolating the manual valves for the Loop D hot leg and cold
leg sample lines and the unusual event was terminated. The packing
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was replaced on the Loop D cold leg sample valve. While the unit was off-line the following additional repairs were made:
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packing was replaced on the pressurizer spray valve RC007, the
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steam flow transmitter 2FT512 was recalibrated, and the 2B EDG I
local air start controller which failed during EDG testing was repaired. After the above repairs were completed, the unit was
placed back on line at 2:30 a.m. on December 4, 1989.
During the evolution, the main turbine failed to trip manually
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using the control room turbine trip pushbuttons.
The turbine was
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tripped locally at the turbine pedestal. The trip pushbutton~
cable and coil were checked satisfactory for continuity and the i
trip mechanism was cleaned. The failure could not be duplicated.
f.
Low Battery Electrolyte Level i
During a tour of Battery 211 room, the inspectors noted that the i
electrolyte level for one battery cell was approximately one-eighth i
inch low. Two additional cells were also observed to be low.
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tech staff engineer was notified and verified that the electrolyte level was adequate for battery operability.
The electrolyte levels for the other batteries were verified to be satisfactory.
Discussions with the cognizant technical staff engineer indicated that the electrolyte levels were checked monthly; however, the ems t-are not instructed to increase the levels until the level is below the vendor recommended level The resident staff will continue to monitor the surveillance program for the station batteries. This is considered an Open Item (295/89039-03(DRP);304/89035-02(DRP)).
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Fitness-for-Duty Commitments by the Licensee in a letter to the Office of Nuclear Reactor Regulation dated January 3, 1990, Corporate Commonwealth Edison stated that their Fitness-for-Duty (FFD) Program met the requirements in 10 CFR Part 26 and was fully implemented on January 3,1990 at the Zion Station. The residents reviewed this program in paragraph 9.b.
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h.
Cold Weather Preparation (71714)
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The inspectors reviewed the licensee's program of protective measures for extrene cold weather to which the licensee committed in response to IE Bulletin 79-24 j
The inspectors verified that the licensee inspected systems s9sceptible to freezing and ensured the presence of heat tracing, j
space heaters, and/or insulation; the proper setting of thermostats;
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and that the heat tracing and space heating circuits have been
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energized. The licensee has inspected systems which have been subjected to maintenance and/or modification during the past year to determine-if cold weather protective measures have been reestablished. The inspectors had no concerns.
5.
Monthly Surveillance Observation (61726)
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The inspector observed Technical Specifications required surveillance I
testing on the safeguards, auxiliary feedwater, containment spray, and
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diesel generators systems, and nuclear physics surveillance testing.
The inspector verified whether testing was performed in accordance
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With adequate procedures, whether test instrunentation was calibrated, whether limiting conditions for operation were met, whether removal and restoration of the affected components were accomplished, whether test results conformed with technical specifications and procedure requirements and were reviewed by personnel other than the individual directing the test, and whether any deficiencies identified during the testing were properly reviewed ana resolved by appropriate management
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personnel.
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The inspector also witnessed portions of the following test activities:
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PT-10 Safeguards Actuation, Unit 1 PT-20 Centrifugal Charging and Letdown System Power Operated Valve Tests
PT-7B Auxiliary feedwater Pump Service Water Valves
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Operability Checks PT-3C Penetration Pressurization Test TSS 15.6.10f Type B Leak Rate Tests i
TSS 15.6.10e Type C Leak Rate Tests PT-6 Containment Spray System Tests and Checks PT 40-23 Valve Remote Position Indication Verification TSS 15.6.43-1 Endurance Testing of Diesel Generators During Refueling
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TSS 15.6.51 Zero Power Physics Measurements following Refueling TSS 15.6.52 Initial Criticality After Refueling and Nuclear Heating
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Level I
GOP-2 Plant Startup
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The inspectors noted the following observations:
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Type B and C Leak Rate Testing l
The licensee performed testing to determine the 10 CFR 50 Appendix
J Type B and C leak rates for Unit 1.
The as-found leakage was t
approximately 220 standard cubic feet per hour (SCFH) and the
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as-lef t leakage was approximately 52 SCFH. The leakage limit is
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285 SCFH; therefore, the as-found and as-left leakagea were
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acceptable.
b.
OB Fire Pump Failure
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On November 29, 1989, the center desk NSO noticed that the trip
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annunciator for OB fire pump was lit with the pump running, and that the fire header pressure was dropping. An operator at the fire pump observed decreasing rpms on the diesel fire pump and shut down the ) ump locally. Subsequent investigation found that the diesel tur>o-charger had failed.
