IR 05000397/1990028
| ML17286A549 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 12/28/1990 |
| From: | Johnson P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17286A548 | List: |
| References | |
| 50-397-90-28, NUDOCS 9101150115 | |
| Download: ML17286A549 (33) | |
Text
e U.S.
NUCLEAR REGULATORY COMMISSION REGION V
Report No:
Docket No:
Licensee:
Facility Name:
50-397/90-28 50-397 Washington Public Power Supply System P. 0.
Box 968 Richland, WA 99352 Washington Nuclear Project No.
2 (WNP-2)
Inspection at:
WNP-2 Site near Richland, Washington Inspection Conducted:
October 22 - December 2, 1990 Inspectors:
R.
C. Sorensen, Senior Resident Inspector D. L. Proulx, Project Inspector (November 13 - 16, 1990)
Approved by:
o nson, se Reac Projects Section
ate
>gne Summary:
Ins ection on October 22 - December 2,
1990 Re ort No. 50-397/90-28
Areas Ins ected:
Routine inspection by the resident inspector and project inspector of control room operations, licensee action on previous inspection findings, operational safety verification, engineered safety features (ESF)
status, surveillance program, maintenance program, licensee event reports, special inspection topics, procedural adherence, and review of periodic reports.
During this inspection, Inspection Procedures 61726, 62703, 71707, 90712, 90713, 92700, 92701, 92702 and 93702 were utilized.
Safet Issues Mana ement S stem SINS Items:
None.
Results:
General Conclusions and S ecific Findin s Si nificant Safet Matters:
Deviation from the Master Data Sheet approved specifications for a containment isolation valve motor operator without Plant Technical or Generation Engineering concurrence (paragraph 12).
91'011501i5 902228 PDR ADQCl( 05000391
r
)
-2-Summar of Violations and Deviations:
None.
However, two issues were left unresolved see paragraphs 9, 12, and 13).
0 en Items Summar
Two followup items, one deviation, one violation, one unresolved item, and four LERs were closed.
Three new items were opene,
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DETAILS Persons Contacted
- J. Baker, Plant Manager
- L. Harrold, Assistant Plant Manager S. Davison, guality Assurance Manager C. Edwards, guality Control Manager
- R. Graybeal, Health Physics and Chemistry Manager
- J. Harmon, Maintenance Manager A. Hosier, Licensing Manager R. Koenigs, Generation Engineering Manager
- S. McKay, Operations Manager
- J. Peters, Administrative Manager G. Gelhaus, Acting Technical Manager W. Shaeffer, Assistant Operations Manager R.*Webring, Assistant Maintenance Manager The inspectors also interviewed various control room operators, shift supervisors and shift managers, and maintenance, engineering, quality assurance, and management personnel.
- Attended the Exit Meeting on December 3, 1990.
Plant Status At the start of the inspection period, the plant was operating at 100%
power.
On October 24, Generation Engineering discovered a design defi-ciency in that Class 1E power fo various control room instrumentation (Divisions I and II) had been cross-connected to non-Class.
1E power.
This placed the plant outside the design basis.
Technical Specification 3.0.3.
was entered, an Unusual Event (UE) was declared, and a plant shutdown was initiated.
The problem was corrected within an hour of the UE declaration, and power was restored to 100% shortly thereafter (refer to Paragraph S.b for further discussion).
On October 30, the licensee discovered that emergency diesel generator (EDG) fuel oil samples sent to a contractor for analysis were not being analyzed per Technical Specification-approved testing methods, and thus were not meeting the surveillance requirement.
Since this affected all three trains of EDGs, Technical Specification 3.0.3 was entered and an Unusual Event was declared.
The NRC granted a temporary waiver of compliance for seven days until diesel fuel could be analyzed by the contractor using a Technical Specification-approved method.
On October 31, an indication of a possible crack was discovered in a socket weld on a test connection downstream of the. high pressure core spray (HPCS) injection valve.
On November 2, the licensee determined through use of ultrasonic testing methods that the indication was a
crack about 30Ã through-wall (see paragraph 9).
The decision was made to shut down the plant to repair the crack.
Cold shutdown was achieved on November 3.
After testing over 100 other welds and repairing the cracked socket weld, the plant was restarted on November 10.
