IR 05000461/1986017
| ML20204A513 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 04/29/1986 |
| From: | Jablonski F, Knop R, Ulie J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20204A505 | List: |
| References | |
| 50-461-86-17, NUDOCS 8605120301 | |
| Download: ML20204A513 (25) | |
Text
{{#Wiki_filter:. % U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-461/86017(DRP) Docket No. 50-461 License No. CPPR-137 Licensee: Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name: Clinton Power Station Inspection At: Clinton Site, Clinton, IL Inspection Conducted: February 24 through April 7,1986 Inspectors: T. P. Gwynn P. L. Hiland F. J. Jablons [[ N Date d *% d h Yk h J. M. Ulie ' 'f //M /F,6 Date Rc 2;Gg . Approved By: Richard C. Knop, Chief
- 9 Reactor Projects Section IB Date Inspection Summary Inspection on February 24 through April 7, 1986 (Report No. 50-461/86017(DRP))
Areas Inspected: Routine safety inspection by two resident inspectors and two regional based inspectors of preoperational testing and operational preparedness activities including applicant action on previous inspection findings; IE Circular followup; review of construction deficiency report; employee concerns; review of allegations; functional or program areas (including site surveillance tours, operating procedures review, and preoperational test witnessing); independent inspection effort plant
maintenance program review; safety evaluation report review and followup; and site activities of interest.
Results: One violation and two unresolved items were identified.
The violation (paragraph 8.b.) related to the improper use of a temporary procedure change which resulted in a procedure that was inadequate to control the processing of ' nonconformance reports under the applicant's Operational Quality Assurance Manual.
The first unresolved item related to the subsequent revision of the affected procedure.
The second unresolved item related to the adequacy of a safety significance evaluation performed by the applicant for a construction . deficiency report. These findings, indicate that additional attention to detail l is required by plant management, and staff to assure that safety-related activities are properly performed.
~ 8605120301 860506 PDR ADOCK 05000461 G PDR
. % DETAILS 1.
Personnel Contacted Illinois Power Company (IP) D. Antonelli, Director, Plant Operations K. Baker, Licensinj and Safety (L&S)
- J. Brownell, Licensing Specialist G. Bell, Director, Construction and Procurement Quality Assurance (QA)
C. Calhoun, Quality Projects Coordinator, IP QA R. Campbell, Director, Quality Systems and Audits, QA R. Cannon, 10 CFR 21 and 10 CFR 50.55(e) Coordinator, Licensing and Safety +*W. Connell, Manager, QA
- J. Cook, Assistant Manager, Clinton Power Station (CPS)
- E. Corrigan. Director, Quality Engineering and Verification, QA
+*H. Daniels, Project Manager D. Findley, Startup Engineer, Fire Protection +5. Fisher, Manager, NS R. Frantz, Licensing Specialist +W. Gerstner, Executive Vice President E. Gray, Chemetron Fire Systems Representative +J. Greene, Manager, Startup (50) W. Hahn, Supervisor, Engineer, NSED +D.
Hall, Vice President, Nuclear D. Hoem, Supervisor, Maintenance Planning D. Holesinger, Director, Startup Test, SV D. Holtzscher, Director, Safety Analysis, LS S. Kane, IP Project Engineer E. Kant, Assistant Manager, Nuclear Station Engineering (NSE) +*H. Lane, Assistant Manager, Project Control Center
- J. Loomis, Construction Manager M. Maher, Electrical Supervisor J. Miller, Director, Startup Programs, SU
- J. Palchak, Supervisor, Plant Support Services
+*J. Perry, Manager, Project Control Center R. Phares, Technical Staff Engineer J. Randolph, Startup Engineer, Fire Protection S. Richey, Director, Maintenance L. Rosenbloom, IP Licensing Engineer +*R.
Schaller, Director, Nuclear Training J. Scott, Proiect Engineer, NSED +*D. Shelton, Manager, NSE J. Sipek, Supervisor, Fire Protection - Plant Staff +*F. Spangenberg, Manager, L&S L. Tucker, Director, Maintenance Services +N. Williams, Director, Support Services +J. Wilson, Manager, CPS F. Worrell, Supervisor, Plant Operations R. Wyatt, Director, Nuclear Program Assessment
. . Baldwin Associates (BA)
- R. Greer, Manager Q&TS, IP assigned to BA J. Hawkins, Manager - Quality Assurance
- D. Schlatka, Project Manager J. Thompson, Manager - Quality Engineering Soyland/Wipco
+*J. Greenwood, Manager, Power Supply U.S. NRC Region III +*T. Gwynn, Senior Resident Inspector, Operations
- P. Hiland, Resident Inspector
+R. Knop, Chief, Projects Section IB +C. Norelius, Director, Division of Reactor Projects +R. Warnick, Chief, Projects Branch 1
- Denotes those attending the monthly exit meeting on April 7,1986.
+ Denotes those attending the management meeting on April 1,1986.
2.
Applicant Action On Previous Inspection Findings (92701/92702) (Closed) Open Item (461/85015-09): Modifications to the reactor a.
vessel internals to prevent fatigue failure of incore instrument tubes from flow induced vibration.
(SSER4, paragraph 3.9.2) After the Clinton Safety Evaluation Report (SER) was issued, the NRC staff reviewed and approved the Licensing Review Group (LRG)-II positior, paper regarding modifications of BWR/6 internals that were intended to prevent fatigue failure (breakage) of incore instrument tubes from flow-induced vibration. The committed modifications included (1) installation of flow deflector plates at the Low Pressure Coolant Injection (LPCI) inlets to the core shroud and (2) replacement of the intennediate range monitoring (IRM) tubes in locations near the LPCI injection inlets with strengthened tubes of improved designs.
! The inspector reviewed General Electric Field Disposition Instructions (FDIs) SKNW, 83-20122, and 92/20122. These FDIs detailed the requirements for performing the internal modifications and were annotated as being complete.
The inspector reviewed the applicable work travelers to assure the committed modifications had been completed. General Electric travelers CLBR-01 thru CLBR-05, dated May 27, 1983 thru June 14, 1983 documented the installation of the LPCI flow deflectors.
General Electric traveler WBS 15.0A, dated September 6,1985, documented installation of three IRM dry tubes (#14708789G001) at reactor vessel locations 46-43, 38-11, and 14-11.
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. % The inspector confirmed by review of the above construction installation travelers that the reactor vessel internal modifications referenced in Supplemental Safety Evaluation Report (SSER)-4, paragraph 3.9.2 were complete.