No violations or deviations were identified.
6.
Monthly Maintenance Observation (6270j
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Station maintenance activities on safety related systems and components were observed or r~'iewed to ascertain whether they were conducted in
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accordance with amoved 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 and materials; radiological and fire prevention controls.
In addition, work requests were reviewed to determine status of outstanding jobs and to assure that priority is assigned to equipment maintenance which may affect safety performance.
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Technical Specifications required surveillance testing on the reactor -
ventilation and containment isolation systems were reviewed or observed.
Consideration was given to: procedures; calibration of test instrumentation; 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
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the test; and correction of any deficiencies identified during the
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testing. pT-21, " Reactor Coolant System Leakage Surveillance" was i
reviewed and no problems were noted.
j To110 wing completion of maintenance, the inspector verified that these systems had been returned to service properly.
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a.
Unit 2 Delta T and T-avo Switches in the Wrong Position l
On December 20, 1989 at 7:15 a.m., the Unit 2 operator questioned the status of the loop B delta T and T-avg switches which were
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in the defeat position. No bistables were tripped; however, i
loop calibration stickers were placed on the loop B delta T,
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overtemperature delta T and overpressure delta T meters.
InvestigationsindicatedthattheInstrumentNechanics(IM)had
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started work on the delta T deviation annunciator alarm and were
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investigating loop B earlier on December 19. At approximately i
~3:00 p.m., the dayshift IM crew turned over the work to the
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nightshift and noted that second verifications for system realign-
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ment needed te be completed prior to exiting the procedure.
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second verifications were not completed during the following two
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shifts. The root cause of the incident appeared to be poor turnover
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from the IM crew. The inspectors reviewed applicable electrical
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and logic diagrams and verified that the input to the protective functions was not impacted by the incorrect positioning of the switches.
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b.
Unit 2 Automatic Rod Insertion On December 20,1989, at 10:50 a.m., the Unit 2 control rod bank D l
rods inserted at 72 steps / min due to a large temperature mismatch signal in the rod control system.
The operator responded immediately and placed the rods in manual control which terminated the transient.
Rods stepped in a total of seven steps.
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that while troubleshooting the T-avg deviation annunciator alarm
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the-lMs attempted to take a voltage measurement with a differentia 1 i
volt meter (DVM) set to the resistance scale. This resulted in an
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induced load being placed into the reactor coolaa. temperature circuitry which caused a 'alse auctioneered high temperature signal to the rod control logic system.
The causes of the event appeared to be personnel error in that the incorrect scale was selected for the DVM and procedural inadequacy, in that the operator was not directed to place the rods in manual prior to the troubleshooting
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activities.
The effect of the transient was minimal.
The reactor coolant system temperature dropped less than or.e-half degree F and was quickly restored to normal. The shift engineer instructed the unit operator to place the rods in manual during the subsequent IM
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troubleshooting.
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The licensee will be evaluating all IM procedures affecting automatic rod control. This is considered an Open Item (304/89035-03(DRP)) pending review of the licensee's corrective actions and procedure review, c.
Unit 1 Leaking Conoseals During a scheduled containment walkdown of the primary systems on December 16, 1989 by the Inservice Inspection Group, a small leak was discovered on the reactor head instrumentation column seal (conoseal). Mechanical Maintenance attempted to stop the leak by using a hot retorquing method; however, the attemat was unsuccessful. The leakage was a small bubbling at tie upper and lower seal on one column and at the lower seal on a second. The leak rate was approximately one drop every ten seconds; however, based on concerns of boric acid leakage onto the reactor head and possible further damage to the column if the leak was allowed to
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continue, a decision was made to repair the leaks at that time.-
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required for the repairs. The reactor coolant level was lowered to allow disassembly of the instrumentation columns.
- The conoseals were replaced. Minor scratches.on the conoseal rings appeared to be the cause of the leaks. The unit was returned to hot slutdown and it was verified that the conoseal leaks were repaired.
The reactor vessel head was inspected for possible corrosion damage
from boric acid build up and none was found, d.
28 EDG Fails to Stop with Control Room Switch On December 3, 1989, during testing, the local operator attempted to stop the 2B EDG with the emergency stop push button with no success.
Investigations indicated that the manual start valve seal had lost its resiliency. Engine vibration then caused the manual start valve i
to partially open which overrode the stop signal from the control room control switch. The EDG was stopped by closing the starting
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air manual isolation valve.
