ML17278A229

Insp Rept 50-397/85-11 on 850415-26.Violations Noted: Controls for Measuring & Test Equipment Program Not Implemented,Lack of Mgt Oversight of Onsite QA Surveillance Program & Deviations from Ltr of Tech Specs

ML17278A229
Person / Time
Site:	Columbia
Issue date:	06/03/1985
From:	Burdoin J, Crews J, Ivey K, Andrea Johnson, Johnson P, Kanow L, Sherman C, Toth A, Thomas Young NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML17278A227	List: ML17278A226 ML17278A228 ML17278A229
References
50-397-85-11, NUDOCS 8506240243
Download: ML17278A229 (70)

See also: IR 05000397/1985011

Text

U. S.

NUCLEAR REGULATORY COMMISSION

REGION V

Report No.

50-397/85-11

Docket No.

50-397

,.

'

License

No.

NPF-21

I

Licensee:

Washington Public Powe~ Supply System

P. 0., Box 968

'Richland,

Washington.99352

Facility Name:

'NP-2

Inspection at:

WNP-2, Benton County, Washington

Inspection conducted:

April 15-26;

1985

Inspectors:

T. Young, Jr.,

'ef,

E

(Team Leader)

ring Section

Date Signed

A.

Johnson

Enforc

e

Offic

J

.

w

Se

r'Re

ngi eer

F.

Bu

oin, Reactor Inspector

. D. Ivey Jr.

a to

n

ector

Kanow, Reac

r Spec li

A. Toth, Senior

R sident

s

ctor

C. I. Sherman,

Radiation Speci

ist

W-ar-4's

Date Signed

<-af- 2@-

Date Signed

s-zE.-K

Date Signed

Date Signed

s -za-Q

Date Signed

8-$<

Date Signed

8-AE'-6

Date Signed

Approved By:

T. Young, Jr., Chief, Engin

in

Section

Date Signed

P.

H. Johnson,

Chic

Reactor Projects

Se

ion 3

Da

e

igned

gg()603

AQOCl

pDR

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~Summa r

Ins ection durin

the

eriod of A ril 15-26

1985

(Re ort No. 50-397/85-11)

Areas Ins ected:

A special,

unannounced

team inspection of maintenance,

measuring

and test equipment

(MME), surveillance testing, quality assurance

activities, onsite/offsite

committee activities,

employee training, health

physics waste programs, plant procedures,

design

changes

and modifications,

and vendor field and technical

manual

change notices.

The team's

approach

was to direct 60 percent of its effort on administrative

controls associated

with the emergency

DGs, the .HPSI" and 'RHR systems

and the

implementation

and adherence

of those controls in the following areas:

MME

Calibration Program;

Maintenance

Program; Surveillance

Program;

Vendor Field

Change Notices;

and Design Changes

and Modifications.

The other 40 percent of

the team's effort was on administrative controls'i'n,the following important

areas:

onsite/offsite

committee activities; quality, assurance

audits (onsite

and offsite); licensed/non-licensed

operator train'ing

plant-operations;

health physics solid waste program; health physics liquids and liquids waste

program;

and health physics

gaseous

waste

system'.

1,

u

The team's strategy

used for thi's'nspection

required the selection of a

sample of MNP-2 administrative'ontrols

associated

with four important

safety-related

systems

(HPSI,

RHR, Emergency 'DGs,

and Station 3atte'ries)

of

. the plant for vigorous examination.

The sample

was representative

of all

management

controls, testing,

methodology

and documentation of all

safey-related

administrative controls a't the WNP-2 Nuclear Power Plant.

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inspection involved 622 hours0.0072 days <br />0.173 hours <br />0.00103 weeks <br />2.36671e-4 months <br />'by 'eight NRC inspectors;

)J

Results:

Of the areas

inspected',

four -violations of NRC requirements

were

identified.

The major weaknesses

identified were,

(1) controls'or the MME

program were not being implemented;

(2) there

was .a,lack of management

oversight of the onsite

QA surveillance program;

(3)'-decisions

were made to

deviate

from the letter of the technical specifications;

(4) storage

retrievability and identification of Class

1 battery records

were inadequate.

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DETAILS

Persons

Contacted

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+J.

+R.

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+="J.

+G.

+-M.

+R.

+L.

+J.

+C.

+R.

+p.

+D,

+K.

+W.

+J.

+M.

+V.

+B.

+B.

E.

+J.

0.

R.

V.

T.

H.

W.

R.

D.

A.

L.

T.

+D.

M.

W.

R.

F.

T.

A.

A.

J.

J.

J.

D.

J.

A.