This item is closed.
b.
(Closed) Open Item (461/85047-03): Appendix 8 of Clinton Power Station (CPS) Fire Brigade Procedure CPS No. 1001.06 identified three locations containing fire fighting equipment for use by the fire brigade.
The inspector toured two of the three locations and observed that not all equipment listed in Appendix B was in place, including a smoke ejector fan at the 800' Control Sleeping Room, and a self-contained breathing apparatus unit at the 737' elevation of the Radwaste Building located at Column R200.
According to the applicant, all equipment required by commitment or procedure will be in place and verified ready for use prior to fuel load.
On March 12, 1986, the inspector verified that the proper fire brigade fire fighting equipment was in place at the 737' elevation of the Radwaste Building, fire brigade cage as identified in CPS Fire Brigade Procedure No. 1001.06.
c.
(Closed) Open Item (461/85047-06): Paragraph E.3.d of Appendix A to Branch Technical Position (BTP) 9.5-1 indicated that standpipes having attached fire hose and suitable nozzles should be spaced at not more than 100 foot intervals.
The applicant's response stated that, " Hose stations have a maximum of 100 feet of 1-1/2 inch hose with an adjustable spray nozzle."
In a related matter, during the inspector's participation in the practical portion of the fire watch hose handling training which included the flow of water, the inspector observed that the adjustable spray nozzle being used, (according to the applicant's training staff, the nozzle was identical to those being used in the plant currently and planned to be used during plant operation) when initially opened, provides a solid stream of water.
In an area containing vital energized electrical equipment, a solid stream of water can carry sufficient electrical current back to a nozzle to kill or injure plant personnel in addition to causing malfunction of vital equipment affecting a safe plant shutdown.
To resolve this concern, the applicant proposed to install approved Class C type nozzles (fog nozzles) on standpipe fire hose located in areas containing considerable energized electrical equipment.
In addition, the applicant proposed to make special emphasis in discussing this concern during fire hose handling training.
The inspector observed twelve of the fire hose stations that have had installed approved Class C type nozzles attached to the standpipe fire hose.
In addition, the fire brigade staff have been made aware of the Class C type nozzles through required reading and Quarterly Requalification Training Sessions.
The inspector verified this by comparing a master fire brigade rester list against the completed required reading list and Quarterly Requalification Training attendance lists. The inspectnr also verified that updated revisions have been completed to Lesson Plan 12002, "Line Hose-Portable and Protective Equipment", Lesson Plan 12012, " Fire Watch", and Lesson Plan 12302, " Fire Watch Coordinator'.
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. . d.
(Closed) Open Item (461/85065-02): Verify that each operating shift is manned by a sufficient number of licensed personnel prior to fuel load.
The inspector reviewed the Clinton licensed operator status and discussed the 5 shift rotation schedule with the Supervisor-Plant Operations.
At the time of this inspection, three groups of SR0/R0 candidates had completed their NRC examinations.
A total of 18 SR0s and 12 R0s assigned to the Operations Department were licensed.
Draft Clinton Technical Specification (TS) section 6.2.2 required a total of ten SR0s and ten R0s to man a 5-shift rotation for the most limiting conditions (Operating Conditions 1, 2, and 3).
The inspector noted that a sufficient number of licensed operators are currently filling the 5 shift rotations.
In addition, the.
inspector verified that a sufficient number of licensed SR0s had completed the Supervisory Operating Plant Experience (50PE) program.
The licensed personnel currently filling the 5 shift rotation meet the requirements of the draft Clinton TSs.
This item is closed.
e.
(0 pen) Open Item (461/85005-19): Verify that valves in the fire protection water supply system which are not electrically supervised are keylocked open with strict key control procedures and monthly veritication of valve position.
The applicant provided a package stating this item was ready for closure.
This item was previously reviewed in Inspection Reports No. 50-461/85042 and No. 50-461/85065.
During this inspection, the inspector reviewed CPS No. 1032.01, Station Keying, revision 4 dated March 7, 1986.
The procedure had been revised to provide strict key control for locks on fire protection water supply valves.
The inspector attempted to verify implementation of the key controls but found that the key controls had not been implemented. Discussion with the Plant Staff fire protection supervisor indicated that additional locks and keys had to be procured prior to implementation of the procedure.
Implementation of the procedure was scheduled for April 25, 1986.
This item remains open pending verification of implementation of CPS No. 1032.01.
f.
(0 pen) Open Item (461/85015-02): Vecify that the applicant is participating in the GE surveillance program for new safety relief valves (SRVs) (NUREG-0152).
The applicant provided a package stating this item was ready for closure.
This item was previously reviewed in Inspection Report No. 50-461/85042.
The following results were obtained during that inspection:
. . CPS Procedure No. 3831.01, Safety Relief Valve Report, details the mechanism to collect data on the actuations and leakage of the safety relief valves in the Main Steam system and generate reports required by the Institute of Nuclear Power Operations, (INPO).
The procedure appears to comply with LRG Position 3-RSB and meets the SER commiunents.
The procedure was an " exempt" procedure and will not be implemented until completion of scheduled review and upgrading.
The procedure contained a "later" and did not yet fulfill the " commitment requirements" of CPS No. 1005.01, Section 8.1.2.9.12(d).
The procedure was scheduled for routine review and upgrading in October, 1985.
Applicant action appeared to fulfill the SER commitment; however, this item remains open pending completion of the routine scheduled procedure review.
This inspection revealed that the status of the program had not changed.
This item remains open.
g.
(0 pen) Open Item (461/85015-03): Verify implementation of the Radwaste Process Control Program.
The applicant provided a package stating this item was ready for closure.
The inspector reviewed the closure package provided by the applicant and determined that the basis for closure was the NRC Office of Nuclear Reactor Regulation approval of the CPS process control program (PCP).
The inspector observed that the action required was to verify implementation of the PCP; that this verification was not possible until the plant was operating and generating radioactive waste; and thac the NRC Region III had deferred inspection of this item until after initial criticality but before 5% power.
This item remains open.
h.
(0 pen) Open Item (461/85015-06): Verify Nuclear Steam Supply System (NSSS) vendor review of low power testing, power ascension and emergency operating procedures is complete prior to fuel load.
The applicant provided a package stating this item was ready for closure.
The basis for closure was stated as follows: According to the Clinton SSER 5, Section 13.6.3, the NRC no longer requires Nuclear Steam Supply System (NSSS) vendor review of the low power, power ascension, and emergency operating procedures (EOP).
