IR 05000528/1990031
| ML17305B018 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 08/13/1990 |
| From: | Wong H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17305B017 | List: |
| References | |
| 50-528-90-31, 50-529-90-31, 50-530-90-31, NUDOCS 9008290235 | |
| Download: ML17305B018 (23) | |
Text
U. S.
NUCLEAR REGULATORY,COMMISSION REGION V
Report Nos.
50-528/90-31, 50-529/90-31, 50-530/90-31 Docket Nos.
50-528, 50-529, 50-530 License Nos.
NPF-41, NPF-51 and NPF-74 Licensee:
Arizona Public Service Company P. 0.
Box 52034 Phoenix, Arizona 85072-2034 Facility Name:
Palo Verde Nuclear Generating Station Units 1, 2 and
Inspection Conducted:
June 25-29, 1990 -
On Site July 2-13, 1990
- In Office
Inspector:
W. P. Ang, Prospect Inspector M. Wong, Chic Reactor Proiects Branch,Section II Date Signed Ins ection Summar
Ins ection on June 25-29 1990 Re ort Nos. 50-528/90-31, 50-529/90-31, and 50-530/90-31 A~Id:
R i
i p
i b
r 1 i p
f h
OA program.
Areas inspected included gC inspections, gA monitoring and gA audits.
During this inspection the following inspection procedures were utilized 30703, 35502, 35702, 40702 and 40704.
Results:
Of the areas inspected, no violations or deviations were identified.
TTTe iiA monitoring program appeared to significantly enhance the licensee's gA
,
program and was considered to be a strength.
The gA program was supported by the active involvement of APS senior management in the review of gA audit reports.
This also appeared to be a strength.
Weaknesses were observed in the apparent need for (1) changes to the licensee's gC inspection/verification of maintenance activities and (2) further reinforcing the use.of appropriate nonconforming condition reports.
The second item is a continuing NRC;concern.
General Conclusions and S ecific Findin s
.
Si nificant Safet Matters:
None Summar of Violations:
None 900S290 '0081
~
Sunmar of Devi ations:
Hone 0 en Items Summar
Two new Unresolved Items were identified concerning the adequacy of I
implementation of the nonconforming condition identification and reporting process and (2) independent verifications and gC inspections of routine maintenance activitie t
DETAILS 1.
Persons Contacted Arizona Public Service (APS B. Ballard, Quality Assurance Director
~W..Marsh, Operations and Maintenance 'Director
"'G. Shell, Quality Systems Manager J.
Summy, Engineering Evaluations Department Manager
- R. Fullmer, QA Audits Manager
"C.
Russo, QC Manager
~T. Bradish,Compliance Manager The inspector also met with other licensee and contractor personnel during the course of the inspection.
NRC D.
Coe, Senior Resident Inspector
~F.
Ringwald, Resident Inspector
~ Attended the exit meeting held on June 29, 1990.
2.
Ins ection of ualit Verification Function Audit Pro ram and Audit ro ram m
emen a son The licensee's requirements and commitments for quality verification functions and Quality Assurance (QA) are contained in section 6 of the Technical Specifications for Palo Verde Units 1, 2, and 3, and in the Updated Final Safety Analysis Report (UFSAR).
An inspection was performed to verify compliance with applicable requirements and licensee commitments.
A.
C Ins ections The inspector reviewed recent significant plant problems and technical NRC inspection findings to determine the involvement of the Quality Department in these issues..
A recent. significant plant problem, documented in Quality Deficiency Report (QDR) 90-0151, occurred in Unit 1 on March 29,:,1990.'when'Auxiliary Feedwater, (AFW)
Pump AFA-POl experienced two overspeed trips during retest,
-
'ubsequent to performance of disassembly and troubleshooting of. the motor operated steam supply valve to the AFW pump.
A subsequent investigation determined that the overspeed trips were caused by incorrectly landed electrical leads for the steam supply valve.
The investigation also concluded that the cause for the incorrect landing of the leads was erroneously recorded termination points that were recorded during the determination process.
No dual verification of the determination or the determination record. was performed.
Retermination was performed and verified in accordance with the incorrect determination recor I
The corrective action for QDR 90-l51 was to change the maintenance instructions to require electricians performing determinations to adequately and correctly identify and record on the "determ/reterm" sheets the termination points for wires to be terminated.
