IR 05000461/1986074

Insp Rept 50-461/86-74 on 861201-05.Violation Noted:Failure to Follow Administrative Procedures in Area of Control of Lifted Leads,Jumpers & Temporary Mechanical Alterations

ML20212B757
Person / Time
Site:	Clinton
Issue date:	12/17/1986
From:	Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20212B702	List: IR 05000461/1986074 ML20212B694 ML20212B716
References
50-461-86-74, NUDOCS 8612290310
Download: ML20212B757 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-461/06074(DRP)

Docket No. 50-461 License No. NPF-55 Licensee: Illinois Power Company 500 South 27th Street Decatur, IL 62525 Facility Name: Clinton Power Station Inspection At: Clinton Site, Clinton, IL Inspection Conducted: December 1 through 5, 1986 Inspectors: J. W. McCormick-Barger J. S. Wiebe K. R. Ridgway P. L. Hiland G. F. O'Dwyer ,

Approved By:

k R. C. Knop, Chief D 12. - 17-N Projects Section IB Date Inspection Summary Inspection on December 1 through 5, 1986 (Report No. 50-461/86074(DRP))

Areas Inspected: Special announced inspection by resident and region based inspectors to perform a pre-full power license operational readiness inspection at the Clinton Power Station. Areas reviewed included: licensee action on previous inspection findings; surveillance testing as required by technical specifications; non-licensed operator and maintenance training; control of out of service equipment and equipment tagging; control of lifted leads, jumpers and temporary mechanical alternations; annunicator status and control; and control room observations. An additional inspection is planned to assess the implementation of the Quality Assurance Program, and followup of previous findings concerning implementation of the Plant Maintenance and Design Changes and Modifications Programs identified in inspection report 461/86053(DRS). This additional inspection and previous inspection 461/86053(DRS) will be considered a part of the pre-full power license operational readiness inspectio Results: Of the eight areas inspected, no violations or deviations were identified in seven of the areas. One violation was identified in the area of control of lifted leads, jumpers, and temporary mechanical alterations (failure to follow administrative procedures - paragraph 5). No significant safety concerns were identified during this inspection; however, several examples were identified where licensee personnel were either not following administrative procedures or these procedures did not exist to control activities that may affect the operation of the plan PDR ADOCK 05000461 Q PDR

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DETAILS Persons Contacted D. Hall, Vice President, Illinois Power Company

• R. Campbell, Manager QA

• J. Greenwood, Manager, Power Supply, WIPC0/Soyland Power

• R. Greer, Director, Outage Maintenance Programs

• J. Perry, Manager, Nuclear Programs Coordination

• F. Spangenberg, Manager, Licensing and Safety

• J. Weaver, Director, Licensing

• J. Wilson, Manager, Clinton Power Company The inspectors also contacted other individuals during the inspectio * Denotes those persons attending the exit interview on December 5, 198 . LicenseeActiononPreviousInspectionFindings(92701)

(Closed)OpenItem(461/86037-4C): Tracking Out of Service Annunicator The licensee was not using the Temporary Modification Log to track out of service annunciators as required by the existing plant administrative procedure During this report period, the inspectors reviewed Administrative Procedure CPS No. 1406.01, "Out of Service Annunicator Tracking",

revision 2, dated October 24, 1986. This procedure provided the controls to disable " nuisance" annunicators and to track out of service annunciators. The controls established were reviewed by the inspectors and were discussed with control room operators to verify proper implementation of the administrative procedur The inspector concluded that the controls established by CPS No. 1406.01 were effective in tracking out of service annunicators. In addition, the inspectors observations in the control room verified proper implementation of the procedure. This item is close No violations or deviations were identifie . Review of Surveillance Testing as Required by Technical Specifications (61726) (61725)

The NRC inspectors performed an in-depth inspection of technical specification (TS) and surveillance testing requirements as specified in the Clinton Power Station (CPS) Administrative Quality Assurance Operating Manual. CPS technical specifications, surveillance procedures, Plant Manager Standing Orders, weekly surveillance schedules, Limiting Condition for Operation (LCO) Tracking Log, and completed surveillance test packages were obtained and reviewe _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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During the inspection the following procedures were revle d:

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IP Nuclear Power Operating QA Manual, Chapter 11,' Revision 12,

" Test Control", dated August 15, 1985, and Chapter 12, Revision 13

" Control of Measuring and Test Equipment *, Aated February 6,198 ,

p i CPS 1005.01, Revision 19. dated September 10, 1986, " Preparation', ,

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Revision, and Implementation of Station Operating Procedures and '

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Documents."

