IR 05000346/1977022
| ML19329B449 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse |
| Issue date: | 07/27/1977 |
| From: | Hayes D, Jablonski F, Williams C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19329B430 | List: |
| References | |
| 50-346-77-22, NUDOCS 8002050641 | |
| Download: ML19329B449 (13) | |
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U.S. NUCLEAR REGULATORY CO)D11S3 ION Q'
0FFICE OF 1 ::iPECTION AUD ENFORCE !ENT
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REGION Ill Report No. 50-346/77-22 Docket No. 50-346 Liccnse No. CPPR-80 0 ? P li)
Licensee:
Toledo EdInon Company-Udg
Edison Pla:.a 300 Madison Avenue D
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Toledo, OH 43652 lU JL b-s Facility Name: Davis-Desse Unit 1 Inve.utigation at:
Davis-Desse Site, Oak Harbor, OH Investigation Conducted:
thy 24-27, 1977 (
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Inspectors:
C. C. Williams D/ 97
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Approved by: D. h. D'a ye s, Cbid 7/ 27 /77
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Projects Section
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Investh;ation Sur nary Investi ntion on May 24-27, 1977 (Renort No. 50-346/77-22)
Areas Inve nigated:
(1) The alleger was interviewed by two NRC inspectors at his home in the Toledo area; (2) the NRC inspectors interviewed members of the linnuee's, Lehtc1's, and trand Industrial Services u nagement, and QA/yc constru. tion, and ap ratione personnel; (3) the inspectors caamined each of the specific allegatione made by the alleger; (4) the inspectors randomly selected penetrations and blockouts for examination and observa-tion; (5) the inspectors observed and examined penetration sealant activity in progress; (6) the inspectors examined, in detail, selected penetrations
.on the emergency ventilation beundary; (7) the inspector reviewed the turn-over program for the emergency' ventilation system and walk down the negat.ive pressure boundaries to evaluate its status; (8) the inspectors reviewed the status of the control room preoperational test and the status of the venti-lation system filter trains; and (9) the inspectors summarized the details
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of a forthcoming Immediate Action Letter for the licensec's management.
'This inspection involved a total of 43 inspector-hours by three NRC inspec-tors.
[h Results:
Four of six general allegations, as understood by the NRC
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Inspectors, were substantiated and found to be significant.
Two of the general allegations were substantiated, but determined to be insignifi-f
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One item of nuncompilance containinn 4 elements of con. sideration
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j was' identified.
(Paragraphs 1.a. 1.b, i.e, and 1.f, Section 1, Details
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and Paragraphs 1 and 4, Section 11, Details)
The corrective actions necessary to resolve the elementn of this item of noncompliance werc
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directed to the licensee under. the auupices of an RIII 1:mnediate Action i
Letter icsued'on Ilay 31, 1977. The dirlectives of this immediate Action l
Letter were verhally delivered te the licensec Juring the investigation i
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exit. interview on April, 27, 1977, and confir.ned by telecon from RIII
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l manancment to 1..
E. Rowe (Vice President, TECo) on the afternoon of
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April 27, l' '. One unresolved matter, relative to the availability 'of
an adequately documented energency ventilation system boundary,~was
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iden tified.
(Paragraph 1,'Section'11, Details)
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DETAILS f'
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Section 1
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Prepared by C. C. Williams
Person's Contacted Principal Liconsee Employees
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- L.
E. Roe, Vice President
- J. D.'Lonardson, Quality Assurance Manager j
- R. E. Blanchon, Construction Supervisor
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- G.
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Eichenaucr, Quality Assurance Engineer
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- D. A. Pocce, Quality Assurance EngJneer
- 0.
Fraser, Quality Control Engineer
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- E. R. Michaud, Operations Engineer FN'
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D Other Personnel
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Individual "A" i
- C. L. Houston, Bechtel Construction Manager
- W.
C. Loucry, Bechtel Quality Assurance
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- C. D. Miller, Bechtel Engineer
- J.
D. Heaten, Ecchtel Quality Control Supervisor i
J. Polverari, BISCO foreman
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W. E. Iby, BISCO Area Superintendent s
i D. M. Nceland, BISCO, Gcacral Foreman K. G. Granate, BISCO Arca Supervisor D. E. Parker, BISCO Insulator C. C. blanchard, BISCO Foreman S. Andreakos, BISCO Project Manager
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J. Kovach, Bechtel Engineer J. Dusseau, BISCO Foreman
W. Burch, BISCO foreman
e K. Michahki, n rSCO rorumm.
l J. A: ms t ron, M SCO Tx.. er.:em ucien Cicrh
R. Sperry, Quality Control Engineer, Bechtel
R. Stuffy, Bechtel Enginecr F. Rollins, BISCO Field Engineer
J. Arslanian, BISCO Quality Control Supervisor
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The inspectors also contacted and interviewed other licensee, Becthel,
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.and contracter employees including. members of the Quality Assurance, Technical, and Engineering staffs.
