IR 05000397/1992036
| ML17289B076 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 12/11/1992 |
| From: | Johnson P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17289B069 | List: |
| References | |
| 50-397-92-36, NUDOCS 9212290131 | |
| Download: ML17289B076 (21) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report No:
Docket No:
License No:
Licensee:
Facility Name:
Inspection at:
50-397/92-36 50-397 NPF-21 Washington Public Power Supply System P. 0.
Box 968 Richland, WA 99352 Washington Nuclear Project No.
(WNP-2)
WNP-2 site near Richland, Washington Inspection Conducted:
October 5 - November 15, 1992 Inspectors:
W. P. Ang, Acting Senior Resident Inspector D. L. Proulx, Resident Inspector K. E. Johnston, Project Inspector (Paragraph 8)
(October 5 - 9, 1992)
Approved by:
P.
H.
nson, Chief React Projects Section
fM ()
Date Si ned
~Summar:
Ins ection on October
1992 - November
1992 Re ort No. 50-397 92-36 t d:
R ti i
p tl by th Id t h p t f
room operations, licensee action on previous inspection findings, operational safety verification, surveillance program, maintenance program, licensee event reports, special inspection topics, and procedural adherence.
During this inspection, Inspection Procedures 61726, 62703, 71707, 71710, 90712, 92700, 92701, 92702 and 93702 were used.
Sa et Issues Mana ement S stem SIMS Items:
None.
Jesuits:
General Conclusions and S ecific Findin s
Si nificant Safet Matters:
None.
Summar of Violations and Deviat ons:
Two violations were identified.
One violation involved the failure to restore a radiation area posting.
mime0lSl
~alZlO PDR ADOCK 05000397
The second violation involved the failure to follow Technical Specifications required procedures for a clearance order, and failure to maintain plant labeling per licensee drawings.
0 en Items Summar
Three followup items and eleven LERs were closed; one new item was opene The second violation involved the failure to follow Technical Specifications required procedures for a clearance order, and failure to maintain plant labeling per licensee drawings.
e tems Summa Two followup items and eleven LERs were closed; one new item was opene ersons Contacted QKGALS
- V. Parrish, Assistant Managing Director for Operations
- J. Baker, Plant Manager L. Harrold, Assistant Plant Manager
- G. Smith, Operations Division Manager
- G. Sorensen, Regulatory Programs Manager
- L. Grumme, Nuclear Safety Assurance Manager D. Pisarcik, Radiation Protection Manager J.
Harmon, Maintenance Manager A. Hosier, Licensing Manager
- S. Davison, guality Assurance Hanager
- J. Peters, Administrative Manager
- W. Shaeffer, Operations Manager R. Webring, Plant Technical Manager
- J. Rhoads, Operation Events Assessment Manager
- D. feldman, Assistant Maintenance Manager
- M. Reis, Compliance Engineer
- P. McBeth, Radwaste Hanager 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 November 20, 1992.
Plant Status At the start of the inspection period, the plant was at 100X power.
An Unusual Event was declared on October 13 due to potentially hazardous fumes being detected at the site.
An equipment operator mistakenly loaded sodium hypochlorite into a storage tank near the cooling towers that contained Calgon; this resulted in an exothermic reaction, and the release of fumes.
Hanagement and Operations personnel responded well to the event, and no serious hazard resulted.
On November 2, the licensee identified the presence of tritium in the storm drains.
This occurrence was the first of several findings of activity in undesired locations.
The plant remained at 100X power (except for momentary downpower maneuvers to support bypass valve testing and control rod exercises)
until the end of the inspection period.
Previousl Identified NRC Ins ection Items 92701 92702 The in'spectors reviewed records, interviewed personnel, and inspected
'lant conditions relative to licensee actions on previously identified inspection findings:
a.
Closed Enforcement Item 397 92-09-02
.
No Corrective Action for Oil Leaks from Standb Li uid Contro SLC S s em um s:
Oil leaks existed from the SLC pumps for approximately one year.
During a SLC system walkdown the inspector found that the SLC pump
oil levels were below the level for operability as defined in licensee procedures.
The licensee identified these leaks in April of 1991, but had taken no corrective action as of February 1992.