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The manual start valve was re>1 aced and the EDG was tested satisf actory. The seals on t1e manual start valves for the remaining EDGs were inspected, No problems were identified.
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IB EDG Major Oil Leak On December 11, 1989, the IB EDG was stopped due to a fuel oil leak through the gasket on the fuel oil strainer.
The EDG was being tested following maintenance which included cleaning the oil
strainer when the leak occurred. The diesel was stopped, the oil cleaned up from the floor, and the "0" ring was replaced.
The diesel generator was then tested satisfactory.
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IA EDG High Bearino Temperature Trip
On December 27, 1989, the 1A EDG tripped from high bearing temperature. An investigation revealed that one of the two bearing
temperature _fuseable links on the number two main bearing had failed. The bearing was inspected, showed minor wear, and was
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conservatively replaced. The temperature fuseable link sensors were removed and replaced for all main bearings.
The removed sensors were tested to determine the fuseable temperature and all were within two degrees of their actuation temperature.
It was believed that this was 4 random failure of the fuseable link.
The EDG PT-11 " Diesel Generator Loading Test," was completed on
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December 31, 1989 and the EDG was returned to service.
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2A Diesel Inoperable Due to Aircraft Crash System Alarms On January 4,1990, the 2A EDG was declared inoperable due to the j
inability to reset the aircraft crash system after being in the
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alarm state for one hour. The electrical maintenance personnel
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were able to clear the alarm by balancing the detector circuits.
Following verification that the aircraft crash system was operable, the 2A EDG was returned to operable status.
No violations or deviations were identified.
7.
Engineering and Technical Support (71707)
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a.
Undersized Auxiliary Feedwater Valve Motor Operators During the refueling outage, the auxiliary feedwater (AFW) flow control valves and motor operators were replaced. During testing, one of eight valves would not fully close.
The licensee's investigation revealed that the motor operated valve (MOV) spring packs were designed for closure against a differential pressure of approximately 1085 psig. The pumps developed approximately 1550 psig discharge pressure.
The MOV spring packs were incorrectly sized which prevented setting of the torque switches for the t
operating differential pressure.
The replaced s) ring pack generated a maximum of approximately 135 ft lbs torque. T1e operating condition requires approximately 165 ft lbs torque to be generated from the spring pack; therefore requiring a spring pack of greater capacity. The spring packs that were provided in the motor operators were based on valve conditions given to Limitorque by I-the Anchor Darling Valve Company in the early 1980s.
ThisisconsideredanUnresolveditem(295/89039-04(DRP))pending j
review by NRC regional inspectors.
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Procurement Vendor Interface Inspections A special inspection of the licensee's procurement program was conducted from November 30 through December 8,1989. Specifically, the activities examined were:
commercial grade dedications, vendor
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l interfaces 10 CFR 50 Appendix B procurements, and vendor Quality
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Assurance audits.
Thirty concerns were identified, four of which were operability
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issues: diesel generator small bore tubing fretting, snubber clevis
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pin material substitution, commercial grade relays installed in
the Reactor Protection System and material substitution cf safety related motor bearings.
The licensee has aggressively addressed and resolved the operability issues.
There were nine procurement programmatic deficiencies:
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receipt inspections, reliance on certifications of conformance for
parts before performing an 18-point audit, lack of traceability for r
commercial grade parts, limited use of single failure criteria, lack of formal periodic vendor contact, critical characteristics of parts not identified EQ components not on EQ listings, extensive reliance on Vendor past performance and, finally, a lack of a formalized
parts testing program.. The team did recognize the Station's efforts
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to improve Zion's procurement program and stated the proposed revisions to administrative procedures would correct most, if not
all, weaknesses identified.
c.
Licensee's Followup on Modification Testing Upon notification that a reactor trip had occurred at Quad Cities due to a problem resulting from a vendor-designed detailed control roomdesignreview(DCRDR)modificationtotheannunciatorsystem, the licensee initiated actions to verify that similar problems did not exist at Zion. An evaluation of the DCRDR modifications designed by the same vendor resulted in the cenclusion that only two modifications had circumstances which could have resulted in problems similar to Quad Cities.
The two modifications with Field Change Requests (FCRs), were walked down to perform wiring verifications.
Three other modifications with FCRs performed by.
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another vendor also had wiring verification checks performed. The licensee concluded that all five modifications were correctly installed and that the potential to result in a challenge to the operability of major plant equipment similar to toe Quad Cities incident did not exist.