The corrective actions further specified that the termination points written on the determ/reterm sheets shall be compared to the installation prior to determination.
'The corrective aetio'n did not require dual verification or QC inspection of the determination.
The corrective actions were verified to have been completed and closed by the Quality Department.
The inspector reviewed QDR 90-151 and discussed the issue with Quality Assurance and Quality Control (QC) personnel.
The inspector determined that no QC inspection was specified for the subject determination /termination.
The inspector reviewed and discussed with QC the licensee's program for identifying and specifying QC electrical inspections.
Procedure 63DP-OQQ06, Revision 0, Determination of Quality Control Inspections, was the procedure used for identifying and specifying QC inspections.
The procedure contained an extensive list of required QC hold points (i.e.,
inspections),
including a list for electrical inspections (paragraph 4.3).
The inspection points required by paragraph 4.3 of the procedure was similar to the list of inspections required by paragraph 5 of ANSI N45.2.4., Installation, Inspection and Testing Requirements for Instrumentation and Electric Equipment during the Construction of Nuclear Power Generating Stations.
However, the inspector noted that all the inspections required by paragraph 5. 1 of ANSI N45.2.4 were not required by paragraph 4,3 of Procedure 63DP-OQQ06.
The licensee is required to meet the provisions of ANSI N45. 2. 4 in this area.
Specifically, Paragraph 3. 1; 3. 1.3 of 63DP-OQQ06 exempts QC inspection of the lifting or relanding of a termination.
Procedure 63DP-OQQ06 requires QC inspection of tightness of connections but was only required if a measurement or torque value was specified by the work instruction.
No verification for tiqhtness of connections was required, if no torque val.ue was specified.
The inspector reviewed 'approximately 10 work orders (WO) to determine the inspection requirements specified by MO's and discussed with QC the following MO's.
This review resulted in two unresolved issues.
,-" 1':-.
MO 00321049 completed February 28, 1990 was a corrective
, -.~" maintenance MO issued to replace the channel
"C" reactor, trip
. ';~
."~ :; breaker pole shaft assembly due to the failure to meet the weld acceptance criteria of NRC Bulletin 88-01.
The MO. req'uired disassembly of the breaker, replacement of the pole shaft assembly and reassembly of the breaker..
QC inspection was required for.determining that the new replacement pole shaft assembly had an acceptable weld and for assuring that a pole shaft assembly with a QC accepted weld was reinstalled.
However, no'C inspection was specified for all other disassembly and reassembly steps for the reactor trip breaker.
Only single party verification by the electrician doing the work was performed for these other step (
The inspector noted that Preventative Maintenance (PM) was subsequently performed on the the Reactor Trip Breaker in accordance with Procedure 32MT-9SB01, Revision 3, Maintenance of Mestinghouse Reactor Trip Switchgear.
The PM included several gC inspections such as, (1) the clearance fov the spring release latch lever, (2) the gap between contact tips, and (3) the UV dropout voltage.
Surveillance test 32ST-9SB01 was subsequently performed.
The NRC inspector expressed concern whether the inspections could adequately identify disassembly/reassembly errors that could cause a breaker malfunction while in sevvice subsequent to maintenance and testing.
MO 385145 was completed on June 26, 1990 to replace the undervoltage device for Unit 2 channel
"C" reactor trip breaker 2JSBCC03.
The work order involved cutting the leads for the undervoltage device, removing existing suspected deficient splices, replacing the undervoltaqe device and reperforming the splices on the leads.
gC inspect>on verified that the correct undervoltage device was installed and that the splicing process was performed correctly.
However, gC verification that the correct wires were being spliced together was not required.
Single party verification of the markings by the electrician doing the work and subsequent cutting (determination) of the leads was pevformed.
The MO procedure signoffs indicate that the leads weve subsequently spliced (landed)
by the same electrician that perfor'med the determination.
However, the determination/retermination form shows a second electrician performing the landing and the first electrician (electrician who performed the determination and marking) performing dual verification using the markings that were made during the determination process.
The NRC inspector expressed concern regarding the adequacy of performing dual verifications using markings/records generated during the single party determination and therefove subject to one person's errors rather than using approved draw>ngs which would avoid reliance on one person's work.
The NRC inspector also questioned the iridependence of a second party verification by the'ndividual that performed the single party determinati'on and marking of
=-
the wires.