Full power was achieved the week of November 1 I[i I
Power was reduced on November 15 to troubleshoot vibration problems on the "B" reactor feedwater pump turbine.
Power was again reduced on November 20 to troubleshoot level control problems on the.6B feedwater heater.
The plant achieved 100K power again on December 2 and remained there through the end of the report period.
3.
Previousl Identi fied NRC Ins ection Items 92701 92702 The inspectors reviewed records, interviewed personnel, and inspected plant conditions relative to licensee actions on previously identified inspection findings:
a.
Closed Deviation 397/89-31-01:
Li htin Not Established er FSAR in RHR Va ve Rooms This deviation concerned a lack of lighting in an RHR valve room on the 471'evel of the reactor building, found during an inspection in October 1989.
The FSAR committed the licensee to provide lighting in this room, but all the lighting was found burned out.
In response to this deviation, the licensee committed to a number of actions, including:
Revising PPM 10.25.63,
"Emergency Lighting Inspection," to be more specific about (1) the types of inspections needed for each type of battery unit and (2) maintaining emergency lightina battery electrolyte levels.
Revising PPM 10.25.64,
"Normal and Emergency Lighting," to formalize the process =for plant lighting inspections, ensuring uniformity in inspections performed and records maintained.
Marking all accessible normal emergency lighting and emergency reserve ballast lighting with blue stickers to distinguish them from normal plant lighting and requiring immediate action if they are found burned out.
A memorandum to this effect was circulated to all plant personnel.
The inspector verified that these actions had been carried out as coranitted in the licensee's response letter.
This item is closed.
i,l b.
Closed Foll owu Item 397/90-04-01:
Review Overhead Crane Survei ance This item dealt with performance of the overhead crane surveillance test.
This test ensures that crane interlocks are operable and that the crane hook stops at certain distances from.-the spent fuel pool.
The procedure contained specific guidance that these distances may be estimated from the refueling floor, implying that two individuals were needed to perform the procedure, one to operate, the crane from the cab.and one to estimate the distance from the floor.
However, at the time only one individual was present to perform the procedure.
This did not appear to the inspector to meet the intent of the procedur I t
Maintenance management representatives stated at the time that the intent of the procedure was only to verify the operability of the crane interlocks, as required by the Technical Specification surveillance test, and not to measure specific distances.
That was accomplished by a specific maintenance procedure performed yearly.
These licensee representatives agreed to revise the procedure to-reflect this.
The inspector reviewed the revised procedure and found that it met the Technical Specification requirements and that it contained guidance that the distances the crane hook was to stop from the fuel pool were only approximate and not exact.
In addition, the inspector reviewed documentation of past performances of this, surveillance test and interviewed other crane operators and concluded that the test had been consistently performed with two individuals.
This item is closed.
Closed Violation 397/90-10-02
Failure to Post a Hi h
Radiation Area In May 1980 the inspector had discovered that the access to the "A" residual heat removal (RHR) heat exchanger room was not barricaded and conspicuously posted as a high radiation area.
The HP technician who was in the room earlier had removed the posting in order to facilitate the removal of equipment from the room.
A formal root cause analysis conducted by'the licensee concluded that the contract HP technician had forgotten to replace the barrier and posting upon leaving the room.
A contributing cause was identified to be insufficient supervisory overview of contract technician per-formance.
The technician was counselled on radiological posting requirements and performance expectations.
General Employee Training has been revised ho include additional emphasis on radiological control requirements.
Improvements have also been implemented with regard to radiological postings.
Specifically, additional postings will be provided at certain r adiologically controlled areas.
Finally, a reorganization of the Health Physics and Chemistry Department in September 1990 was partially in response to this violation, and could lead to improvements in work control, ALARA, and waste management.
This item is closed.
of P ant Mana ement Efforts e ate o Eat n
sn t e a
o o 1ca Contr ol led Area RCA Closed Followu Item 397 90-03-01
Followu on 'Effectiveness
The inspector had identified several indications of eating, drinking and smoking in the RCA, including candy wrappers, cigarette butts, and a beverage can.
Other observed evidence included chewing gum and sunflower seeds.
Although the inspector did not see anyone actually engaging in these activities, the concern was brought to the attention of plant managemen Plant management issued a memorandum to.all plant personnel on karch 9, 1990 reminding them about the need to refrain from eating, drinking, smoking, and chewing in the RCA.
