IR 05000528/1986033
| ML17303A199 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde |
| Issue date: | 12/18/1986 |
| From: | Ball J, Bosted C, Fiorelli G, Ivey K, Richards S, Sorensen C, Zimmerman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17303A197 | List: |
| References | |
| 50-528-86-33, 50-529-86-32, 50-530-86-26, IEIN-86-003, IEIN-86-3, NUDOCS 8701050306 | |
| Download: ML17303A199 (54) | |
Text
870105030b Sb1219 PDR ADGCK 05000528
PDR U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos:
Docket Nos:
License Nos:
Licensee:
50-528/86"33, 50-529/86-32, 50"530/86-26 50-528)
50-529, 50-530 NPF"41, NPF-51, CPPR-143 Arizona Nuclear Power Project P.
0.
Box 52034 Phoenix, AZ. 85072-2034
~diSi N:
P1
2 N
2
2 1 21,2!2.
Ins ection Conducted:
October 13, 1986 - November 25, 1986 Inspectors:
S, t-oR.
immerman, en>or ess ent nspector lore 1,
ess ent nspector Pe Q.
C. Bosted, ess ent nspector i~
2 Sds/Bi ate sgne l2 Ie ak Date signed i~ is/BS Date lgne
.
Ba
, Resident nspector K.
vey, es>dent nspector Date Soigne t2 IS 84, Date Signed Approved By:
orensen, egion nspector S. Richards, Chief, nglneersng Section ate
e ia/is/K,
2 2
Summary:
Ins ection on October
1986 - November
1986 (Re ort Nos.
50-528 86-33 50-529 86-32 and 0- 30 86-26 Areas Ins ected:
Routine, onsite, regular and backshift inspection by t e ive resi ent inspectors and one regional inspector.
Areas inspected included:
followup of previously identified items; review of plant activities; plant tours; engineered safety system walkdowns; plant maintenance; surveillance testing; preoperational test witnessing and procedure reviews,; startup test results review; Licensee Event Report followup; periodic and special report review; testing of pipe supports;
'lant modifications; followup of IE Bulletins and Information Notices;
~v
e followup of a personnel contamination event; followup of an inoperable control element assembly; TMI Action Plan Items; and non-licenseed operator training.
Ouring this inspection the following Inspection Procedured were covered:
255659 307029 30703s 37301>
377007 414009 61/079 617269 627039 703089 70314, 70333, 70336, 70347, 70370, 70433, 70436, 70447, 71302, 71707, 71710, 72301, 72608, 72616, 72624, 82301, 90712, 90713, 92700, 92701, 92703, 93702, 94702.
Results:
Of the 16 areas inspected, one violation was identified.
~Omsssson in a Licensee Event Report submitted on October 17, 1986, of the cause of failure of a containment isolation valve paragraph 7. b(2)).
i P
I
DETAILS Persons Contacted:
The, below listed technical and supervisory personnel were among those contacted:
Arizona Nuclear Power Pro ect (ANPP)
R. Adney,
~J. Allen,
~L. Brown,
"J.
R.
Bynum, B. Cederquist, J.
Dennis, M. Fernow,
~D.
Gouge,
~J.
G.
Haynes,
"M. E. Ide, M. Jump,
~J. Kirby, A. McCabe, D. Nelson,
"R. Nelson, G. Perkins, J. Pollard, F. Riedel, C.
Russo,
~T. Shriver, L. Souza,
~E.
E.
Van Brunt, R. Younger,
~O. Zeringue, Operations Superintendent, Unit 2 Operations'anager Radiation Protection and Chemistry Manager PVNGS Plant Manager Chemical Services Manager Operations Supervisor, Unit 1 Training Manager Operations Superintendent, Unit 3 Vice President, Nuclear Production Corporate equality Assurance Manager Startup Manager, Unit 3 Project Transition Manager Assistant Startup Manager, Unit 3 Operations Security Manager Maintenance Manager Radiological Services Manager Operations Supervisor, Unit 2 Operations Supervisor, Unit 3 Manager of equality Audits and Monitoring Compliance Manager Assistant equality Assurance Manager Jr.,
Executive Vice President Operations Superintendent, Unit 1 Technical Support Manager Bechtel Power Construction Bechtel D. Anderson, D. Hawkinson, G. Hierzer, J.
Houchen, Chief Resident Engineer Project equality Assurance Manager Field Construction Manager Project Manager The inspectors also talked with other licensee and contractor personnel during the course of the inspection.
~Attended the Exit Meeting on November 25, 198 A II I
I I
II
'I II
I
+I
I
,4" 1 I
(
Elj I
J f)
A I
A ~
E J
'I
.I
I I I
JJ'
II E
rl F E Ir dd II4 J
II I
I II N
A
2.
Followu on Previousl Identified Items Unit 1 a ~
(Closed Followu Item (528/85-.43-02):
Valve Status Control.
o owu udge ts This concern arose when valves associated with -the diesel generators had been discovered out of position.
The inspector reviewed the following audits of valve position, valve status prints, and valve alignment sheets to determine if problems existed with operators maintaining status of valve positions:
ST-86-0121, ST-86-0140, ST-86-0259, ST-'86-2604, ST-86-2647, ST-86-2774, ST-86-2775, ST-86-2900, and ST-86-2979.
No deficiencies were identified as a result of these audits.
The inspector was satisfied with the scope and depth of these audits.
b.
C.
The inspector also reviewed an audit that the operations department conducted of their own on October 24, 1986.
No problems were identified by the audit.
Finally, the inspector reviewed the latest revision to Operating Department Guideline No. 17, which incorporated more stringent controls over system status.
These controls appeared to be adequate.
This item is closed.
(Closed)
Ins ector Followu Item 528/86-09-02
EER Trackin Procedure o
e Im emented.
V
'
ll The licensee determined that engineering evaluation reports (EERs) were not being tracked.
A gA corrective action report (CAR) was issued and required Operations Engineering to develop a tracking system that would positively control the EERs.
'The inspector reviewed 73AC-OZZ29 "Engineering Ev'aluation Request",
Revision 5,issued June 8, 1986.
,The procedure addressed the duties of the EER coordinator, who assigns a
number to the EER and maintains the EER file and Computer Tracking System.
After the EER has been dispositioned, the EER is closed out by the EER coordinator, who ensures that the appropriate reviews have been" comple'ted.
The procedure:
adequately implemented the necessary,EER tracking controls.