In addition,,'the NRC inspector questioned compliance of the MO with.'ANSI N18.7-1976 and IEEE 336 termination verification/inspection requirements.,
MO 00414793 was issued.Harch 19, 1990, but had not bee'n",.
performed at the time'f;,'the 'NRC"inspection.
The MQ r'e'quired determination of six Plant-Protection System (PPS); cables inside cabinet 1JSBCC01 and;incl'uded rerouting the cables and reterminating them.
The cables 'provide Unit 1 controloom indication for various safety system parameters, such as ex-core linear power channel C, log power channel C, rate of power change channel C; pressurizer pressure variable set
point, steam 'generator j. variable set point and steam generator 2 variable set point.
The WO resulted from work request (WR)
337796 which stated that "these cable have not been placed in the cable tray or properly supported."
The WO specified gC inspection for proper routing but not for proper retermination of the cables.
The WO also specified that all leads lifted/relanded were to be documented on determination/retermination sheets.
These sheets typically require single party verification of determination and dual verification of retermination.
Similar to (2) above, the NRC inspector expressed concern regarding the adequacy of the determination/retermination verification process.
In addition, the inspector had a discussion with the originator of 337796, the system engineer, regarding the need for a material nonconformance report (MNCR) for the condition identified by the WR.
During discussions with the system engineer and the system engineer's supervisor, the inspector was initially informed that an MNCR was not written and was not appropriate since no requirements were being violated by the cables not being properly routed and supported inside the PPS cabinet.
The inspector reviewed the applicable specification and determined that specification 13-EN-306, paragraph 8. 1. 1.G, required:
"Cable entering equipment enclosure shall be routed in the wirinq channels provided in the enclosure.
Cable support requ>red to relieve stress on cable splices. and terminator shall be in accordance with 8.2. 10.........".
This was discussed with the system engineer and his supervisor.
MNCR 90-SB-0012 was subsequently issued.
An operability evaluation was also performed.
The system engineer determined that no technical specification operability questions resulted since the cables provided indication and no control functions.
During a subsequent discussion with the Engineering Evaluations Department Manager, the manager stated that he would request additional gA training for system engineers regarding when to write MNCRs.
The inspector's concerns regarding the adequacy of verifications/inspections of electrical equipment assembly, and cable terminations were discussed with both the Site Director, and the equality Department Director.
The licensee stated that'they would evaluate their verification process to determine if,any changes were needed.
The Site Director stated during the,"exit interview that he did not expect a drastic change from the'existing process.
Pending further evaluat'ion and inspection, the-":"
verification process concerns were identified as Unresolved,;.Item 50-528, 529, 530/90-31-01.
In addition, the concern regarding the use of WOs 1n lieu of MNCRs for identifying and correctzng
'.-.:,
.
nonconforming conditions was identified as Unresolved Item'50-528, 529, 530/90-31-02.
Subsequent to the on-site inspection, the NRC inspector further reviewed the UFSAR, the Palo Verde Technical Specifications, ANSI
18.7 - 1976, and IEEE 336 and discussed the requirements with the Office of Nuclear Reactor Regulation (NRR), Performance and equality Evaluation Branch.
The inspector determined the following requirements and licensee commitments applied:
UFSAR Chapter l.8 accepts the position of Regulatory Guide (R.G.) 1.33, with certain exceptions.
2.
R.G. 1.33, gA Program Requirement (Operations),
Revision 2, February 1978, Part B, second paragraph; states in part that where conformance to the recommendations of this Regulatory Guide is indicated in an application without further qualification, this indicates the applicant will comply with the "requirements" of ANSI N18.7-1976/ANS 3.2, as supplemented
'r modified by the regulatory position of this guide.
I'FSAR Chapter 1.8 does not'ake exception to Section 5.2.7 or 5.2.17 of ANSI N18.7-1976.
Section 5.2.7 of ANSI N18.7-,1976 states in part that maintenance or modifications which may affect the functioning of safety-related structures, systems or components be performed in a manner to ensure quality at least equivalent to that specified in original design bases and requirements, materials specifications and inspection requirements.
In addition, a suitable level of confidence in structures, systems, or components on which maintenance or modifications have been, performed shall be attained by appropriate inspection and performance testing.
Section 5.2. 17 of ANSI N18.7-1976 states in part:
"A program for inspection of activities affecting safety shall be established and executed by or for the organization performing the activity to verify conformance with applicable documented instructions, procedures, and drawings.