As immediate corrective actions, the licensee added oil to the pumps, changed Plant Procedures Manual (PPM) 2.4.1,
"SLC System Operations," to reflect the new prescribed pump oil levels, and added a check of pump oil levels to the Equipment Operator (EO)
logs.
The following long term corrective actions have also been completed:
(1) this event was reviewed as required reading with all System Engineers, Reactor Operators (ROs),
EOs, and maintenance personnel, and (2) the licensee reviewed their program for trending oil additions to safety-related equipment.
Subsequent to this review, PPHs 1.3.7A, "Minor Maintenance,"
and 1.19.5,
"Lubrication Oil Analysis Program,"
were changed to include instructions for use of the "Oil Addition Form" which is to be filled out and sent to the oil sampling program lead engineer for trending purposes.
The inspector reviewed the procedure changes, which appeared to be satisfactory.
In addition, the inspector has frequently checked the SLC pumps for oil leakage and proper oil level, and no further discrepancies have been noted.
The licensee's corrective actions appear to be satisfactory to prevent recurrence.
This item is closed.
Closed Enforcement Item 397 92-03-02
.
Im ro er
CFR 50.59 royal of Containment Atmos heric Control CAC Test.
The licensee proposed to perform a test of the CAC system with all drywell and wetwell isolation paths open.
This would have resulted in suppression pool bypass leakage in excess of the quantity allowed by the Technical Specifications (TS) for power operation.
This appeared to be a test not described in the Final Safety Analysis Report (FSAR) that required a TS change to implement during power operation.
The test was approved by the Plant Operations Committee
'POC), but the licensee did not request a TS change prior to implementation, as required by 10 CFR 50.59.
The licensee revised PPH 1.2.4 (Revision 15), "Plant Procedure Review, Approval, and Distribution," to provide instructions for reviewers to become familiar with the plant design basis when reviewing safety-related procedures.
Enhanced reactor safety training was implemented for all personnel qualified as 50.59 reviewers in a two week "Design Basis Safety" course.
The members of POC were given training on the lessons learned from this event, and this event was incorporated into the lesson plans for the licensee's
CFR 50.59 training course.
In addition, all procedures related to CAC were changed to include precautions against introducing unanalyzed suppression pool bypass leakage paths.
The inspector reviewed the procedure changes and the training lesson plans, attended several POC meetings, and concluded that the licensee's corrective actions were satisfactory.
This item is close c ~
Closed Followu Item 50-397 86-25-03:
Fi e
ain U der esel Generator Buildin This item noted that 12-inch fire protection water mains were installed underneath the safe shutdown emergency diesel generator building.
Discussions with licensee and contractor personnel indicated that during construction a break occurred in this fire protection piping.
The licensee had to break through the diesel generator building floor to repair the leak.
The inspector was concerned that the installation did not meet the National Fire Protection Association Code NFPA 24, Chapter 8, concerning protection against damage.
The item was left open pending further NRC review.
The NRC completed initial review of this item and notified the licensee by letter dated Nay 12, 1989, that the installation was considered adequate, pending further review of the adequacy of fire main thrust restraints.
The licensee provided updated thrust restraint information to the NRC by letter dated September 11, 1989.
The NRC completed review of the updated thrust restraint information and notified the licensee by letter dated June 26, 1990, that the design was adequate, pending installation of a indicating check valve, to allow the licensee to identify major leakage in the underground fire mains.
The licensee committed to the installation of the indicating check valve in a letter dated September 11, 1989.
The licensee installed the indicating check valve in accordance with Plant Modification Record 87-0158-0,
"Detector Check Valve Downstream of FP-P-3."
The inspector reviewed the check valve installation instructions and found that the instructions had installed the valve as committed.
The inspector concluded that this item was adequately resolved based on the installation of the check valve and the NRC technical review of the installation, as described in the June 26, 1990, letter.
This item is closed.
4.
0 erational Safet Verification 71707 a ~
lant Tours The following plant areas were toured by the inspectors during the course of the inspection:
Reactor Building Control Room Diesel Generator Building Radwaste Building Service Water Buildings Technical Support Center
Turbine Generator Building Yard Area and Perimeter b.
