IR 05000358/1981018
| ML20010B621 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 07/22/1981 |
| From: | Daniels F, Gwynn T, Warnick R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20010B616 | List: |
| References | |
| 50-358-81-18, NUDOCS 8108170349 | |
| Download: ML20010B621 (13) | |
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a U.S. NUCLEAR hEGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-358/81-18
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Docket No. 50-358 License No. CPPR-88 Licensee: Cincinnati Cas and Electric Company 139 East 4th Street Cincinnati, Ohio 45201 Facility Name:
W. H. Zimmer Nuclear Power Station Inspection At:
W. H. Zimmer Moscow, Ohio Inspection Conducted: June 1-5, 8-12, 15-19, 22-26, 1981
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R FID Fue Inspectors-F. T. Daniels 7-22-f/
RF80 W
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T. P. Gwynn 7-22-//
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Approved By:
R. F. Warnick, Chief 7-gg-F/
Reactor Projecta Section 2B Inspection Summary Inspection on June-1-5, 8-12. 15-19, 22-26, 1981 (Report No. 50-358/81-18)
Areas Inspected : Routine resident inspection of Previously Identified Items, Follousp on IE Bulletins and Circulars, Followup Immediate Action Letter, Preoperational Testing Quality Asnurance, Preoperational Test Records, Pre-operational Test Procedure Reviev, Fire Prevention / Protection, Maintenance Procedures, Operations Staf f Trr.ining, and Plant Tours. This inspection involved a total of 185 inspector-hours onsite by two NRC inspectors, including 24 inspector-hours onsite during offshif ts.
Results : Of the eleven areas inspected, ten were found to be satisfactory and one item of noncompliance was identified in the area of Preoperational Testing Quality Assurance (Violation of 10 'CFR 50, Appendix B, Criterion XVI, j
Corrective Action, Severity Level IV).
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8108170349 810730 -
PDR ADOCK 05000358 G
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Personnel Contacted
- J.
R. Schott, Plant bbnager
- H.
R. Sager, Quality Assurance Manager
- S. C. Swain, CG&E Construction Project Manager
- J. J. Wald, Station Quality Engiccer M. F. Rulli, CG&E Quality Engineer W. T. Gott, Training Coordinator J. C. Buck, CG&E Lead QA Auditor P. I. Adkins, CG&E Lead QA Auditor J. F. Schaeffer, GED W. D. Waymire, Manager GED S. E. Martin, Professional Engineer B. Varchol, KEI QA Training Coordinator P. Kyner, KEI QA Manager C. Schroeder, KEI Turnover Ccordinator M. B. Hill, EPD Office & Document Control Supervisor R. Ballow, GE System Engineer D. M. Outcault, EPD Tech Staff Engineer R. E. Donnellon, EPD bbintenance Supervisor and others of the station staff.
- Denotes those attending monthly exit interview.
2.
Licensee Action on Previously Identified Items (Closed) 10 CFR 50.50(e) Reportable Item, M-17, Diesel Generator Oil Cooler Failure.
The water box was repaired, hydrostatically tested and the diesel was successful load tested for eight hours with no evidence of oil or water contaminatlon.
(0 pen) Unresolved Item (50-358/80-21-01): Reevaluation of Fire Ptaplans.
The inspector verified that the licensee is taking action to resolve identified problems with these preplans, however that action is not complete. This item will be the subject of a future inspection.
(Closed) Unresolved Item 50-358/81-07-01): Comprehensive QA Audit similar to the requirements of the Startup Manual for Preoperational turnover packages.
This item has been upgraded to Noncompliance (50-359/81-18-01).
(0 pen) Unresolved Item 50-358/79-38-03):
Responsibilities Not Assigned For Establishing Retention Periods For Records.
The inspector determined that the licensee is attempting to develop the required administrative controls. This item will be followed up in a future inspection.
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(Closed) Unresolved Item (50/358/81-15-03): Lack of guidelines for-
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- CC&E Review of' HJK Surveillance Report as per 1 tem 9 of '8 April 1981
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Immediato Action Letter.