CPS 1005.07 Revision 7, dated November 13,1986, " Temporary C)inges to Station Procedures." ,

CPS 1011.00, Revision 0, dated December 18, 1985, " Surveillance Testing Program." .> !

CPS 1011.02, Revision 6 dated July 30,.1986, "Inplementation 4,nd ,

Control of Testing Program." '

CPS 1011.05, Revision 1, dated June 26, 1986,'" CISSurveillance Testing." i

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CPS 1011.06, Revision 2, dated July 30, 1986, " Routine Surveillance Tracking and Scheduling." a CPS 1401.01, Revision 10, dated, September 18. H86, " Conduct of Operations." ,

CPS 1405.02, Revision 2, dated April 25, 1986, " Limiting Condition ofOperations(LCO) Tracking." ,, t CPS 3001.01 C002, Revision 0, dated January 16,1984, Mode 2 Checklist."

CPS 3002.01 C002, Revision 1, dated January 3, 1984, "Mooe 1 Checklist." .

CPS 3002.01 C003, Revision 0, dated Janidry 6,1984, " Mode 3 Checklist."  ;

CPS 3006.01 C001, Revision 2, dated September 20, 1986, " & de 4 Checklist, (Individual test check)" ,

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CPS 3007.01 C001, Revision 1, dated September 20, 1986, " Mode 5 Checklist." .

CPS 3007.01 C003, Revision 1 dated Septembar 20, 1985, " Core -

Alterations Checklist." ,

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CPS 3007.01 C004, Revision 1, dated September 28, 1986, " Control Rod Withdrawl Checklist."

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The following Surveillance Procedures were reviewed during this inspection:

CPS 9000.01, Revision 20, dated July 7, 1986, " Control Room Surveillance Log" and data sheets D001, Revision 20, dated July 5, 1986, for Modes 1, 2, and 3, and D002, Revisen 22, dated September 28, 1986, for Modes 4 and CPS 9000.02, Revision 20, dated July 7, 1986, " Unit Attendant Surveillance Log" and data sheet D001, Revision 21, dated October 16, 198 CPS 9031.04, Revision 20, dated May 12, 1986, "RPS Reactor Vessel Water Level 1321-N080A (B, C, D) Channel Calibration."

CPS 9031.13, Revision 20, dated May 17, 1986, "SRM Channel Functional."

CPS 9052.03, Revision 20, dated January 28, 1986, "ECCS Division 1-Automatic Actuation."

C?S 9030.01, Revision 21 and TCN 86-1603, dated November 26, 1986,

" Analog Trip Module (ATM) Channel Functional and Calibration Check Instructions."

CPS 9052.03, Revision 20, dated January 28, 1986, "ECCS Division 1 Automatic Actuation."

CPS 9052.04, Revision 20, dated December 23, 1985, "LPCS System Header Filled and Flow Path Verification."

CPS 9053.01, Revision 21, dated October 7, 1986, "RHR System Header Filled and Flow Path Verification."

CPS 9053.06, Revision 20, dated March 5, 1986, " Containment Spray Functional Test."

CPS 9053.07, Revision 21, dated November 21, 1986, "RHR Pumps A, B, C, Operability Test."

CPS 9432.15, Revision 21, dated November 21, 1986, "RHR Heat Exchanger A Room Differential Temperature E31-N600A(B) and RHR Heat Exchanger B Room Differential Temperature E31-N611A(B) Channel Functional / Calibration."

CPS 9431.04, Revision 20, dated May 12, 1986, "RPS Reactor Vessel Water Level B21-N080A (B, C, D) Channel Calibration."

CPS 9432.16, Revision 21, dated June 12, 1986, "RHR Heat Exchanger Room Temperature E31-N608A(B)/E31-N610A(B) Channel Calibration /

Channel Functional."

CPS 9432.06, Revision 20, dated June 9, 1986, "CRVICS RCIC Steamline Flow E31-N083A(B) and E31-N084A(B) Channel Calibration."

Other documents reviewed included:

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PlantManagerStandingOrder(PMS0)-30, Revision 3, dated October 20, 1986.

