IR 05000346/1988002

Insp Rept 50-346/88-02 on 880101-0215.Violations Noted.Major Areas Inspected:Action on Previouly Insp Findings,Maint, Operational Safety,Surveillance,Performance Enhancement Program,Ler Followup,Security & Onsite Followup of Events

ML20151H827
Person / Time
Site:	Davis Besse
Issue date:	04/05/1988
From:	Defayette R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20151H809	List: IR 05000346/1988002 ML20151H806 ML20151H816
References
50-346-88-02, 50-346-88-2, NUDOCS 8804200550
Download: ML20151H827 (14)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-346/88002(DRP)

Docket No. 50-346 License No. NPF-3 Licensee: Toledo Edison Company Edison Plaza, 300 Madison Avenue Toledo, OH 43652 Facility Nam 2: Davis-Besse 1 Inspectic n At: Oak Harbor, Ohio Inspection Conduc'ced: January 1 through February 15, 1988 Inspector: P. M. Byron D. osloff

. htY Approved By: R. DeFayette, C 'ef Reactor Projects Section 2B Dat'e

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Inspection Sumrrary Inspection on January 1 tr. rough February 15, 1988 (Report No. 50-346/88002(DRP))

Areas Inspected: Routine, unannounced inspection by resident inspectors of licensee action on previous inspection findings; operational safety; maintenance; surveillance; performance enhancement program; licensee event reports followup; security; onsite followup of events; fuel receipt; management meetings; and independent safety engineerin Results: Of the 11 areas inspected, no violations or deviations were identified in 10 areas; two violations were identified in the followup of licensee event reports (failure to submit a Special Report in a timely manner and failure to comply with Technical Specification 3.8.2.3., Paragraph 7.b); however, in accordance with 10 CFR 2, Apperdix C,Section V.A., a Notice of Violation was not issued for the failure to comply with Technical Specification 3.8. {DR ADOCK 05000346 DCD o

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P . DETAILS 1. Persons Contacted . Toledo Edison Company (TED) .

D. Shelton, Vice President, Nuclear

• L. Storz, Plant Manager

• N. Bonner, Assistant Plant Manager, Maintenance i R. Flood, Assistant Plant Manager, Operations l *E. Salowitz, General Superintendent Outage and Program Management

• L. Ramsett, Quality Assurance Director S. Jain, Independent Safety Engineering Director I D. Briden, Chemistry Program Manager G. Grime, Industrial Security Director B. Beyer, Nuclear Projects Director

• M. Stewart, Nuclear Training Director M. Schefers, Information Management Director T. Myers, Nuclear Licensing Director J. Scott-Wasilk, Nuclear Health & Safety Director

• P. Hildebrandt, Engineering General Director

• J. Wood, Systems Engineering Director G. Gibbs, Performance Engineering Director V. Watson, Design Engineering Director D. Wilczynski, Configuration Management Engineering Manager R. Scott, Chemistry Superintendent

• G. Honma, Compliance Supervisor

• R. Schrauder, Nuclear Licensing Manager D. Haiman, Engineering Programs Director D. Erickson, Radiological Control Superintendent R. Donnellon, Mechanical Superintendent R. Butler, I&C Superintendent T. Haberland, Electrical Superintendent C. Daft, Technical Planning Superintendent D. Lightfoot, Facility Modification Superintendent L. Young, Licensing, Fire Protection J. Moyers, Quality Verification Manager S. Zunk, Nuclear Group Ombudsman D. Harris, Manager Quality Systems

• J. Sturdavant, Licensing Principal C. Bramson, Document Systems Manager G. Skeel, Nuclear Security Operations Manager L. Wade, Quality Control Manager L. Worley, Configuration Management Implementation Manager E. Benson, Nuclear Materials Manager U.S. Nuclear Regulatory Commission

• P. Byron, Senior Resident Inspector

• D. Kosloff, Resident Inspector

• Denotes those personnel attending the February 19, 1988 exit meetin *

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2. Licensee Action on Previous Inspection Findings (92701) (Closed) Open Item (346/86030-02 (DRP)): Marginally acceptable auxiliary feedwater (AFW) pump performance. The licensee's corrective action was to either increase the AFW pump turbine high speed limiter set point or initiate a technical specification change to require less AFW flow. The licensee chose to initiate both actions. Technical Specification 7.1.2 was changed to reduce required AFW flow from 800 to 600 gpm. In addition, the high speed limiter set points were increased in surveillance test procedures, ST 5071.12,