The inspector verified that guidelines have been established for above-said review by CG6E.QI. Group procedure,1 Review. and Disposition of HJK ~
Surveillance Reports.. (10-QA-06, revision 00)
3.
IE Bulletin Followup For the"IE Bulletins listed below the inspector verified that the.
written response was within the time period stated in. the bulletin, that the written response included the irformation required t'o.be
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reports 3, that the written response included adequate corrective action commitments based on information presentation in the bulletin and the-licensee's response, that. licensee management forwarded copies of the written; response to the appropriate.onsite management representatives, that information discus.d in the licensee's written response was accurate, and.that corrective action taken by.the licensee was as described in the~
written response.
(Closed) IE Bulletin 80-05: Vacuum Condition Resulting in' Damage to Chemical Volume Control System (CVCS) Holdup Tanks.
4.
IE Circular Followup.
For the IE Circulars listed below, the inspector verified that the Cir-cular was received by the licensee management, that a review for applica-bility was performed, and that if the circular was. applicable'to the'
facility, appropriate corrective actions were taken ' or were scheduled to be taken.
(Closed)IE Circular 79-05: Moisture Leakage in Stran'ded Wire Conductors.
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(Closed) IE Circular 80-11: Emergency Diesel Generator Lube Oil Cooler Failurc'.
5.
Followup on Immediate Action Letter (I AL) Dated April 8,1981.
The inspectors reviewed the licensees progress in the implementation of the various requirements imposed by.the I AL.
The results of the inspec-tion were:
a.
Item 1 - Concerning QA Staffing
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The CG&E QA staff was still being increased and as of June-29,1981
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l it was still 7 individuals short of the projected necessary staffing level. The work load of the QA engineers is still quitel great,' but
as the last-few individuals are' acquired and some of the requirements
Imposed by the IAL are completed, this work load will become less.
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The majority of the new personnel-are contract individuals'and only
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three-are new CG&E employees. These' individuals are-re, at college
. graduates, therefore it will take at least a year for them to become qualitied Quality-Engineers.-
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Item 3 -- Concerning QC Inspections The QC inspection staff was only fr ar individuals short of. the new projected staffing level of 32.-
All but three inspectors are con-tract individuals, but the licensee intends to acquire eight quali-fled inspectors to become part of the CG6E staff.
i There still was sufficient inspectors on site to perform the required reinspections of ongoing construction activities,
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Item 4 - Concerning QC Inspection Procedures The administrative review of all QC inspection procedures has been -
completed by CG&E and HJK Company. The next phase will be the tech-nical review (i.e. code compliance, inspection criteria, etc...).
The Region III USNRC Technical staff' will continue to provide a -fur-ther review of some of the. procedures.
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Item 5 - Concerning Training The inspector verified that both KE1 and CG&E QC Inspectors were receiving necessary training as inspection procedures were revised, that inspection supervisors were being kept abreast of the status of inspector ' qualification, and that training records were being -
maintained current for QC inspectors. One discrepancy noted in the qualification requirements for a CG&E QC (electrical) inspector was-
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corre;ced immediately.
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Item 8 - Concerning QA/QC _ Records
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There has been no significant progresa made since the last inspection of this area (refer to IE Inspection Report 50-358/81-15).
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Ite n 9 - Ccreerning Condition Adverse to Quality The guidelines have been es'tablished and procedures written for the CG&E QA Group to insure Nonconformance- (NR).and Surveillance (SR)-
reports issued by HJK Group are reviewed, evaluated and dispositioned p roperly. These actions were considered adequate to closecut unre-solved item 50-358/81-15-03.
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Item 10 - Concerning the Ac3it Program The licensee was in the process of developing a new revised audit-
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schedule and implementing procedures for a new comprehensive 'atdit program. Also, the : surveillance program to audit ongoing construc--
tion activities-is.still in the developmental stages. During the interim, since 8 April 1981 Immediate Action T-er, 100% reinspec-
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tion has been and will continue' to be na by the CG&E QC e
- 0-358/81-15-04 is inspection group. Therefore, unresolve u.
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still considered open and the development of the ~ surveillance pro-gram will be followed up in subsequent inspections.