This item is closed.
J (Closed)
Ins ector Followu Item (528/86-.16-01):
Radiation Protection Practices 1n the Radlolo leal Contro ed Area RCA.
The licensee committed to perform a, study to evaluate.
improvements in frisker locations, use of personnel aids which might prevent the spread of contamination and reduce the amount
J
'I t
of contaminated areas.
June, 1986.
The study was to be',completed by It The inspector followed several improvements regarding radio-logical practices over the past several months.
The licensee has included a posted procedure for the proper removal of anti-contamination (Anti-C) clothing at the 140'ress out
.
area, increased the frisker locations throughout-the RCA, and located step off pads and Anti-C barrels closer to the work areas.
Also, improvements
'were made in 'the use of new whole body friskers at the RCA egress.
The inspector also noted that the number and square footage of contaminated areas was being reduced.
This item is closed.
Unit a 0
(Closed Violation (529/86-23-01-:-
Failure to Provide
'rrectsve Act>on for orel n
atersa sn Auxar Rela Cab>nets.
The inspector had discovered
"debris located in and on Class lf relays in all 3 units.
A similar condition had previously been identified and corrected by tli'e licensee.
I t
Ten separate corrective actions were proposed by licensee by letter dated September 5, 1986.,
The inspector verified implementation of these corrective actions, including retraining of personnel, implementation of preventative maintenace procedures for the auxiliary relay cabinets, and implementation of gC hold points in work procedures to verify cleanliness'he inspector was satisfied with the licensee's corrective actions.
This item is closed.
b.
(Closed Followu Item 529/86-24-01:
Review Reactor Coolant um R
P I ter B owdown Procedure.
This item deals with the flushing of the RCP seal injection filters which resulted in accelerated pump seal degradation.
The flushing procedure used was included in an engineering evaluation document provided to the Operations Group in response to a request for engineering assistance in flushing the cyclone filters.
The procedure did not include the vendor's technical manual recommendation that primary system temperature be below 200 degrees F and pressure be below 300 psig when flushing the filters.
A permanent operating
, procedure specifying temperature and pressure conditions consistent with the technical manual has been written to cover future cyclone filter flushes.
This item is close n I
,I M
M E
II M
4-i
~4 P
M M
lhl h, s
- A h
M I
I h
, I
'1
',
M h
M M
M
C.
(Closed) Violation 529/86-17-01):
Failure to Follow Procedure unn lr ock estrin
.
Unit a.
The licensee's followup effort regarding this enforcement matter was reviewed by the inspector.
The actions included clarification of procedure 73ST-9CL03,
"Containment Airlock Seal Leak Test", communications in the form of management directives and video tapes discussing procedure adherence, and the initiation of an investigative program which will include a
review and evaluation of personnel errors for the purpose of determining root causes and corrective'ctions.
These actions were considered consistent with the commitment made by the licensee to the NRC.
Mhile this item is co'nsidered closed, personnel error matters will continue to be followed as part of the routine inspection program.
Closed Ins ector Followu Item (530/86-03-11):
Pi e
Su ort ocks n etas ns n eve ces.
During the NRC Construction Assessment Team (CAT) 'inspection, a
need for the licensee to expend additional effort in assuring, that all 'necessary locking, or retaining devices were installed
,
on pipe supports was identified.
During this inspection, the inspector reviewed the licensee's actions'egarding this concern.
In addition, as further documented in paragra'ph 9 of this report, the inspector examined 38 support installations to verify the proper installation, of locking or retaining devices.
No discrepancies were identified.
This item is closed.
3.
Review of Plant Activities a ~'nit 1 At the start of the reporting period, Unit 1 was operating at lOOX power.
The plant operated 35 days at lOOX until November 19.
A blown fuse on the non-class control instruments for narrow range level for Steam Generator 1 caused feedwater level to increase, in Steam Generator 1.
Operator action in manual control was not totally effective, and after several swings in steam generator level, the reactor tripped on low level in Steam Generator 1.
A subsequent high level in Steam Generator 2 caused a Hain Steam Isolation actuation.
Shortly after the Hain Steam Isolation, an Auxiliary Feedwater Actuation Signal was received on Steam Generator 1 low level.
Investigation into the cause of the narrow range level instrument blown fuse was ongoing at the conclusion of the inspection period.
The circuit board was replaced and the original board and blown fuse were being analyzed for a root cause of failure.
The inspector will follow the licensee's investigative actions (528/86-33-01).
r k
I I
C
The plant was restarted on November 21, 1986, and returned to power on November 22, 1986.
Power operation continuedat lOOX through the end of the reporting period.
Unit 2 The plant operated continuously during the period.
With minor exceptions reactor power level was lOOX.'n November 19, during the testing of the main turbine'top valves, the "B" feedwater pump tripped causing a reactor power cUtback to 20%%uo.
An investigation of the pump trip revealed the cause to be from a combination of a rapid opening of the No..- 2 turbine stop valve and two defective pump suction pressure'witches.
One switch had a continuously closed contact and the other switch was out of calibration.
The licensee s investigation'nto the deficiency of the pressure switches was ongoing at the conclusion of the inspection period.
Following completion of feed pump suction switch calibration, power was raised to 60X.
On November 20, a condenser tube leak in the lA Main Condenser required plant power to be reduced to 40%%uo.
The leaking tube was located and plugged along with preventive plugging of ten other adjacent tubes.
The condensate demineralizers were regenerated, and plant power was raised to 100K on November 22.
The licensee's investigative actions will be reviewed during a subsequent inspection (529/86-32-01).
Unit 3 During this inspection period, the licensee completed integrated hot functional testing in Unit 3.
Testing commenced with heat up of the reactor coolant system to normal operating temperature and pressure, with the desired operating conditions of 565 degrees F and 2250 psig being achieved on October 27.
Shortly after achieving these conditions, a leak developed at a nozzle weld on the letdown heat exchanger forcing the licensee to cooldown the plant in order to effect repairs.
The licensee was able to return to normal operating temperature and pressure on October 30.
At this same time, another leak was found to have developed at the nozzle weld of an instrumentation penetration on the Steam Generator 1.
The licensee was able to continue operating with this condition.
On November 4, an unanticipated opening of a main steam isolation valve, UV-170, occurred causing a slight cooling of the reactor coolant system below normal operating temperature.
The valve was closed and conditions stabilized.