Inspections, examinations, measurement's, or test of material, products, or activities shall be performed for each work,',.
operation where necessary.,to assure quality.
Such inspections shall be performed by qualified individuals other-tha'n those who performed or directly,,supervised the activity bein'g" inspected.
Inspection of~oper'ating activities (work furictions associated with normal operation of the..plant, routine maintenance, and certain technical services routinely" assigned to the on site operating organ'iz'ation)
may be 'conducted'by,.;
second-line supervisory personnel
'or by, other qualified':-" '
personnel not assigned first-line supervisory responsibil;ity for conduct of the work.
These independent inspections,
.'i":.e.,
those performed by individuals not assigned first-line supervisory responsibility for the conduct of the work, are not intended to di lute or replace the clear responsibility of first-line supervisors for the quality of work performed under
~
their supervisio For modifications and non-routine maintenance, inspections shall be conducted in a manner similar (frequency, type, and personnel performing such inspections)
to that associated with construction phase activities (see also Section 5.2.7)."
6.
UFSAR Chapter 1.8 states that for operation phase activities that are comparable to activities occurring during the construction phase, the Regulatory Guide 1.30 applies with certain interpretations.
7.
Regulatory Guide 1.30-1972 states in part in paragraph C that,
"The requirements for the installation, inspection, and testinq of nuclear power plant instrumentation and electr>c equipment which are included in ANSI N45.2.4-1972, "Installation, Inspection, and Testing Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Station" (also designated as IEEE Std 336-1971)
are generally acceptable and provide an adequate basis for complying with the pertinent quality assurance requirements of Appendix B to lOCFR Part 50, subject to the following:....."
Paragraph 3 states,
"Although subdivision 1. 1 of ANSI N45.2.4-1971 stuies that the requirements promulgated apply during the construction phase of a nuclear power plant, these requirements are
.also to be considered applicable for the installation,
'inspection, and testing of instrumentation'and electric equipment during the operation phase of a nuclear power plant."
8.
Paragraph 5. l. 1 of ANSI N45. 2. 4-1972 states, that
"Inspection shall be made to verify that equipment is being located, installed, assembled, andlor connected to comply with latest approved-for-construction drawings, manufacturers instructions',
and installation specifications.
Such inspections shall include, as appropriate, verification.of:
(1)
Leveling and alignment
"1 "~
(2)
Clearance and tolerances
=
(3)
Proper location and routing of cables and sensing"1ines (4)
Tightness of connections and fastenings (5}
Freedom of movement (6)
Correct polarity (7)
Proper grounding (8)
Terminations (9)
Fluid levels and pressures ('10)
Absence of leaks (11)
Physical integrity (12)
Identi ficati ons"
No interpretations or exceptions to the above cited portions of ANSI N45.2.4 - 1972 (IEEE 336-1971)
were stated.
Based on the above licensee commitments and NRC requirements, the NRC inspector concluded the following:
APS has committed to comply with the stated requirements of R.G.
1.33 and 1.30, ANSI N18.7-1976, and ANSI N45.2.4 (IEEE 336).
2.
3.
ANSI N18.7-1976 requires inspections of maintenance activities.
ANSI N45.2.'4 requires inspection of electrical component assembly, terminations and grounding.
ANSI N18.7-1976 paragraph 5.2.17 requires inspections for modifications and non-routine maintenance to be performed in a t
YYY t
d tth t
tt ph activities, i.e.,
by gC or equivalent inspectors.
ANSI N18.7-1976 paragraph 5.2.17 allows. inspection of routine maintenance activities by ualified individuals other 7fiMa those who erformed or direct su ervised the activit
~hh>>
Y
<<Y supervi sory personnel.
In summary, based on the inspection, the subsequent review of of licensee commitments, and discussions with NRR, the NRC inspector had the following unresolved issues pending further inspection and review of the licensee's inspection program (Unresolved Item 50-528,529, 530/90-31-01).
Further clarification of the licensee's inspection program is needed to determine the acceptability of inspection of terminations which do not verify conformance to latest approved for construction drawings, manufacturer's instructions, or installation specifications, but uses determination logs and markings that had not been verified by a second party.
Further clarification is needed as to the inspections performed during the replacement of reactor trip breaker.undervoltaqe coils.