Illinois Power's (IP) Procedure Generation Package of E0Ps is based on generic owners group guidelines that the staff has already reviewed and approved.
In addition, IP administrative controls require the NSSS vendor representative to review and approve low power and power ascension procedures.
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. . Review of the CPS Safety Evaluation Report, supplement 5 (SSER5), Section 13.6.3, revealed that NSSS vendor review of E0Ps was no longer required; review of low power and power ascension test procedures was still required.
The applicant's startup administrative program did provide controls to assure NSSS vendor review of low p6wer and power ascension procedures.
The applicant provided no evidence that that review was > complete.
This item remains open pending completion of that review.
i.
(0 pen) Open Item (461/85015-11): Inspection of station battery operation and maintenance, documented in Inspection Report 50-461/85015, identified inconsistencies between the draft CPS TS survaillance frequency and the surveillance frequencies specified in the IEEE standards that IP was committed to meet.
The applicant provided a package stating this item was ready for closure.
The closure package provided by the applicant indicated that the FSAR had been recently revised (Amendment 37) to take exception to the surveillance frequency specified in IEEE-450, Recommended Practice For Maintenance, Testing and Replacement of Large Lead Storage Batteries for Generating Stations and Substations.
The exception, while consistent with draft TS requirements, had not been reviewed and accepted by the NRC Office of Nuclear Reactor Regulation (NRR).
In addition, the inspector observed that other inconsistencies in the requirements for CPS batteries had been recently identified by the plant staff during performance of reviews undertaken in response to a recent NRC Notice of Violation.
This item remains open pending verification of NRR acceptance of the applicants new commitments.
j.
(0 pen) Open Item (461/86016-01(2)): The trip setpoint and allowable value in the CDS TS, Table 3.3.3-2, Emergency Core Cooling System Actuation Instruinentation Setpoints, items A.1.d and B.1.d, appeared to conflict.
The allowable value was given as 5 seconds + or -0.5 seconds and the trip setpoint was given as >5 seconds.
The inspector was concerned that the setpoint could be set outside the allowable value without corrective action.
The inspector reviewed this matter with the applicant and with the technical specification reviewer, NRC Office of Nuclear Reactor Regulation.
The instrumentation involved was a solid-state delay timer for the residual heat removal (RH) system pump start delay in the low pressure coolant injection (LPCI) mode.
The TS required corrective action any time the timer setpoint was found to be outside the allowable value.
Review of surveillance procedure CPS No. 9430.30, revision 20, NSPS Untested Islands / Calibration 1-999 Second Time Delay, paragraphs 8.2.8 and 8.8.5 revealed that the procedure provided for the necessary corrective action on the basis of the allowable value.
. . The apparent conflict noted by the inspector in Inspection Report No. 50-461/86016 was not a real conflict.
The procedure implementing the CPS TS requirement clarified the use of the setpoint value.
No changes to CPS TS were required as a result of this review.
Item (2) is closed; however, (1), (3), and (4) associated with this open item remain open and will be reviewed in a subsequent inspection.
k.
(0 pen) Violation (461/86008-01): Illinois Power Company (IP) failed to assure that Stone and Webster (S&W) (the IP maintenance contractor) personnel performing activities affecting quality were properly trained.
The inspector reviewed preliminary results the applicant had prepared in response to the subject violation.
The applicant performed a review of the training and qualification requirements of the applicable IP and S&W programs.
This review confirmed the violation did exist and the applicant has started a corrective action program in response to the violation.
The corrective action performed by the applicant included the following: S&W Maintenance Management Manual (MMM) Procedure 9.4 was
revised and issued February 21, 1986.
The revision required completion of training for each S&W maintenance personnel prior to issuance of a S&W badge.
Adherence to this revision will assure S&W personnel receive training before performing work.
A qualification and training matrix was developed in accordance
with MMM 9.4 to provide training status to S&W job supervisors for use in the selection of personnel for specific tasks.
Procedure MMM 2.4, Maintenance Training, was issued March 21,
1986.
This procedure required all S&W maintenance personnel to meet the training requirements of Clinton Power Station Maintenance Department qualification.
Training of S&W personnel to this procedure was scheduled to be completed in April 1986.
At the conclusion of this inspection period, the applicant had not responded formally to this violation.
The inspector will continue this inspection when the applicant formally responds to the violation and the corrective action to prevent recurrence is fully implemented.
No violations or deviations were identified.
3.
IE Circular Followup (92701) a.
(Closed) IE Circular 79-12 (461/79012-CC): Potential Diesel Generator Turbocharger Problem.
. . The applicant presented a package to the inspector for closure.
This circular was previously reviewed in Inspection Reports No. 50-461/80004, No. 50-461/82007, and No. 50-461/85065.
At the conclusion of the last inspection, this circular remained open pending clarification of the status of CPS 9080.02; pending assurance that three other Temporary Charge Forms (TCFs) would be incorporated, if required; pending receipt of objective evidence of inspection of the diesel generator oil coolers; and pending revision of CPS No. 8207.01 to address the circular.
The inspector verified that the diesel generator surveillance procedures (CPS 9080.02 and the other procedures) properly addressed the circular and that no revision were required.
The inspector reviewed documentation of inspection of the diesel generator oil coolers which verified that no oil leaks existed in the oil coolers.
The inspector reviewed CPS 8207.01, 8000 Hour Diesel Engine Inspection (Division I, II and III), Revision 2 dated March 18, 1986, and found the procedure was responsive to the circular.
This circular is closed.
b.
(Closed) IE Circular 79-13 (461/79013-CC): Due to defective starting contactors, including magnetic switches, causing failure of certain diesel fire pumps to start remotely at two nuclear power plants, the NRC issued IE Circular 79-13. Cummins Engine Company, manufacturer of the diesel fire pumps, recommended replacement of magnetic switches' Model Numbers 118848 and 199573, with magnetic switch Model Number 217588.
The inspector visually verified that two magnetic switches, Model Number 217588, are physically installed on each of the two permanently installed diesel fire pumps located in the screen house.
In addition, the inspector verified that three additional replacement magnetic switches (Model Number 217588) are onsite and properly stored.
This circular is closed.
No violations or deviations were identified.
4.
Review of Construction Deficiency Report (92700) (0 pen) Construction Deficiency Report 55-85-03(461/85003-EE): On April 4, 1985, the applicant notified NRC, Region III (Ref. IP memorandum dated April 4, 1985), of a potentially reportable deficiency involving firewalls constructed with eight inch hollow core concrete masonry units (CMU's) that may not meet the three hour fire resistance rating stated in the applicant's Fire Protection Evaluation Report (FPER-1978).