Subsequent troubleshooting failed to identify the cause for the valve's opening.
The licensee was continuing to evaluate this situation at the close of this inspection.
On November ll, a main steam safety relief valve, PSV-579, was noted to be lifting.
=-Testing revealed the valve to be set 20 psig below its design set point.
Review of previous test data by the licensee identified an error had been made in interpreting the data, resulting in the valve being set too low.
The valve was reset and tested with acceptable results.
On November 14, the licensee performed the initial
J
H II
~
P
roll of the main turbine and on November 15 synchronized the main generator to the utility grid, producing
MM for approximately three minutes.
Mith the completion of all required testing at the 565 degree F,
2250 psig operating plateau, the licensee commenced cooldown on November 20 and achieved ambient conditions on November 23.
Other significant items which developed during this report period included the licensee's discovery of a defective field pole on the "B" Diesel Generator.
This generator had not yet been preoperationally tested.
Also problems were found to exist with the operation of DC motor operated valves in that during cycling of some valves, the vital AC inverter associated with the same DC bus tripped.
The licensee was continuing to troubleshoot this problem at the close of this inspection.
The licensee had also begun preparations for the conduct of integrated safeguards testing at the close of this inspection period.
The licensee considers Unit 3 to be 99.8X construction complete with an anticipated fuel load date in the first quarter of 1987.
The above noted component deficiencies will be reviewed further during a subsequent inspection (530/86"26-01).
d.
Plant Tours The following plant areas at Units 1, 2 and 3 were toured by the inspector during the course of the inspection:
Auxiliary Building Containment Building (Unit 3)
Control Complex Building Diesel Generator Building Radwaste Building Technical Support Center Turbine Building Yard Area and Perimeter.
I The following areas were observed during the tours:
l.
0 eratin Lo s and Records.
Records were r'eviewed against Technical Spec)fscatson and -administr'ative control pro-cedure requirements.'.
3.
Monitorin Instrumentation.
Process instruments were observed for correlation between channels and for con-formance with Technical Specification requirements.
Shift Mannin
.
Control room and shift manning were observe for conformance with 10 CFR 50.54.(k), Technical Specifications, and administrative procedures.
4.
~Ei Li
.
Vl'
i 1b k
versfled to be 1n the position or condition required by Technical Specifications and administrative procedures for the applicable plant mode.
This verification included
H
f (
routine control board indication reviews and conduct of partial system lineups.
5.
E ui ment Ta in
.
Selected equipment,'or which, tagging requests ha been initiated, was observed to verify that tags were in place and the equipment was in the condition specified.
6.
General Plant E ui ment Conditions.
P'(ant equipment was o serve or sn scatsons o
system le'akage, improper lubrication, or other conditions that would prevent the system from fulfillingtheir'functional requirements.
7.
Fire Protection.
Fire fighting equipment and.controls were observed for conformance with, Technical Specifications and administrative control procedures.
8.
Plant Chemistr
.
Chemical analysis results were reviewed for conformance with Technical Specifications and admin-istrative control procedures.
9.
Securit
.
Activities observed for conformance with regu atory requirements, implementation of the site security plan, and administrative procedures included vehicle and personnel access, and protected and vital area integrity.
10.
Plant Housekee in
.
Plant conditions and material/
, equipment storage were observed to determine the general state of cleanliness and housekeeping.
Housekeeping in the radiologically controlled area was evaluated with respect to controlling the spread of surface and airborne contamination.
ll.
Radiation Protection Controls.
Areas observed included contro point operation, records of 'licensee's surveys within the radiological controlled areas, posting of radiation and high radiation areas, compliance with Radiation Exposure Permits, personnel monitoring devices being properly worn, and personnel frisking practices.
No violations of NRC requirements or deviations were identified.
4.
En ineered Safet Feature S stem Malk Down - Units 1 and
Selected engineered safety feature systems (and systems important to safety)
were walked down by the inspecto~ to confirm that the systems were aligned in accordance with plant procedures.
During the walkdown of the systems, items such as hangers, supports, electrical cabinets, and cables were inspected to determine that they were operable, and in a condition to perform their required functions.
The inspector also verified that the system valves were in the required position and locked as appropriate.
The local and
l4<
I I
I'
I
T
II
e
(g
I II I
l II hl II I
4 I
I h
'
ahP
- 5
'I
'\\
I
4 II I
I h
II II h
remote position indication and controls were also confirmed to be in the required position and operable.
Unit 1 Accessible portions of the following systems were walked down on the indicated date.
~Sstem Supplemental Protective System 125V DC Electrical Distribution, Channels
"A" and "B" Date October 17 October
Hydrogen Recombiners Essential Cooling Mater, Trains "A" and "B" October
I
-
- October
November 5, Essential Spray Ponds, Trains "A" and "B" October
Chemical Spray System, Trains "A" and "B" November
,
Diesel Generator Systems, Trains "A" and "B" November
Unit 2 Accessible portions of the following systems were walked down on the indicated dates.
~Sstem Diesel Gener ator Systems, Trains "A" and "8" Date October
Essential Cooling Mater, Trains "A" and "B" October
Essential Spray Ponds, Trains "A" and "B" November
125V DC Electrical Distribution, Channels
"A" and "B" November
Containment Spray Systems, Trains "A" and "B" Chemical Spray Systems, Trains iiAu and iiB November
November
t
0
,9 No violations of NRC requirements or deviations were identified.
5.
Surveillance Testin
- Units 1 and
'a 0 b.
Surveillance tests required to be performed by the Technical Speci ficati ons (TS) were reviewed on a sampling basis to verify that: 1) the surveillance tests were correctly included on the facility schedule; 2)
a technically, adequate, procedure existed for performance of the surveillance tests; 3) the surveillance tests had been performed at the frequency, specified in'the TS; and 4) test results satisfied acceptance criteria or were properly dispositioned.
Portions of the following surveillances were observed by"the inspector on the dates shown:
Unit 1 Procedure 36ST-9SB04 36ST"1SE06 72ST-OSB02 41ST-1ZZ23 Unit 2 Descri tion PPS Functional Test Log Power Functional Test CPC/CEAC Restart'EA Position t-Dates Performed October
October,16
. October
October
P d
~0iti Dates Performed 42ST-2DG01 42ST-2SFOl 42ST-2AF03 Diesel Generator
"A" Start and Load CEA Operability Checks Auxiliary Feedwater System Pump Operability October
October
November
No violations of NRC requirements or deviations were identified.