"Auxiliary Feedwater Pump 1-1 Quarterly Test," Revision 1 and ST 5071.22, "Auxiliary Feedwater Pump 2 Quarterly Test," Revision This item is closed, (0 pen) Unresolved Item (346/87026-01 (DRP)): Three reports of missed fire watches. Licensee Potential Condition Adverse to Quality (PCAQ)

reports87-391, 87-449, and 87-570 identified situations where Technical Specification required fire watches may have been misse During the inspection period, PCAQs88-045 and 88-054 identified similar situation The inspectors and the Region III fire protection specialists will review all five cases collectively, (0 pen) Open Item (346/87026-09 (DRP)): Vehicular traffic into the protected area. The licensee performed a survey of all incoming vehicles from December 17 through 31, 1987. The vehicle search security officer made a subjective determination as to the need for the vehicle to enter the protected are The survey results indicated that approximately twelve percent of incoming traffic had no need for access to the protected are The licensee decided to perform an additional survey which will be performed in March to attempt to validate the results of the December 1987 survey. The inspectors believe that because the period during which the survey was performed included the Christmas holidays, the results were skewed. The licensee is considering reducing the number of vehicles with access to the protected area in order to reduce its window of vulnerabilit No violations or deviations were identified in this are . Operational Safety Verification (71707)

l The inspectors observed control room operations, reviewed applicable logs, j and conducted discussions with control room operators during the months of January and February. The inspectors verified the operability of selected emergency systems, reviewed tagout records, and verified proper return to service of affected component Tours of the auxiliary, turbine, water treatment, and service water I buildings were conducted to observe plant equipment conditions, including

! potential fire hazards, fluid leaks, and excessive vibrations; and to verify that maintenance requests had been initiated for equipment in need

of maintenance. The inspectors, by observation and direct interview, l

verified that the physical security plan was being implemented in

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accordance with the station security plan, l

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- The inspectors observed plant housekeeping and cleanliness conditions and verified implementation of radiation protection controls. During the months of January and February, the inspectors walked down the accessible portions of the Main Feedwater, Reactor Protection, Anticipatory Reactor Trip, Steam and Feedwater Line Rupture Control, Service Water, Emergency Diesel Generator, Essential 120 Volt AC, Essential 4160 Volt AC, Essential 480 Volt AC, Essential 125 Volt DC, Component Cooling Water, and Control Room Emergency Ventilation Systems to verify operabilit These reviews and observations were conducted to verify that facility operations were in conformance with the requirements established under technical specifications, 10 CFR, and administrative procedure No violations or deviations were identified in this are . Monthly Maintenance Observation (62703)

Station maintenance activities of systems and components important to safety and listed below were observed / reviewed tc ascertain that they were conducted in accordance with approved procedures, reaulatory guides, and industry codes or standards and in conformance with technical specification Tne following items were considered during this review: the limiting conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicable; functional testing and/or calibrations were performed prior to returning components or systems to service; quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were implemented; and fire prevention controis were implemented, i

Work requests were reviewed to determine status of outstanding jobs and

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to assure that priority is assigned to maintenance of equipment whi:h is safety related or important to safety which may affect system performance.

l The following maintenance activities were observed / reviewed:

l l * Preventive maintenance of #3 Component Cooling Water (CCW) Pump

• Installation of new solenoids on instrument air dryer valves

• Retrofilling of essential electrical transformer oil l * Installation of a new service water valve for the CCW heat exchanger l

l * Troubleshooting of a reactor trip breaker

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• Preventive maintenance on DC Motor Control Center * Replacement of fuses in a pressurizer heater breaker and main steam valve MS 106 starter. Work on both of these jobs was delayed because replacement fuses were not available on site. The licensee initiated Facility Change Request (FCR) 86-0066 to ensure the proper fuses are available when needed to restore operability of equip.?ent. The completion of this FCR is an open item (346/88002-01(DRP)).