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_ Safety Verification and Quality Assurance (SV/QA) (71707)
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EDG Testing Frequencies i
The inspectors reviewed the logs to determine if all required surveillances for the emergency diesel generators (EDG) were performed. Discussions with the technical staff indicated that the completion of the EDG start log was based on an informal instruction, " Instructions for Logging Zion Diesel Generator Engine Starts," written by the technical staff for the operations staff.
Each EDG start including post maintenance testing starts were to
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be logged.
if an EDG failed the surveillance, the operators were
instructed to conservatively declare the test a valid failure and increase the testing frequency accordingly. The technical staff would then evaluate whether the failure was valid according to the guidelines of Regulatory Guide 1.108, " Periodic Testing of Diesel Generator Units used as Onsite Electric Power Systems at Nuclear Power Plants" The inspectors made the following observations:
(1) Confirmatory Order dated Pebruary 29 1980 states, in part,
that EDG testing shall be performed In acco,rdance with
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Regulatory Guide 1.108 with a corresponding change in the
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allowable outage time as stipulated in the Order.
(2) EDG 1A and 0 failed their surveillances on Ncvember 17 and 22,
1989, respectively. Neither of these failures were entered i
into the start log; therefore, the log did not reflect an increased testing frequency when Unit 1 incurred the second-
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failure. However, the surveillances were not required since the unit was in the cold shutdown mode during this period.
(3) The log for Unit 2 did not include the failure of the EDG 0 on November 22, 1989; therefore, the total number of failures was incorrect.
No surveillances were missed; however, since
the EDGs were tested daily in accordance with TS 3.15.2.0 due
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to the inoperability of EDG 0.
The inspectors were concerned that while no surveillances were
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missed, the potential existed to violate the testing requirements described in Regulatory Guide 1.108 as implemented by the
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Confirmatory Order. The licensee issued a Night Order inctructing the operators to follow the EDG start instruction until a more formal process is developed. This is considered an Open Item
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(295/89039-05(DRP);304/89035-04(DRP))pendingthereviewofthe licensee's corrective actions.
g No violations or deviation were identified.
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. Temporary Instrisc* ion 2515/101 Loss of Decay Heat Renoval
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The purpose of this temporary instruction was to assure that o
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actions to prevent and, if necessary, respond to a loss of decay heat removal (DHR) #uring operations with the reactor coolant
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system (RCS) partially drained were implemented in accordance
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yith Generic Letter t18-17, " Loss of Decay Heat Removal." This T! addresses the st. ort-term licensee program entitled " expeditious
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actions."
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The ins)ector reviewed the licensee's response, a letter from i
R. A. 01rzanowski, CECO Nuclear Licensing Administrator, to Dr. T. E.-Murley, Director of Office of Nuclear Reactor Regulation, dated December 30, 1988.
i The inspector reviewed the following documents:
AOP 6.3 Loss of RHR Shutdown Cooling
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LO-TAA-5b Mid Loop Operations
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Mi-1 Draining the Reactor Coolant System for Refueling or Maintenance
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M1-ID Draining and Filling a Single Reactor Coolant Loop Mi-1E Isolating and Draining the Reactor Coolant Loops
MI-1G Draining the Reactor Coolant System for Integrated Leak
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Rate Testing and then for Refueling MI-6 Filling and Draining the Refueling Cavity and Draining the Fuel Transfer Canal
Mi-8 Containment Closure PT-0 Appendix E, Operating Surveillance Check
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The temporary instruction addressed the following concerns:
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(1). Discussions on the Diablo Canyon event of April 10, 1987, related events, and lessons learned, and training prior to entering rc.Nced inventory conditions should be provided.
The inspector discussed the Diab k Caryon event with several licensed personnel and verified that t.he event, root causes
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and lessons learned were understood. The inspector reviewed
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the training material used during initial operator training
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and outage-related training prior to reduced inventory i
operations and>found them to be adequate.
(2) Procedures and administrative controls to reasonably assure that containment closure will be achieved prior ta the time core uncovery would occur in the event of a loss of DHR should be implemented.
The inspector reviewed applicable procedures and determined that the licensee had adequate control to close the contain-n:ent within two hours during intentional and unplanned reduced inventory conditions.
Discussions with the operating staff indicated that the operators were aware of the containment closure requirement and were trained on the procedures.
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e (3) At least two independent, continuous temperature indications f
representative of core exit conditions should be provided
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whenever the reactor is in a reduced inventory condition.