This initial notification was followed by an interim report dated May 3, 1985, (Reference IP Letter U-10273) and a final report dated September 19, 1985, (Reference IP Letter U-600222). According to the applicant's September 19, 1985 letter, Sargent and Lundy (S&L) evaluated the findings regarding the fire resistance rating of the hollow core CMU's used to construct firewalls at Clinton Power Station and determined that the condition is not safety significant within the scope of 10 CFR 50.55(e) reporting requirements.
According to the
S . applicant this evaluation of the findings and determination was based on the latest update of the FPER-Amendment 1 (March 4, 1986), and the Safe Shutdown Analysis - Amendment 1 (SSA) (March 4, 1986).
Additionally, the September 19, 1985 letter stated in part, "This evaluation and determination ... was independent of the suppression system added to meet Appendix R requirements."
The inspectors' followup addressed specifically the installation of the suppression system in the Auxiliary Electric Equipment Room and Fire Area CB-3 and other fire protection features located in the Control Building (elevation 781) referenced above.
A documentation package on the potential deficiency was provided to the inspector for review including a letter dated December 11, 1985, from Illinois Power Company to NRR which indicated that physical tests were performed on five eight-inch blocks of hollow core CMU's.
The test results of the five blocks indicated that they were made of calcareous gravel having a fire resistance rating of approximately 1.9 hours instead of the 3-hour rating previously documented in FPER-1978.
Section 3.3.3.2 of the SSA identifies that the Division 1 and 2 Nuclear System Power Supplies (NSPS) support system, and the inverter rooms (Fire Zones CB-3e and CB-3f) are required for safe shutdown and are located within Fire Area CB-3.
It was also mentioned was that a fire in Area CB-3 could disable the Division 1 and 2 (Redundant) nuclear system power supplies (based on Appendix R criteria) and that if these power supplies are lost, plant shutdown can be performed from the remote shutdown panel.
Plant shutdown from the ruote shutdown panel requires the use of Off-Normal Procedure CPS No. 4003.01 entitled, " Remote Shutdown".
Further.
Figure 11 " Cable Tray Drawings" of the SSA shows where a fire in Fire Area
CB-3 cauld potentially cause damage to Division 1 (CB-4) and 2 (CB-2) cabling when using the Appendix R criteria which would require installation ' of a fire suppression system in Fire Area CB-3 after determining that the designated fire barrier is less than the 3-hour barrier.
On March 14, 1986, the inspector met with the applicant's staff regarding their determination that this issue was not reportable and the inspectors' specific review of the Auxiliary Electric Equipment Room.
The applicant's justification for this issue not being reportable was based on their belief that the onsite fire brigade could respond and control any fire emergency within the 1.9 hours of fire resistance provided by i ' the CMU's and prior to redundant trains having fire damage done to them.
With regard to a fire in Area CB-3 which could disable the NSPS power supplies possibly requiring plant shutdown from the remote shutdown panel and the use of Off-Normal Procedure (s), the Licensing and Safety Ccerdinator present at the March 14, 1986 meeting did not believe the use of Off-Normal Procedure CPS No. 4003.01 to be "Significant" as related to the 50.55(e) review criteria.
During this followup, the use of the applicant's Procedure L.3, Revision 0, dated May 20, 1985, including Attachment L.3-1, was utilized for guidance in evaluating the applicant's conclusion that this potential 10 CFR 50.55(e) report is not safety significant.
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. . Section 6 of Attachment L.3-1 provides clarification of 50.55(e) phrases including "Significant", "could adversely affect," and "At any time".
Attachment L.3-1 indicates that the clarification for "could adversely affect" does not imply that it would absolutely adversely affect safe operations, but implies a probability that safe operations may be adversely affected if the proper conditions existed. As mentioned before, Section 3.3.3.2 of the SSA indicated that if a severe enough fire were to occur in Area CB-3 and affect the NSPS power supplies, toen plant shutdown may have to be performed from the remote shutdown panel and the Off-Normal Procedures would be implemented.
"At any time" is clarified as meaning that all accident conditions of operation must be considered. The Off-Normal Procedure CPS No. 4003.01 would be used under accident conditions (fire in Area CB-3). "Significant" is interpreted as likely to have an effect on, or influence, the safe operation of the facility in an adverse manner.
The use of Off-Normal Procedures and the need to safely shutdown the plant from the remote shutdown panel certainly appears to indicate an accident condition and an "off-normal" manner in which to shut the plant down.
According to Attachment L.3-1, one of the tests of significance includes, but is not limited to, safety-related items.
Section 6.b(1) of the Attachment states, "The 50.55(e) requirement applies to any structure, system, or components (SSCs) if it contains a deficiency which were it to have remained uncorrected could have affected adversely the safety of operation of the facility.
This includes those SSCs that, even if not classified as safety-related, could cause or contribute to the degradation of integral plant safety as a result of an adverse interaction with safety related SSCs.
Primary examples of this are undesirable conditions or failures in a nonsafety system, structure (decreased fire resistance rating of the CMU's), or component which could ilipact or degrade safety systems or a safety function."
Furthermore, Part 50.55(e)(i)(iii) of Title 10 indicates that a significant deficiency in construction to be a structure which would require extensive repair to meet the criteria and bases stated in the safety analysis report.
The CMUs which provide 1.9 hours of fire resistance would require extensive repair to upgrade the firewalls to meet the 3-hour fire resistance rating criteria.
This item is considered an unresolved item (461/86017-01) pending a re-review by the applicant considering the interaction between the CMU walls decreased fire resistance rating and the protection of redundant divisions using Section III.G 2 of Appendix R criteria in determining the reportability of this issue under the provisions of 10 CFR 50.55(e) and its applicable guidance documents.
One unresolved item was identified.
5.
Employee Concerns (99014) The inspectors reviewed concerns expressed by site personnel from time to time throughout the inspection period.
Those concerns related to regulated activities were documented by the inspectors and submitted to Region III.
Five concerns were transmitted to the regional office during this report period.
. . 6.
Review of Allegations (99014) a.
(Closed) Allegation (RIII-85-A-0026; #119): BA engineers threatened with termination.
All technical issues pertaining to this allegation were inspected as documented in Inspection Reports 50-461/85002 and 85041.
On May_31, 1985, it was alleged that a person was discriminated against and eventually discharged by BA for reporting safety concerns at the CPS.