The (2)
(3)
(5)
following items were observed during the tours:
0 erati Lo s and ecords.
Records were reviewed against Technical Specification and administrative control procedure requirements.
onitorin Instrumentation.
Process instruments were observed for correlation between channels and for conformance with Technical Specification requirements.
E~hif N
i
.
C t t
delft i
g b
d 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 veri-fied 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 Specification limiting conditions for operation were verified by direct observation.
E ui ment Ta in
.
Selected equipment, for which tagging requests had been initiated, was observed to verify that tags were in place and the equipment was in the condition specified.
Danger Tag Clearance Order 92-10-0008 was inspected on October 13, 1992, and the inspector found that one danger tag had been hung improperly.
According to information on the Clearance Order and the tag, the tag was supposed to be hung on breaker HCC-8CA-1D for component
"EDR-P-5".
The tag was actually hung on a breaker labeled HCC-8CA-1C.
Top Tier drawings in the control room indicated that the label plate for EDR-P-5 should have been on breaker 1D of HCC-8CA.
The inspector notified the Shift Hanager of these observations and a Problem Evaluation Request (PER)
was initiated.
Further investigation revealed that the danger tag was indeed on the correct breaker for deenergizing this piece of equipment.
However, the Equipment Operator (EO) apparently did not completely verify the labeling of the component being tagged.
Therefore, the EO did not have the opportunity to notify the Shift Hanager to resolve the discrepancy, or to initiate a Request for Technical Services (RFTS) or a Labeling Request Form, as required in PPH 1.3.8,
"Danger Tag Clearance Order."
Subsequent investigation revealed that HCC-8CA was mislabeled because the labeling on this electrical cubicle was removed to support painting, and was not restored to its proper configura-
tion per drawings E535, sheet 58A, and E503, sheet 8.
Involve-ment of independent quality assurance (gA) or quality control (gC) personnel was not apparent for the painting of safety related equipment at WNP-2.
In addition, during a recent plant tour, the inspector noted that the grease fittings for the main steam leakage control (HSLC) system fans had been painted over.
The inspector was concerned that other safety-related equipment labeling errors or other painting deficiencies may have existed, that may result in adverse consequences if similar problems occurred.
The failure to maintain proper labeling of electrical cubicle HCC-8CA, and the failure to adhere to the clearance order procedure is an apparent violation of 10 CFR 50, Appendix 8, Criterion V, and Technical Specification 6.8.1.
(Violation 397/92-36-01).
General Plant E ui ment Conditions.
Plant equipment was observed for indications of system leakage, improper lubrica-tion, or other conditions that would prevent the system from fulfillingits functional requirements.
Annunciators were observed to ascertain their status and system operability.
Fire Protection.
Fire fighting equipment and controls were observed for conformance with administrative procedures.
Plant Chemistr
.
Chemical analyses and trend results were reviewed for conformance with Technical Specifications and administrative control procedures.
Radiation Protection Controls.
The inspectors periodically observed radiological protection practices to determine whether the licensee's program was being implemented in conformance with facility policies and procedures and in compliance with regulatory requirements.
The inspectors also observed compliance with Radiation Work Permits, proper wearing of protective equipment and personnel monitoring devices, and personnel frisking practices.
Radiation monitoring equipment was frequently monitored to verify operability and adherence to calibration frequency.
During a backshift (Sunday morning) inspection of the reactor building, on November 15, 1992, the acting Senior Resident Inspector observed that the radiation area barrier and sign for the RCIC pipe space at elevation 471 had been removed such that the barrier rope was not hanging across the opening but was hanging with both ends of the rope on a common padeye on one side of the opening and was not readily noticeable as a barrier for the opening.
The inspector notified HP, who subsequently surveyed the area and reinstalled the barrier.
HP subsequently informed the inspector that the area was less than one mr/hr at the time of the survey but is posted as a radiation area because of the potential for a high radiation level to exist in the area.
HP initiated PER 292-1291 for the noted condition and an incident review was performe I
4
The NRC inspector subsequently determined that similar viola-tions of radiation area posting requirements had previously occurred, as identified by the NRC in inspection reports 92-28 (July 92), 91-10 (April 91), 90-10, 89-13 and 89-09.