Several weeks 1 ater, plant management requested plant gA to conduct a surveillance to verify compliance with the policy regarding eating, drinking, or smoking in the RCA and to evaluate the effectiveness of their attempt to sensitize plant personnel in this regard.
Plant gA concluded that plant personnel were complying with the policy.
II This item is closed.
e.
Closed)
Unresol ved Item 397/90-10-01:
Alarms on Friskers Mere Sut f The inspector had observed on three separate occasions that alarms on personnel friskers had been turned off.
Further followup was needed to determine whether this was contrary to plant procedures.
I The inspector determined that plant procedures do not require the alarm on the personnel friskers to be set at 100 counts per second above background-;
However, the licensee readily acknowledged that this feature is a benefit to persons using the friskers to warn them of potential'contamination.
All friskers are given a source check daily by the HP staff and part of the source check procedure is to check the alarm setpoint of the frisker.
HP management has surmised that the reason the alarm function was shut off on some friskers is that they also are often used for detecting contamina-tion of equipment and materials, which may be highly contaminated.
However, standard practice is to reinstate the alarm function, with the setpoint consistent with background radiation.
The HP super-visor,reminded the HP technicians to ensure that the alarm function on friskers is maintained operable for personnel benefit.
The inspector interviewed a sample of HP technicians to assess their familiarity with the source check procedure to ensure there was not a programmatic problem with the alarm setpoints.
No problems were
'identified.
This item is closed.
4.
0 erational Safet Verification 71707 a ~
Plant Tours Portions of the following plant areas were toured by the inspectors during the course of the inspection:
Reactor Building Control'oom Radwaste Building Service Water Buildings Yard Area and Perimeter
b.
The (i)
(2)
following items were observed during the tours:
0 eratin Lo s and Records.
Records were reviewed against Technical Specification and administrative control procedure requirements.
Monitorin Instrumentation.
Process instruments were observed for correlation between channels and for conformance with Technical Specification requirements.
(3)
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d lif ig b
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- for conformance with 10 CFR 50.54(k), Technical Specifica-tions, and administrative procedures.
The, attentiveness of the operators was observed in the execution 'of-'their'duties and the control room was observed to be free of distractions such as non-work related radios and reading materials.
E ui ment Lineu s.
Valves and electrical breakers were verified to be in the position or condition required by Technical Specifications and administrative procedures for the applicable plant mode.
This verification included routine control board indication reviews and conduct of partial system lineups.
Technical Specifications limiting conditions for operation were verified by direct observation.
As part of this effort during this inspection period, the inspector interviewed several control room operators to assess their knowledge and understanding of various control room annunciators.
While; the control room staff was found to be very knowledgeable and aware of annunciators on the front panels of the control room, weaknesses were observed in this regard on certain back panels.
For example, trouble lights for sample racks SR-20 and SR-21 were not well understood.
Operations management was encouraged to ensure that operators are aware of all control room annunciators:and.their opera-tional significance.
The Operations Manager acknowledged the inspector's comments subsequent to the exit meeting.
(5)
E ui ment Ta in.
Selected equipment, for which tagging re-quests a
een )nitiated, was observed to ver'ify that tags were in place and equipment was in the condition specified.
General Plant E ui ment Conditions.
Plant equipment was observed for indications of system leakage, improper lubrication, or other conditions that would prevent a -system
'from fulfilling its functional requirements.
Annunciators were observed to ascertain their status 'and operability.
Fire Protection.
Fire fighting equipment and controls were f
ih lii< through wall.
Repair of the weld necessitated draining of the associated piping, also requiring opening of the vent connection isolation valve.
Because this would have compromised primary
containment integrity, the licensee shut down the unit to effect repairs.
This was accomplished on November 2.
The socket weld on the HPCS injection line drain connection was repaired.
Engineers from Generation Engineering analyzed the weld failure and determined that the cause of the crack was a preexisting flaw, propagated by approximately four HPCS injections since plant startup.
(This is more thoroughly discussed in inspection report 90-27).
Over 100 other welds in several other ESF systems were examined by dye penetrant testing for evidence of similar type failures.
None were found.