- denotes those present at the exit interview.
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,1.icensee Action on Previous Tuspection Findings
None identifJed.
Items Investinatyd 1.
Interview wit h the Allreer and Findimm During Subsequent _ Plant In s p ec t_i_g)
Individual "A" contacted the 14111 of fice by telecon twice 'on May 23, 1977. During these conversations he made hi;'hly specific allegations regarding the quality and control of the Davis-Besse Plant penetra-tion blockout scaling activity.
At this time, RIII arranged to inter-view Individual "A" at his home. The following allegations were made during this interview and subseqt-y investigated:
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a.
Individual "A" stated that "some pcnctrations within the plant have not been seal.ed and there is no docunented nechanism for assuring that these par.etrations will be scaled; an examp12 may be found in Roca 419."
Finding - Substantiated Inspection of the penetration in Room #419 and other areas substantiated this allegation.
Examination of plant documents disclosed that this penetratiou had not been previously identi-f'~ss (
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ficd on docurentation which would have required its closure.
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Penetrations of this category are identified on civil drawings
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which were not availabic to BISCO employcos. Other areas exam-ined in this regard did not contain any " uncontrolled penetrations."
b.
Individual "A" stated that "During the " interim" negative pressure boundary testing, (Emergency Ventilation System) many penetrations, doors, conduits, and floor drains were either covered with masking tape or otherwise improperly scaled.
For example, some we e sealed with tape and caulking, and condulets were filled with silicon fcam. 15 t co ver, chia a curred uithout prior IW,ineering and QA/%.x.nt rol.
Saee of these fD.ec vere identified with QC Trace Numbers but many were not."
Individual "A" could not provide specific locations but referenced other members of the BISCO staff who could and stated that these conditions would be easily detcetable through observation.
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Interoy,ation of other members of Ihe site contractors staff and int.pection an.i olinervat Jon by the MRC inspectors confirmed the existance of nonconforminy, seals made with tape, caulking and/or silicon' foina in condulets, doors, drains, and conduits.
There condit iinm (in p art) were not controlled by documented inst'cuctionc f rom en;;ineering uer QA/QC.
Tt was reported by the. licensee's representatives that the site ractor (UISCO) was instructed to make t.hese " expeditious" c-st. ts as a result of leaks detected during interim testing of the Emergency Vcntilation System.
For expediency, such seals and seal repairs were not controlled in the usual fashion in that Engineering and OA/QC did not approve these repairs prior to implementation. The inspectors found t; hat all of these "re-
. pairs" were identified by the craft forces with trace numbers a s ' e L.; instructed.
1t. was f.he stated intcnt of the licensee te une t.hese tv cc nu:abcr identifications to retio-fit T,nginceting and QA/QC involvement in this work.
The above decision and the subsequent sealing violated the licensee's quality assurance commitments and reduced the prob-ability that conforming repairs and/or configurations would be accompliched.
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The " expeditious" and improper penctration sealing activity was found by XRC inspection to be confincd to penetrations within the Emergency Ventilation Syctcm boundary, as defined by the licensee's representatives.
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Individual "A" stat.ed that a large percentage of the BISCO drawings used to control the penetration and block out sealing were erroneoun in that the drawings frcquently dcn't reflect the as-built configuration.
For example, he stated that in Roe:r, n.
110, the uni's look not.hing like the as-i.uiltc.
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Findings - Substantiated Examination of the BISCO production /Bechtcl Engineerir.r, con-trol drawings and instructions relative to blockouts and penetrations showed that no substantial deficiencies exist.
While it is true that various drawings in BISCO's control don't show the current as-built condition, the process (docu-ment control) is such that all such drawings are in process.
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of revinion to show f f na1 as-huilt configurations.
At the g
time that the drauings questi.oned by Individual "A" were made, they were acceptably accurate.
Subsequent installations changed the confi".ucations.
Final drawings showed the as-bullt configuraLions.
d.