In addition, the licensee had also observed similar conditions and documented those conditions in PER 292-1186 and 292-1187.
Licensee corrective actions for those violations have not adequately precluded recurrence of the radiation area barrier deficiencies.
This appeared to be a repeat violation of licensee radiological control posting and barrier procedures and was identified as a violation of Technical Specifications Section 6.8.1 (Violation 397/92-36-02).
(10) Plant Housekee in
.
Plant conditions and material/equipment storage were observed to determine the general state of clean-liness and housekeeping.
Housekeeping in the radiologically controlled area was evaluated with respect to controlling the spread of surface and airborne contamination.
(11) ~ecur t The inspectors periodically observed security practices to ascertain that the licensee's implementation of the security plan was in accordance with site procedures, that the search equipment at the access control points was opera-tional, that the vital area portals were kept locked and alarmed, and that personnel allowed access to the protected area were badged and monitored and the monitoring equipment was functional.
En ineered Safet Features Walkdown Selected engineered safety features (and systems important to safety)
were walked down by the inspectors to confirm that the systems were aligned in accordance with plant procedures.
During the walkdown of the systems, items such as hangers, supports, electrical power supplies, cabinets, and cables were inspected to determine that they were operable and in a condition to perform their required functions.
Proper lubrication and cooling of major components were also observed for adequacy.
The inspectors also verified that certain system valves were in the required position by both local and remote position indication, as applicable.
Accessible portions of the following systems were walked down on the indicated dates.
~Sste Diesel Generator Systems, Divisions 1, 2, and 3.
Hydrogen Recombiners Low Pressure Coolant Injection (LPCI)
Trains "A", "B", and "C" ates October 22, 28, November
October 21, November
October 21, November
1 h
Low Pressure Core Spray (LPCS)
High Pressure Core Spray (HPCS)
Reactor Core Isolation Cooling (RCIC)
Residual Heat Removal (RHR), Trains
"A" and "B" Scram Discharge Volume System Standby Liquid Control (SLC) System Standby Service Water (SSW) System 125V DC Electrical Distribution, Divisions 1 and
250V DC Electrical Distribution No violations or deviations were identified.
October 22, November
October 21, 28, November
October 21, November
October
October 21, 22,
October
November
October 21, November
October 21, November
5.
Surveillance Testin 61726 Surveillance tests required to be performed by the Technical Specifica-tions (TS) were reviewed on a sampling basis to verify that:
(1)
a technically adequate procedure existed for performance of the surveil-lance tests; (2) the surveillance tests had been performed at the frequency specified in the TS and in accordance with the TS surveillance requirements; and (3) test results satisfied acceptance criteria or were properly dispositioned.
Portions of the following surveillance tests were observed by the inspectors on the dates shown:
ates Performed 7.4.8.2.1.23 HPCS-Bl-DG3 quarterly Operability Checks October
7.4.3.1.1.b Scram Discharge Volume Vent and November
Drain Valves Stroke Time Testing While observing the performance of Plant Procedures Manual (PPM)
7.4.2.1.23, the inspector observed that the surveillance required the user (in step 7. 1.7) to check the internals of the HPCS battery for evidence of flaking and sediment.
However, the battery racks were constructed such that the bottom of the cells'nternals was obstructed from sight.
The surveillance procedure contained a precautionary step stating that due to the proximity of the battery cells to the walls, the internal inspections could not be fully performed.
The inspector was concerned that PPM 7.4.8.2. 1.23 may have been inadequate to verify the overall condition of the batter The inspection of the cell internals was only required by the WNP-2 TS to be performed every 18 months.
TS 4.8.2.l.c.l requires the licensee to verify "the cells, the cell plates and battery racks show no visual indication of physical damage or abnormal deterioration."
PPM 7.4.8.2.1.19,
"18 Month Battery Testing of HPCS-B1-DG3," the 18 month surveillance for the HPCS battery, echoes these requirements.
However, PPM 7.4.2. 1.19 also did not appear to provide direction on how to inspect the internals for sediment.
The licensee stated that the intent of this TS was to inspect all accessible portions of the cells when performing this surveillance, and that the primary method of verifying the condition of a cell was to perform voltage checks.