An investigation by the United States Department of Labor resulted in a finding that the person's layoff was part of a reduction in force, and not a result of discrimination.
The person appealed the finding to the Office of Administrative Law Judges, and a hearing was held.
The Office of Administrative Law Judges ordered that the person's complaint about discrimination be dismissed on February 3, 1986.
This matter is closed.
No violations or deviations were identified.
b.
(Closed) Allegation (RIII-85-A-0167; #166): Certification of BAQA auditors and lead auditors.
Region III received a copy of a letter originally sent to an executive vice president of IP.
The letter, dated September 25, 1985, had information from an individual who previously filed a discrimination suit with the State of Illinois about unequal pay for an auditor by BA.
In the letter, the individual identified a person employed by BA who received auditor and lead auditor certification in June 1983, and April 1984 respectively; however, the person did not meet the requirements of ANSI N45.2.23 - 1978 " Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants".
The individual's concern was specific to the awarding of points for certification in the areas of experience and rights of management.
Inspector's Notes: (1) There were two BA procedures that described the requirements for certifying auditors and conducting audits during the period June 1983 through April 1984.
BQA 150 " Quality Assurance Audits", revision 8
BQA 181 " Qualification & Certification of Quality
Assurance Auditors", revision 2 Neither procedure referenced ANSI N45.2.23 - 1978, but the requirements of BQA 181 were very similar to it.
(2) Because the allegation was made to IP, the inspector made independent assessments and reviewed IP's investigation of this matter in accordance with Region III policy.
IP's review of this matter is contained in their file #635.
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(3) Information pertaining to BAQA auditor training and certification is also contained in Inspection Reports 50-461/82018 and 83015.
Concern No. 1 Area of Experience for Auditor.
~ In June 1983, the person was certified as an auditor based on the following scoring system: Education - 2 points (3 points maximum)
Experience - 2 points (6 points maximum)
Rights of Management - 3 points (4 points maximum)
Total - 7 points (6 points minimum)
The person had been in the auditing department for 15 months; therefore, the person should have received only 1 point.for experience.
, NRC Review , BA procedure BQA 181 required full 12 months of experience to accumulate a service point for experience. The inspector noted that if only one service point had been credited for experience, the person would still have had six points which meets the minimum requirement for certification as an auditor.
Results The concern is substantiated; however, the person still met the overall minimum number of service points required by BQA 181 to be an auditor.
Concern No. 2 Rights of Management In April 1984, the person was certified as a lead auditor based on the following scoring system: Education - 2 points (4 points maximum)
Experience - 7 points (9 points maximum)
Rights of Management - 1 point (2 points maximum)
Total - 10 points (10 points minimum)
The person had been fn the auditing department for 24 months; therefore, should nave received only 6 points for experience.
. , . NRC Review The inspector reviewed BA procedure BQA 181 that described the methods for accumulating service points for experience.
The inspector substantiated that the person should have only received six points for experience based on two points for technical experience, and four points for nuclear QA auditing.
However, as included in IP File #635 and documented on BA memorandum JVH#1963986, the seven points given for experience included one point for pre-BA employment experience which was justifiable in the opinion of the BA evaluator.
BA procedure BQA 181 describes the " rights of management" to award service points.
The attributes for lead auditor defined as " rights of management" were leadm. ship, sound judgement, maturity, analytical ability, tenacity, past performance, QA training, and active participation in site QA audits.
The inspector noted that BQA 181 did not have qualitative acceptance criteria for evaluating " rights of management"; however, neither does ANSI N45.2.23.
As documented in BA memorandum JVH#1963986, even if only six points had been awarded for experience, it would have been justifiable for BA management to have awarded two points for " rights of management" instead of one for a total accumulation of 10 points.
The inspector also noted in the individual's September 25, 1985 letter, that the individual never questioned the subject person's ability to perform or lead an audit, or that the individual's certification had any impact on safety or quality of the plant.
Results The concern is substantiated; however, there was no evidence indicating that the person failed to perform the duties of a lead auditor, nor that plant quality or safety was affected in any way.
Concern No. 3 There have been certifications awarded to personnel who have not fulfilled the requirement of completing five audits; it is suggested that all lead auditor certifications awarded from November 21, 1983, through September 17, 1984, be reviewed for accuracy.
NRC Review BA procedure BQA 181 required prospective lead Auditors to have participated in a minimum of five nuclear QA program audits; however, as stated in the procedure, the requirement could be waived based on a person's background or ability in a quality related field.
The practice of waiving the audit requirements was recognized as a weakness in July 1983, as documented in IPQA audit Q31-83-7.
The IP audit team recommended that BA revise BQA 181 to conform with ANSI N45.2.23.
As documented in BA QPCR No. 83-104, an attachment to BQA 181, on October 11, 1983, waiving the auditing requirement was disallowed.
In March 1984, as documented in Amendment 29 to the
._ f ! . . . Final Safety Analysis Report, IP formally committed to Regulatory Guide 1.146, " Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants", which endorses ANSI N45.2.23 - 1978.
As documented in BA memorandum JVH#1963986, the personnel files for six BA auditors certified between January 1983, and August 1985, were re-reviewed by the BA Manager of QA.
In addition, the inspector reviewed the certification file for three other auditors.
In no case were problems identified with the certification of the nine BAQA auditors.
Results The concern was not substantiated. Waiving of the five audits was allowed by procedure until October 1983; none of the reviewed certification files were inaccurate.
Concern No. 4 Auditor certifications have been awarded to personnel who were not within the scope of the qualifying procedure.
NRC Review As documented in BA memorandum JVH#1963986, any employee who has the required experience and educational ! 'ckground could be trained and certified within the scope of the BA training and certification program. Also, as documented in the memorandum, persons not directly working in the audit department could be given " rights of management" points based on discussions with the employee's immediate supervisor.
The scope of BA procedure BQA 181 includes lead auditors and auditors.
Auditors include technical specialists and management representatives who participate in audits.
This practice is endorsed by ANSI N45.2.23 and Regulatory Guide 1.146.
Results The concern is not substantiated.
Procedure BQA 181 would have been used to qualify and certify QA auditors regardless of an employee's previous department.
The use of technical specialists and management representatives on audit teams is recommended by ANSI , N45.2.23.
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. . .
Conclusion Based on the investigation performed by IP as documented in IP file
- 635, and the independent review by the inspector, it is concluded that the specific individual and other BA audit personnel were properly certified according to the requirements of the BA certification process; and the certification process was adequate.
