IR 05000333/1979016

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IE Insp Rept 50-333/79-16 on 790918-21.Noncompliance Noted: Failure to Conduct Special Procedure Review in Training Program & Failure to Document Use of Measuring & Test Equipment
ML19290D970
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 11/07/1979
From: Caphton D, Cowgill G, Zimmerman R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19290D959 List:
References
50-333-79-16, NUDOCS 8002290581
Download: ML19290D970 (13)


Text

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 50-333/79-16 Docket No. 50-333 License No. DPR-59 Priority

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Category C

Licensee:

Power Authority of the State of New York P. O. Box 41 Lycoming, New York Facility Name:

James A. FitzPatrick Nuclear Pouer Plant Inspection at:

Scriba, New York Inspection conducted:

September 18-21, 1979 Inspectors: h M

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C. J. Cowg111 III, Reactor Irispector dgte41gnpd

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Approved by:

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D. 'L. 'Ca%t'on, Chief Nuclear Support date signed Section I, R0&NS Branch Inspection Summary:

Inspection on September 18-21, 1979 (Report No. 50-333/79-16)

Areas Inspected:

Routine, unannounced inspection by regional based inspectors of licensee action on previous inspection findings; licensed operator requalification training; general employee training; craft and technician training, unlicensed operator training; administrative control of safety-related maintenance; review of safety-related maintenance activities, qualification records of selected individuals who performed safety-related maintenance; IE Bulletin Response; and, review of plant operations and facility tour.

The inspection involved 73 inspector-hours onsite by three NRC regional based inspectors.

Results: Of the ten areas inspected, no items of noncompliance were found in six areas, one item of noncompliance was found in each of three areas (Deficiency -

Failure to conduct Special Procedure review, paragraph 3.b.2.(a); Deficiency -

Failure to document use of measuring and test equipment, paragraph 8.c.;

Deficiency - Failure to make proper entries in jumper and lifted lead log, para-graph 6.a.).

Region I Form 12

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(Rev. April 77)

800:2990

DETAILS 1.

Persons Contacted

  • E. Abbott, Operations Superintendent
  • R. Baker, Maintenance Superintendent N. Brosee, Mechanical Engineer
  • R. Burns, Radiological and Environmental Services Superintendent
  • V. Childs, Assistant to Resident Manager
  • R. Converse, Assistant to Operations Superintendent
  • W. Fernandez, Assistant to Maintenance Superintendent
  • J. Flaherty, Assistant to Instrument & Control Superintendent
  • J. Hoddy, Acting Technical Services Superintendent
  • S. Hudson, Shift Supervisor
  • H. Keith, Instrument & Control Superintendent G. Laughlin, Training Specialist J. Leonard, Resident Manager A. McKeen, Assistant to Radiological and Environmental Services Superintendent
  • R. Pasternak, Superintendent of Power
  • D. Tall, Training Coordinator
  • R. Young, Training Engineer (Corporate Office)

The inspector also interviewed other licensee employees, including members of the technical and engineering staff, reactor operators, and general office personnel.

  • denotes those present at the exit interview.

2.

Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (333/78-04-03):

Establishment of calibration program for Technical Specification Balance of Plant Instrumentation.

The licensee has updated the generic instrument calibration form to include shift supervisor's approval to perform the work, second level results review, and returning the instrument to service.

The licensee representative stated that specific acceptance criteria is recorded prior to the start of work.

(Closed) Unresolved Item (333/77-33-06):

Head correction included in calibration procedures.

HPCI-RCIC Steam Line Low Pressure Switches have been calibrated with a correction for water head.

In addition, the licensee has performed a review to ensure that other instrument settings have been corrected, where necessary, for water hea (0 pen) Unresolved Item (333/78-27-01):

Review of facility procedures.

The inspector noted that the two year periodic review has been completed almost in entirety.

However, a large number of proposed procedure revisions, as a result of the periodic review, remain to be reviewed by PORC.

In conjunction with the above, during the inspection of maintenance activities, the inspector noted that the Maintenance Department and Instrument and Control (I&C) Department have not designated in writing the number or location of the controlled copies of the Mai",enance Procedures and I&C Procedures, respectively.

Further, a question appears to exist as to whether the copy of Maintenance Proce-dures in the Maintenance Superintendent's office is to be considered a controlled copy.

The inspector informed the licensee representative that during a period of numerous procedure revisions, the need to maintain controlled copies current, is of great importance.

The licensee representative acknowledged the inspector's comment and stated that a list designating controlled copies will be developed for the Maintenance and MC Departments.

The above item remains open pending PORC review f proposed revisions, licensee action to designate controlled copies anu subsequent NRC:RI review.

(0 pen) Unresolved Item (333/78-13-04):

ECCS bus power monitors.