Individual "A" s ta ted that Bechtel Engineering provides what appedred to him to be incorrect and conflicting instructions relative to the une of si].icone foams (SF 20 and SF 150) and pipe 1. acts for sealing piping penctrations.
That is "fre-quently the same wall drawing for seal ng pipe penetrations will specify both the silicone foam and pipe boots."
Indi-vidual "A" did not think that penetrations through a common wall could have different criteria for closure.
He stated
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that an example of this may be fcund on the north wall of Room #126.
Finctine - Subste stiare !
The description of the conditions described by Individual "A"
were found to be correct.
However, the allegation of error is not correct in that the use of siliconc foam and caulking versus the use of boots, to seal pipe pencerations depends on the amount of pipe covement during operations or hcatup.
If
the pipe movement exceeds the criteria, then boots are used to f
make the scal.
If not, tnen the silicone focms are used.
\\v The exampic pointed out in rocm #125 by Individual
"A" was a
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correct observation.
The NRC examination found that an error had been made during silicone foam damming operations.
This
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error had been previously identified and uas properly con-trolled.
No other instances were identified by NRC inspec-tors or other B1SCO craftsmen.
e.
Individual "A" stated in summary that the Daergency Ventila-t. loa Test Boundary w.s not-adequntel'f def acd for sealing and leak te r purporea. L ay more penetrations (other than thoec on the boundary), doors, drains, t.nd-conduits had to be sealed either with temporary tapint;, caulking, and/or silicone foam during the " Interim pressure testing" and the concurrent smoke leah detection.
He indicated that all apparent leakers were
- plugged in the above fashion until the air pressure criteria was met.
He further stated that there was no indication that mm lli
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permanent conforming repairs are intended nor was there any indication that Conineering and Quality Assurance was fully aware of-the extent of the repairs and plugs.
Many of these repairs were not identified by trace numbers.
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Find ina - Sulmtant iated The inspectors confirned through discussion with the BISCO craf tsman and obcorvationc that this allegation was substan-tially correct.
Irems other than those on the specified EVS Boundary such as conduit ends without trace numbers were observed to be scaled with a combination of tape and caulk-ing material; condulets were either taped or filled with silicone foam; door frames were observed to be taped; wall sockets were observed to be taped; and floor drains were observed to be-taped.
Many of these temporary fixes were not on the (cmoke list)
1.e.,
trace numbers had not.been assigned.
The-licencea's representatives stated that in this reacrd it was also the intention to evaluate the successfulness of the as-built seals during the " interim" EVS rest.
However, so many leahs were detected during this testing, that it was
decided that the production crews should immediately plug all leaks detected during the draw doun and smoke testing. All m
such leaks ucre to be assigned " trace numbers" which would
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cnable Engineering and QA/QC to evaluate them later.
However, j
it is apparent that nany of these fixes were not assigned trace numbars and.this nonstandard repair process was not propccly controllad.
f.
Individual "A" stated that "a comprehensive documented procc-dure (criteria) for executing " walk-down" inspections for determining if all penetraticns (including the CVS Boundary)
have been properly sealed does not prevail across the entire TECo organization, i.e., EISCO-Beethcl Engineering, QC and TECo QA orge.n!zaticac."
i Finding - Substantiated
Through examination and discussion with the licensee's rep-
recentatives the inspector concluded that clearly defined
- criteria and instructions relative to the control of the inspection and verification of blockout and penetration status for~the CVS boundary is not adequately established.
This condition was apparently. caused by or aggrevated by m
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the uncontrolled repairs made during interim EVS test and incomplete estahlinhment of the " Smoke List" which untensibly
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documented.all repairs, and deficient conditions.
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The following list summarizes the room designations which
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identify the locations of the dincrepancies identified by Indiviihtal "A" and :. hose arean identified by other BISCO craf tsmen in respone to NRC qiicsLionn:
(1) Location of caped floor drains:
Roems 314, 303, 208, 236 an/ 125.
(!;ote :
a modification te preclude the need for taping has been approved and should be in
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place.
It prescribes the installation of " Wafer Check Valves" in the drains within the EVS Boundary.)
(2)
Location of penetrations not scaled and not identified by documentation as needing to be scaled.
Example:
Rova 419 and/ur 418.
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(3)- Arcas where temporary tape was found as of May 25:
l Rooms 314, 303, 203, 236 and 225.
(4)
BISCO Foreman identified conduit scal with tape cov-ered uith caulking raaterial and subsequent repaired condition in passageway.
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Apparant discrepancy in closure critcria between boots
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and silicone foam at rooms 125 and 126.