It is also conciuded that even though some aspects of the allegations were substantiated, there was no evidence of impact on plant safety or quality.
This matter is closed.
No violations or deviations were identified.
c.
(Closed) Allegation (RIII-85-A-0183; No. 168): Improper certification of BA QC electrical inspectors.
This allegation was closed in Inspection Report No. 50-461/85065.
Subsequent to the inspection, an individual provided information to the resident inspector about photographs which had been taken in 1984, of an examination that was subject of the NRC inspection.
The information was considered by the reviewing inspector who determined that photographs of the examination would not change the results of the inspection.
This matter is closed.
No violations or deviations were identified.
d.
(Closed) Allegation (RIII-86-A-0001; No. 178): Dumping of raw sanitary sewage into Clinton Lake.
An individual contacted the NRC on January 2, 1986, about the disposal of raw sanitary waste into the lake adjoining the Clinton Power Station.
The individual stated that Illinois Power had been dumping excess raw sanitary waste into the lake since June 1985, including 350,000 gallons during the Christmas period and that prior to June, Baldwin Associates shipped the excess waste to the Clinton Sanitary District.
Since this allegation is outside the purview of the NRC, on February 4, 1986, the allegation was forwarded to the State of Illinois Environmental Protection Agency for action.
This matter is closed.
No violations or deviat'ons were identified.
7.
Functional or Program Areas Inspected a.
Site Surveillance Tours (71302/60501) At periodic intervals throughout the report period, surveillance tours of selected areas of the site were performed.
Those surveillances were intended to assess: cleanliness of the site; storage and maintenance conditions of plant equipment and material; potential for fire or other hazards which might have a deleterious
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. % . effect on personnel or equipment; storage conditions of new fuel; and to witness maintenance and precperational testing activities in progress.
At the conclusion of the previous inspection period (Inspection Report 50-461/86008), the inspectors noted a decrease in the level of general plant cleanliness throughout most accessible areas.
During this inspection period, the inspectors have noted an improvement in general plant cleanliness.
The effort on the applicant's part to upgrade cleanliness zones throughout the plant as the construction population declines will continue to be monitored by the inspectors.
No violations or deviations were identified.
b.
Operating Procedures Review (42450) This inspection commenced a review of procedures to be used in the plant operations phase to confirm that the plant operating procedures are prepared to adequately control safety-related operations within applicable regulatory requirements.
This inspection is being performed using a diverse group of NRC inspectors including three Senior Resident Inspectors at operating boiling water reactor sites in Region III; the Clinton resident inspectors; and an Argonne National Laboratory contractor inspector.
(1) Applicable Requirements, Applicant Commitments, and Guidance Documents Documents (a) 10 CFR 50 (b) Regulatory Guide 1.33, revision 2, Quality Assurance Program Requirements (Operation) , (c) ANSI N18.7-1976, Administrative Controls and Quality Assurance For The Operational Phase Of Nuclear Power Plants . (d) ANSI N45.2-1977, Quality Assurance Program Requirements For Nuclear Facilities.
(e) CPS Final Safety Analysis Report (FSAR), through amendment !
(f) CPS Draft Technical Specifications (g) CPS No. 1005.01, Preparation, Review and Approval of Station Procedures, revision 16, dated March 1, 1986 (h) System P&ID and C&ID
(2) Procedures Selected for Review Procedure Revision Title (a) 1011.02
Imple. & Control of Surveillance Test (b) 1013.02
Fuel Handling, Gen. Resp.
(c) 1014.01
Safety Tagging Proc.
i E
. % . Procedure Revision Title (d) 1405.02
LCO Manual Tracking (e) 3101.01
Main Steam (f) 3203.01
Component Cooling H2O (g) 3208.01
Cycled / Makeup Condensate (h) 3211.01
Shutdown Service H2O (i) 3220.01
Suppr. Pool Make-Up (j) 3305.01
RPS (k) 3313.01
LPCS (1) 3314.01
Standby Liquid Control (m) 3412.01
Essen. SWGR Heat Removal (n) 3501.01
Hi. Volt. Aux. Powar Sys.
(o) 3509.01
Instrument Power (p) 3842.01
Plant Communication Alarm Test (q) 9012.01
Scram Disch. Vol. Vent & Drain Valve Op Test (r) 9051.01
HPCS Sys. Pump Op.
(s) 9052.01
LPCS Operability Checks (t) 9053.03
Div. 2 Simul. Auto Actua.
(u) 9080.03
Diesel Gen. Operability (v) 9080.04
Diesel Gen. Auto Load / Reject Verif. Test (w) 9080.09
Unit Power Supply Xfer Availability (x) 9090.01
Refueling Interlocks Operability Test (y) 9092.01
Inclined Fuel Xfer Sys. Interlocks Funct.
(2) Discussion At the conclusion of this inspection period, review of the above procedures was still in progress.
Results of this review will be documented in a subsequent inspection report.
c.
Test Witnessing _ Diesel Generator Roon CO2 Concentration Test (70311) On March 13, 1986, the inspector was preuent to witness the performance of the Diesel Generator Room Number 2 carbon dioxide (CO2) concentration test including an overview review of the Checkout and Initial Operations (C&IO) Test Procedure Numbered XTP-FP-CO-72, and the vendors (Chemtron) CO2 system Operation and Service Manual.
During the performance of this concentration test, the inspector observed the failure of one vertical ventilation duct fire damper out of three to close completely, due to the electrothermal link (ETL) conduit having gotten wedged between the fire damper blade and the bottom of the fire damper assembly base.
In addition, the inspector observed the failure of the CO2 to discharge into the Diesel Generator Room due to a broken CO2 return line failing to actuate the master selector valve.
Consequently, during the applicant's investigation of the broken return line, an apparently defective solenoid was also discovered.
The three deficiencies mentioned above constituted failure at this attempt for a successful CO2 concentration test.
. . , . On approximately March 18, 1986, the applicant's Fire Protection - Project Manager informed the inspector that the deficiencies had been corrected and a successful concentration test was performed as of March 17, 1986 for each of the three Diesel Generator Rooms.
Pending inspector review of the test packages concerning the successful CO2 concentration tests for the Diesel Generator Rooms, this is considered an open item (461/86017-02).
No violations or deviations were identified.
8.
Independent Inspection Effort-Review of Plant Maintenance Program (42450) a.
Introduction The inspector reviewed changes made to CPS administrative procedure CPS No. 1029.01, Preparation and Routing of Maintenance Work Requests, revision 7.
