ML17199S298
| ML17199S298 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Braidwood, LaSalle, 05000000 |
| Issue date: | 08/14/1987 |
| From: | Ploski T, Matthew Smith, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17199S296 | List: |
| References | |
| 50-237-87-28, 50-249-87-27, 50-373-87-25, 50-374-87-25, 50-456-87-26, 50-457-87-26, NUDOCS 8708280042 | |
| Download: ML17199S298 (12) | |
See also: IR 05000237/1987028
Text
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I
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-456/87026(DRSS); 50-457/87026(DRSS);
50-237/87028(DRSS); 50-249/87027(DRSS);
50-373/87025(DRSS); 50-374/87025(DRSS)
Docket Nos. 50-456; 50-457
50-237; 50-249
50-373; 50-374
Licensee:
Commonwea 1th Edi son Company
Post Office Box 767
Chicago, IL
60690
Licenses No. NPF-72; CPPR-133
Facility Names:
Braidwood Nuclear Power Station, Units 1 and 2
Dresden Nuclear Power Station, Units 1 and 2
LaSalle County Nuclear Power Station, Units 1 and 2
Inspection At:
Braidwood Site, Braidwood, Illinois and
Emergency Operations Facility, Mazon, Illinois
Inspection Conducted:
August 3-7, 1987
Inspectors:
T. PloskW.~ ;,,.._
s/14/$2
Date
Approved By:
. M. Smith VJ.51 f
wi&lJ~J.fchief
Inspection Summary
Section
~!l~An
Date
Date
Inspection on August 3-7, 1987 (Reports No. 50-456/87026(DRSS); S0-457/87026(DRSS);
50-237/87028(DRSS); 50-249/87027(DRSS); 50-373/87025(DRSS); 50-374/87025(DRSS))
Areas Inspected:
Routine, unannounced inspection of the following areas of
the licensee's emergency preparedness program:
activation of the emergency
plan; operational status of the emergency preparedness program; emergency
detection and classification; protective action decisionmaking notifications
and communications; shift staffing and augmentation, and licensee action on
previously identified items.
This inspection involved two NRC inspectors.
Results:
One violation of NRC requirements was identified at the Mazon
Emergency Operations Facility.
The violation is applicable to the Braidwood,
Dresden, and LaSalle Stations.
8708280042 870820
ADOC~ 05000237
G
..
DETAILS
1.
Persons Contacted
- E. E. Fitzpatrick, Station Manager
- K. L. Kafron, Production Superintendent
- R. D. Kyrouac, Quality Assurance Superintendent
- L. E. Davis, Assistant Superintendent
- P. Barnes, Regulatory Assurance Supervisor
- R. E. Aker, Radiation Chemistry Supervisor
- M. Takaki, Regulatory Assurance
- L. Literski, GSEP Coordinator
- A. Scott, Emergency Planning Trainer
- A. J. D
1Antonio, Quality Control
- L. 0. Benington, Quality Assurance Inspector
- J. L. Bowman, Emergency Planning
- T. Markwalter, Nuclear Services Emergency Planning
W. Brenner, Principal Offsite Emergency Planner
P. Habel, Shift Engineer
F. Krowzack, Technical Assessment Supervisor
- Denotes those personnel listed above who attended the exit
interview on August 7, 1987.
2.
Licensee Action on Previously Identified Items
(Closed) Item No. 457/80015-BB:
Bulletin issued in 1980 on possible loss
of power to the Emergency Notification System (ENS) to the NRC Operations
Center.
As indicated in Inspection Reports No. 456/87010(DRSS) and
No. 457/87010(DRSS), ENS telephones have been installed in the Control
Room and Technical Support Center.
The inspector determined by visual*
inspection and records checks that both instruments were still installed
and have been periodically tested in accordance with procedures.
The
power failure requirements have been met, as both telephones receive
power from the Security Bus, backed by the Security Diesel Generator,
which would start and take load if the bus would fail.
This item is
closed.
(Open) Open Items No. 456/87021-01; No. 457/87019-01:
The 1987
Braidwood Public Information Brochures, containing revised language,
will be distributed within the 10-mile Emergency Planning Zone during
1987.
The inspector interviewed the Principal Emergency Planner (Offsite),
who indicated that the brochures would be ready for distribution by
mid-August, 1987.