6.
Plant Maintenance - Unit 1 and
a ~
b.
During the inspection period, the inspector observed and reviewed documentation associated with maintenance and problem investigation activities to verify compliance with regulatory requirements, compliance with administrative and maintenance procedures, required gA/gC involvement, proper use of safety tags, proper equipment alignment and use of jumpers, personnel qualifications, and proper retesting.
The inspector verified reportability for these activities was correct.
The inspector witnessed portions of.the following maintenance activities:
k jf rp
)
C
- 'cf ~
I J
I I'
li h
I I'f
I
Unit 1
~II t
o Maintenance on "B" Charging Pump Repl'acement of "B" Charging Pump Block Troubleshooting on PPS Channel
"C" Linear Calibration Test Circuit Maintenance on Control Element Drive Mechanism Main Generator
"B" Dates Performed October
October
October
October
Unit 2 Descri tion Restoration of Control Room.
Heating, Ventilation and Air Conditioning (HVAC)
Dampers Diesel Generator
"A" Preventative Maintenance Dates Performed
October,21 October
o Installation of Security Barriers in Control Room HVAC Ducts November
No violations of NRC requirements or deviations were identified.
7 ~
Licensee Event Re ort (LER Followu
- Units 1 and
a 0 The following LERs associated with operating events were reviewed by the inspector.
Based on the information provided in the report it was concluded that reporting requirements had been met, root causes had been identified, and corrective actions were taken as appropriate.
The below listed LERs are considered closed.
Unit 1 LER NUMBER LER 85-67 LER,85-70 LER 86-04 DESCRIPTION n
'Low Flow Alarm on Plant "Vent 'Radiation Monitoring System.
-Azimuthal Power Tilt Not Verified.
Plant Pressure Raised Above 430 psi blithout Removing Power to Safety Injection Tank Isolation Valve V
'U lit r
LER 86-17 LER. 86-03-00 Fuel Building Ventilation Actuation Due to Spurious Signals From RU-31.
Reactor Trip and Engineered Safety Features Actuation Due to Loss of Power.
LER 86-21-00 LER 86"21-01 LER 86-22-00 LER 86-22-01 LER 86"31"00 LER 86-33-00 LER 86-34-00 Atmospheric Dump Valve Low Pressure Transmitter Cross Connected.
Containment Purge Isolation Due to Personnel Error.
Control Room Essential Filtration Units Inoperable Due to Unqualified Charcoal.
Reactor Trip Due to Spurious Low Reactor Coolant Flow Trip.
Personnel Error During Performance of a Surveillance Test.
LER 86-35"00 Inadvertent Operation Mith Inoperable Steam Generator Downcomer Isolation Valves.
LER 86-36-00 LER 86-39-00'ER 86-40-00 Non-conservative Reactor Coolant Low Flow Trip Setpoints Supplied by Vendor.
Inoperable Main Feedwater Isolation Valves Due to Incorrect Engineering Evaluation.
Inadvertent Engineered Safety Feature (ESF)
Actuation Due to Personnel Error.
LER 86-44-00 Reactor Trip Due to Spurious Low Reactor Coolant Flow Trip.
LER 86-45-00 Reactor Trip Initiated by Manual Generator Trip.
LER 86-49-00 Inadvertent Actuation of ESF Due to Personnel Error.
Unit 2 LER NUMBER DESCRIPTION LER 86-02-00 LER 86-02-01 ESF Actuation Due to An Incorrect Sized Amperage Fuse.
LER 86-24-00 Inadvertent Operation With Inoperable Steam Generator Snubbers Due to Personnel Error.
The following Unit 2 events were also reviewed during the inspection period to the same criteria as stated in paragraph
"a" abov,12 Closed)
LER 86-11 "Pin Connectors Of Insufficient Len th en ered Both ra)ns f
OP S
A no era e
- Unst The report discussed the inoperability of both trains of Balance of Plant Engineered Safety Features Actuation Systems (ESFAS) because pins in the ESFAS module connector were not of sufficient length.
This matter is discussed in NRC Inspection Report 529/86-17.
The report" also discussed the fact that the plant entered into Technical Specification Limiting Condition for Operation (LCO) 3.0.3 as required; however, the unit could not be placed in Hot Shutdown within the time required by Technical Specifi-cations.
The licensee's report states that at the time only two of the three charging pumps. were operable, consequently makeup water could not be supplied fast enough to allow cooling of the RCS from Mode 3,.to Mode 4, within the time period without causing the pressurizer heaters to become uncovered.
Technical Specifications require only two charging pumps to be operable.
The licensee is currently considering requesting an amendment to plant Technical Specifications relaxing the time requirement of LCO 3.0.3.
Mhile the LER is ',
considered closed, the plant cooldown matter will remain open until the Technical Specification change request is submitted to the NRC (529/86-32-02).
(Closed LER 86-46 "Inadvertent Safet
'In ection Due o
om onent Ma function
- Unst 2 On September 22, while in Mode 1 at 100K power, an inadvertent safety injection signal occur red (no injection) during the performance of a surveillance test on the Engineered Safety Features Actuation System (ESFAS).
The signal resulted from the combination of a malfunctioning manual safety injection actuation switch in one channel while a second ESFAS channel was being tested.
Initial licensee findings related to the switch malfunction revealed that corrosion of the silver plated contacts had occurred resu]ting in high contact resistance.
This condition affected the resetting of the circuit (contacts normally closed - open on signal).
The switch is designed for 120 volts and several amps of current, and was being used in a 28 volt milliamp circuit.
This is believed to have contributed to the degradation of the silver plating on the contacts.
The licensee representative stated that the high voltage/current application will normally result in a "self cleaning" effect on the contacts.
The licensee is conferring with the vendor on an appropriate resolution to the problem.
The inspector will follow the licensee's actions (529/86-32-03).
i
i Additionally, the subject LER addressed the fact that a containment isolation actuation occurred, as designed, following the inadvertent safety injection.
All equipment was stated in the LER to have functioned properly with the exception that dual position indications, were received in the Control Room for three steam generator (S/G) blowdown containment isolation valves - V222, V225 and V500g.
The licensee determined by 'opening a downstream sample valve and, observing no flow, that V225 was, closed.
The position indication problem with V225 was s'ubsequently found to be due to a reed switch in 'need of adjustment (W.O. 178321).
