IR 05000295/1993002
| ML20034E851 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 02/19/1993 |
| From: | Dunlop A, Huber M, Jeffrey Jacobson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20034E845 | List: |
| References | |
| 50-295-93-02, 50-295-93-2, 50-304-93-02, 50-304-93-2, GL-89-04, GL-89-4, NUDOCS 9303020019 | |
| Download: ML20034E851 (9) | |
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U.-S.
NUCLEAR REGULATORY COMMISSION
REGION III
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Reports No. 50-295/93002(DRS); No. 50-304/93002(DRS)
l Docket Nos. 50-295; 50-304 License Nos. DPR-39; DPR-48 l
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l Licensee:
Commonwealth Edison Company Opus West III
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1400 Opus Place - Suite 300
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Downers Grove, IL 60515 Facility Name:
Zion Nuclear Power Station - Units 1 and 2
Inspection At:
Zion, IL Inspection Conductedt, January 19-29, 1993 i
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'e 2//9/73
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Inspectors:
A.
Dunlop
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M. Huber)
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1 2//9/93 Approved By:
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J. M. Jacpbsony Chfef Date Materials & Processes Section Inspection Summary Inspection conducted January 19-29, 1993 (Reports No.
50-295/93002(DRS); No. 50-304/93002(DRS))
Areas Inspected:
Announced safety issues inspection of the i
licensee's incorporation of Generic Letter (GL) 89-04, " Guidance
on developing acceptable Inservice Test Programs" into the Inservice Testing (IST) Program (TI 2515/114) and the licensee's program on check valves (TI 2515/110).
Results: The inspection disclosed one violation (Paragraph 2.b.(2)) concerning duration of pump testing and two unresolved items (Paragraphs 2.b.(1) and 3.d) concerning the use of
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reference curves for pump testing and not performing partial stroke testing of several safety injection valves on a quarterly basis.
Based on this inspection, TI 2515/114 and TI 2515/110'are considered closed.
The licensee demonstrated a strength in the following area:
The use of non-intrusive testing to establish baseline data
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for determining valve degradation.
9303020019 930219 PDR ADOCK 05000295 O
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TABLE OF CONTENTS
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Pace
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Persons Contacted.....................................
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2.
Inservice Testing of Pumps and Valves.................
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a.
Scope............................................
5 b.
Pump Testing.....................................
I (1)
Pump Reference Curves.......................
1 (2)' Duration of Tests...........................
l (3)' Evaluation of Test Results..................
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c.
Valve Testing....................................
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3.
Check Valve-Program...................................
'4 a.
Scope............................................
b.
Design. Application Review........................
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c.
Preventive Maintenance...........................
d.
Inservice Testing................................
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Non-Intrusive Testing............................
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Trending.........................................
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Unresolved Items......................................
5.
Exit Meeting..........................................
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DETAILS l
1 1.
Persons Contacted j
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Commonwealth Edison Company (CECO)
- T. Joyce, Station Manager
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Bump, Nuclear Quality Program Superintendent-l
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Wozniak, Technical Superintendent R. Chrzanowski, Technical Staff Supervisor
- C.
Schultz, Quality Control supervisor
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- K. Moser, Assistant Technical Staff Supervisor j
- J.
Madden, Assistant Technical Staff Supervisor
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Pigon, Engineering Support /EQ Group Lead
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Robey, Inservice Inspection Group-Leader j
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Yuen, Mechanical / Thermal Group Leader i
M. Burns, Primary Group Leader
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Stimac, Nuclear Licensing l
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Vega, Mechanical / Structural (M/S) Design Check valves
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Dietz, M/S Design
- D.
Zebrauskas, M/S Design IST i
A. Toy, Safety Injection System Engineer l
J. Marean, Auxiliary Feedwater System Engineer l
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- L.
Cook,-Inservice Testing Engineer l
- R. Sanchez, Check Valve Program Coordinator j
- K.
Dickerson, Regulatory Assurance l
M. Mason, Regulatory Assurance ll D.
Beutel, Technical Staff
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R. Whittier, Quality Verification U.
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Nuclear Regulatory Commission (NRC)
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- J.
Smith, Senior Resident Inspector
R.
Leemon, Resident Inspector j
- Denotes those personnel attending the exit meeting on j
January 29, 1993.
2.
Inservice Testina of Pumps and Valves
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The inspectors reviewed IST procedures and coupleted IST surveillances.
Generally, the methods used for the testing
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of pumps and valves were adequate.
The test frequencies and-
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acceptance criteria were specified and provisions were'made
for prompt operability determinations.
Areas reviewed are-l discussed below.
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Scope
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'l The scope of the licensee's IST Program appeared j
adequate.
Selected plant systems were reviewed to
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ensure'that the program scope was adequate.. Technical l
Specifications'(TS) and Emergency Operating Procedures
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f (EOPs) were also reviewed to evaluate the program I
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scope.
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l b.