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6.
Preoperational Testing Quality Assurance The inspector verified that the licensee's program for QA/QC surveillance and audit of preoperational testing activities has continued to be implemented as described in previous IE inspection reports (refer to 50-358/80-14, 80-21, 80-26,-and 81-07).
In particular, the inspector verified that revision made to a previously reviewed procedure conformed to applicable standards and regulatory guidance; that selected audits and surveillance activities performed since the last inspection of this area were performed in.accordance with approved procedures as designated by surveillance schedules; that deficiencies identified during the performance of preoperational testing activities were being controlled via the nonconformance reporting system; and that nonconformance reports were being dispositioned by the station material review board.
In addition, the inspector attempted to verify that the licensee's surveill-ance and audit of preoperational turnover activities from construction to the Electric Production Department were being conducted in accordance with established procedures or checklists, and that corrective actions for any discrepancies identified were being taken in an appropriate and timely fashion.
a.
Documentation Reviewed (1)
QA. SAD.07, Revision 03, Operational QC Inspection Program dated April 11, 1981 (2)
_ Station Audit EC-ME-06, Work Requests dated May 29, 1981 and response (3)
Station Audit RP-RC-02, Radiation Protection dated March 12, 1981 (4)
Nonconformance Report 81-74-E dated May 28, 1981 (5)
CG&E Startup Manual, Revision 05 dated July 25, 1979 (6)
QA&S Field Audit Report #322 dated July 17-18, 1980 (7)
QA&S Field Audit Report #351 dated April 24, 1981 (8)
System Index Test bbtrix for PT-VC-02 (9)
System Index Test Matrix for PT-VG-01 (10)
QA&S Field Audit Report #354 dated June 22, 1981
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b.
Findings (1)
During the last inspection of this area, an unresolved item was disclosed (50-358/81-07-01) concerning Startup Manual requirements which were not reflected in the implementing p rocedures. Of particular concern to the inspector were the QA requirements of Section 6.3.2 and 6.3.3 which had been deleted from the implementing procedures.
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this concern, the CG6E QA Fbnager commited to performing a comprehensive audit similar to that required by the Startup Manual for preoperational turnover packages. The audit was to include a representative sample of both turned ov'er systems and systems being readied for turnover, and was to be completed by April 8,1981. Reference a.(7) above is the audit report.
Reply to these audit findings was requested by Fby 25, 1981 but had not been received by June 12.
Four of the audit check-list items were not completed "due to priorities which occurred during the conduct of the audit." This audit report did not address the concerns expressed in unresolved item 81-07-01.
This was brought to the attention of the CG&E Q4 lbnager several times, including a followup report on unresolved item 81-07-01 in IE Inspection Report #81-15, but no action was taken.
Therefore, the inspector audited two system index test matrices; one for the VG System (compiled before deletion of the imple-mentation of the Startup Manual QA requirements), and one for the VC System (compiled after deletion of the implementation of the Startup bbnual QA requirements).
The inspector found that construction test documentation con-tained in the VG turnover package was complete end certified complete by H. J.. Kaiser QA.
One discrepancy was found in the
. documentation for construction test HVAC-5 performed on filter package IVG05SB; the maximum allowable leakage was identified as 2.25 CFM and the measured leakage was identified as 3.30 CFM.
This discrepancy was brought to the attention of the cognizant construction engineer who identified nonconformance report #7451.
(This nonconformance report, dispositioned accept as is, has been included in the PT-VG-01 turnover package for completeness.)