While the licensee's actions in response to.these cracks. in the.HPCS system were considered to be aggressive and respons'ible, problems of an identical nature have occurred in the past (see inspection* report 89-17)
and an opportunity was missed at that time to deal with them effec-tively.
As documented in that inspection report, the Assistant Plant Manager agreed at that time to assess vibration problems on the HPCS test return line to the suppression pool and correct them by the end of the 1990 refueling outage (R-5).
Furthermore, an identical problem was experienced with HPCS-V-23 in November 1989 in that it failed to stroke fully closed against pump discharge pressure (see LER 89-43).
While the licensee inspected the internals of the valve during R-5, apparently no assessment was made of the Limitorque actuator and the status of the various torque and torque bypass switches, as well as the spring pack.
At the exit meeting, the Plant Manager agreed to provide the inspector a synopsis of actions taken prior to and during R-5 to deal with the HPCS vibration and cracking problems, as well as a discussion of actions taken during R-5 for HPCS-V-23.
NRC concerns regarding the repetitive nature of these problems were also discussed following the SALP manage-ment meeting on November 28, 1990 (Meeting Report No. 397/90-30).
This issue remains unresolved (Unresolved Item 397790-28-01).
During the shutdown conducted on, November 2, reactor vessel level reached the Level 8 setpoint due to sluggish response of certain feed-water valves.
Actuation of the Level 8 setpoint caused both feedwater pumps to trip.
Later, due to questionable judgment on the part of the control room operators, the Level 3 setpoint was reached, initiating an automatic reactor protection system (RPS) actuation.
The Operations Manager stated at the exit meeting that he was in the process of personally providing training to each operations crew-on proper actions to take following a Level 8 feedwater pump trip.
No violations or deviations were identified.
One, unresolved item was identified (refer to paragraph 13).
Review of Periodic and S ecial Re orts 90713 Periodic and special reports submitted by the licensee pursuant to Technical Specifications 6.9. 1 and 6.9.2 were reviewed by the inspector.
This review included the following considerations:
the report contained the information required to be reported by NRC requirements, and the
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reported information appeared valid.
Within the scope of the above, the following reports were reviewed by the inspector.
Monthly Operating Reports for September and October, 1990.
No violations or deviations were identified.
ll.
Diesel Fuel Oil Procurement and Testin 61726 The inspectors reviewed the diesel fuel oil procurement and testing programs to verify licensee compliance with the Technical Specifications (TS).
The inspectors examined TS requirements, Final Safety Analysis Report (FSAR) commitments, Plant Procedures Manual (PPM) surveillance procedures, applicable American Society for Testing and Materials (ASTM)
standards, the Policy f'r Diesel Fuel Oil Procurement and Testing for Emergency Diesel Generators, recent vendor comounications, the Prelimi-nary Root Cause Analysis for recent diesel fuel oil problems, and various Generation Engineering memoranda.
Overview The licensee has identified three different violations of TS requirements for diesel fuel oil within the last year.
LER 90-01, issued in early 1990, described an event in which the licensee requested, and was authorized, a temporary waiver of c'ompliance to TS 4.8. 1. 1.2.d.2.
This TS requires verification that the impurity level in the fuel oil is less than 2 milligrams of insolubles per 100 milliliters, when tested in accordance with ASTM D2274-70.
The licensee hired a consultant to assess the diesel fuel program at WNP-2 as corrective actions for the LER.
The consultant recom-mended that amendments to the TS be issued to facilitate the procurement and testing of the diesel fuel oil.
On June 6, 1990 the NRC gr anted the licensee's request for an amendment to the TS.
The surveillance procedures in the PPH were subsequently revised.
In October of 1990, the licensee discovered that the vendor who conducts laboratory analysis of the fuel oil had unilaterally decided to use testing method ASTM-4294 to determine the sulfur content.
This method was not approved for use by the TS.
The licensee was authorized another temporary waiver of compliance until the sulfur content was determined by the correct method.
In November of 1990, during a TS review, the,licensee discovered that the TS requirement for periodic sampling for water accumula-tion in the diesel fuel oil storage tank was, not in the PPM surveillance procedures, nor was it documented as ever having been performed.
This test had been inadvertently dropped from the PPM procedures during a revision of the procedures concerning diesel fuel oil.