Work Order 177900 was implemented on September 22 to troubleshoot the cause of the dual'osition indication for S/G No.
1 blowdown valve V500g.
Initial inspection of the valve by an instrumentation and control (I8C) technician determined that the valve was approximately 10K open.
V500g is an "
air-to-open/spring-to-.close valve; with the air vented.
through a two-way solenoid valve to atmosphere upon receipt of a "close" signal'.
The vent line has a mu'ffler attached at the end to prevent foreign matter from entering the line and having a potentially adverse affect on the solenoid valve operation.
As part of the troubleshooting effort, a Control Room operator stroked the valve and the I8C technician observed that V500g appeared to be stroking slowly, and again stopped at about the 10K open position.
The technician then removed the muffler and the valve fully closed.
Internal inspection of the muffler determined that a small amount of loose particles were present, which restricted air flow.
The valve was stroked with the muffler off, with no problems noted.
The muffler was cleaned ultrasonically and reinstalled.
The valve was again stroked without problems and was declared operable.
The above LER did not include the cause of the failure of the valve to close (plugged muffler on discharge vent line).
This is contrary to 10 CFR 50.73(b) which requires the cause of each component failure, if known, associated with an engineered safety feature actuation to be included in the LER, and represents a violation (529/86-32-04).
During the inspector's review into the failure of V500g, it was determined that the licensee's actions dealt solely with correcting the problem with V500g at Unit 2.
Further, based on discussions with licensee personnel, it appeared that only selected individuals closely related to the actual troubleshooting effort were aware of the cause of the valve failure.
Consequently, no action was initiated to evaluate the potential generic implications to similar air-operated valves at the site.
The inspector expressed this concern to plant and corporate management and stressed that particular attention should be provided toward ensuring that thorough corrective actions are
t
)
V
/
kl
]
1'
consistently implemented for conditions adverse to quality.
Additionally, the inspector found that a formal root cause analysis into the failure of V500( had not been accomplished.
Plant procedure, 73AC-OZZ37, Root Cause of Failure, describes the conditions necessary to initiate a root cause analysis.
Paragraph 5. 1. 1 states that,
"Root Cause of Failure Data Sheets will be initiated for related component failures of equipment where:
a failure trend has been established; or a significant failure, as determined by Operations Engineering (OE) Supervision, has occurred irrespective to any trend."
The inspector noted that the procedure appeared flawed in that OE does not see many of the safety related work orders issued and therefore is not aware of all component malfunctions.
For example, the appropriate system engineer within OE, responsible for the main steam system (which includes V500(), was not aware of the failure of the valve to close.
Therefore, a deter-mination of the significance of the failure could not be made.
The licensee also recently recognized the above weakness in the process for initiating a root cause analysis, and was preparing to issue a corrective action report to document the problem.
The inspector will follow the licensee's processing of the corrective action report, including implementation of corrective actions (529/86-32-05).
Troubleshooting of V222 (Work Order 177916)
determined that a reed position switch was out of adjustment.
The inspector will review the licensee's maintenance activities and retest results performed on V222 during a subsequent inspection (529/86-32-06).
8.
Purification Ion Exchan er Pur in
- Unit 1 On November 17, 1986, while purging the "A" Purification Ion Exchanger, a small amount'of resin was inadvertently blown into the Auxiliary Building exhaust duct.
The section of contaminated duct was located in the overhead area of an infrequently traveled valve gallery.
The high purge air flow caused the release of noble gases from the exhaust duct.
This resulted in high airborne radioactivity at the 120 foot elevations of the Auxiliary and Radwaste Buildings.
No particulate or iodine nuclides were identified.
Contact radiation levels of approximately 6.5 Rem/hour were detected on the exhaust duct near the penetration of the ion exchanger vent line due to resin particles.
The radiation level at 18 inches from the duct was 350 mrem/hour.
The radiation level at head level was approximately 150 mrem/hour.
The inspector held discussions with'licensee personnel and reviewed the work order (W.O. ) used to purge the ion exchanger.
W.O. 4188357 was issued to replace a leaking manway gasket on the "A" Purification Ion Exchanger.
The ALARA group determined that the ion
'
I wl wwt J
l.
I wv v
exchanger should be vented prior to opening the manway.
The ALARA recommendations specified that three intake vents and the vent line penetration into the Auxiliary Building exhaust duct should be taped shut.
The work order directed Maintenance to ensure the ion exchanger was vented prior to opening the manway, but it gave no instructions on how to accomplish the venting evolution.
After the initial venting, Radiation Protection (RP) personnel determined that purging with air was necessary to further reduce radiation levels.
Since the work order did not include instructions for purging, the ALARA and RP groups decided that the method to be used was to supply air to the bottom of the ion exchanger.
In addition, the ALARA group specified that no more than five psig of air should be used.
Operations personnel agreed with this"method and commenced the purge.
However, no air gauge was used to verify the five psig limit, and the intake vents and vent line penetration were not taped shut as the ALARA group had specified.
Upon beginning the purge, increased readings were received on the Auxiliary Building exhaust duct radiation monitor (RU-10), as expected.
After approximately 45 minutes, RU-10 alarmed.
In response to the alarm, the purge was terminated and the 120 foot elevation of the Auxiliary Building was posted as an Airborne Radioactivity area.
The licensee calculated the total integrated release during the initial purge to be 1.41 curies consisting primarily of Xe-133 and Xe-135.
The licensee also calculated the percent of the quarterly release limit to be less than
.01K.
Approximately 4.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> later, purging was recommenced by supplying air to the -top of the ion exchanger and approximately 4.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> after that, frisker background in the 120 foot elevation of the Radwaste Building began to increase and it also was posted as a
Airborne Radioactivity area.
A subsequent investigation by the licensee revealed that resins had been forced into the exhaust ducting and some had been blown to the Auxiliary Building roof where they were captured in the normal air handling unit'filter.
The resins were removed by vacuuming'nd radiation levels returned to normal.
The licensee has experienced problems with leaking manway gaskets in the past and had purged ion exchangers previously without the difficulties encountered in this case.
Work Orders (W.O.) 106643 and 123478, issued September 1985, and December 1985 respectively, included purging of the "B" Purification Ion Exchanger and W.O.
127019, issued January 1986, included purging of the Preholdup Ion Exchanger.
In each of these work orders, instructions were included to supply air, and in two cases nitrogen also, to the top of the ion exchanger to perform a purge.
However, W.O.