This activity involved determination and termination, and therefore appropriate termination inspection/verification (i.e., routine or non-routine)
requirements of ANSI N18.'7,;and IEEE 336 should have been @met".,;-.
Similarly, further clarification>>s'eeded of the licensee's inspection program to determine what inspections/verifications were performed for the disassembly" and reassembly of reactor trip breakers.
Further review of the licensee's program is needed to determine how the program provides for the following:
a.
b.
Distinction of routine versus non-routine maintenance and the applicable inspections/verifications for each.
Definition of "independent party" where inspections are not required to be performed by QC.
Qualification requirements for non-QC personnel performing inspections.
C Or ani zati on.and Functions The QC organization was reviewed and discussions held with Quality Department managers and QC supervisors in conjunction with the inspection of QC functions during electrical equipment assembly and cable terminations.
The QC organization and its responsibilities are delineated by procedure 630G-OZZ01 revision 0.
The NRC inspector noted that the QC site organization included 15 inspectors (5 per unit) and 4 foremen for inspectioris of the 3 units,
inspectors for MNCR and WO review and processing, 5 inspectors for outage planning and 5 inspectors for receiving inspections and warehouse material control.
Five QC inspectors per unit for all shifts appeared small although it was recognized that they, were augmented when needed, during non-outage occasions; at the sacrifice of some of the other inspection functions (MNCR 8 WO processing, receiving inspections, outage planning),
and augmented by contract inspectors during outages..
The Quality Department Director acknowledged the inspector,'s observation, and noted that an independent review of the site's manpower also observed QC being slight understaffed, but stated that.the QC staff was comparable to that of other reactor plants.
The inspector encouraged the licensee to evaluate current QC inspection needs and anticipated work load.
The QC WO review process was also reviewed and discussed with Quality Department and QC management.
Procedure 63DP-OQQQ06 provided checklists for the QC procedure review:
The NRC inspector noted that the procedure and the checklists do not specifically require review of the work orders to determine if QDR's or MNCR's would be required for conditions ehcountered while completing the WO.
The QC Manager and Quality Department Director acknowledged.the NRC insp'ector's observation but disagreed that QC should perform an inline review function of WO's for identification'f nonconforming conditions.
Pending further inspection and review, this was identified as an additional concern associated with Unresolved Item
,
50-528, 529, 530/90-31-02.
The NRC inspector noted that Plant Standards and Construction had-rejection rates of approximately 22 percent and 26 percent,
,
respectively, based on QC WO review 'for May 1990..
No QDR's or CARs had been written to identify and resolve the high rejection rate.
However the Quality Department does, issue monthly reports.'that identify rejection rates by departments.
A special assessment of the QC WO review process and the resultant rejection rate was performed by the Nuclear Safety Department (NSD) and a report was issued April 26, 1990.
The NSD report noted that the primary weakness in the process
rl
was that gC was being requested to perform the MO reviews prior to performance of technical review by work control personnel.
The report recommended performance of the technical review ~rior to submittal to gC.
The report also recommended that the
'Model Mork Order" program for generic work be expeditiously implemented.
Pending further inspection and review of licensee corrective actions to improve the MO gC rejection rate, this was identified as a further concern associated with Unresolved Item 50-528, 529, 530/90-31-02.
ualit Monitorin Monitoring of work activities by the equality Monitoring Group of the equality Department was reviewed.
Performance of equality Monitoring exceeds the
CFR Part 50, Appendix 8, requirements for audits and inspections.
The equality Monitoring organization and responsibilities are discussed in procedure 6206-OZZ01, Revision 1.
A review of the Monitoring Observation Report log noted that over 330 monitoring activities were performed in June 1990.
The log indicated that subject areas being monitored were predominantly areas of timely concern, i.e. Unit 1 restart operations activities, radiological control activities, and maintenance activities.
The log also indicated that the monitoring activities resulted in meaningful findings.
For example, monitoring of chemistry activities identified that reactor coolant boron analysis was not performed in accordance with procedure; monitoring of operations activities noted that an incorrect switch was operated during performance of a surveillance; and monitoring of control room activities noted. that a control room log entry did not log completion of pressurizer heat up evolutions.
Ongoing gA monitoring of control room operations activities and of maintenance of a Unit 1 Diesel Generator Starting Air Compressor, were reviewed.
The inspector discussed the work activities being monitored with the gA Monitors involved and the personnel performing the work and reviewed applicable procedures for the activities being monitored.