As a result, licensee management tasked the Events Assessments Group to conduct a root cause analysis for these occurrence L a
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b.
Root Cause Anal sis c ~
The inspector reviewed a preliminary copy of the root cause analysis concerning the diesel fuel oil problems.
The inspector noted that the'nalysis appeared to be thorough, and that it made several strong recoranendations to correct the above-mentioned problems on a long-term basis.
The principal conclusions and recommendations in the root cause analysis were as follows:
II (1) It was noted that as many as five separate'groups had a role in the procurement and testing of. the.,diesel fuel oil, with no centralized person or group in charge of the overall program.
This led to potential problems, one of which was that chemis-try results did not go directly to the chemistry department.
This could have caused unsatisfactory chemistry results, and therefore unusable fuel oil, to have gone undetected for an unnecessarily long period of time.
This, in turn, could have impacted equipment operability and delayed necessary correc-tive actions.
The licensee proposed to resolve this problem by centralizing the procurement and testing of diesel fuel oil among chemistry personnel, and by requiring that all diesel fuel oil test results be faxed to the chemistry department as soon as possible.
(2)
The licensee was developing a matrix of TS requirements versus PPN procedures to ensure that all requirements are being met, and will act upon any further discrepancies noted.
(3)
The Events Assessment 'Group recotmended in the root cause analysis that the data sheets for the results of diesel fuel oil chemistry tests contain a block for the ASTH method employed to evaluate the results documented.
This would appear to ensure that the licensee can quickly detect when the vendor has used a method not approved by the TS.
ins ector Observations In addition to the problems identified by the licensee, the inspector also made the following observations:
(1)
The policy for "Diesel Fuel Oil Procurement and Testing for Emergency Diesel Generators" is used as a basis for purchasing and testing new diesel fuel oil.
However, this document appeared to be inconsistent with the PPN procedures and the TS requirements.
The following concerns
"w'ere noted by the inspector regarding this policy document:
The document listed ASTN Standard 0975-77 as a reference document for the testing requirements.
The TS requires that the fuel oil be tested to ASTH D975-8 '
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Different limits were listed for some of the analyses (Cl oud Point, AP: Gravity, and Copper Strip Corrosion)
than in the PPM procedures.
The policy document listed tests to be performed which were not noted in the PPM procedures (Accelerated Stability, Low Heating Value).
The policy statement document neglected to list one analysis required by the PPM procedure (Filtration Cleanliness Method A).
The inspector noted that the policy statement for Diesel Fuel Oil Procurement and Testing for Emergency Diesel Generators was in need of review to ensure that apparent inconsistencies, such as those noted above, are alleviated.
(2)
During a review of the ASTM standards, the inspector became concerned with the limit established by the licensee in the PPM procedures for Cloud Point.
(The Cloud Point defines the temperature at which a cloud or haze of wax crystals appears in the oil under prescribed test conditio'ns, and generally relates to the temperature at which wax crystals begi'n to precipitate from the oil in use.)
ASTM D975-81 recommends that the cloud point be specified at 6 degrees Celsius (C)
above the tenth percentile minimum ambient temperature for the area.
Charts within the ASTM appear to recommend that the cloud point for diesel fuel oil procured by MNP-2 be set at-12 degrees Celsius (approximately 10 degrees Fahrenheit (F)).
However, the ASTM procedure does allow for different limits for the cloud point based upon equipment design and location of the fuel oil.
Since the oil is normally stored seven feet underground.
the licensee has calculated the cloud point to be 32 degrees F vice the 10 degrees F mentioned.
This calcula-tion assumes that tanker trucks which transport the fuel oil in cold weather (i.e. temperature less than the cloud point)
are not sufficiently delayed in transferring the fuel oil from the tanker to the licensee's underground diesel fuel oil tanks.
The licensee has noted that occasionally these tanker trucks must wait up to four days at the site until the diesel fuel oil is transferred to the NAP-2 underground tanks.
This could place the usability of the fuel oil within the tankers in question if the ambient temperature were below the cloud point of the oil.
This anomaly was addressed in licensee memorandum RFTS 89-10-172, dated February 6, 1990, issued by a member of the engineering staff.