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The inspector's review concentrated on the Residual Heat Removal System .

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. (RHR) including the Low Pressure Coolant Injection mode.(LPCI) and the '

Low Pressure Core Spray System (LPCS) and consisted of a cross check 2 - of all TS surveillance requirements for these systems with the Master List of Surveillance Requirements and applicable surveillance procedure '

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The inspectors determined that all required TS surveillances for these systems were on the Master List. The Master List contained the

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procedure number for each Channel Check (shift or daily),. Channel Functional Test (usually monthly), and Channel Calibration (each

, refueling or 18 months). -It also listed the responsible department,

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the surveillance frequency or other initiating trigger, the sequential test number, and identifying comments. The inspectors determined that ,

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the TS frequency requirements were correctly entered in the Master Lis i Ten of the RHR surveillance test procedures, 40%, were reviewed for completeness of coverage, restoration of equipment following the tests, and TS limits. Except for the discrepancies listed in the following

paragraphs, the procedures appeared to be adequate.

i During.the review of the above RHR surveillance procedures the inspectors

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noted that in many of the procedures, section 1 titled " Purpose" identified the wrong TS number as being satisfied by performance of the procedure. Whan questioned, the licensee stated that the TS number error t

was due to last minute changes to the TS just prior to license issuance,

{ which re'sulted in the renumbering of several TS requirements. The licensee stated that it was aware of this problem and intended to make the appropriate corrections during the next periodic revision to the '

associated procedures. The licensee also estimated that more than 100

, surveillance procedures were affecte The licensee was informed that this was not an acceptable method to 3 correct procedural errors and that interim corrective actions such as

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preparations of Procedure Deviation for Revision (PDR) forms or other methods would have to be employed in a timely manner. The licensee i indicated that it may employ a Plant Manager Standing Order (PMS0)

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indicating that the TS references in surveillance procedures are not s to be relied upon and to refer to an interim surveillance procedure

to TS cross referencing document for reliable information. Resident d

i inspector followup of this concern will be tracked as an open item (461/86074-01(DRP)).

Operations Support (0S), has the responsibility of maintaining the Master List of Surveillance Requirements and auditing the program. Operations Support issues a weekly schedule of surveillances performed on a weekly

or greater frequency. Each assigned department has the responsibility of performing the surveillance and returning completed and approved

surveillance test packages to OS. Surveillances of more frequent periods are carried in shift logs or other data sheets. These are audited by the group performing the checks and by OS on a weekly frequency.

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Members of OS stated that scheduling and coordination of the various groups performing the surveillances were carried out through the Shift Supervisor Operations. Inspectors observations during the inspection indicated no significant problems in coordinating test The inspectors reviewed established procedures and checklists to assure the completion of surveillances when making mode changes, core

- alterations, or. starting control rod withdrawls. The inspectors determined that the required surveillances as listed in the TS for the RHR, and LPCS systems were included in these checklists. No discrepancies were note The inspectors reviewed the methods used to establish and control'the time that equipment is out of service for surveillance testing and to meet the action-requirements for LCOs. The TS surveillance outage start and completion times are indicated by a red "I" in the Control Room Log and TS maintenance outages by a red "T". When equipment is out of the LC0 and in an action statement it is carried in the LC0 Log, which is reviewed each shift for the status of open action items. No deficiencies were noted in this are The inspectors reviewed surveillance procedure CPS No. 9031.13 "SRM ,

Channel Functional", performed on December 2, 1986. The inspectors noted '

that a Temporary Procedure Deviation (TPD) form was used to document a change that was clearly a permanent change in which a PDR should have been used. The use of a TPD is administratively limited to only one occurrc.nce of the activity and does not result in a subsequent revision to the surveillance procedure nor is it made a permanent attachment to +

the procedure for subsequent use, as is a PDR. When questioned by the inspectors, the licensee indicated that until recently its administrative control procedure for changing surveillance procedures did not allow more than one PDR to be written against any one surveillance procedure before the procedure was to be revised. The licensee stated that the procedure in question was in the revision process and since procedure revisions normally take between three to four weeks, a TPD was being used in the interim. The licensee stated that the recent change, dated November 18, 1986, to CPS No. 1005.07. " Temporary Changes to Station

, Procedures", allows the use of multiple PDRs and therefore the TPD should not have been used. The inspectors requested that the licensee perform a review of recently performed surveillance procedures to assure that no other surveillance procedures were being inappropriately changed using

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TPD forms.