Following completion of maintenance on the Service Water, Component Cooling Water, Reactor Protection, AC electrical, and Main Steam Systems, the inspectors verified that these systems had been returned to service properl No violations or deviations were identified in this are . Monthly Surveillance Observation (61726)

The inspectors observed technical specifications required surveillance testing on the Reactor Protection System, ST 5030.17, "Intermediate Range Prestartup Functional Test," and ST 5030.20, "Reactor Trip Breaker Response Time Test," and verified that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that limiting conditions for operation were met, that removal and restoration of the affected components were accomplished, that test results conformed with technical specifications and procedure requirements and were reviewed by personnel other than the individual directing the test, and that any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personne The inspectors also witnessed portions of the following test activities:

• DB-MI-3001.06, "Channel Functional Test of PSL-4534B, Main Feed Pump 2, Turbine Hyraulic Oil Trip, Anticipatory Reactor Trip System Channel 2"

• ST 5016.02, "Fire Protection System Electric Pump Weekly Surveillance Test"

• ST 5031.24, "Steam and Feedwater Line Rupture Control System Steam Generator Level Inputs Monthly Test"

• ST 5075.01, "Service Water System Monthly Test" No violations or deviations were identified in this are . Performance Enhancement Program (71707)

During 1984 and 1985, the licensee initiated three programs to improve performance in an attempt to alleviate regulatory concerns. The Performance Enhancement Program (PEP) was the first program starte When it became apparent that the PEP was going to be a long term program

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with little immediate impact, the Interim Performance Eahancement Program (IPEP) was developed to provide short term improvements. Subsequent to the implementation of these programs, the licensee experienced the June 9, 1985 loss of feedwater event. A course of action (C0A) program implemented to correct conditions identified by the event, incorporated many elements of the IPEP and PEP program The licensee, however, did not close out those IPEP and PEP items which had been incorporated into the C0A but chose to concurrently maintain three interwoven program The inspectors have reviewed the PEP and IPEP programs and determined that, of the identified items, approximately 80% have been complete In addition, organizational and programmatic changes have caused several of the items to no longer be applicable. The inspectors have inspected approximately 45% of the completed items and determined that the licensee's corrective actions have been adequate. The licensee is tracking all of the IPEP and PEP items on its licensee commitment tracking system (LCTS)

and the corrective action programs are in place. The IPEP and PEP programs are considered to be closed based on the inspector's review of completed items and the licensee's corrective actions. The items which have not been completed will be inspected on a continuing basis as part of the normal inspection process. The following open items are closed:

• 346/RP-06014 Consultant to Update System Auxiliary Diagrams

• 346/RP-09011 QA Supervisor Returned to QA Department

• 346/RP-12012 Verify Drawing Accuracy

• 346/PP-12016 Expedite Facility Change Request (FCR) Closure. The inspectors verified that the licensee has developed a program to expedite FCR closure. The success of this program will be reviewed in the future as part of the normal inspection proces * 346/RP-12019 Computerize Drawing Logs o 346/RP-14013 Compare License Documents to National Fire Protection Association Requirements

• 346/RP-88009 Supervisory - Employee Relations l

• 346/RP-88015 Nuclear Program Procedures

• 346/RP-88016 Hazardous Chemical Safety

• 346/RP-88017 Administrative Control of Software Changes e 346/RP-88020 Improve Integrated Living Schedule Program (ILSP)

i * 346/RP-88021 Improve Project Management Performance / Function t

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. * 346/RP-99013 Integrated Approach to Goals, Objectives and a Strategic P?.in

• 346/RP-99029 System By System Review of USAR

• 346/RP-99036 Increase Backshift Coverage. The inspectors verified that the lit.ensee has a program to provide continuous maintenance coverag * 346/RP-99061 Write Nuclear fraining Procedure * 346/RP-99062 Implemeat Master Training Schedele

• 346/RP-99210 Reduce lifted Wire and Jumper Iog Entrie The inspectors verified that the licensee reduced the number of entries in the log. The inspectors verified that management attention is F.aintained to minimize the number of lifted wires, . jumpers, and temporary mechanical modification * 346/RP-99310 Reduce Maintenance Work Order (MWO) Backlo During previous inspections the inspectors verified that the NWO backlog has been reduce The inspectors verified that management attention is maintained to minimize the MWO backlo * 346/RP-99311 Personnel Shep Facility Constructio The inspectors verified that this structure is complete and in us * 346/RP-99510 INP0 Accreditation. The inspectors verified that LSe licensee was accredited in December 198 * 346/RP-99592 Balance of Plant QA