124166 on the "A" Purification Ion Exchanger, issued December 1985, included no instructions for purging.
This work order was used by the work planner to generate W.O.
188357 and therefore, no instructions for purging were included.
The licensee has initiated an investigation into this work order and its associated problems.
Specifically, the licensee is 'reviewing
If
the adequacy of the work order instructions for venting, the method used for purging, and the radiological controls associated with the work order.
This matter is considered unresolved, pending further inspector review (528/86-33-02).
9.
Personnel Contamination Incident - Unit 2 On October 30, 1986, a craftsman was exposed to an airborne radiation release from a Volume Control Tank (VCT) sensing line during the performance of Unit 2 preoperational test 73PE-2SS02,
"Nuclear Gas Sampling Test Hydrogen and Oxygen Analyzers".
The release occurred when the craftsman disconnected a sample line from the VCT as part of the test preparation.
The isolation valve in the sample line to the hydrogen/oxygen analyzer had not been isolated and the plant was operating at 100%%uo power at the time.
The sample line was reconnected at the direction of a technician who was monitoring the activity at the time, but not before airborne activity had been released to the room.
An air sample taken following the release indicated the airborne activity concentration to be 1290 HPC of short lived noble gases.
The craftsman was decontaminated without problem and a whole body count confirmed internal exposures to be negligible.
The licensee estimated whole body exposure to be 10 mrem with minor exposure from skin contamination.
The basic factors which contributed to the problem are as follows:
1)
The preoperational test procedure used for the test was designed to be used when the plant was preoperational and no radioactive inventory existed.
Consequently, no instruction for isolating, the sample lines before disconnecting them or radiation precautions were included in the procedure.
2)
The Radiation Exposure Permit used by the test 'engineer and craftsman did not cover the activity of disconnecting sample lines containing radioactive material.
It was intended for use in connection with plant tours and inspections.
Consequently no protective clothing was worn.
t 3)
Inadequate communications between the organizational "units and individuals involved in the activity contributed to disconnecting the sample line without proper controls.
The licensee's corrective actions included the te'rmination of testing and the counseling of the individuals.
The 'licensee plans to revise the procedure to incorporate the needed controls to do the test under current plant, conditions.
The procedure will be formally reviewed by the Plant Review Board, test procedure review group and the -radiation protection group.
Based on discussions with licensee management, an additional action involving personnel tr'aining will also be included in the licensee's followup effort.
The inspector will evaluate
WN'I
L k
I I
l N~
l
'L A f
n i
M k
j r
I J
J v,
IE L
y'1 (
~II l I*
t
1
'P,
1
the adequacy of the licensee's corrective actions during,a subsequent inspection (529/86-32-07).
10.
Ino erable Control Element Assembl (CEA) - Unit 2 During the performance of the monthly surveillance test to determine CEA operability, CEA 828 could not be withdrawn after.it had been inserted five inches for the test'.
The CEA was further inserted several more inches to confirm it was not a stuck rod, and again could not be withdrawn.
The inspector confirmed"that the appropriate Technical Specification action statement requirements were implemented in the required time periods'.
These included a
reduction in power and a determination of shu'tdown margin.
The problem was found to be a defective coil driver card which,was replaced.
The CEA then operated normally and the test was completed satisfactorily.
No violations of NRC requirements or deviations were identified.
ll.
Plant Modifications - Unit 2 The inspector reviewed plant change packages and confirmed that the design changes were properly reviewed and approved; were controlled by established procedures; appropriate post work testing was identified; and impact statements affecting procedure changes, training, as-built drawing changes, maintenance, ALARA and fire protection were included in the packages.
The following plant change packages were reviewed:
82-02-DG-054 Addition of Supports on the Diesel Generator Fuel Lines.
83-02-FH-005 Installation of Visual Level Gauge in Spent Fuel Pool
~
84-Ol-PG-003 Charging Pump Motor Circuitry Modifications 84-01-SI-016 85-02-ED-012 Revise Setpoints for the Shutdown Cooling System Interlock and Low Temperature Revision to the Heater Drain Tank Pump Control Circuit.
85-Ol-gK-004 Addition of Two Ionization Fire Detectors 85-02-LR-024 85-01-RC-043 Addition of Flow Meters and Throttle Valves in External Seal Mater Supply to Radwaste Pumps.
Revise RCP Speed Sensor Circuit 85-02-SI-073 Addition of Shims to Pipe Support II
The inspector also reviewed the licensee's temporary modification program.
The inspector confirmed the program includes controls related to 10 CFR 50.59 reviews, tagging, installation, independent verification following restoration, responsibilities associated with program implementation, and periodic reviews for continued use of installed temporary modifications.
The inspector.
chose 3 -installed temporary modifications and confirmed that procedural requirements were met.
No violations of NRC requirements or deviations were identified.
Non-Licensed Staff Trainin Units 1 and
The non-licensed staff training was evaluated to determine if the classroom training that the licensee provided to plant employees met the, regulatory requirements of 10 CFR 19 and 10 CFR 20, and site administrative requirements.
The inspector reviewed selected course lessons plans and presentations.
Training records for selected participants who had successfully passed the site-access required courses were also reviewed.
Course outlines in site access training, basic radiation protection, fire prevention, respiratory protection, and self contained breathing apparatus were reviewed.
Training records for 14 individuals were reviewed to verify that the required training had been attended and that the individual's training was still current.
Training records for workers in the following disciplines were reviewed:
Principle Staff members (supervisory personnel)
Maintenance technicians Radiation protection technicians
, Chemistry'echnicians Non-licensed operators Technical staff members equality control inspectors The inspector also discussed training with selected members of the above staffing groups to ascertain that an adequate knowledge level existed and that the training provided the necessary relevant information, The inspector noted that all training records were current.
From discussions with plant staff members, the inspector concluded that the training met the regulatory requirements and provided the appropriate subject matter to site personnel.
No violations of NRC requirements or deviations were identifie Jl
1 II v
I
lt 13.
Licensee Res onses to Bulletins and Information Notices - Units~ 1
and a 4 3.
n I
n Closed IE Bulletin IEB 79-14 - "Seismic Anal sis of As-uilt Sa et -Re ated Ps sn S stems
- Unst The inspector reviewed the licensee's actions in r'esponse to Bulletin 79-14.
This Bulletin required the licensee.'o verify that seismic analyses performed on safety-related piping applied to the as-built configuration of 'the safety-related piping.