The licensee has submitted a Technical Specification change.

The above item remains open pending resolution of the trip level setting and subsequent NRC:RI review.

(Closed) Unresolved Item (333/78-08-08):

Housekeeping and Cleanliness Control.

The inspector reviewed Work Activity Control Procedure 10.1.7, Housekeeping and Cleanliness Control, Revision 1, and found it consistent with ANSI n45.2.3.

(Closed) Deficiency (333/78-08-05):

The licensee has prepared required technical training instructions.

(Closed) Deficiency (333/78-14-07).

The subject operator walk through

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evaluations were conducted prior to September 30, 1978.

3.

Licensed Operator Requalification Training a.

Program Review Reference ITP 5.

Licensed Operator Requalification, Revision 1, dated August 28, 1978.

The inspector reviewed the licensee's program with regard to the requirements of 10 CFR 55, Appendix A and the Accepted Operator

Requalification Program.

The accepted program was submitted as Exibit B of amendment 22 to the Facility License.

The above referenced procedure implements this program.

The inspector determined from a review of this procedure that the program as currently established provides for the following:

an established, planned, continuing lecture schedule;

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documentation of personnel attendance

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required reactivity control manipulations

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discussions / reviews of changes in facility design, procedures,

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and facility license; and review of abnormal / emergency procedures.

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The inspector noted during discussions with the licensee represen-tative that the Licensed Operator Shift Report included in the referenced procedure has been replaced.

The new form supplies the same information required previously.

The licensee representa-tive stated that the procedure should be chaaged to identify the form currently in use.

The license 9 representative agreed to have the procedure revision completed by January 1, 1980.

This item is considered unresolved pending NRC:RI inspection (333/79-16-01).

b.

Record Review (1) The inspector selected and reviewed the records of twelve licensed operators to verify that each contained the following documentation:

completed course and yearly examinations; and

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manipulations of controls for reactivity changes required by the program.

(2) Findings (a) During the record review, the inspector determined that a review of the facility special procedures had not been assigned for the period June, 1978 to January, 1979.

The inspector further determined from a re"iew

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of completed training reports for the same period that the special procedures were not covered for all licensed operators.

This is contrary to the requirements of Section 5.5.5, item 4 of the referenced procedure which implements the requirements of 10 CFR 55 and the accepted requalification program.

This is an apparent item of noncompliance at the deficiency level.

(333/79-16-02)

(b) The inspector further determined during the record review that:

Four senior licensed operators had not reviewed

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the site emergency plan during the year 1978; Two senior licensed operators scored less than 80

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on one or more parts of toe 1978 annual requalifica-tion examination and were thus required to attend the associated requalification lectures given during the year 1978.

The inspector could find no documentation to support the attendance at the required lectures by the subject individuals.

Two senior licensed individuals have not taken the

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1979 annual requalification examination to date.

Further, the two subject individuals are delinquent for the individual reading assignments for the first two quarters of 1979.

The licensee represen-tative stated that a specific program to make the subject individuals current in the requalification program is in progress.

The licensee representa-tive further stated that the subject individuals would be current by December 31, 1979.

Item (b) was identified in a quality assurance audit conducted in September 1979 by a representative of the Power Authority State of New York, and is considered unresolved pending NRC:RI review of steps taken to correct the above listed audit findings (333/79-16-03).

During the record review, the inspector noted that certifications were required for individuals prior to their conducting testing or inspection activities.

The activities requiring certification were defined in Station Administration Procedure 4.3, Test and Inspection System, Revision 0, dated April 1, 1977.

The inspector

further noted that in certain isolated cases, these certifications were out of date.

The licensee represen-tatives noted the out of date certifications and stated that they would be promptly corrected.

These certifica-tions will be reviewed in a subsequent inspection.

4.

General Employee Training a.

Program Definition The inspector reviewed the licensee's procedures with respect to the program definition requirements of:

10 CFR 50, Appendix B, Criterion II; 10 CFR 19.12; 10 CFR 73.50; and for:

new and existing employees; temporary employees; technicians; and, craft personnel.

These programs establish training which covers:

administrative controls and procedures; radiological health and safety; controlled access and security; industrial safety; emergency plans and procedures; fire fighting training; and quality assurance indoctrination.

Formal training is also provided for female employees on the contents of Appendix A to Regulatory Guide 8.13.

b.

Program Participation The inspector reviewed the licensee's records to assure that the required training had been given.

In addition, the inspector conducted interviews with certain of those individuals whose records were reviewed.

The interviews verified that:

the scope of the training was similar to that contained in the licensee's records; the training as conducted was meaningful to those attending; and that the areas presented were covered accurately and sufficiently from the participants' point of view.