In addition, the licensee stated that the cells for the HPCS battery were removed from the racks during the R6 refueling outage, and no evidence of sediment was noted.
"IEEE Recommended Practice for Maintenance, Testing, and Replacement of Large Lead Storage Batteries for Generating Stations and Substations,"
was the basis for the development of this surveillance.
The inspector reviewed this reference and did not find any further prescriptive direction regarding inspection of the cells'nternals for sediment.
This issue requires further review by the inspector prior to resolution, and is considered an unresolved item.
(Unresolved Item 397/92-36-03)
No violations or deviations were identified.
Plant Maintenance 62703 During the inspection period, the inspector observed and reviewed documentation associated with maintenance and problem investigation activities to verify compliance with regulatory requirements and with administrative and maintenance procedures, required QA/QC involvement, proper use of clearance tags, proper equipment alignment and use of jumpers, personnel qualifications, and proper retesting.
The inspector verified that reportability for these activities was correct.
The inspector witnessed portions of the maintenance activities associated with replacement of the digital electro-hydraulic (DEH) system fuller's earth oil filter element, 2-DEH-F-9, which was performed in accordance with MWR AP0928 on November 15, 1992.
No violations or deviations were identified.
Licensee Event Re ort LER Followu 90712 92700 The following LERs associated with operating events were reviewed by the inspector.
Based on the information provided in the report it was concluded that reporting requirements had been met, root causes had been identified, and corrective actions were appropriate.
The following LERs are considered closed.
LER NUMBER 90-19-01 DESCRI PT ION Pressure Suppression Pressure Limit Curve in the EOPs Not in Agreement with Design Calculations
91-03-01 92-14-01 92-23-01 92-25-01 and
92-28 Improper Testing of the Standby Gas Treatment System HPCS, LPCS, and RHR Flow Setpoint Errors Missed Technical Specification Surveillance and Fire Tour Data due to Inadequate Work Practices HPCS Inoperable due to Partial Failure of Pump Rotor Upper Air Deflector Diesel Room Air Handling Units Failure to Auto-start after Loss of Offsite Power 92-32 and 92-32-01 Unplanned Actuation of ESF Component due to Decrease in Reactor Water Level Resulting from Voided Feedwater Piping 92-39 Reactor Mater Cleanup Isolation due to High Differential Flow 92-40 Diesel Generators'tart and Load Times not Heasured during TS Surveillance The following LERs were reviewed but require further review of corrective actions and the root causes:
LER NUMBER 92-19-01 92-17 92-20 DESC IP ION ADS Inoperable due to Inadequate Installation Fouling of SSM Side of RHR "A" Heat Exchanger LPCS Minimum Flow Element not Properly Installed 92-35, 92-35-01 Inadequate Testing of Scram Discharge Volume Vent and Drain Valves 92-37, and 92-37-01 manual Reactor Scram due to Core Instability 92-38 Failure to Perform Offgas Analysis within Technical Specification Time Requirements No violations or deviations were identified.
8.
Review of Corrective Action Trackin The inspector reviewed the licensee's Plant Tracking Log (PTL), the licensee's primary corrective action and commitment tracking system.
The inspector made the following general observations:
~
The PTL itself was cumbersome and difficult to use.
The inspector found that short of having a report printed out, it was not possible to determine the number and relative age of sets of action type ~
No one group or individual had overall cognizance of the system.
The work control group had responsibility for maintenance of the data base; however, the group was not responsible for assuring that PTL items were addressed.
~
While responsibility for individual items was established, action due dates were not rigorously imposed and priorities were not consistently established.
~
In general, the successful implementation of the PTL was left to the groups responsible for particular types of items.
The inspector noted that Generation Engineering had done a good job of establish-ing responsibilities, priorities, due dates, and expected work efforts for the Requests for Technical Services (RFTS) backlog.
The inspector did not observe the same for Plant Engineering's Technical Evaluation Request (TER) backlog.
~
As discussed below, the inspector found that the licensee had lost track of several Part 21 and LER reportability evaluations and LER updates.