Bechtel, as the licensee's architect-engineer, was tasked with addressing the requirements of the Bulletin.
Design elements to be inspected during system walkdowns were identified in Bechtel Internal Procedure IP-4.37.
This procedure defined the program for addressing the pertinent points of IEB 79-14, and was reviewed during a previous NRC inspection of Unit 1.
That inspection found that IP 4.37 complied with the requirements of IEB 79-14 (see Inspection Report 84-43).
The inspector reviewed a sample of four walkdown packages for conformance to IP-4.37.
All packages reviewed implemented the guidelines of IP 4.37.
The inspector independently walked down portions of the four piping systems involved using the same stress isometric drawings walked down by Bechtel resident engineers.
The purpose was to verify the accuracy and validity of the findings identified in the walkdown packages during the licensee's walkdowns of those systems.
Mhile the inspector had questions concerning various as-built features of piping and pipe supports, all were resolved to the inspector's satisfaction.
Any deviations identified during the various walkdowns by Bechtel engineers are documented in the walkdown packages and reviewed by stress engineers at Bechtel Norwalk.
By incorporating the as-built data into the original design input, the engineers were able to determine whether pipe stresses were still acceptable.
At the time of this inspection, of 176 walkdown packages, 6 packages remained in the field awaiting completion of certain work activities while 34 packages were known to be awaiting final reconciliation of the piping stress calculations and the as-built piping configurations.
The licensee's program calls for the completion of these actions prior to fuel load.
The inspector was satisfied with the licensee's actions regarding IEB 79-14 and it is closed for Unit ),
lg C,
b.
IE Information Notice No. 86-03 "Potential Deficiencies in nvsronmenta ua sf>cat)on of Lsm)tor ue otor a ve erator inn
-
nsts
2 and 3.
The subject information notice identified the potential for the existence of environmentally unqualified jumper wires in motor valve operators.
This notice was reviewed with the licensee during two previous inspections (Reference:
Inspection Reports
- 50-530/86-03 and 50-528/86-27).
During these inspections, the inspector verified on a sample basis in each Unit that no unqualified wire had been installed in valve operators.
At the time of these inspections, the licensee stated that all wire procured for use in safety-related installations was qualified for all environments and therefore the licensee planned to conduct no additional reviews of either hardware installations or work documentation.
However, during this inspection period, the licensee informed the inspector that unqualified wire could potentially have been installed in safety-related valve.operators due to the existence of a single reel of unqualified wire having been made available for use in the field.
This problem was apparently first identified by the licensee in June 1984 and documented in CAR CP 84-172.
At that time, the licensee wrote an engineering change evaluation (ECE)
restricting the use of the wire to specific environments.
The licensee, however, failed to implement the restrictions, allowing the wire to continue to be available for use in areas for which it was not qualified.
This fact was just recently recognized by the licensee and was documented in CAR CP 86-182.
As a result.of this finding, the licensee undertook the review of all work orders for which wire of the type in question had been requisitioned from the warehouse.
This review determined that although a,potential for misuse of the wire had existed, no instances of the wire being installed in an area for which it was not qualified had occurred.
The inspector reviewed the actions taken by the licensee in determining that no problem existed and was satisfied with the licensee's approach.
As a result of the fai lure to apply the ECE restriction on the wire, the licensee undertook a review of all other ECEs to determine if any other restrictions on material usage may exist and if these restrictions have been observed.
The results of the licensee's review of other ECEs shall be the subject of a future inspection (528/86-33-03).
t Control Room Annunciator Status
-'" Units 1 2 'and 3.
\\
The inspector considered the Unit 1-'and 2 Control Roo'ms to,have a
relatively high number of lit annunciator's.
The cause of the alarm conditions varied, and included valid alarms, alarms due to, component malfunctions, and cases.'where design changes were necessary to remove the annunciator from a lit condition 'and allow it to provide a useful alarm function.
/he number of 1'it annunciators has been an area of previous disc'ussions with the licensee, and has been documented in recent Systematic Assessment of Licensee Performance (SALP) reports, as well.
The licensee has
M 4 ',I I
~
IK
~
I\\
K
significantly improved the situation through the, performance of design changes and corrective maintenance activities, and has roughly halved the number of lit alarms.
There still remains the need for a dedicated effort to further reduce the number of unnecessary alarms.
Approximately one-third of the alarms in Unit 2 are expected to be worked during the January-February, 1987 maintenance outage.
Pith regard to Unit,1, the licensee stated that all annunciators requiring design changes are expected to be modified during the first refueling outage, presently scheduled for September, 1987.
In addition, the licensee stated that annunciators which can be worked without an outage, will continue to be repaired/modified in accordance with the assigned work control priority.
Design changes for the Unit 3 annunciator system are also being implemented.
Licensee management has initiated a continuously lit annunciator summary at the operating units, which provides a
listing of each alarm, the cause of the alarm condition, and the work order number or design change package number associated with the repair.
This item will remain open pending evaluation of the licensee's progress to improve the effectiveness of the Control Room annunciator systems for all three units (528/86-33-04).
Startu Test Results Review - Unit 2 The following test packages were reviewed:
P d
~d 72PA-2RX16 Steady State Core Performance Test 72PA-2RX18 CEA Shadowing Factor/Radial Peaking Factor Verification 73PA-2SF04 Control System Checkout 73PA-2NAOl Loss of Offsite Power Test 72PA-2RX36 Steady State Core Performance Test 72PA-2RX51 Steady State Core Performance Test Percent Power 50%%uo 50K 50%%uo 50K 80K 100%%uo 72PA-2RX50 Variable Tave (ITC and Power Coefficient) Test 100K 73PA-2SF06 Control System Checkout lOOX The inspector confirmed that test results either had been submitted and reviewed by the Plant Review Board (PRB) Test Review Group or that the test packages were being prepared for issuance to the PRB review group.
The inspector verified that the tests were properly completed,',
acceptance criteria met, test exceptions were properly addressed and resolved, and data acquisition was completed as require r F
l I
1))
a'
No violations of NRC requirements or deviations were identified.
16.
Prep erational Testin
- Unst 3 a.