The discussions indicated that the monitors appeared to be knowledgeable of the areas being monitored and appeared to be observing appropriate attributes.
The NRC inspector noted, however, that both monitors observed were not permanent members of the Monitoring staff; one was a gA
,-
Inspector and the other was a equality Engineer from the equality.,
Systems organization.
The inspector further'noted that the small quality monitoring staff consisted of a supervisor, two coordinators, and five monitors an'd that vacancies existed for, three additional monitors.
The inspector recognized that the small staff was being augmented by personnel from other portions of the equality Department.
equality Monitoring appeared to be a strength in the licensee's equality Assurance Program, despite the relatively small staff.
Due to the current issues at Palo Verde, monitoring being performed
appeared to be predominantly reactive.
The inspector commented that further improvement of the program in the future would be a more balanced performance of pro-active monitoring, where discrepancies can be identified and corrected before they result in significant problems and issues.
No violations or deviations were.identified.
D.
gA Audits The Quality Audits organization and responsibilities are described
.in procedure 620G-OZZ01, Revision 1.
The QA Audit schedule was reviewed.
Recent QA Audit reports were reviewed and an ongoing audit was reviewed.
1)
A Western Region Joint UtilityAudit of the Palo Verde QA program was performed on April 23-27, 1990 and a report issued April 27, 1990.
The audit concentrated on the QA Audit Program, Corrective Action Program, Monitoring Program and the Nonconformance Control Program.
The subject area audit'ed and the 5 day time constraint of the audit appeared to limit it to a more compliance-based, rather than performance-based, audit.
This aspect was reflected in the majority of the check sheets used during the audit.
However, the audit resulted in some timely and meaningful findings and recommendations, such as recommendations dealing with generation of, nonconforming condition reports by the Quality Department.
" It was noted that one of the recommendations of the audit was to increase performance-based audits.
2)
A QA audit regarding conformance to Technical Specifications and License Conditions was performed April 16-25,'1990 and documented in-Audit Report 90-008.
The audit appeared to be both performance-based and compliance-based.
The audit included observation of performance of surveillance tests on the Plant-Protection System, Containment Hydrogen Monitoring System and Radiation Monitoring System.
The audit appeared to be an improvement in quality, scope and performance to those performed in previous years.
The audit report was reviewed and commented on by the, Executive Vice President, Nuclear in letter 001-00257-MFC dated '.June 12,
- 1990.
The letter demonstrated strong support and invo'lvepent
--. in the QA program by the Executive Vice President, Nucleai
-;
."',. '" ~ The letter illustrated a prompt and detailed review'ot~the'-."
audit report and a commitment to correcting identic'ed"'"'"
'iscrepancies.
Similarly, letter '001-00255-MFC, dated Jun'e,'ll, 1990, provided the Executive Vice President; Nuclear 'comments on Audit Report 90-003.
The NRC inspector discussedthe
',~ "
letters with the Quality Department Director and inquired about similar responsiveness by the Vice President Nuclear Production or members of his staff.
The Quality Department Director stated that the comments of, the Vice President, Nuclear Production were typically conveyed by means of discussions with
V
the equality Department rather than by means of letters or memoranda.
3)
A gA Audit of Refueling.Operations, Audit 90-005, was in proqress during this inspection.
The.majority of the audit activities dealing with observation of Refueling Operations had been completed and that the remainder of the ongoing audit was predominantly documentation reviews and documentation of the audit.
The inspector met with the Audit Team Leader and involved auditors to discuss the audits performed on refueling operations and the findings of the audit.
This discussion indicated that the auditors involved were knowledgeable about refueling activities and previous problems experienced during refuelinqs such as the stuck fuel assembly occurrence, mispositioning of a fuel assembly, and liftinq of an incorrect fuel assembly during previous refuelinq activities.
The description by the auditors of the audit activities during the refueling operation indicated that meaningful performance-based audits were performed.
Although not yet completed, the audit appeared to have been performed satisfactorily.
No violations or deviations were identified.
3.
Unresolved Items
Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or deviations.
Two new unresolved items identified during the inspection are discussed in paragraph 2 above.
4.
Exit Interview (30703)
The inspection scope and findings were summarized on June 29, 1990, with those persons indicated in paragraph one above.
The inspector described the areas inspected and discussed the inspection findings.
Two Unresolved Items wer e identified and discussed with the license ~
l