This memorandum states, in part:
"A caution should be added to the abnormal procedure to require that the fuel added have a cloud point below its
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temperature and that the mix temperature once the fuel is added to the tank must be above the cloud point of the fuel already in the tank... the fuel added to the tank must not be cloudy, and the calculated temperature of the fuel in the tank once the new fuel in the tank is added, must not be below the cloud point of the fuel'that was in the tank before adding fuel.
This calculation... will be done before adding fuel to the tank."
Besides the calculation the memorandum recommends, the memo appears to imply that a sample of the new fuel oil be taken to verify that it is not cloudy.
The inspector noted after interviews with the Operations Pro-cedures Supervisor, the engineer who authored the memorandum, and the Chemistry Supervisor that no evidence was readily apparent that the above recommendation had been addressed.
This was discussed during the exit meeting.
(3)
The inspector also noted that the FSAR commitments regarding diesel fuel oil testing and procurement were inconsistent with other references (e.g., Technical Specifications).
The inspector did not determine whether these inconsistencies were being addressed by a pending FSAR update.
d.
~SUmna r The licensee appears to have largely addressed the problems with diesel fuel oil procurement and testing.
However, certain program-matic weaknesses and inspector observations, as noted above, were discussed with and acknowledged by licensee management.
Licensee actions related to these issues will be examined during a future inspection (Followup Item 397/90-28-03).
No violations or deviations wer e identified.
12.
Reactor Core Isolation Coolin RCIC Valve Ino erabilit 61726 On November 16, RCIC-Y-8, a containment isolation valve, failed its stroke time surveillance test.
While PPM 7.4.7.3.3 specifies a stroke time of 10 seconds or less, stroke times of about 10.5,.seconds were measured.
The licensee entered Action Statement 3.6.3.a.2 for contain-ment isolation valves, which requires isolating the containment.'penetra-tion with an alternate isolation valve.
In this case, this rendered the RCIC system inoperable.
Later, on November 17, MWR AR 1695 adjusted the closed indication of the valve to 94% in order to achieve a stroke time of less than ten seconds, even though the MWR specifically stated to adjust the closed indication to not less than 96% of full stroke closed.
According to the Maintenance Manager, this was done without Plant Technical or Generation Engineering concurrence.
A stroke time of 9.5 seconds was subsequently measured, and the valve was returned to an operable status on November 17.
The RCIC system was subsequently
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declared operable on November 18.
A Problem Evaluation Request (PER)
was issued to document the actions taken to return the valve'to operable status.
Later on November 18, a shift manager, realized the significance of the actions taken, that the stroke time had been adversely affected, and that.the valve may in fact not be operable; he again declared RCIC-V-8 inoperable.
however, a period of approximately 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> existed on November 18 when the applicable action statement for this containment isolation valve was not ent'ered.
An NCR was written, by the license on November 19 to document a violation
, of the Technical Specifications.
The inspector noted,,that violations of Technical Specifications for containment isolation valves are potentially significant.
The Technical S'pecifications state that the closure strbke time for RCIC-Y-8 (for containment isolation purposes)
is 13 seconds vice ten seconds.
The-inspector will review this matter in more detail during the next inspection period to determine specific requirements for this valve.
This issue is unresolved (Unresolved Item 397/90-28-04).
How-ever, the inspector noted during the exit meeting that deviations from the Master Data Sheets for individual containment isolation valves would appear to require the concurrence of Plant Technical or Generation Engineering, since unauthorized deviations could adversely affect the operability of the valve.
Licensee management concurr'ed with this observation.
13.
No violations or deviations were identified.
One unresolved item was identified, as discussed above and in Paragraph 13.
Unresolved Items 14,.
Unresolved items are matters about which more information is required to determine whether they are acceptable items, violations, or deviations.
Unresolved items addressed durihg this inspection are discussed in paragraphs 9 and 12 of this report.
Exit Meetin 30703
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The inspectors met with licensee management representatives periodically during the report period, and at the conclusion of Mr. Proulx's inspec-tion on November 17, to discuss inspection status.';-An 'exit meeting was conducted with the indicated personnel (refer to paragraph,l)
on December 3, 1990.
The scope of the inspect'ion and 'the 'inspe'ctors'"
findings, as noted in this report, were discussed with and acknowledged by the licensee representatives.
The licensee did not identify as proprietary any of the information reviewed by or discussed with the inspector during the inspectio I[
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