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(6)
Craftsncn repetted tape still used ir. Rooms 115, 113,
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and 105 (verified by Bechtel Engineers walk-down on
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May 25).
-(7) Within Rcom 314 a ventilation damper had to be recycled by hand during previous test.
This was done by Bechtel
organizerien.
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Hot lab, Room 424 el. 603, verify that all drains and duct penetrations have been propecly scaled.
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(9)
Verify that all "Cera" fiber has been removed or proper i
seals made in Rooms 221, 115, 113, and 105.
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(10) Verify that door (seals) were repaired where required in Rooms 314, 303, 113, and 208.
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Se<1uence of Events and immediate Action Letter
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The allegations were received on May 23, 1977. The investigation was initiated on thy 24, 1977.
On May 25, 1977, the NRC inspec-tors concluded after insp>ction, that the allegations were
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substantially true and q nlity control probkmn existed.
On May 25, 1977, the TEco y tce President acknowledged these conditions and comn.itted to inmediate corrective action relative to the EVS
' boundary blockoutn penetratioas doors and drainc.
The primary con-cern una to satisfy cc.;d! Lions necessary for testing the emerr;cucy ventilation system.
On May 26, 1977, the licensee informed R111 that all corrective actions were complete and requested reinspec-tion. The NRC inspector returned to the site on May 26, 1977, and continued the investigation by' interrogating 10 BISCO craftsmen relative to the status of the rework.
During these discussions several of the craftsmen identified additional areas wherein non-controlled work (scals) and temporary tape on doors and drains had not yet been renoved.
On May 27, 1977, at the NRC's request tbc licent.ac's repcosentativcs conducted an inspectf an of the areas reported by the BISCO craftsmen as being incomplete.
The results of this inspection confirmed the continuing existence of discrep-ant seals and temporary tape. The corrective action taken was proven to be inadequate. On May 27, 1977, the NRC inspectors verbally outlined the tent of an NRC R111 Immediate Action Letter to the licensee's represcntatives.
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j-This Immediate' Action Letter specified what corrective actions
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must be taken rending further regulatory action.
The licensee concurred vith these reaarks. They are as follows:
Prepare comprehensive procedures for control of penetration a.
inspections.
b.
Conduct inspcetions of areas containing penetrations with-
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in the boundaries defined in the above procedures utilining engineering and QA personnel'of TECo and Bechtcl.
c.
Docunent any obscrved ceviations from design, including material, workmanship, and incomplete or missing scals.
d.
Repair all discrepancies in accordance with approved proce-
.dures, e.
Ensure both TECo 'and Bechtel engineering and QA review and approve all repairs.
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Co rree t all required floor drain seals to meet design l/
requirements.
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Provido riocumentst.ien control for interf ace between h1SCO and other site contractnen to insure proper inspection and repair of any.previously released seals.
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Infern the InII of fice when all. disert:pancien are
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corrJeted sa we can rev;cu the rer:ults of your correc-
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tive action.
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The underst antiing was t %t the above wonid he completed prior to the official performance of T.P.
110.01, Ibergency Ventilation f
System Test.
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Exit Interview i
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The inspectors met with the' licensee representatives (denoted under,
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Persons Contr.cred) at the co.*clusicr. of t he.inve.st:ia.vt len on May 27, l
19T/. Thc incpceurc cun::cr. sad the purpc,rc erd.'indina.r of the
investigation.and discussed the directives of the RIII Immediate i
l Action Letter which is to be issued relative to corrective actions.
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The licensee achnculcdged the findin;;s as reported.
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V Section Il k
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Prepared by:
J. P. Kohler
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Reviewed by:
'h'. :.h 1[i t t l e
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Perso:s Contected Rick !!artell G. Euhanhaarer, Quality Assurance Engineer
- J. D. Lenardson, Quality Assurance !!anager
- D.
A. Poage, Toledo Edison QA
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- J. D..Heaton, Ecchtel QC
- C. D. Miller, D*chtel CPDE
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C. Lee.:ry, bec.I.tcl QA
- R.
E. ' Dj anchong, Toledo Edison Construction
- E. R. M tchaud, Toledo Edison Test Project Manager
- 0. M. _ Fraser, Toledo Edison QC
- L.
E. Roe, Toledo Edison Vice President
- C.
L. liusten, Bechtel Construction !!anagenent J. Kovachs, Bechtel Engineer
- denotes - nresent at the exit interview.
1.