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( Subsequently, the licensee informed the inspectors that it reviewed all surveillances performed during the last month and found three other cases where TPD's were inappropriately used. The licensee indicated that PDRs were processed for all four surveillance procedures. The inspectors reviewed the new revision of CPS No. 1005.07 dated November 13, 1986, and concluded that the change appropriately remedied the problem of previously not allowing multiple PDRs to be written against any one procedure. Based on this procedure change and corrective i actions taken by the licensee to remedy the errors associated with the l

four cases where TPD's were inappropriately being used subsequent

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to the administrative procedure revision, the inspectors have no further concern in this are Two surveillance tests, RCIC Reactor Water Level 8 B21-N693A and B Channel Functional Tests, were observed on December 4, 1986, to determine if operators were trained and competent and were following approved instructions and procedures. The procedure used was CPS 9030.01, " Analog Trip Module (ATM) Channel Functional and Calibration Check Instructions",

Revision 21, dated November 25, 1986, and Checklist C007, Revision 2 The procedure was under an approved CPS Temporary Change No. 86-1603, dated November 26, 1986. The temporary change was a procedure deviation to allow performance of a channel check at the completion of the channel functionals while the Self Test System was still in'a degraded mode rather than switching to the " Monitor Compare Mode", which causes frequent failures of the "Self Test System."

The above procedure and checklist included the required sections and adequate instructions and included independent verification of system restoration. The data sheet contained acceptance criteria. Personnel contacted prior to the test and the person performing the test appeared to be knowledgeable and competent. No deficiencies were note The inspectors noted that the licensee was using the CPS comment control form (CPS No. 1005.01 F002) to identify problems encountered during the performance of surveillance test. The licensee stated that these forms were used to document non-technical enhancement type concerns and that for technical concerns, personnel were instructed to use PDRs. The licensee also stated that these forms were placed in files, sorted by procedure number, to be used during the next applicable procedure revisio The inspectors determined from the review of these forms and the administrative procedure controlling these forms, CPS No. 1005.01

" Preparation, Review, Approval, and Implementation of Station Procedures and Documents", that these forms were being used for a purpose that was not prescribed in the administrative procedure. CPS No. 1005.01 directs the use of the comment control form as a means for reviewers to submit procedure comments during formal review of proposed or revised procedure These forms are then to be reviewed by the department or group responsible for the procedure and after appropriately addressing the comments, a copy of the form is to be returned to the originator with an indication as to the resolution of the comments.

I l The inspectors review of a sample of the procedure files where these comment control forms were being maintained, indicated that the information contained on the forms may be more than enhancement type information. In addition, the forms did not indicate if a technical i review had been performed to assure that the comment form was not

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identifying a change that should have required an immediate PDR or procedure revision. Also, copies of the comment forms with proposed licensee actions, did not appear to be sent back to the originator in l a timely manner, if at all, as indicated by multiple submittals of

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comment forms with similar concerns by the same individual. The inspectors expressed their concern with the control of these forms during the inspection and exit, and was informed that actions would be taken to address the concern. The residents followup of this item will be tracked as an opan item (461/86074-02(DRP)).

No violations or deviations were identifie . Non-Licensed Operator and Maintenance Training (41400) Non-Licensed Operator Training The inspectors examined training requirements for non-licensed operators at the Clinton Power Station. Overall, the inspectors determined that the program was adequate. The program is primarily divided into lectures and on the job training (0JT). Signatures of authorized personnel on qualification cards track the accomplishment of lesson plans, 0JT, and other aspects of training for each individual. New requirements are regularly identitied that must be added to the qualification cards to be accomplished by the individual in order for the individual to be considered qualifie An example of this, appropriate to Clinton's recent experience, is that when a system is turned over from the Start Up Organization to the Operations Department, operators must become qualified on that system. From interviews with personnel the inspectors learned that approximately four months ago a large number of systems were turned over from Start Up to Operations, therefore identifying new qualification requirements for operators signature card Apparently the administrative process for placing these new qualification requirements onto the qualification cards was inadequate because operators would become competent on turned-over systems and ready for sign-off on their qualification cards weeks before the qualification sign-off spaces were administratively placed on their qualification cards. Personnel from the office of the Supervisor-Plant Operations, which presently administers the OJT program, stated that they had become administratively overwhelmed and requested that NTD assume the administration of the 0JT program. NTD accepted this mandate and is presently in the process of writing a program with procedures. The inspectors were informed by NTD personnel that these procedures should be completed by the end of December. From interviews with licensee personnel, the inspectors also learned that no formal procedures presently