Following completion of mail and bulk distribution,
a letter will be sent to the NRC regional office verifying distribution
compl~tion with mailing dates and bulk distribution lists.
This item
remains open .
2
3 .
Emergency Plan Activations
The inspector reviewed Licensee Event Reports (LERs) for the period March
through mid-July 1987, plus licensee records associated with two emergency
plan activations which occurred during that period.
The Unusual Events
declared on March 9 and July 1 were properly classified.
These were the
only situations which warranted an emergency plan activation for the
aforementioned time period.
Initial notifications for both Unusual Events
to the State of Illinois and the NRC were completed within the regulatory
time limits.
Notification messages were adequately documented.
The
licensee
1 s evaluations of these emergency declarations were adequate.
Based on the above findings, this portion of the licensee 1s program is
acceptable.
4.
Operational Status of the Emergency Preparedness Program (82701)
a.
Emergency Plan and Implementing Procedures (also 82204)
The NRC regional staff documented its approval of Revision 2 to the
Braidwood Annex to the Generating Station Emergency Plan (GSEP) by
letter dated July 8, 1987.
The Braidwood Annex accurately reflected
the approved generic GSEP, Revision 6/6A, and provided accurate
plant-specific information.
The inspector reviewed the Document Control staff 1 s distribution
records of changes to the Plan and Emergency Plan Implementing
Procedures (EPIPs).
A sample of records were examined to determine
- whether such revisions had been properly sent to the NRC within
30 days of final approval as required by 10 CFR 50.54(q).
No
discrepancies were identified in the examined distribution records.
Based on the above findings, this portion of the licensee 1 s
program is acceptable.
b.
Onsite Emergency Facilities, Equipment, and Supplies
The inspector toured the onsite Emergency Response Facilities
(ERFs) which were located as described in the Braidwood Annex.
The
facilities were adequately maintained and in a state of operational
readiness.
In addition to the official telephone directories, copies
of unofficial March 1986 telephone directories were located at all
positions in the TSC.
The GSEP Coordinator indicated these
directories were not official plant directories and had been provided
for the 1986 exercise by corporate emergency planning staff.
The
inspector indicated concern for out-of-date, unofficial documents
being available for use by GSEP personnel in an emergency situation.
The telephone directories were removed by the GSEP coordinator for
updating by corporate personnel .
3
c.
During the TSC tour, the inspector noted that Area Radiation
Monitors (ARMs) AR073 and AR074 were malfunctioning.
The ARMs
.
gauges indicated no reading, while the ARMs 1 visual alarms indicated
high radiation levels.
The inspector determined that the problem
had existed for several weeks.
Licensee staff speculated that the
malfunction was due to startup testing involving the RM-11 system.
The licensee generated Work Request No. A15207 in order to return
both ARMs to operational status.
A sufficiently high priority was
assigned to the work request so that repair work would commence
within about one week.
The inspector noted that the TSC 1 s Continuous
Air Monitor was operable.
Also, adequate procedural provisions
existed for periodic habitability surveys of the TSC should it be
activated.
The inspector reviewed documentation of quarterly emergency supplies
inventories required by BwZP 5001-5 and found records complete with
one exception.
The inventory for the hospital kit is conducted by
Dresden personnel as the hospital is used jointly by both plants.
An earlier agreement had been reached between the two plants
regarding the responsibility for hospital inventories.
Copies
of the quarterly inventories were produced by the Braidwood GSEP
Coordinator for the inspectors review in the same day.
The records
verified the quarterly inventories were completed by Dresden
personnel as required.
The inspector reviewed letters of agreement with offsite support
agencies and contractors who support the utility during an
incident.
All letters were on file according to requirements.
Letters were sent to the town of Essex. and Custer Park Township.
Copies of these letters had not been signed and returned.
An
interview with the GSEP Coordinator revealed that the two agencies
were part of a mutual aid agreement with the Braidwood Fire Department
and thus were legally required to assist them .. Although letters of
agreement are not on file, training is offered to both entities by
the Braidwood Station.
Based on the above findings, this portion of the licensee's
program is acceptable.
Offsite Emergency Facilities, Equipment, and Supplies
On August 4, 1987, the inspector toured the Emergency Operations
Facility (EOF) and determined that it was not in an adequate state
of operational readiness.