Records were reviewed for and selective interviews conducted with employees as listed below:

two relatively new employees;

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four employees with more than one year of service; and,

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three temporary employees

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The inspector's findings were similar to those identified in Quality Assurance Standard Audit #298 conducted on July 25, 1979.

Items identified and corrective actions committed to in the QA Audit were (1) Procedure ITP 3, General Employee Training, Revision 0, approved October 28, 1977 to be revised by January 1, 1980 to

reflect the fact that the New Employee Training Checklist is no longer in use and (2) the annual retraining for 1979 will be scheduled prior to the end of 1979; a makeup session will be held for staff members directed to attend by the Superintendent of Power or the Resident Manager, with all training to be completed by January 1, 1980.

Completion of this' corrective action will be subject to future inspection and is considered an unresolved item (333/79-16-04).

5.

Craft and Technician Training a.

Program Definition On the job and formal technical training requirements for I&C, Radiation and Environmental, Maintenance and non-licensed operators are provided by the indoctrination and training procedures listed below:

ITP 6, Training for Instrumentation and Control Technicians,

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Revision 0, dated May 17, 1978.

ITP 7, Training for Radiation and Environmental Technicians,

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Revision 0, dated May 26, 1978.

ITP 9, Training for Maintenance Personnel, Revision 0, dated

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May 26, 1978.

ITP 10, Training for Non-Licensed (Auxiliary) Operators,

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Revision 0, dated August 25, 1978.

The inspector identified no items of noncompliance, b.

Record Review and Personnel Interviews The inspector reviewed the records for and conducted interviews with selected employees to verify that the required training had been conducted.

The interviews were directed at confirming that the information which had been presented and that they were able te describe how the training applied to their job positions.

Those interviewed were in the following technical categories:

one electrician

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one non-licensed auxiliary operator

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S one chemist

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one I&C technician

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The inspector identified no inconsistencies between the information contained in the training records and the information provided during the interviews.

6.

Review of Plant Operations The inspector reviewed selected facility operation logs and toured areas of the facility to determine that operations were in accordance with the Technical Specifications (TS).

1.

The Shift Supervisor's Log, Control Room Operator's Log, Shift and Daily Logs, Jumper Logs and the Reactor Water Daily Data Logs were reviewed.

This review combined with panel observations in the control room and observation of various parameters throughout the facility during the plant tour verified that plant conditions conformed to TS requirements, with the exception of the below listed items.

2.

The inspector reviewed the Jumper and Lifted Lead Log.

During the course of this review, the inspector picked one active log sheet and verified that jumpers were installed.

The inspector noted that three active sheets with log numbers79-180, 78-205, and 78-204 did not have the jumper numbers logged as required by facility Work Activity Control Procedure 10.1.3, Placement of Jumpers, blocks or lifted leads, Revision 1, dated June 13, 1979.

The inspector further noted the following:

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When the licensee installed Jumpers79-181 and 79-182, there was no description entered in the control room log; When jumpers79-183 and 79-184 were issued, there was no log

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entry made; When jumper 79-182 was removed and returned to service, no

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log entry was made indicating a retum to service.

The inspector identified his concerns to licensee representatives.

The licensee representative immediately conducted an inventory of all assigned jumper numbers.

There were 45 jumpers assigned and 26 were missing from the cabinet.

Thirteen of the jumpers missing from the cabinet were accounted for by entries in the jumper lo The licensee representative then conducted a search for the unaccounted for jumpers.

At the time of the completion of the inspection, one jumper was unaccounted for.

The items listed above constitute an apparent deficiency level item of noncompliance (333/79-16-05).

3.

During the review of plant logs, the inspector noted that during the recent plant startup in September, 23 MOV57 (HPCI suction from suppression chamber) was left shut for five hours with primary pressure greater than 150 psig.

The inspector also reviewed Occurrence Report 79-135 which detailed the degradation to the HPCI system.

The above item requires further NRC:RI review, including reporting requirements, and is considered unresolved (333/79-16-06).

b.

Facility Tour The inspector toured the following accessible areas and observed general plant conditions with special emphasis on housekeeping and cleanliness, excessive valve leakage or piping vibration, shift staffing and turnover, radiation control zones properly established and identified and compliance with Technical Specifica-tion limits where applicable.

control room

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battery rooms

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Reactor Building

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The inspector identified no items of noncompliance.

7.

Administrative Control of Safety-Related Maintenance The inspector reviewed the following procedures with respect to the requirements of the Technical Specifications, Section 6, "Administra-tive Controls", ANSI N18.7, " Administrative Controls for Nuclear Power Plants" and Reculatory Guide 1.33, " Quality Assurance Program Require-ments".

Administrative Procedure (AP) 1.2, Plant Operations Review

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Committee, Revision 2, May 19. 197.

AP 1.4, Control of Plant Procedures, Revision 2, February 16,

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1978.