• 346/RP-99594 QA Training per Division /Depm ment

• 346/RP-99611 Improve the Engineers' Performance

• 346/RP-99613 Configuration Management Program for Davis-Besse

• 346/RP-99615 Commitment Management

• 346/RP-99616 QA Procedures Review Group

• 346/RP-99617 Action Plan for Need, Conduct and Faview/ Approval of Safety Evaluaticas

• 346/RP-99618 Station Review Board (SRB) Perfor. nance Criteria

• 346/RP-99620 Company Nuclear Review Board (CNRB) Training

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1 * 346/RP-99621 Appointment of CNRB Subcommittee for Reviewing / Screening of Routine and Periodic Documents

• 346/RP-99622 Improve Preparation of CNRB Members Prior to CNRB Meetings

• M6/RP-99623 Submit Approcriate Information to the CNRB for their Review

• 346/RP-99624 Provide Procedures to Control Nuclear Safety Related Activities

• 346/RP-99626 SRB Training

• 346/RP-99627 Evaluate the Safety Management Progra * 346/RP-99629 Develop a Failure Analysis Program

• 346/RP-99636 Select a Method for Updating the Stock System

• 346/RP-99637 Improve the Facility Change Request Process

• 346/RP-99638 Improve Toledo Edison /Bechtel Communicatione,

• 346/RP-99639 Establish Realistic Schedules and Clear Priorities The closure of these items does not alter the licensee's earlier commitments to complete related actions or to maintain programs that were establishe No violations or deviations were identified in this are . Licensee Event Reports Followup (92700) Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine that reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had been accomplished in accordance with technical specifications (TS).

(Closed) LER 86-016 Safety Features Actuation Due to Shor (Closed) LER 87-008 Inoperable Safety Features Actuation System (SFAS) Sequence While operating at 100% power, the SFAS Channel 4 sequencer failed its monthly surveillance test ard the sequencer was declared inoperable. TS 3.3.2.1 required that all four sequencars be operabl The licensee entered TS 3.0.3 and commenced shutting the unit dow In addition an Unusual Event was declared in accordance with the Davis-Besse Emergency Preparedness Plan (EP-1500). The sequencer was repaired and the event was terminated with the reactor at 9 percent powe _

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The licensee determined that the requirement to have four sequencers was overly conservative and inconsistent with the general SFA5 desig An emergency TS change was initiated and granted. The licensee determined that the cause of the failure was a degraded power suppl The licensee initiated a preventative maintenance program for the power supplies. The inspectors reviewed the program and this item ,

is close b. The following LER's were reviewed during the inspection period but could not be closed:

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(0 pen) LER 88-001 Seismic Trigger Does Not Meet Technical Specification Frequency Range TC Limiting Condition for Operation (LCO) 3.3.3.3 requires the sei mic monitoring instrumentation shown in Table 3.3-7 (which includes the seismic trigger) be operable at all time On January 6, 1988, the licensee determined that the seismic trigger which was installed on June 25, 1977, does not have the frequency range response that is required by Table 3.3-7. Action statement a. of TS LC0 3.3. requires that whenever one or more seismic monitoring instruments is inoperable for more than thirty days, the licensee must submit a Special Report to the Commission within the next ten days outlining the cause of the malfunction and the plans for restoring the instrument to operable statu The failure to restore the seismic trigger to operability within thirty days and to submit a Special Report to the Commission within the next ten days is a violation of TS 3.3. (346/88002-02). AlthoJgh the TS was violated, the installed seismic trigger met the frequency response of Regulatory Guide 1.12,

"Instrumentation for Earthquakes," and it appears that the TS is overly consarvative. On February 5, 1988, the licensee submitted LER 88-001, which satisfies the Special Report requirement, and is no longer a violation of TS 3.3. The inspectors determined that this violat'on has no safety significance because the seismic trigger has no safety function, it meets the requirements of Regulatory Guide 1.12, ar.d it functioned when an actual seismic event occured in January 198 Prior to the discovery of the inoperable seismic trigger, the licensee had already completed corrective action to prevent recurrence of the violatio The licensee determined that the cause of the violation

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was an improper modification of the seismic trigger that occurred when

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a new seismic trigger was installed on June 25, 1977. An inoperable seismic trigger was replaced with a new seismic trigger on that date, and apparently the licensee did not recognize that the new seismic trigger was a different model with a different frequency respons On September 29, 1987, the licensee released procedure NG-NE-0304 R1,