Pumo Testina
f (1)
Pump Reference Curves The inservice test procedures-used for the
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auxiliary feedwater (AFW) pumps used reference l
curves to define acceptance criteria for flow and
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differential pressure (d/p),.which was not in
accordance ASME Section XI Code.
The Safety Evaluation Report (SER), dated June 4,. 1991, on
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the IST program stated that reference curves may
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not be equivalent to the ASME Section XI Code l
requirement for performance of IST for pumps and j
relief requests should be individually requested l
for each pump.
The licensee developed Pump
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Position-08 submitted to NRC on January 7, 1993, i
which stated reterence values would be established
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i with a tolerance band.
A review of this position
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l in test procedure PT-7A-ST, " Auxiliary Feedwater Pump A System Checks and Tests," indicated that t
the flow tolerance for the AFW pump was +30,
-20 gpm from the reference value.
The associated d/p acceptance criteria was then based on the pump
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curve for the reference flow and associated tolerances.
As such, the licensee was still using
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a portion of a pump curve and relief from the Code
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requirement that had not been requested as stated in the SER.
Test procedure PT-2A-ST, " Safety Injection System
l Tests," also included a tolerance on the flow l
reference value for the safety injection (SI)
i pump; however, no attempt was made to adjust the i
flow rate during the test to obtain the flow
reference value.
In this case, the d/p acceptance
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criteria was based only on the flow reference
value without taking into account the flow
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tolerances.
Tnis was based.on testing the pump on
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the flat part of the pump curve and as such, the
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d/p did not vary significantly over the flow
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range.
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Based on this inspection and in consultation with
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NRR, the use of reference curves for pump testing
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was not in accordance with the Code.
This is
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con _idered an unresolved item (50-295/93002-i
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01(DRS); 50-304/93002-01(DRS)) pending licensee actions to perform pump testing in accordance with
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the Code requirement or to submit a request of i
relief from the Code requirement.. This_ item i
should be evaluated for all pumps included in the-
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IST program.
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(2)
Duration of Tests
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Inservice test procedure PT-7A-ST, " Auxiliary Feedwater Pump A System Checks and Tests," dated October 20, 1992, did not contain the 5 minute
'I wait period after adjusting AFW flow to establish a reference flow prior to recording the required
measurements (eg. flow, d/p, and vibration) for
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pump testing.
The test procedure started the AFW-pump and required a 10 minute warmup period.
Subsequently flow was adjusted to_ establish a
reference flow and then the required measurements were taken immediately.
This sequence was
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observed during testing of the unit 2 turbine-driven AFW pump.
t IWP-3500, " Duration of Tests", requires that each pump shall be run at least 5 minutes under conditions as stable as the system permits, which
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in this case, would be the point at which the reference flow was established.
The measurements i
or observations of each of the quantities
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specified by the Code shall be measured at the end of that 5 minute period.
The licensee had I
interpreted the Code requirement that the pump
needed to be operating for a 5 minute period and incorporated the 10 wait time as a result of this interpretation.
However, operating the pump for
'i 10 minutes prior to establishing the required flow rate, would not be consistent with IWP-3500 as the system may not immediately stabilize after the flow rate was adjusted.
Failure to follow the requirements of ASME Section XI, IWP-3500, was considered a violation (50-295/93002-02(DRS); 50-304/93002-02(DRS)).
i (3)
Evaluation of Test Results During the performance of PT-7A-ST, several
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vibration readings were identified to the control
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room as being in the required action range.
Based
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was made not to declare the AFW pump inoperable, i
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equipment.
Prior to taking new data, it was-
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determined that.the operator had misread the
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vibration equipment and in fact, no data was in the required action range.
However, the decision i
not to declare the pump inoperable, when the test l
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data was found to be in the " Action Range,".was l
l-not consistent with GL 89-04, Attachment 1,
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Position 8, which states, in part, "as soon as the
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data is recognized as being within the Required
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Action Range for pumps the associated j
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component must be declared inoperable."
This position was communicated to the licensee to
ensure timely operability determinations.
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In other instances where equipment was found to be l
in the required action range, equipment was i
declared inoperable in a timely manner.
As such, j
this issue did not appear to be a significant j
j concern.
c.
Valve Testina l
In most cases the guidance of GL 89-04 was incorporated into the IST program for valves.
An issue regarding
the testing of check valves was documented in paragraph 3.d of this report.
3.
Check Valve Procram a.
Sco_pe The scope of the check valve program was considered good.
Zion Station adopted the. CECO corporate check valve program consisting of two parts.
One part consisted of requirements of the ASME Code Section XI.
The second part includes preventive maintenance (PM)
activities.
The program included valves identified in INPO SOER 86-03, " Check Valve Failures or Degradation,"
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check valves in the inservice testing (IST) program,
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and other balance of plant check valves.
There were 460 check valves included in the licensee's PM program, including 314 IST valves.
There was a 100% overlap between the IST program and the PM program.
The scope of the check valve program was consistent with the SOER and had the proper amount of management support.