Test Procedure Review The inspector reviewed the following preoperational test procedure for technical and administrative adequacy:
P d
~d 90HF-3ZZ01 91CM-3SI02 91HF-3CH01 91HF-3CH02 91HF-3RC02 Precore Hot Functional Testing - Controlling Document Shutdown Cooling System Commissioning Test Precore CVCS Integrated Test Boration/Dilution Measurements Pressurizer Performance The inspector found that the procedures provided a clear explanation of the purpose, prerequisites for performance, appropriate sign-off steps, and quantitative or qualitative acceptance criteria as required.
I.
~PIP The inspector witnessed the performance of the above preoperational tests to verify that test instrumentation required by the procedure was calibrated and in use; work was performed by qualified personnel; and results satisfied procedural acceptance criteria or were properly dispositioned.
No violations of NRC requirements or deviations were identified.
17.
Testin of Pi e Su orts and Restraint S stems - Unit 3 The inspector examined 38 dynamic pipe support installations (snubbers)
in Unit 3 prior to and subsequent to the start 'of Hot Functional Testing.
The supports examined are listed in Table 1.
TABLE 1 Steam Generator ¹1 Main Steam'Lines, 3SG-033" H015 3SG-036-H013 3SG-036-H015 Steam Generator
¹1 Downcomer Feedwater Line Steam Generator ¹1 Blowdown Line 3SG-008-H003 3SG-008-H005 3SG-008-H020 3SG-039-H003 3SG-039-H013 3SG-039-H014 3SG-053-H003 3SG-053-H005
hl h
I I
f I
h C
Steam Generator ¹2 Downcomer Feedwater Line
'SG-011-'HO03 3SG-011-H005 3SG-011-H020 Steam Supply Lines to Auxiliary Feedwater, Pump Turbine Reactor Coolant System Letdown. Line Shutdown Cooling System Suction Piping Pressurizer Spray and Vent System Piping 3SG-082-H003 3SG-082-H005 3SG-082"H008 3SG-082-H009 3CH-027-HOOA 3CH-027-HOOE 3CH-027-HOOF 3CH"027-HOOP 3RC-051-H001 3RC-051-H003 3RC-051-H004 3SF"240-H012 3SF-241-H005 3SF-241-H007 3SF-241-H012 3SF-241-H014 3RC-009-HOOE 3RC-017-H046 3RC-018-H016 3RC-018-H018 3RC-062-H039 3RC-146-HOOK 3RC-008-HOAU 3RC-521-HOOA The inspector visually examined the installations to determine o
Components were free from corrosion or other signs of deterioration.
that:
o Connecting joints, moving parts, piston shafts, etc.
were free from foreign materials that might obstruct proper operation.
o Support plates, extension rods and connecting joints were bent, deformed or loose.
not o
All bolts, nuts, washers, locking devices, and fasteners were tight and secure.
o The snubber was the specified size and stroke length, and was properly oriented.
o The support was properly located in accordance with drawings relative to piping, and no interferences appeared to exist
.which would restrict pipe or snubber movemen 'I I
!
The inspector observed the supports in both cold and hot positions to determine if the initial cold piston setting and snubber stroke length provided for the associated design movements (with the resulting hot piston position neither overextending nor compressing the snubber).
The inspector also reviewed the licensee's snubber preservice examination records for accuracy and completeness.
The following procedures were referred to during this inspection:
73TI-9ZZ03 91HF-3RC01 91HF-3ZZ06 91HF-3ZZ07 91HF-3ZZ08 Snubber Preservice Examination Procedure RCS Expansion Measurements BOP Piping Steady State Vibration Test BOP Piping Dynamic Transient Test BOP Piping Thermal Expansion Test No violations of NRC requirements or deviations were identified.
Review of Periodic and S ecial Re orts - Units 1 and
Periodic and special reports submitted by the licensee pursuant to Technical Specifications 6.9.1 and 6.9.2 were reviewed by the inspector.
This review included the following considerations:
the report contained the information required to be reported by NRC requirements; test results and/or supporting information were consistent with des'ign predictions and performance specifications; the validity of the reported information.
Within the scope of the above, the following reports were reviewed by the inspector.
Unit 1 o
Monthly Operating Report for October 1986.
o (1-SR-86-55)
Reactor Trip and ESFAS Actuation Unit 2 o
, Monthly Operating Report for October 1986.
o (2-SR-86-015)
Reactor Trip Associated with Features Initiation.
I No violations of NRC requirements or deviations I
an Engineered Safety Were, identi fied.
TMI Action Plan Items II I
I.G.l. Trainin Durin Low Power Testin I
=
The inspector reviewed implementation of the licensee's commitments contained in letter ANPP-22261-WFg/TFg, dated November"'10, 1982.
These commitments included:
1.
Conduct of loss of offsite power test and total loss of flow, test from 80K power with natural circulation verificatio ~~
tf lf (~
JKgj if I
! 3 L
l
Data from these tests will be used to verify and update the simulator's natural circulation modeling.
2.
The annual
"loss of core coolant flow/natural circulation" requalification training will be conducted on the simulator following verification of the simulator's modeling using the above test data.
Although the above testing was completed in Unit 1, the licensee has yet to upgrade the simulator to fully model the behavior of the plant observed during the conduct of the tests.
Licensee management committed to fully implement the above commitments by the end of the 4th quarter of 1987.
This item remains open.
III D. 1. 1 Primar Coolant Outside Containment This item requires licensees to implement a program to reduce leakage from systems outside containment that could contain highly radioactive fluids during an, accident.
The inspector had previously reviewed leak test procedures for the safety injection system in Unit 1 and the post accident sampling system in Units 1 and 2 (see inspection report 50-528/86-23).
During this inspection, the inspector reviewed the licensee s
performance, of procedure 42ST-2SI09, ECCS Systems Leak Test, for Unit 2.
The procedure was performed properly.
Excessive leakage identified was dealt with appropriately through the issuance of work orders.
The inspector also reviewed licensee submittals to NRC dated June 6, 1985 and June 5,
1986 that described the leak reduction program and the ongoing preventative maintenance program.
Finally, the inspector reviewed portions of audit 86-026, which audited implementation of the above program.
The inspector was satisfied with the licensee's implementation of this TMI item and it is closed.
20.
Unresolved Items 21.
Unresolved items are matters about which more information is required to determine whether they are acceptable, violations or deviations.
An unresolved item is addressed in this inspection in paragaph 8 of this report.
Exit Meetin The inspector met with licensee management representatives period-ically during the inspection and held an exit on November 25, 1986.
The scope of the inspection and the inspector's findings, as noted in this report, were discussed and acknowledged by the licensee representative I