"Safety Review and Evaluation," for controlled distribution. The inspectors verified that attachment IV to NG-NE-0304 R1 lists systet number 099-02, "Seismic Monitoring System," as a system important to

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safe operation which requires a safety review and a safety evaluation

of any changes. In late 1986 and early 1987, the licensee implemented a formal training program for personnel who perform safety evaluation The licensee is preparing a request for amendmcnt of the TS. If the

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TS amendment is approved, the existing seismic trigger will meet the requirements of the TS. The licensee has also purchased a new seismic trigger which will meet the existing TS requirements. The new trigger is expected to arrive by March 2, 1998, and will be installed upon receipt. The inspectors have reviewed the corrective action and consider it satisfactor The violation is closed. The LER will remain open until the TS is changed and the new seismic trigger is installe (Closed) LER 88 002 Class 1E Battery Charger Placed in Service after Maintenance without All Seismic Qualification Requirements Met TS LC0 3.8.2.3 requires that with the plant in Mode 1, 2, 3, or 4; d.c. bus train "A" shall be energized and operable with two operable full capacity battery chargers in service. With the plant operating in Mode 1, the licensee found that one of the two battery chargers in train "A" (1N) had been placed in service while inoperable and remained in service and inoperable for about 19.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. Action statement b. of TS LC0 3.3.2.3 requires that with only one charger operable, the inoperable charger must be restored to operable status within two hours or the plant must be in at least hot standby within the next six hours and in cold shutdown within the following thirty hours. The failure to restore the battery charger to operable status or place the plant in hot standby within the required time is a violation of TS 3.8.2.3. (346/88002-03(DRP)).

Battery charger 1N was inoperable because its seismic qualification was not maintained. The charger had been taken out of service for maintenance, and backup charger IPN had been placed in servic During maintenance the balance potentiometers on charger 1N were adjusted but not sealed. For the charger to maintain its seismic qualification, its potentiometers must be sealed to prevent movement during a seismic event. Although the charger was properly tested following maintenance, it was placed in service before the potentiometers were sealed. The inspectors reviewed seismic qualification documentation and discussed the seismic qualification of the chargers with licensee personnel. The inspectors found that during the seismic testing of a Class 1E rectifier the potentiometers had changed position, causing voltage fluctuations. During battery charger seistnic testing there was no problem with the potentiometer However, since the battery chargers and rectifiers are almost identical, the manufacturer recommended that the potentiometers be sealed on both types of equipment. Therefore, although it is prudent to seal the potentiometers on the battery chargers, it is not certain that the charger with the unsealed potentiometer would have been affected by a seismic event and if it had been affected it would still have functioned, but possibly in a degraded conditio . _ -

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The licensee's investigation determined, as described in the LER, that the cause of this event was personnel error by nonlicensed maintenance personnel. An erroneous signature placed on the Maintenance Work Order (MWO) during the day shift was not immediately corrected and an individual on the next shift, who was not aware of the error, gave the MWO to the Shift Supervisor who placed the charger in tlervice.

As corrective action the licensee emphasized to all maintenance foremen and supervisors the impertance of all MW0's showing the current status of wor The licensee reviewed the event with operations personnel to make them aware of the potential for errors when MW0's are processed by people who have not been directly involved in the job. The licensee also revised procedure MP 1410.71,

"Battery Charger and Regulated Rectifier Maintenance," by adding a sign-off step for sealing the potentiometer This violation meets the tests of 10 CFR 2, Appendix C, Section V.A; consequently, no Notice of Violation will be issued, and this matter is close While discussing this LER with licensee personnel, the inspectors were unable to determine whether quality control (QC) involvement should have prevented the event. The procedure sign-off sheet attached to the MWO did not have a maintenance engineering staff signature indicating all acceptance criteria had been met and QC reviewed the MWO package before it was released to the Shift Supervisor. The licensee's review of QC requirements in such a situation is an open item (346/8802-04(DRP)).

No other violations or deviations were identified in this are . Security (81074)

The licensee initiated a surveillance program to determine its

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effectiveness in detecting contraband entering the protected area.

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On February 12, 1988, the licensee attempted to transport a weapon into the protected area via pedestrian and vehicular access. The inspectors observed both surveillances. The licensee plans to continue this program by randomly performing the surveillances. The inspectors will periodically observe the performance of these surveillances.