AP 3.1, Procedure for Maintenance Procedures, Revision 2, #:tober

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31, 1977.

AP 3.3, Procedure for Instrument Maintenance Procedures, Revision

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0, April 1, 1977.

AP 4.2, Control of Measuring and Test Equipment, Revision 2, July

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13, 1979.

AP 10.1, Control of Work Activity Control Procedures (WACP),

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Revision 1, August 18, 1978.

WACP 10.1.1, Procedure for Control of Maintenance, Revision 2,

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July 18, 1979.

WACP 10.1.7, Housekeeping and Cleanliness Procedure, Revision 1,

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July 26, 1978.

Standing Order Number 4, Shift Relief and Log Keeping, Revision

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3, July 25, 1979.

No items of noncompliance were identified.

8.

Review of Safety-Related Maintenance Activities The inspector reviewed safety related maintenance conducted by a.

the licensee on a sampling basis to verify that:

Limiting Conditions for Operation (LCO's) were met while

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equipment was out of service; Required administrative approvals were obtained to perform

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the work; An approved procedure was used where required;

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Required inspections were performed;

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QA/QC records were available to substantiate quality of work

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and parts used;

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The maintenance was performed by qualified maintenance

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personnel; and A Reportable Occurrence Report, if required, by Technical

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Specifications, was submitted based on review of circum-stances associated with the maintenance activity.

b.

Tne following maintenance activities, including associated work requests, procedures, and functional tests, were reviewed.

Work Request (WR) 10-2367, completed September 5, 1979, 'B'

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RHR Discharge Check Valve - leaking.

WR 23-1384, completed July 25, 1979, Loose Anchor Bolt -HPCI

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Steam Supply Pipe Support.

WR 01-125-2572, completed August 22, 1979, 'B' Standby Gas

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Treatment Train Prefilter Replacement.

WR 70-2256, completed August 24, 1979, Relay Room Exhaust

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Fan - Faulty Overload Relay.

WR 10-1880, completed June 30, 1979, LPCI Independent Power

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Supply Batteries - dirty.

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WR 11-1119, completed June 9,1979, Standby Liquid Control Valve Connector Pin - broken.

WR 71-1019, completed June 25, 1979, Cell #6 on 'B'

125V

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Station Battery - cracked case.

WR 71-71, completed June 20, 1979, Replace Cells #29 and #51

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on 'A' Station Battery.

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WR 71-1212, completed July 2, 1979, Retorque Intercell Connections.

WR 93-753, completed June 27, 1979, Replace Ammeter 93-AM-

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1C.

WR 10-1272, completed July 3, 1979, 'D'

RHR Pump Discharge

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Check Valve.

WR 07-728, completed March 27, 1979, Replace / Repair Source

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Range Monitor 'G' Fluctuating and Driftin.

WR 20-3188, completed September 15, 1979, Drywell Floor Sump

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Pump Totalizer.

WR 17-1003, completed June 23, 1979, Off Gas Radiation

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Monitor.

c.

During the review of documentation associated with maintenance activities, the inspector noted that the particular torque wrenches used in the performance of four separate Work Requests (WR) were not identified on the appropriate WR, or by a log entry, thereby preventing traceability to the maintenance activities for which the wreiiches were used.

The Work Requests in question included WR 10-2367, 10-1880, 71-71 and 71-1212.

Failure to document the use of measuring and test equipment is contrary to the requirements of Technical Specification 6.8.A which requires adherence to plant procedures and represents an item of noncompliance at the deficiency level (333/79-16-07).

9.

Technician Qualification _s_

The inspector reviewed the qualification records of selected individuals having responsibility for maintenance of safety-relatad systems and components to verify that their experience level and training were in accordance with the guidelines set forth in ANSI N18.1, Selection and Training of Nuclear Power Plant Personnel.

No items of noncomoliance were identified.

10.

IE Bulletin 79-10, Reaualification Training Program Statistics The inspector verified by record review and discussion with licensee personnel and review of Power Authority of the State of New York letter, J. D. Leonard to B. H. Grier of May 22,1979 JAFP-79-253 that:

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the written response was provided within the time period stated in the Bulletin; the written response included the required information;

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licensee forwarded the response to appropriate onsite management

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representatives; and,

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the information contained in the response was accurate.

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No items of noncompliance were identified.

11.

Unresolved Items An unresolved item is a matter about which more information is required to ascertain whether it is acceptable, an item of noncompliance, or a deviation.

Unresolved items disclosed during the inspection are discussed in paragraphs 3.a, 3.b, and 4.b.

12.

Exit Interview The inspector met with licensee representatives (denoted in paragraph 1) on si e at the conclusion of the inspection on September 21, 1979.

The purpose, scope and findings of the inspection, as documented in this report were discussed.