The inspector observed several tables
containing numerous stacks of procedures and plan revisions and
aperture cards of P&ID
1s from all three plants which use the Mazon
facility as their EOF during an emergency situation.
The inspector
discovered that the filing was backlogged roughly six months for
Braidwood procedures, and five months for LaSalle procedures, and
about one month for Dresden procedures.
About a six month backlog
of aperture card filing existed for all three plants.
Upon further
4
..
r~search and interviews, the inspector determined that the licensee
did not have sufficient provisions to ensure timely filing of these.
reference materials on a routine basis.
This constitutes a violation of 10 CFR 50.47(b)(8) which states,
"Adequate emergency facilities and equipment to support the response
are provided and maintained.
In addition, 10 CFR 50, Appendix B,
Section IV, states in part:
"Measures shall be established to
control the issuance of documents, such as instructions, procedures,
and drawings, including changes thereto, which prescribe all
activities affecting quality.
These measures assure that documents
including ch?nges ... are distributed to and used at the location
where the prescribed activity is performed.
11
In response to the inspector's concern, the Braidwood Station sent
eight clerical personnel to the EOF on August 5.
This staff completed
the filing of Braidwood procedures and aperture cards within one
day.
LaSalle Station sent two clerical personnel to complete their
backlog of filing.
By the end of the inspection, the licensee
assured the inspector that the immediate filing backlog problem was
solved;
however, a long-term solution had not been finalized.
The Braidwood Quality Assurance staff have added an audit line item
in their permanent audit schedule of the GSEP, which requires a
review of the operational readiness of the Mazon EOF.
The Manager,
Quality Assurance, was expected to instruct all Stations' QA staffs
to address EOF operational readiness in their annual audits of the
Stations' emergency preparedness programs.
This is a Severity
Level IV violation (Supplement VIII).
The violation will be tracked as Open Item
No. 50-456/87026-01;
No. 50-457/87026-01; No. 50-237/87028-01;
No. 50-249/87027-01;
No. 50-373/87025-01; and No. 50-374/87025-01.
Other supplies and equipment such as telephones, maps, radios,
computer equipment, etc., were operational.
However, copies of
unofficial telephone directories from March 1986 were located at
various positions and were out-of-date.
The inspector noticed that
Dresden had onsite and offsite emergency organizations call out
procedures dated March 1985 on file in the Dresden Station EPIP
binder.
The inspector understood that current call out directory
had been discontinued from the Dresden Station EPIPs because it
contained plant personnel's home telephone numbers.
In addition to the aforementioned violation, the following items
should be considered for improvement:
The licensee should ensure that a current copy of the
onsite emergency call out directory for the Dresden
Station is maintained at the Mazon EDF .
5
Copies of unofficial telephone directories in
the Mazon EOF should be eliminated or incorporated
into the official telephone directories.
d.
Organization and Management Control
In the Spring of 1987, the licensee formed a Technical Services
Consolidated Performance Assessment Department, which is based
at the corporate offices and reports to the Technical Services
Manager.
The inspector discussed the function of this department
with its supervisor, who was onsite with about ten individuals to
conduct a three-day, pilot assessment of health physics, the ALARA
program, radwaste, and emergency preparedness activities.
In
addition to these four areas, the department was also expected to
eventually assess chemistry and training at the six nuclear stations
and the corporate offices.
However, overall training activities
were not planned for in-depth assessment by this group until the
INPO accreditation process had been completed.
Also, assessment of
the corporate aspects of these six functional areas was not planned
until sometime after a comprehensive INPO evaluation of corporate
activities that was scheduled for later in 1987.
Assessments at
the Dresden and Byron Stations were scheduled in 1987.
The goal of
the new assessment department was to have all six stations ranked
among the top 25 percent of the nation's nuclear plants by 1992
based on such industry performance measurement systems as INPO
guidelines and good practices.
The inspector understood that the department's current full-time
staffing consisted of a supervisor, an administrative coordinator,
and three team leader positions (Health Physics/ALARA), (Chemistry/
Radwaste), and (Training/Emergency Preparedness).
Not all of the
team leader positions had been filled.
Staffing for the pilot
assessment team had been drawn from other stations and the
corporate offices.
The team assessing Braidwood's emergency preparedness program
consisted of a corporate emergency planner (acting team leader)
and the GSEP Coordinators from the Byron and LaSalle Stations.