! No violations or deviations were identified in this are . Onsite F_ollowup of Events (62702 and 93702)

During the inspection period, the licensee experienced several events, one of which required prompt notification of the NRC pursuant to 10 CFR 50.72. The inspectors pursued the events onsite with licensee personne In each case, the inspectors verified that the notification was correct and timely, if appropriate, that the licensee was taking prompt and eppropriate actions, that activities were conducted within regulatory requirements and, if corrective action was completed during the inspection period, that corrective action would prevent recurrence. The specific events are as follows:

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o Unusual event, low level in ultimate heat sink due to high wind o Class IE Battery Charger Placed in Service after Maintenance without All Seismic Qualification Requirements Me o Improper surveillance of fire detection system. This event is being reviewed by a Region III fire protection inspector. This is an unresolved item (346/8802-05(DRS)) pending completion of the inspector's revie o Dropped control ro No violations or deviations were identified in this are . Fuel Receipt (60502)

On January 6, 1988, the licensee received its first fuel shipment for the fifth refueling outag Sixty four fuel assemblies were received with the last shipment arriving on January 22, 1988. The inspectors observed receipt inspection of new fuel assemblies and transfer to the fuel storage pit. The inspection was performed in accordance with licensee procedure No violations or deviations were identified in this are . Management Meetings On January 25, 1988, the Director of the Division of Reactor Projects III/IV/V and Special Projects, NRR and the Vice President-Nuclear with members of their respective staffs met to discuss the licensee's upcoming six month refueling outage and also toured the plan On February 2, 1988, the Regional Administrator, the Executive Vice President, and Vice President-Nuclear with members of their respective staffs met to discuss the licensee's preventive maintenance and configuration management programs and the upcoming refueling outag A plant tour highlighted the major modifications to be accomplished during the outag . Independent Safety Engineering (ISE)

ISE performs a nuclear safety overview and audit functio ISE meets periodically with the inspectors to inform them of its activities and to discuss any concerns the inspectort .uay have. ISE also provides the inspectors with its semiannual reports and other reports as requeste ISE informed the inspectors that the Monitor Program, which began in November 1987, was being continued beyond its original duration. The Monitor Program is an independent review of operation, maintenance and administrative activities conducted by monitors who primarily observe activities in the control room. The monitors are appointed by the Vice President - Nuc1 car and their findings are reviewed and evaluated by IS The monitors have been directed to identify potential problems that could

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impact the nuclear safety of the plant, its personnel and equipment, or the general publi ISE reported that so far no safety significant observations have been identified and a significant number of observations have been very positive with respect to the operators' conduct and professionalism in performing their assigned duties. Ongoing and recantly c.ompleted ISE projects were discussed including spray shield program improvements, review of Babcock and Wilcox Topical Reports, de electrical system failure modes and effects analysis, and a review of a temporary loss of heat balance computer calculation capability that occurred during a planned de-energization of Reactor Protection System Channel As a result of questions asked by the inspectors, 10 CFR 50.59 reviews

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and ".he Technical Specification Verification Program were briefly discusse No violations or deviations were identified in this are . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. An unresolved item disclosed during the inspection is discussed in paragraph . Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspectors, and which involve some action on the part of NRC or licensee or bot Open items disclosed during the inspection are discussed il paragraphs 4 and . Violations For Which a "Notice of Violation" Will Not Be Issued The NRC uses the Notir.e of Violation as a standard method for formalizing the existence of a v;olation of a legally binding requiremen However, because the NRC wants to encourage and support licensee's initiatives for self-identificatice and correction of problems, the NRC will not generally issue a Notice of Violation for a violation that meets the tests of 10 CFR 2, appendix C,Section V.A. These tests are: (1) the violation was iuentified by the licensee; (2) the violation would be categorized as Severity Level IV or V; (3) the violation was reported to the NRC, if required; (4) the violation will be corrected, including measures to prevent recurrence, within a reasonable time period; and (5) it was not a violation that could reasonably be expected to have been prevented by the licensee's corrective action for a previous violatio Violation of a regulatory requirement identified during the inspection for which a Notice of Violation will not be issued is discussed in l

Paragraph 7.b.

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16. Exit Interview (30703)

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

throughout the month and at the conclusion of the inspection and summarized the scope and findings of the inspection activities. The

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licensee acknowledged the findings. After discussions with the licensee, the inspectors have determined there is no proprietary data contained in this' inspection report.

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