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i Interactions between corporate and other CECO stations were noted with check valve coordinator meetings held to discuss check valve program activities and to exchange information on check valve issues.
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During the NRC check valve audit at Byron Station in
July 1991, several issues were identified concerning the program and the corporate directive.
The licensee's response to these issues, dated November 27, 1991, stated that issues were generic and would be
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reviewed by September 1, 1992, for all CECO stations.
l The first issue concerned the generic exclusion of 2 i
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inch and smaller diameter check valves from the check valve program without addressing criteria such as system cleanliness, operational frequency, chemical stressors or component wear.
The second issue was that I
the corporate directive allowed the use of IST as an i
indicator of check valve degradation in lieu of PM (i.e.,
disassembly and inspection or non-intrusive l
testing).
l Zion Station received interim guidelines on the use of i
IST leak rate testing to defer FM of check valves and l
recommendations for avaluating small, 2 inches or
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smaller in diameter, IST valves which were not in the j
check valve program.
The guidelines and
recommendations were implemented at Zion and addressed the concerns identified during the Byron inspection.
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Desian Application Review i
Zion Station implemented the requirements provided by j
corporate engineering in NOD-TS.9, " Check Valve
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Directive," which detailed the check valve program developed by the Architect-Engineer (AE).
No problems were noted.
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Preventive Maintenance Preventive maintenance of check valves was divided into l
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disassembly and inspection (D/I); and non-l intrusive testing (NIT) based on the assigned priority.
Check valves in the PM program were prioritized as u
l Level A, Level B, or Level C.
Level A valves were l
required to be disassembled and inspected, Level B l
valves received AIT and Level C valves were monitored to determine if a change in priority level was warranted.
D/I was the primary means for evaluating check valve degradation for the majority of valves in the check valve program.
D/I was also used in the IST program to meet Code exercising requirements.
During plant outages, D/I requirements of the check valve and IST program were met simultaneously for a given valve.
The licensee was using the D/I to gather baseline data on l
each valve.
In addition, NIT was being performed on
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r valves prior to and after D/I, although not required by t
their program.
By performing both types of PM, the
licensee should be able to validate the results of NIT.
This baseline data also should be valuable information i
for the optimization phase of the check valve program
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that would revise the priority levels of the valves i
after obtaining sufficient data.
The use of NIT prior r
to and after D/I was considered a strent A.
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Work requests and inspection results were reviewed to ensure proper implementation of the D/I program.-
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process for visual inspections of check valves appeared-to be acceptable.
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d.
Inservice Testina i
Check valve testing, in most cases,-was in accordance j
with GL 89-04.
Exceptions were identified and noted i
below.
Testing to verify a valve would go to its full
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l open position was accomplished by establishing the full j
flow required by the respective system or by D/I.
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Verifying a check valve would close was accomplished by l
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seat leak testing, pressurizing downstream piping and j
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verifying no pressure increase on the upstream piping,
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D/I, or for pump discharge check valves, verifying no
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reverse pump rotation.
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Check valves SI8957A-B and SI9002A-D were not being l
tested on a quarterly basis as required by the Code, i
These valves were addressed in IST program cold
shutdown justifications VC-16 and VC-18, which stated l
j that testing could not be accomplished on the Code j
frequency since the discharge pressure of the residual l
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heat removal pumps was lower than the reactor coolant
system pressure and there was no recirculation path available during power operations.
A review of P& ids identified the SI accumulator test return line as a possible recirculation path available during plant
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operations for partial stroking the valves on a i
quarterly basis.
This will be considered an unresolved item (50-295/93002-03(DRS); 50-304/93002-03(DRS))
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pending licensee review of this potential flow path.
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Non-Intrusive Testina
Zion diagnostically tested selected valves to determine l
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if.a check valve was operating abnormally.
NIT was
performed in accordance with TSGP-83, " Check Valve Non-Intrusive Acoustic Testing," to provide a consistent
method of identifying the internal condition of valves.
The licensee continued to develop further experience in
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the use of NIT and to explore the possibility of using
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other types of monitoring equipment that would enhance l
the current monitoring program.
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Trendina i
No formal trending program had been established.
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However, the check valve coordinator was responsible for reviewing D/I results and component measurements.
The data that would be used in a formal trending program was being recorded and analyzed for j
incorporation back into the program.
Corporate CECO l
has stated that trending guidance would be made
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available to the stations in an upcoming revision to
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the directive. _The revision was scheduled to be l
completed by the end of 1993.
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Unresolved Items j
i Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable j
items, items of noncompliance, or deviations.
Unresolved
items disclosed during this inspection are discussed in j
Paragraphs 2.b.(1) and 3.d of this report.
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Exit Meetina
i The inspectors met with licensee representatives (denoted in
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Paragraph 1) at the conclusion of the inspection on
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January 29, 1993.
The inspectors summarized the purpose,
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scope and findings of the inspection and discussed the
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likely informational content of the inspection report.
The j
licensee identified none of the documents or processes
reviewed by the inspectors during the inspection to be j
proprietary.
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