The construction test documentation contained in the VC turnover package was incomplete..In particular, the following test documentation was not included:
(a)
EC-1 forms were not included for the following cables:
VC-231#, 311#, 312*, 313, 335*, 397, 400, 401, 710 VR-060 thru VR-139 inclusive *
VT-115 thru 117, 120 thru 148, and 150 thru 167 inclusive *
VW-085 thru 089 inclusive *
VX-128 thru 148, and 156 thru 205 inclusive *
VY-070 thru 075 inclusive *
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Various test documentation sas missing pertaining to verification of the following S&L-E1010 electrical design drawings:
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Drawing Missing Documentat' ion E1010 Pg. VC 12
.EC-12#
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VC 15 EC-12
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VC 16 EC-11, 12, 13
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. VC 17
'EC-11, 12#, 13
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VC 24-EC-12
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VC 25 EC-12, 13
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VT 17'
EC-12, 13 :
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VR 11 EC-12, 13
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VC'28
'EC-12, 13
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VC 27 EC-12
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VC 26 EC-12, 13
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VC 23 EC-12, 13
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VW 06 EC-12, 13
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VX 12 EC-12, 13
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V 03 EC-12, 13 The turnover' coordination group (TCG) was initially unable to produce any of the aforementioned documentation,.however,' items marked with an asterisk (*) were subsequently located misfiled in their area.
Inspection at the Electrical Operating and Test Department (EOTD)
revealed that the items marked with a pound (#) had completed test documentation on file (only a cross-sectional sample-of the missing documentation was checked by the inspector). However, it was determined that an annunciator verification test -(EC-11)-
had not been performed for E1010 Pg. VC-17. ' This may also be ~
the case with other tests which were' not' included in the sample.
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These outstanding test requirements were not identified on the system punchlist prior to turnover for preoperationsl. testing-as required by SU.PRP.01.
The results of this NRC audit, were immediately brought to 'the uttention of licensee personnel and were ' subsequently 'the, subjectL of a meeting between the NRC. resident inspectors-and the CC&E Managers of GED and QA. A CG&E Audit (CG&E QA Audit-Report #354 dated June. 22, 1981) conducted subsequent to this meeting as a result of the NRC findings failed to identify any problem with construction test documentation in package PT-VC-02.
l-The inability of CG&E QA&S to take appropriate action, _ to identify,'and to correct this problem which has been repeatedly
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brought to-the attention of the CG&E QA Manager by NRC inspectors
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is in noncompliance with 10 CFR-50, Appendix'B, Criterion XVI~
and the Wm. H. Zimmer Quality. Assurance Manual, Section 16.1:
which states'in part that the QA Division of CG&E is responsible:
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for evaluating QA program deficiencies identified by project
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participants and'that the corrective action.-required.to eliminate
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the deficiencies,' assurance that corrective action'is taken and appropriately documented, and reporting such deficiencies and corrective actions to appropriate levels of management is I
the responsibility of QA.
(50-358/81-18-01)
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~(2) The TCG did not have-the' latest revision of-SU.ACP.14 and.
SU. ACP.19 in their controlled copy of the startup administra-
tive and' proj ect procedures. - This was brought to the attention of EPD Document Control. Also, this controlled copy manual,
. contained copies of SU.ACP.06, 09, 11, 12, and 15, all of which had been previously cancelled. 'This was corrected immediately by-the turnover coordinator.
(3) The cognizant' system engineers signature did not appear.on the -
first page.of the VC SITM as required by SU.PRP.06, Section 5.4.
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This_ finding is similar to CG6E AFR #351, item #2 for the VV and RR Systems.
7.
Preoperational Test Records-The inspector verified that administrative controls have been established.
'and implemented for maintaining records of preoperational activities, for recrods storage, and for records retention as required by the Wm. H.
Zimmer FSAR, ANSI N45.2.9:- 1974,'and applicable regulatory guidance.
(a) Documentation Reviewed-(1)
RM. SAD.01, Revision 00, Records Management dated July 3,^1978 (2).