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exist to define who is responsible for and the mechanisms to ensure, the identification of new qualification requirements for operators and the completion of these new requirements by the operators. These processes are presently informally accomplished by the office of the Supervisor Plant Operations and the inspectors are concerned that the program might be susceptible to malfunction because of personnel absences, personnel changes or other unforeseen but probable change Evidence of this informal program vulnerability to breakdown was Operations previously mentioned administrative overload resulting in an appeal to NTD for assistance. It will be determined in future

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inspections if the new procedures written by NTD satisfy these concerns. These concerns will be tracked as an open item (461/86074-03(DRP)).

Overall however, the training. program appeared adequate and able to supply sufficient numbers of operators to support plant operatio ' Maintenance Training The inspectors performed a review of the training and qualification requirements for maintenance personnel including Control and Instrumentation (C&I) Electrical, and Mechanical technicians. The inspectors reviewed CPS No. 1502.03 " Personnel Qualifications for Maintenance Activities", revision 3, dated July 1,1986, and interviewed maintenance supervisors. In addition, the inspectors reviewed selected personnel training record The training program, described in CPS No. 1502.03, was found to meet regulatory requirements. Interviews with maintenance supervisors and the inspector's review of selected maintenance training. records, indicated that the licensee appeared to be following its prescribed progra Although the training program meets regulatory requirement, which are minimal primarily because of the NRC's decision to allow INP0 ,

to formulate and implement an industry wide training program,-the licensees program appeared to fall short of training programs found elsewhere during similar stages of plant licensing. In particular, there were no requirements for C&I technician qualification cards or check list that would assure that C&I technicians have received training and been checked out on specific Measuring and Testing Equipment (M&TE) and specific plant equipment. The program currently in place provides some general assurances that technicians are trained in this area, including the requirement to successfully pass a test on M&TE and performing employee evaluations in this area prior to certifying them as level II or III technician The licensee informed the inspectors of its goal of developing an INP0 accredited maintenance training program and submitting to INP0 the required self evaluation by January 1988. An approved INP0 training program should address the inspectors concerns in this i

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area. However, the inspectors informed the licensee of the program weakness identified above. The licensee stated that they will be reviewing this area to determine if an interim program or changes

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to the existing program is warranted. Residents followup of this concern will be tracked as an open item (461/86074-04(DRP)).

No violations or deviations were identified.

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. Control of Lifted Leads, Jumpers and Temporary Mechanical Alterations (37700)

The inspectors reviewed Administrative Procedure CPS No. 1014.03,

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" Temporary Modifications", revision 8, dated July 19, 1986. The inspectors determined from this review that the subject procedure had been written, reviewed, and approved in accordance with licensee administrative controls. The procedure assigned responsibility and authority for the control of temporary modifications on equipment and systems to specific licensee personnel. Instructions were provided for technical review, documentation, implementation, audits, and removal of temporary modifications, including provisions for the performance of safety evaluations required by 10 CFR 50.5 The inspectors reviewed the Temporary Modification Index and the open Temporary Modification Permits that were being maintained by licensee personnel in accordance with CPS No. 1014.03. The inspectors noted that approximately 75 Temporary Modifications were in effect at the time of the inspectio A number of deficiencies were noted by the inspectors in the administrative control of temporary modifications as follows:

The specified monthly audit required by CPS No. 1014.03, paragraph 8.6.1 was not performed during the month of November 1986. The last audit performed was dated October 21, 198 Five Temporary Modifications had been installed or partially installed greater than ten days without review and approval by the Facility Review Group (FRG) required by CPS No. 1014.03, paragraph 8.3. Seven Temporary Modifications were still open after the " Estimated Date of Removal" without approval of an extension period by the Manager - CPS as required by CPS No. 1014.03, paragraph 8. The inspectors noted that similar deficiencies in the administrative control of Temporary Modifications had been brought to the attention of the licensee. As documented in Inspection Report 50-461/86054, paragraph 6.c and Inspection Report 50-461/86060, paragraph 6.d, the licensee had failed to perform required audits of active Temporary Modifications twice prior to this inspection.