The inspector asked the licensee to generate a list of pre-1990 noncon-formance report (NCR) and plant deficiency report (PDR)
PTL items.
This list contained 18 items.
In a review of these items (the inspector reviewed the details of 7 of the 18), it was apparent that there had been no significant work to resolve these issues for up to 4 years.
In one case, the reportability analysis for a nonconformance report had not been completed.
In late 1986, the containment drywell was purged and vented.
The Technical Specifications stated that the drywell should be vented through the standby gas treatment system (SGTS) where the effluent would be filtered through charcoal filters and be monitored before being discharged.
Operators determined that approximately 500 cfm (10X)
bypassed the SGTS and was discharged unfiltered.
The bypass flow was terminated after 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
The drywell had been sampled prior to the release.
The event was documented as NCR 287-017.
The licensee per-formed a reportability evaluation and determined that since the drywell purge was lined up through the SGTS, the event was not reportable.
The inspector reviewed this event and determined that it was reportable in accordance with 10 CFR 50.73 as a Technical Specification (TS)
violation and that the licensee should have submitted a Licensee Event Report (LER) in early 1987.
However, the TSs have since been changed to remove the radiological effluent TSs and place them in the Offsite Dose Calculation Manual (ODCN).
Although the ODCH still requires the drywell to be purged through the SGTS, this is no longer a TS requirement and failure to do so is now not reportable.
The inspector also found that the licensee had not submitted LER revi-sions as projected for the following 1988 LERs:
~
LER 88-05:
The control room emergency filtration unit had high bypass leakage.
The licensee had planned to update
-11-
~
LER 88-08:
~
LER 88-31 the LER to provide an evaluation of postulated post-accident control.room dose.
Six fire seals in the reactor building were found not sealed.
The licensee had planned to update the LER after an inspection to determine whether further deficiencies existed.
There had been no apparent action since February 1989.
The control room remote air intake was found to be susceptible to a single failure.
The licensee had planned to update the LER to provide an evaluation of postulated post-accident control room dose.
The inspector found that the following nonconformance reports identified problems as having the potential to be reported under
CFR Part 21:
~
NCR 287-0366:
A design computer error did not take safety relief valve chugging and the operations basis earthquake into consideration in the fatigue analysis.
The last apparent action was in Parch 1990.
~
NCR 287-059:
Service water radiation monitors may not detect a
release due to high post-accident reactor building radiation levels.
The last apparent action was September 1989.
~
NCR 285-0543:
Fire damper S hooks were found not to be seismically qualified.
The status of this item was not apparent from the NCR file.
The inspector was unable to independently determine if any of these issues should have been reported under Part 21.
The licensee had not taken substantive action on any of these LER or Part 21 reviews in several years.
In addition, the due dates listed in the PTL had all been exceeded by two to four years.
The inspector discussed these issues with the Compliance Hanager, currently responsible for the resolution of these issues.
He showed the inspector an action plan which provided a schedule for when these items would be addressed.
He stated that since their response to the containment atmosphere control (CAC) enforcement action in early 1992, the compliance organization had placed a priority on the resolution of outstanding reportability evaluations.
He stated that this backlog had been dispositioned and that efforts were underway to address the backlog of other issues such as LER updates and Part 21 reviews.
In summary, the PTL appeared to be used as a master listing of corrective actions, technical reviews, and commitments.
Although it has the capability to provide issue ownership and due dates, the PTL has not been implemented such that it will drive issue resolution.
While there are examples where categories of actions, such as the RFTS backlog, have been successfully prioritized and managed, these appeared to result from a
ij V
J
-12-conscientious manager who had developed a secondary tracking system.
The weaknesses of the PTL were demonstrated by the failure to provide timely.
LER updates and Part 21 reviews, as described above.
The above weaknesses were discussed with licensee management during an exit meeting on October 9, 1992.
9.
Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable items, violations, or deviations.
An unresolved item addressed during this inspection is discussed in paragraph 5 of this report.
The inspectors met with licensee management representatives periodically during the report period to discuss inspection status, and an exit meeting was conducted with the indicated personnel (refer to paragraph I)
on November 20, 1992.
The scope of the inspection and the inspectors'indings, 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 inspectors during the inspectio j II H)'