Categories addressed by this team included:
emergency organization
and administration; emergency preparedness training; emergency
response facilities and equipment; emergency assessment and
notification; onsite personnel protection provisions, and the
Performance objectives and associated evaluation
criteria were listed under each category, along with numerical
references to various INPO documents.
The inspector understood that
the assessors selected a sample of performance objectives from each
category and determined if they had been adequately met based on
record reviews and interviews.
Station management was informed of
the team 1 s preliminary findings during an exit meeting.
The team
1 s
findings would later be documented in an internal report .
6
The GSEP Coordinator has participated in meetings with her
counterparts from the other five stations.
Meetings during 1986 and
1987 had been conducted on about a quarterly basis.
Some meetings
had also included members of the corporate emergency planning staff
besides the corporate supervisor based at the Mazon EOF.
The
meetings served a number of useful purpos~s, including the
opportunity to compare experiences and exchange ideas.
The inspector obtained a copy of the agenda for the GSEP
Coordinator counterpart meeting scheduled for September
1987.
The overall decline in the six stations' SALP ratings for emergency
preparedness is to be a major topic for discussion.
Attendees have
been asked to be ready to discuss a number of listed suggestions for
improving the stations' SALP ratings, many of which have already
been expressed in NRC Inspection Reports and/or exit interviews
associated with recent appraisal, exercise, and routine emergency
preparedness inspections.
The inspector concluded that a number
of the suggestions reflected the valid need for the licensee to
go outside its organization to gather information on how other
licensees prepare players and controllers for annual exercises
and how the exercise scenarios can be made more innovative and
challenging.
The GSEP Coordinator was a station employee who reported to the
Services Superintendent through the Rad Chem Supervisor.
The
coordinator also functionally reported to the corporate Supervisor
of Emergency Planning through an Emergency Planning Supervisor based
at the Mazon EOF.
The coordinator was responsible for the day-to-day
maintenance of the onsite program.
The coordinator was also actively
involved in conducting some onsite emergency preparedness training
activities, such as certain drills.
A training instructor from the
Station's Training Department conducted classroom GSEP training and
maintained GSEP training records for members of the onsite emergency
organization.
During 1986, the licensee had assigned various corporate emergency
planning staff members to visit each Station's GSEP Coordinator on
a quarterly basis in order to review the Coordinators' progress on
assigned tasks.
The visits were announced and were intended to
verify that responsibilities were being carried out, rather than
how well the tasks were being done.
The visits were correctly
not considered as audits of the Coordinators' work.
The Braidwood
Station 1 s Coordinator stated that several such visits had occurred
during 1986, but that none had taken place in 1987.
The Coordinator
had no documentation of the 1986 reviews, and had assumed that the
quarterly visits had been discontinued for 1987.
Based on the above findings, this portion of the licensee's
program is acceptable.
7
- .
e .
f.
Training (also 82206)
The inspector determined that all required emergency preparedness
drills had been conducted and critiqued since the Fall of 1986.
The drills were adequately documented.
The GSEP Coordinator
1 s
tracking system had been satisfactorily implemented to correct
items identified during critiques.
The inspector reviewed the emergency preparedness training records
of 16 randomly selected members of the onsite emergency response
organization.
The training program consisted of a generic GSEP
training, position specific training and required reading.
A test is
administered for both types of training sessions and a passing grade
of 70 percent is required.
Personnel who fail to meet the required
time frame for training are referred to the Plant Manager.
The
inspector concluded that all personnel reviewed had completed or
were in the final process of completing training within the required
annual time frame.
Plan and implementing procedures revisions are routed to cognizant
emergency personnel as required reading.
A cover sheet requiring a
signature and return date within two weeks of receipt is attached.
The inspector
1s review of training records indicated signature pages
of required reading were returned within the required timeframe.
The inspector reviewed documentation of training presented to
offsite support agencies.
The training was presented by Radiation
Management Corporation to primary fire departments, ambulance support
and hospital staff.
Sign-in sheets and lesson objectives were
reviewed.
The inspector determined that the annual training
requirement of offsite support personnel had been met.
Based on the above findings, this portion of the licensee 1 s
program is acceptable.