Ens
_ncy Vent Sveten Turaaw r The inspector interviewed e :ployees of Ecchtcl, Bisco, Babcock L'ilcon and Toledo _ Edison. The personnel intervieus uere conducted in order te determine the different organizational responsibilitics for corapletion of construction activitics on the Emergency Venti-lation Systen (EVS).
Based on these interviews, the inspector determined that the liccasee did not include the boundaries of the EVS in the cyatem definition of the CVC.
A walkdown of,the EVS boundary defined in TP 110.01 determined that
.ponctrations, doors, and drains which formed part of the EVS boundary were being turned over to startup personnel with teraporary closures, such'as tape, forming the seal for critical EVS boundaries.
At the time of the inspection there were no plans to replace the tempor-ary closure material with permanent fixes before performance'of the preoperational CVS test (TP 110.01).
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At the management c::l t, the inspector stated that he would not (
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witness a proopertiticual test performed on a system whJch con-
tained temporary closures that tormed the seal on critical boundaries.
Furthermore, the inspector stated that he considered
the haundarles of the INS to be part of the system,and that a
procedure would have to be developed which defined these houndaries
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i and had detailed acc~ptemce criteria foi cmnplet ion and quality control prior to petforn.enee of the l'V'; proepc rational test.
Tbc licensee acknowledged rheau cor:vuts.
2.
Contro3 Room Preog rattenal Test.
The preoperational test performed on the control room requires
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the maintenance of a 1/8 inch ug positiva pressure by supplying 111tered =ahcup air f rom outside the control room.
During the inspection the inspector revieved memorandum which stated that temporary sealinn material would be necessary to seal air leakage if dif ficulty was encountered in maintaining the 1/3 inch vg positive prer % rc.
The inspector questioned the individual responsible for the Davis Besse startup progra::: and was informed that the control room preoperational test had been completed.
He vas unabic to state whether temporary scalirg material was rer.vved prior to performance of the test.
During the management exit, the inspector stated that he considered the boundaries of the contrel room to be part of the
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control roo;:. emers,cncy ventilation systcn anc'
nrocedures
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would have to be developed for the inclusion of tnese o,.mdcries in the co-pletion prerequisites prior to cor trol rocm test perfor-mance. The inspector stated that the ce:tple ted test would be considered invalid if tc-morary closure mate rial was found.
In a phone call subsequent to the inspectior., the inspector was informed that procedures were bcirq, develop d that defined the control room boundar.4 s so that temporary closure material, if used, ceuld be replaced with permanent mate.-ial.
The inspector statud t hat,hc control room prv perr.tiona.; Lest waald b.
innpceted durin;, a sebaquent 1.u p a tion.
3.
Filter Trainc Preorcrational testin;; of ventilation systems which contain charcoal are being performed without the ciarcoal installed.
There are three systems affected:
The Emcegency Ventilation System; Fuel Building Ventilation System; ontrol Room Venti-lation system. The inspector stated that le did not consider the preoperational test of these systems to be complete until the charcoal was installed.
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The 11censee stated that interior painting which is currently
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Laking place could au.arcely alfeet the charcoal filter elements and that the det erminatir:n var made to delay Innta11ation of the charcoal.
Consequently, during the preoperational test of the EVS, a dif ferential presni.cc device would simulate the pressure drop across the fil tern and that the pressure drop would be verifled as connareittive when the charcoal filters were installed.
The inc:pector ctated the TS 4.6.4.4.c tequires DOP and fre.on testinr. of flitration cystemu after cach complete or partial filter placement.
Cor.sequently, aftcr charcoal filter insta].
Lors and prior to moving from Mode 5 to Mode 4, tech-nical cpecification filter testing would be required in addition to votifying the differential pressure.
4.
EVS L'alkamg At the innpt etor's insictatic.., a valkdova of the fellowing E7S boundarle.4 a-defined in TP 110.01 v:2c initim.cd by the li c,n.s ee.
Mechanical Penetration Ruona one through four; cast and west ECCS pump roons. During this walkdown, the licensee discovered temporary closure inatorial vas still present in the EVS boundary.
This material uns removed by the licensee.
liowever, no assurance could be given that all material was removed.
The inspector stated at the manngemtat cr.it that additional quality control would be
['3 necessary prior to perforn:nce of the EVS preoperational test to V)
assure all teuperary closure material was removed.
i 5.
Startup Peckace for Systen 34 The inspector reviewed the conpleted duct leakage and air balancing reports for system 34.
No deficiencies were found.
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