In response to a change in Corporate Nuclear Procedure (CNP) 3.03, Nonconforming Material Report, changes were made to procedure CPS No. 1029.01 via procedure deviation for revision (PDR) 86-094 dated March 13, 1986.
The change effected by the PDR resulted in a top level plant administrative procedure (1029.01) not being adequate to control work activities in conformance with the applicant's Quality Assurance Program and the requirements of 10CFR50, Appendix B.
The inspector concluded that the POR used to implement the procedure change was issued in violation of plant procedures at the direction of plant management; that the change made in accordance with the POR would not have been approved for use as written if the change had been subjected to appropriate review and approval prior to distribution; and that CPS No. 1029.01, revision 8 still contained provisions and features which required resolution by the applicant.
The following paragraphs provide the details of this independent inspection.
b.
Details The purpose and scope of CNP 3.03, Nonconforming Material Report, was revised on March 11, 1986.
That revision added the following provisions to the CNP: Maintenance Work Requests (MWRs) may be used, in lieu of an NCMR [ Nonconforming Material Report], for documenting, correcting, and trending non-ASME Section III nonconformances which can be resolved by a repair disposition which does not affect fit, form, or function; rework; or reject.
This revision represented a substantive change in the CNP, which had previously required the documenting of nonconformances on a NCMR.
The change also represented a substantive change in the use of the MWR, which had previously been identified in the applicant's program as a corrective action document only.
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. . % . In order to implement the change in the CNP, a special assistant to the Manager - Clinton Power Station prepared PDR 86-094 to CPS No.
1029.01, revision 7.
The PDR, issued on March 12, 1986, provided the following instructions concerning the procedure revision: (8.2.6) At the end of the note, add a second note " Maintenance Work Requests may be used in lieu of an NCMR, for documenting, correcting, and trending non ASME section III nonconformances which can be resolved by a repair disposition which does not affect fit, form or function; rework; or reject. A description of the problem, the resolution and the signature of the NSED engineer shall be shown on the MWR.
A QC inspection of the completed corrective action shall be obtained and documented on the MWR and then MWR shall be annoted as a nonconforming condition.
This note was added to the instructions provided to the maintenance planners for preparation of the MWR work package.
This change came to the attention of the inspector on March 20, 1986.
The inspector performed a brief review of CPS No. 1029.01, revision 7, in light of the above change.
The review resulted in a number of questions concerr.ing the ability of the applicant to demonstrate conformance with the IP Operational QA Manual (0QAM), Chapter 15, Nonconforming Materials, Parts or Components.
Because the change was processed on a PDR rather than in a revision of the procedure, the change had not been explicitly reviewed by IPQA and other affected organizations prior to issuance.
The inspector briefly reviewed CPS No. 1005.07, Temporary Changes To Station Procedures, revision 4 dated February 7, 1986.
That procedure provided the following information concerning the use of the PDR: (*2.2.2.2) PROCEDURE DEVIATION for REVISION (PDR) - a temporary change to an approved CPS procedure. When approved, the PDR will result in a revision to the procedure of which the scope is limited to the change (s) contained in the PDR.
(*8.1.2) The change shall be necessary to continue work in i progress.
Additionally, the work in progress shall be essential to maintain plant availability or to ensure plant nuclear safety.
PDRs to 10XX procedures require verbal approval from the Manager - Clinton Power Station or designee; PDRs to 11XX through 19XX require verbal approval from the responsible Department Head or designee.
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. % . NOTE During the construction phase of the plant, PDRs may be used to remove "laters" from all series of procedures.
Additionally, prior to fuel load, trial use of surveillance procedures is permitted per Appendix A.
(*8.1.4) A temporary change shall not be used to alter the intent of the original procedure as defined in the procedure purpose section.
Prior to issuance of PDR 86-094, the purpose of CPS No. 1029.01, Preparation and Routing of Maintenance Work Requests, was to provide control of maintenance work and corrective action to identified deficiencies. After issuance of the PDR, the purpose of the procedure was expanded to include all aspects of documenting, dispositioning, correcting and trending of nonconformances; thus the PDR represented a change in the intent of the original procedure, in violation of CPS No. 1005.07, paragraph 8.1.4 (461/86017-03A).
In addition, the work of documenting, dispositioning, and trending of nonconformances using the MWR program was not in progress at the time of issuance of the PDR.
Thus, the PDR violated CPS No. 1005.07, Paragraph 8.1.2 (461/86017-038).
Since the POR did not provide or reference procedure steps necessary to address all applicable aspects of the Operational QA Manual for control of nonconformances, the PDR violated CPS No.
1005.07, paragraph 2.2.2.2 (461/86017-03C).
Finally, the FDR, as a change to a 10XX procedure, was approved by the Manager, CPS prior to issuance.
Eecause CPS No. 1029.01 was changed via a PDR, the change was not reviewed by all affected organizations prior to issuance for use.
Issuance of the PDR resulted in a plant administrative procedure that was not adequate to implement the requirements of the applicant's 0QAM Chapter 15.
The issuance of PDR 86-094 was in Violation of CPS 1005.07 and represents a Violation of 10 CFR 50, Appendix 3, Criterion V and the IP Operational QA Manual, Chapter 5, which require that activities affecting quality be accomplished in accordance with written procedures (461/86017-03).
This matter was discussed extensively with the Manager, CPS, the Director, Quality Engineering and Verification, the Manager, Licensing and Safety, and others of the applicant's staff.
The applicant has denied the violation because they believe that the PDR did not change the intent of the procedure.
On March 20-21, 1986, IPQA performed a detailed review of CPS No.
1029.01, revision 7, as revised by PDR 86-094.
Their review resulted in a number of comments requiring resolution.
The review was summarized by IPQA as follows:
21 -. _
. s . "PDR 86-094 is rejected by QA because it does not meet the requirements of the 0QAM Chapter 15 and CNP 3.03..." This information appeared to confirm the inspector's concern.
On March 25, 1086, the applicant issued revision 8 to CPS No. 1029.01 to incorporate the change made by PDR 86-094 and to provide appropriate review and approval for the change by all affected organizations.
Comments developed during that review and approval process were not documented and resolved in accordance with CPS No. 1005.01, Revision 16, paragraph 8.3.1.5.
This is an unresolved item (461/86017-04A).
In conjunction with the issuance of CPS No. 1029.01, Revision 8, the applicant developed a cross reference'between the 0QAM, Chapter 15, and CPS No. 1029.01 and other impicmenting procedures.