MM. SAD.01, Revision 01, Station Maintenance dated May 14, 1979 (3)
MM. SAD.02, Revision 02, Preventive Maintenance dated February 8,:
1980 (4)
SU. ACP.0'4, Revision 04, Preparation, Review, Approval, and -
Revisions to Preoperational Test Procedures dated April 19, 1979 (5)
SU.ACP.05, Revision 10, Conduct of Preoperational Tests dated April 2, 1981 (6)
SU. ACP.07, Revision 06,- Qualifications of Preoperational Test Personnel dated April 2,1981 (7)
US.ACP.13, Revision 05, Processing of Engineering Change Requests dated January 16, 1981 (8)
SU.PRP.01, Revision 13, System Release and Turnover dated Novem-ber-11, 1980 (9)
SU.PRP.04, Revision 05, Punchlist Item Completion and Maintenance In Turned Over and Non-Turned Over Areas dated July 22, 1980'
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SU.PRP.06, Revision 00, Generation and Control of the System Index Test Matrix dated December 4, 19_80
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SU.PRP.09, Revision 00, Turnover Group Records ' dated August 27, 1980 (12)
.TR. SAD.01, Revision 00, Station Training Progsam dated May - 11, 1978
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(13)
QD.QAI.15, Revision 00, Disposition of QA/QC Group Quality Assurance Records dated January 7, 1981 (14)
RC.RPP. 1.211, Revision 07, Radiation Exposure Records and Reports dated February 5,1981 (15)
DC.DCP.02, Revision 02, Transmittal of Documents and Records dated March 21, 1980 (16)
DC.'JCP.03, Revision 02, Operation of the Central File dated September 14, 1979 (17)
DC.DCP.05, Revision 00, Destruction of Documents, Records, and Reports dated September 14, 1979 (18)
DC.DCP.06, Revision 02, Procedure Control dated September 14, 1979 (19)
DC.RIC.05, Revision 00, Hard Copy File Maintenance dated October 23, 1980 (20)
DC.RIC. 06, Revision 00, Document Disposition dated October 23, 1980 (b)
Findings (1)
DC.DCP.03, Section 3.7.1 described acceptable present practice for controlling DDC's at the station while the station document control center is acting as a sattelite of the construction document control center. However, if the station becomes the central location for controlling DDC's (ie: upon completion of construction), then the practice of Section 3.7.1 would not be acceptable for control of lifetime records. Also, Section 3.7.2 refers to " VOIDED" nonconformance reports (NR's).
Reference to QA. SAD 06, Nonconformance Reporting, reveals that there is no provision for voiding NR's.
These items were brought to the attention of the Office and Document Control Supervisor for his information and possible action.
(2) DC.DCP.05 fulfills the requirement of Regulatory Guide 1.33, Appendix A, as the general administrative procedure for record retention and is classified by Regulatory Guide 1.33 as " safety-related". However, this procedure was prepared in accordance with the requirements of SA. SAD.06, Review, Approval, Issue, Revielon, and Useage of Implementing Procedures, as a nonsafety-related procedure (ne independent review, no SRB cpproval, etc.)
This was brought to the attention of the Office aad Document Control Supervisor and the Station Quality Engineer who stated that their final action on unresolved item (50-358/79-38-03)
would address this concern.
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(3)
The records storage facility is under construction as part of the service building addition. The records storage facility and controlled environment conditions of ANSI N45.2.9-1974 should be satisfied upon completion of construction.
(4)
The inspector selected three types of records (preventive maintenance, corrective maintenanca, and turnover system index test matrices) and verified that these records are being maintained and are retrievable as described in the implementing procedures.
No items of noncompliance or deviations were noted.
8.
Preoperational Test Procedure Review The inspector reviewed the Reactor Core Isolation Cooling System pre-operational test procedure PO.RI 01, Revision 01 dated bby 11, 1981.
This included a review for proper management review and approval, procedure format, test objectives, prerequisites, acceptance criteria, initial test conditions, references, proper administrative test controls, and a sample check for technical adequacy of the detailed step-by-step procedure. Several minor comments were discussed with the cognizant system engineer.
No items of noncompliance or deviations were noted.
9.
Fire Prevention / Protection The inspector verified that fire protection system surveillances were being conducted in accordance with a schedule; that fire fighting equipment was inplace in the control room, cable' spreading room, on the refueling floor, and in selected areas of the reactor building, and had been recently tested; that control room panel interiors and the cable spreading room were free of combustible materials; and that no obvious fire hazards existed in selected areas of the reactor building. No independent fire inspections have been performed since the last inspection in this crea.
a.