The inspectors review of Temporary Modifications that had been audited on October 2, 1986, or earlier, indicated that the licensee was identifying and taking appropriate actions to control Temporary Modifications. The inspectors concluded that the deficiencies identified in b. and c. above, resulted from the licensee's failure to perform the required audit for the month of November 1986. This is a violation of 10 CFR 50, Appendix B, Criterion V, as implemented by Illinois Power (IP)

Operational Quality Assurance Manual, Chapter 5, which states in part that each IP organization is responsible to use formal instructions,

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procedures, and related material for performing activities affecting the quality or functions of systems, structures, or components (50-461/86074-05(DRP)).

No other violations or deviations were identifie . Control of Out of Service Equipment and Equipment Tagging (71707)

The inspectors reviewed Administrative Procedure CPS No. 1014.01,

" Safety Tagging Procedure", revision 11, dated September 17, 1986, which provided instructions for safety tagging of equipment at the Clinton Power Statio The inspectors reviewed the Tag Out Index, maintained in the control room, to verify implementation and that audits were conducted in accordance with CPS 1014.01. The inspectors noted that required audits were documented in the Tag Out Index and on the specific Tag Out Permits as required by the procedur At the time of the inspection, four active Tag Out Permits existed for

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the RHR system. The inspectors verified by direct observation in the field that these tag outs were properly installed and the position or condition of equipment tagged was as specified on the Tag Out Permi The Tag Out Permits verified were as follows: 86-5189, 86-5210, 86-5492, and 86-605 For the areas reviewed, the inspectors noted that control of out of service equipment and equipment tagging was being implemented in accordance with CPS No. 1014.0 No violations or deviations were identifie . Annunciator Status and Control (37700)

By direct observation, the inspectors reviewed the status of annunciators located on panels in the Control Room. The inspectors also interviewed licensee operating personnel regarding a number of actuated annunciator The operators were knowledgeable concerning annunciator status and were observed to be attentive and responsive to annunciators which actuated during the time the inspectors were in the Control Roo Annunciators which were malfunctioning could have been disabled in accordance with Administrative Procedures. These procedures establish controls for the identification, documentation, and restoration of disabled annunciator Inspectors review of selected annunciators showed that the licensee had properly identified the affer.ted annunciators by affixing adhesive labels to the annunciator window In summary, the overall status of plant annunciators appeared consistent with plant conditions. Licensee administrative controls for the identification of annunciator malfunctions appeared to be effectively implemente i

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No violations or deviations were identifie . Operation af Plant (71715)

The inspectors observed control room operation. The operators were professional in their conduct of plant business. They were attentive to the unit.and annunciators were acknowledged and analyzed. Shift turnovers were formal and utilized the shift turnover sheets. All pertinent information appeared to be properly turned over to the oncoming shift. Operating logs were timely and reflected operations during the shift. Access to the " horseshoe" area was controlle Communications were generally good and no problems occurred during the inspection which could be attributable to poor communications. It was noted, however, that communications were not being conducted in accordance with Plant Managers Standing Order PMS0-36 which requires repeatbacks for orders or equipment status reports. Repeatbacks were routinely given when using the radio, but not for face-to-face, telephone or gaitronics communications. This may be a result of the conflicting requirements in Operations Standing Order 0S0-42, which only requires repeatbacks for "significant information" passed over the radio and the gaitronic During discussions with operating personnel, the inspectors determined that the operators were knowledgeable concerning plant systems, the current plant status, and ongoing maintenance. Work performed by other departments appeared to be well controlle In summary, it was noted that communications could be improved to comply with management polic No violations or deviations were identifie . Open Inspection Items Open inspection items are matters which have been discussed with the licensee, which will be reviewed further by the inspectors and will involve some action on the part of the NRC or licensee or both. Open inspection items disclosed during the inspection are discussed in Paragraphs 3 and . Exit Interviews (30703)

The inspectors met with licensee representatives denoted in Paragraph 1 throughout the inspection period and during the exit held on December 5, 1986. The inspectors summarized the scope and results of the inspection and discussed the likely content of the inspection repor The licensee did not indicate that any of the information disclosed during the inspection could be considered proprietary in natur ., - - . - _ , - _

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