The inspector noted that the majority of CPS No. 1029.01 paragraphs referenced in the matrix had been revised in Revision 8.
On Aoril 1-2, 1986, the inspector performed a detailed review of CPS No. 1029.01, Revision 8, with the assistance of a contractor inspector from Argonne National Laboratory.
The inspectors met with the applicant on April 3 and 6, 1986, to discuss questions that resulted from the review.
At the conclusion of the inspection, there were eight questions which remained unresolved regarding the adequacy of CPS No. 1029.01, Revision 8, to control safety-related work within the scope of the procedure.
Those questions remaining unresolved were as follows: (1) Resolution of comments to the draft procedure revision (461/86017-04A).
(2) Definition of the term "a repair disposition that does not affect fit, form, or function" (461/86017-04B).
(3) Definition of job priorities for security system and other important equipment that doer not directly affect plant operation (461/86017-04C).
(4) Disposition of form CPS No. 1029.01F007 when a maintenance request is converted to a maintenance werk request (CPS No.
1005.01, Appendix A, paragraph Documents (g)) (461/86017-04D).
(5) Definition as to the location where permission to release equipment or systems for maintenance is documented / recorded by designated operating personnel (ANSI N18.7-1976, paragraph 5.2.6) (461/86017-04E).
(6) Paragraph 8.2.3 did not provide or reference instructions for maintenance planners concerning what was required to obtain a .
,. -.. - -. _ _.
. % . minimally acceptable work package.
In addition, no job instructions were available to the maintenance planners concerning the preparation of a work package (461/86017-04F).
(7) The procedure did not provide or reference limitations on the term " Tool Box Skills" (461/86017-04G).
(8) CPS No. 1029.01, Paragraph 8.2.17 required clarification of the words "The work can continue if the results will be within design requirements" (461/86017-04H).
The applicant was actively pursuing resolution of the above questions at the conclusion of the inspection.
This matter is unresolved (461/86017-04).
The adequacy of the applicant's procedure review and approval process is the subject of unresolved item (461/85012-02) which was recently addressed in Inspection Report 50-461/85065.
The applicant was in the process of developing a corrective action plan to resolve that item during this inspection period.
c.
Results One violation and one unresolved item were identified.
9.
Safety Evaluation Report Review and Followup (92719) The following items from NUREG-0853. Safety Evaluation Report related to . the Operation of Clinton Power Station, Supplement 5, were referred by the Office of Nuclear Reactor Regulation, Division of Licensing, to Region III for confirmation of applicant actions.
a.
SSERS, paragraph 2.6.1.1 - Verify that a 2'6" high berm has been constructed around the Unit 2 excavation site and berm has been stabilized with vegetation, if necessary, to prevent soil erosion.
(461/86017-05).
b.
SSERS, paragraph 3.10.3.1 - Verify that prior to fuel load: 1) the 24 and 36 inch purge and vent valves have mechanical stops installed to limit maximum opening angle to 50 degrees; 2) orientation of these valves is in accordance with manufacturer's recommendation; , ! and 3) the body-to-bracket bolt material for the 36 inch valves has i been changed to higher strength materials.
(461/86017-06).
c.
SSERS, paragraph 7.5.3.1 - Verify that separate Class IE power i supplies have been provided for both fuel zone level channels prior j to startup from the first refueling outage.
(461/86017-07).
The above items are open and will be reviewed in subsequent inspections.
! No violaticns or deviations were identified.
i
[
. s . 10.
Site Activities of Interest a.
Fuel Load Schedule (94300) On March 21, 1986, Illinois Power Company announced that the March 31, 1986 scheduled fuel load date for Clinton Power Station would not be met.
Due to additional testing that must be completed prior to fuel load and due to scheduling difficulties, the applicant did not identify a new scheduled fuel load date. The applicant believes that late June to early July is a realistic time frame for a licensing decision.
b.
Readiness For Fuel Load Meeting (30702) On April 1, 1986, NRC Region III management met with IP management at the Clinton Power Station to discuss the current state of readiness of CPS to load fuel.
This was the third of a series of such meetings to be held with IP management on a routine basis.
Personnel attending the meeting are identified by (+) in Paragraph 1 of this report.
The meeting, which lasted about two hours, included the following: , (1) A short briefing by Mr. Hall concerning the status of the facility and actions being taken to address current problems (2) Preoperational Test Program Status (3) Test Deferral Request (4) CPS Safety Review Program (5) Status of the conduct of surveillance testing for credit (6) Plant procedure reviews in progress (7) CPS " Things" list In addition, some discussion of the findings documented in paragraph 8. of this report were discussed at the conclusion of the meeting.
Both Region III and IP management agreed to schedule the next monthly management meeting for May 1, 1986.
c.
Seismic Monitoring Instrumentation (92701) The inspector observed an IP maintenance technician inspect a triaxial seismic monitoring recorder located in the screenhouse.
The purpose of the inspection was to determine if the recorder had . felt the ground acceleration caused by an earthquake epicentered near Cleveland, Ohio.
The results of this inspection were discussed with a seismologist in NRR. The information recorded by the instrument appeared to be construction noise.
No further action is deemed necessary.
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_- -_-_ - . t , 11.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations.
Two unresolved items disclosed during this inspection are discussed in paragraphs 4. and 8.b.
12.
Open Items Open items are matters which have been discussed with the applicant, which will be reviewed further by the inspector, and which will involve some action on the part of the NRC or applicant or both.
Four open items disclosed during the inspection are discussed in paragraphs 7.c and 9.
13.
Exit Meetings (30703) The inspectors met with applicant representatives (denoted in Paragraph 1) throughout the inspection and at the conclusion of the inspection on April 7, 1986.
The inspectors summarized the scope and findings of the inspection activities.
The applicant denied the violation described in paragraph 8. occurred.
The applicant's denial was duly noted and identified to Region III management. The applicant acknowledged the other inspection findings.
The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection.
The applicant did not identify any
- uch documents / processes as proprietary.
The resident inspectors attended exit meetings held between Region III based inspectors and the applicant as follows: Inspector (s) Date Love, Sutphin 2/27/86 Hare, Oestmann, Holtzman 2/28/86 Keating 3/3/86 Stasek, Evans, Larson, Ward, Baxter 3/6/86 Scheibelhut 3/7/86 DuPont, Ulie 3/13/86 Snell, Foster, Allen, Smith 3/14/86 Drouin 3/14/86 Paul 4/3/86 Scheibelhut 4/4/86
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