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Maintenance instructions and abnormal procedures pertaining to
reduced inventory conditions required at least two independent i
core exit thermocouples to be operable. The temperature indications are required to be monitored and docunented at 15 minute intervals.
i (4) Two independent, continuous RCS water level indications should be provided whenever the RCS is in a reduced inventory
condition.
Level indication is provided by a level recorder located in the control room and a sightglass located in containnent. The
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sightglass is part of the Refueling Vessel Level Systems (RVLS)
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modificationM22-1(2)-87-03 which was installed and declared r
operational for Unit 1 in february 1989. The system will be
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declared _ operational for Unit 2 during the upcoming outage
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prior to entering reduced inventory conditions.
The design, installation, and testing for Unit I were reviewed during a
revious NRC ins p(295/88003(DRS))pectionconductedinApril1988
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The inspector reviewed maintenance instructions and administrative procedures cnd verified that the level indiutors were compared every 15 minutes when in reduced
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inventory and that guidance including warning personnel in containment was provided if a discrepancy was identified.
(5) Procedures and administrative controls should be implemented
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to avoid operations that deliberately or knowingly lead to perturbations to the RCS while in reduced inventory.
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A statement has been added to the applicable maintenance
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instructions to avoid all operations that could lead to such perturbations. Any such operations must be preapproved by
the operations staff.
(6) At least two available or operable means of adding inventory
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to the RCS that are in addition to the normal DHR system
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should be provided.
Review of applicable procedures indicated that one charging pump with an operational flow path and a gravity feed path via the RWST to cold leg A must be operable prior to reducing RCS inventory.
Steps are included to verify that an adequate vent path is provided to prevent pressurizations which would disable the gravity feed.
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(7&B)Proceduresandadministrativecontrolsshouldbeimplemented l
that reasonably assure that all hot legs are not blocked
simultaneously using nozzle dams or by closing loop stop valves
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enless a vent path is provided.
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The RCS is equipped with loop stop valves. The inspector
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verified that 1)rocedures to properly isolate a loop were provided and that vent paths were required prior to reduced inventory conditions.
The inspector had no concerns. This Tl is considered closed, b.
Temorary Instruction 2515/104, Fitness-for-Duty On December 15, 1989, the resident staff completed Temporary l
Instruction 2515/104, Fitness-for-Duty (FFD) Inspection of Initial
Training Programs.
The program appeared to meet the following
objectives:
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ffD policy awareness training, i
FFD training for supervisors, and FF0 escort training The licensee's program appeared to meet the requirements of the Fitness-for-Duty rule. T11s TI is considered closed.
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10. Training (41400)
During the inspection period, the inspectors reviewed abnormal events and unusual occurrences which may have resulted, in part, from training deficiencies.
Selected events were evaluated to determine whether the classroom, simulator, or on-the-job training received before the event was sufficient to have either prevented the occurrence or to have mitigated its effects by recognition and proper operator action.
Personnel qualifications were also evaluated.
In addition, the inspectors determined whether lessons learned from the events were
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incorporated into the training program.
Events reviewed included the events discussed in this report.
In addition, LERs were routinely evaluated for training impact.
No events reviewed this period were found to have significant training deficiencies as contributors.
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Two training sessions on Fitness-for-Duty were attended by the resident inspectors.
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On January 12,four apparent violations concerning operator licensing.1990, a pertaining to This is discussed in a special inspection report (295/89040:304/89036)
and in an enforcement conference report (295/90002;304/90002).
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11. 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 both. Five Open Items disclosed
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during this inspection are discussed in paragraphs 2b, 4b, 4f, 6b, and i
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Unresolved Items
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Unresolved items are matters about which more information is required
in order to ascertain whether they are acceptable items, items of
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noncompliance or deviations.
One Unresolved items disclosed during this inspection is discussed in paragraph 7a.
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Exit Interview (30703)
On January 4 1990, the NRC presented the initial SALP 8 report to the i
licenseedurIngtheSALPmeetingheldattheZionsite, i
The inspectors also met with licensee representatives (denoted in Paragraph 1) throughout.the inspection period and at the conclusion
of the inspection on.lanuary 18, 1990, to summarize the scope and
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findings of the inspection activities.
The licensee acknowledged the inspectors' comments. The inspectors also discussed the likely informational content of the ins?ection report with regard to
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documents or processes reviewed ay the inspectors during the inspection. The licensee did not identify any such documents or t
processes as proprietary.
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