Audits (also 82210)
The inspector reviewed records of audits and surveillances of the
emergency preparedness program and discussed these activities with
the Quality Assurance (QA) Superintendent.
Two audits were performed
in October 1986.
One was an
11onsite
11 audit conducted by QA Department
staff based at Braidwood Station, while the other was an
11 offsite
11
audit performed by QA staff from other locations.
Both audits were
adequate in scope and depth to meet the requirements of 10 CFR 50.54(t).
Audit records were complete and readily available.
The
11 onsite
11 audit
was entirely devoted to the Station's emergency preparedness program,
while emergency preparedness was one of several topic areas addressed
in the 11offsite
11 audit.
All audit concerns were resolved in a timely
manner.
The 1987 annual
11onsite
11 audit of the program was scheduled
for later in August.
In response to the inspectors
1 concern regarding
the untimely filing of procedures and other documents at the Mazon EOF
(see Paragraph 4.d), the maintenance of Braidwood Station records kept
at that facility has been added to the annual audit checklist.
8
The inspector also determined that several emergency preparedness
related items had been addressed in two audits that had been
performed during March and July 1987.
Three surveillances of
certain aspects of Braidwood's emergency preparedness program
had already been conducted during 1987.
One involved observations
of player activities during the annual exercise.
Another involved
player activities during the annual medical drill.
The third
surveillance involved the periodic inspection of respiratory
protection equipment available to emergency response personnel in
certain ERFs and the GSEP Van.
No auditor concerns were identified
during the drill and exercise surveillances, which focused on player
performances rather than on critique quality or critique item followup.
The concern identified during the equipment surveillance was resolved
in a timely manner.
Based on the above findings, this portion of the licensee's program
is acceptable; however, the following item should be considered for
improvement:
Surveillances of emergency preparedness drills and exercises
should also address the adequacy of the critiques and followup
actions taken on identified problems.
5.
Emergency Detection and Classification (82201)
Since 1985, the licensee has been involved in an Emergency Action Level
(EAL) upgrade and standardization project that encompasses all six of its
nuclear stations.
A corporate emergency planning supervisor based at
the Mazon EOF was currently in charge of this effort, assisted by several
emergency planning staff having reactor operator background in BWRs or
PWRs.
The inspector determined that efforts were well underway to
finalize a set of generic EALs for the Bryon and Braidwood Stations
which would be as identical as possible.
The proposed EALs had been in
the internal review and comment process at both Stations, with the goal
of having all comments resolved and the proposed EALs submitted for NRC
approval in September 1987.
The schedule had fallen a bit behind, as
some input had not been received from the architect/engineer for certain
"radioactive effluent release" EALs.
However, the licensee still
expected to have the proposed EALs ready to submit to the NRC in
the early Fall of 1987.
The inspector reviewed the draft, revised EALs for the Byron and
Braidwood Stations plus the currently approved Braidwood EALs for
earthquake situations.
The proposed and currently approved Unusual
Event EALs addressed an earthquake of sufficient magnitude to cause
seismic monitoring instrumentation to alarm.
No EAL addressed the
possibility, expressed in the guidance of NUREG-0654, Revision*l, that
onsite seismic instrumentation may be inoperable at the time of an
Technical Specification 3.3.3.3 stated that the seismic
monitoring equipment was to be operable at all times.
However, should
the equipment be inoperable for more than 30 days, the licensee need
only to submit a Special Report within another ten days that described
9
/
the equipment malfunction and the plans for restoring the equipment
to operable status.
Thus, it was possible for the plant to experience
an earthquake and yet an Unusual Event would not be declared if the
seismic monitoring equipment was inoperable.
An earthquake was felt by some personnel in the Service Building,
including the Senior Resident Inspector, on the evening of June 10,
1987.
The earthquake was not felt in the Control Room.
While the seismic
monitoring system was operable, it did not alarm.
Subsequent equipment
examinations uncovered no problems with the seismic instrumentation,
indicating that the earthquake was less than the alarm setpoint.
No
onsite ,damage from the earthquake was discovered by licensee personnel
who performed some precautionary inspections of plant systems once the
Control Room had received several reports from onsite personnel that
they had felt an earthquake.
However, in accordance with the currently
approved EALs, an Unusual Event was not declared.
The inspector interviewed a Shift Engineer (SE) who, as Acting Station
Director, would be responsible for the initial classification of an
emergency situation.