Documentation Reviewed (1)
Surveillance results for the following surveillance p rocedures :
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FE.SFP.721, FP Diesel Weekly Battery Check (b)
ME.SFP.722, FP Diesel Quarterly Battery Check (c)
OP.SFP.714, FP Electric Pump Operability Test (d)
OP.SFP.718, FP Diesel Operability Test (e)
OP.SFP.736, FP System Valve Lineup Check
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Findings (1)
The inspecter noted that.:able tray 2080K in the cable spreading room contained lumber (a 1" x 12" x 6' plank)
and foam rubber padding. This material was removed by the licensee.
(2)
The inspector observed that the fire hose in station 1FP-33M on the 575 foot elevation of the reactor building was disconnected from the fire header. This was re-attached immediately by operations personnel.
(3)
Although control room panels were free of combustible materials, the inspector noted the accumulation of dust in the cabinet interiors.
This was of particular concern since several multi-layer switches provided with dust covers were missing their dust covers and are therefore susceptible to contact fouling. This was brought to the attention of EPD management.
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No items of noncompliance or deviations were noted.
10.
Maintenance Procedures The inspector reviewed maintenance procedures to determine their ade-quacy for control of maintenance on safety-related systems and components.
This included a detailed review for procedure scope, technical content, and appropriate format.
a.
Documentation Reviewed (1)
ME.RFP.3.04, preliminary draf t, Steam Separator Removal and Installation (2)
ME.RFP.4.01, preliminary draf t, Drywell Head Removal (3)
ME.RFP.3.03, preliminary draf t, Steam Dryer Removal and Installation (4)
ME. CMP.4.04, preliminary draft, D'esel Main Bearing Replace-ment.
b.
Findings (1)
The draft maintenance procedures, although incomplete, generally reflect the minimum format requirements imposed by the station administrative directives.
(2)
Two of the draft maintenance procedures do not have QC hold or witness points specified. This will be rectified in the review process.
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' The W'. ' H. Zimmer Master Procedures Index does not reflect (3)
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all outstanding maintenance procedures to be written.
In particular, surveillance procedures ' required to satisfy-
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technical specifications requirements were not included on the list.
The maintenance supervisor-stated that this omission will be corrected.
-No items of noncompliance or. deviations were'noted.-
11.
Operations Staff Training The -inspectors verified.that the operating staff.was being trained 1
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utilizing a continuing training program, although, some facets aof various programs aren't being conducted until just prior to fuel load, that the on-the-job training requirements have been established for the various categories of personnel assigned at the station, and that responsibilities. for evaluation of the various training programs has been-assigned.
a.
Material Reviewed (1)
Documents (a)
Wm. H. Zimmer FSAR, Chapter.13.2, Training Program (b)
ANSI N18.1-1971, Selection and Training of Nuclear:
Power Plant Personnel.
(2). Trainir.g Records (a)
Two Preoperational/Startup Engineers (b)
Two Staff Supervisors'
(3)
Procedures (a)
TR. SAD.06, Revision 00, Rad / Chem Technician Training (b)
QA. SAD.08, Revision 01, QA/QC Personnel' Qualifications Requirements b.
Findings (1)
- Some clerical errors were noted in_ personnel training records.
These were either already being corrected or were corrected immediately by the Training Coordinator.
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(2)
The previously identified unresolved-items in the area of
~ training (#80-17-01, #80-21-03 and #81-01-01) are stillecon-sidered open and will be reinspected 'during subsequent inspec-tions.
No items of-noncompliance or deviation were noted.
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12.
Plant Tours The inspector noted burnt and partially charred paper trash lying in the area of the fourth level, RHR Heat Exchanger Room 'B'
in the reactor.
building. This appeared to be the scene of an unreported fire.
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area continued to be a' fire hazard. This was - brought to the ~ 'tention of the licensee and was cleaned up immediately.
The inspector noted a heavy accumulation of paper trash in the area of the water reservoirs for the 'B'
and 'C'
Diesel Generators. This potential-fire hazard was brought to the attention of the licensee and was cleaned up immediately.
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13.
Exit Interview-The inspectors met with licensee representatives (denoted in paragraph 1)
at the conclusion of the inspection on June 26, 1981. The inspectors summarized the scope and findings of the inspection.
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