The SE was readily able to correctly classify
several abnormal plant conditions using the currently approved EALs
found in Procedure BwAP 200-1.
The SE was also adequately aware of the
regulatory time limits for initially notifying State and NRC officials
following any emergency declaration, and adequately understood which
emergency response facilities (ERFs) must be activated within
about one hour following an appropriate emergency classification.
Based on the the *above findings, this portion of the licensee's program
is acceptable; however, the following item should be considered for
improvement:
The licensee should revise the generic PWR and generic BWR EALs for
all six nuclear stations so that an Unusual Event would be declared
if an earthquake was felt onsite and the seismic monitoring systems
were inoperable.
6.
Protective Action Decisionmaking (82202)
The inspector compared procedural guidance on onsite and offsite
protective action decisionmaking to that contained in the GSEP and
Braidwood Annex.
The procedural guidance accurately reflected the
information found in the approved emergency plan.
The inspector interviewed a SE and concluded that he was adequately
familiar with procedural guidance on protective action decisionmaking.
The SE understood that, among his undelegable responsibilities as
Acting Station Director, were the responsibilities for making protective
action recommendations to offsite authorities and authorizing onsite
emergency worker exposures in excess of normal regulatory limits.
He
adequately understood when onsite assembly and accountability was required,
and under what circumstances the subsequent evacuation of non-essential
personnel would or would not be appropriate.
He knew the minimum offsite
10
protective action recommendation for any General Emergency declaration
and was adequately fami1ia~ with procedural guidance for formulating
offsite recommendations.
Based on the above findings, this portion of the licensee's
program is acceptable.
7.
Notifications and Communications (82203)
The inspector reviewed records of monthly, quarterly, and annual
communications tests performed since the Fall of 1986 and determined
that all were satisfactorily completed.
Identified problems were
corrected in a timely manner.
The inspector reviewed Procedure BwZP 300-1 through BwZP 300-3,
11 Initial Notification and GSEP Response
11 and determined that procedures .
were consistent with the classification and emergency action levels.
Random testing of telephones in various emergency response facilities
was conducted.
All telephones were operational.
Call out and
notification procedures were complete and current.
A review of
emergency plan activation for this year verified the licensee
can perform notifications within the regulatory ti me requirements.
ffased on the above findings, this portion of the licensee's program
is acceptable.
8~
Shift Staffing and Augmentation (82205)
The numbers and types of person required to augment onshift personnel
following an emergency declaration were specified in Section 4 of the
GSEP and in Procedure BwZP 600-1,
11 Prioritized Call .Listing for Staff
.* Augmentation.
11
Augmentation provisions met the criteria in Table 8-1
of NUREG-0654, Revision 1.
The procedure identified.adequate numbers
of currently trained personnel for each position in the onsite emergency
organization (Station Group).
The procedure also specified which director,
technical staff, and support positions must respond to the Station for
each of the four emergency classes.
For staff and support level positions,
the numbers of emergency responders varied somewhat depending on which
class of emergency had been declared.
Persons identified in the call
out procedure were prioritized by their estimated travel times from
their residences to the Station.
The GSEP Coordinator was responsible
for updating the call out procedure on a quarterly basis.
The licensee has conducted semiannual, off-hours drills to demonstrate
the capability of the Station Group to adequately augment onshift personnel
in a timely manner.
The licensee conducted an unsuccessful augmentation
drill on March 10 and a successful drill on March 11, 1987.
The first
drill was considered unsuccessful since one call list supervisor had to
be prompted on what to do when another call list supervisor could not be
reached to assist him in making the notification calls.
Records of both
drills were complete and adequately detailed.
11
. "
The licensee's* corporate emergency planning staff has been responsible
for maintaining the
11GSEP Telephone Directory," which identified adequate
numbers of persons for specific positions in the offsite emergency
organization.
Primary and alternate response personnel were identified
for each of the licensee's nuclear generating stations.
The directory
has been updated quarterly.
Based on the above findings, this portion of the licensee's program
is acceptable.
9.
Exit Interview
On August 7, 1987, the *inspectors met,. with. those licensee-. representatives
denoted in Paragraph I.to present their preliminary findings.
The
licensee indicated that none of the items discussed were proprietary
in nature.
12.