Shannon,

Deputy Managing Director

Martin, Power Generations Director

Glasscock,

Director, Licensing and Assurance

Powers, Plant Manager

Baker, Assistant Plant Manager

Peters,

Administration Manager

Bouchey, Director, Support Services

Monopoli, Manager,

Operational

Assurance

Programs

Stickney,

Manager,

Technical Training

Harrold, Assistant Director, Technical Generation Engineering

Burn, Director, Technology

McGilton, Manager,

Nuclear Safety Assurance

Group

Corcoran,

Operations

Manager

Powell, Manager, Plant Iicensing

Koenigs, Electrical Engineer

Cowan, Technical Manager

Chin, Bonneville Power Administration Representative

Parry, Senior Health Physics

Etchamendy,

Manager,

Corporate Contracts

Shockley,

Support Supervisor,

Health Physics/Chemistry

Fitch, Washington State Energy Facility Site Evaluator Counsel

Twitty, Secreatry

to Corporate Nuclear Safety Review Board

Debattista,

equality Assurance

Engineer

Harmon,

ISC Supervisor

Dodson,

Standards

Laboratory Supervisor

Barbee,

Plant Engineer Supervisor

Behl, MME Tool Crib Storekeeper

Wyrick, Plant Engineer

Hansen,

Foreman,

Health Physics

and Chemistry Laboratory

Davison, Electric System Supervisor,

Plant Engineering

I,emon, Electrical Engineer

Kidder, Mechanical

System Supervisor,

Plant Engineering

Warren, Engineer

Dodson, Materials Engineer

Eldhart, Maintenance Engineer

Feldman, Plant equality Assurance

Manager

Bartlett, (}uality Control Supervisor

Jensen,

Administrative Specialist

Patrick, Administrative Supervisor

Walton, Principal Maintenance

Engineer

Houchins,

Manager, Audits

Ogletree,

Manager of Training'Development"

Gorlick, Training Specialist,

Johnson,

Supervisor of Crafts

Wyrick, Senior Training Engineer

Little, Planning Scheduling

Supervisor'nderson,

Mechanical Supervisor

'assey,

Electrical Supervisor

Kugler, Technical Manager,

Generation Engineering,

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C. Foley,

Manager Alternate, Engineering Administration, Generation

Engineering

N. Porter, Electrical/Instrumentation

Manager,

Generation Engineering

G. Kozlik, Shift Manager

(SRO)

M. Mann, Control Room Supervisor

(SRO)

'F. Zrisch, Operations

Engineer

M. Wuerstefeld,

Reactor Engineering Supervisor

J. Parry, Principle Health Phyhsicist, Radiological Programs

+R. Greybeal,

Health Physics/Chemistry

Manager

R. Schockley,

Health Physics/Chemistry

Support Supervisor

D. Carson,

Manager, Radiological Programs

A. Davis, Senior Radiochemist

R. Hintz, Senior Health Physicist

L. Mayne, Radiochemist

J.

Thomas,

Chemical Process

Engineer

F. Walton, Principle Maintenance

Engineer

R. Conseriere,

Shift Manager

W. Schaeffer, Shift Manager

D. Ottley, Radiological Services

Supervisor

D. Beecher,

Chemistry Foreman

D. Kerlee, Principal Engineer/Lead Auditor

In addition to the individuals identified above,

the inspectors

met and

held discussions

with other members of the licensee's

and contractors

staff.

"-Denotes those individuals attending the exit interview on April 19,

1985.

+Denotes

those individuals attending the-exit interview on April 26,

1985.

Onsite/Offsite/

Committee Activities

The purpose of this portion of 'the inspection,was

'to verify that the

onsite

and the offsite safety revi'ew committees'r,their'equivalents

have

been established

and are functioning in conformance with'echnical

Specification requirements

and commitments in the application.

a.

Nuclear Safet

Assurance

Grou

(NSAG)i

The NSAG is responsible for performing indepen'dent'eview

of plant

activities including maintenance,

modifications, operational

problems,

operational analysis

and to aid in the establishment

of

programmatic requirements, for plant activities.

For this inspection

the following documents

were reviewed:

Administrative Procedures

on NSAG Activities

Functional Manual for Nuclear Operation

NSAG Manual

Fact Sheets

on Each

NSAG Member

NSAG Monthly Reports

(October

1984 through March 1985)

NSAG Assessment

of Training Practices

on Changes

(Procedures,

Modifications and LERs)

NSAG Assessment

of Logkeeping Practices

Audit No.84-301

gA Audit of NSAG

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The NSAG is composed of five degree'd, full ctime,'edicated

engineers

located at the VNP-2 site.

Internal 'reports>,(NCRs,

Scrams

and

LERs

etc.)

and external reports

(NRC,

INPO,

GE etc.) are reviewed"by

NSAG

or screened

by the

NSAG Manager.

These reports"are

assigned

an

identification number

and tracked by the computerized

Action~

Tracking System.

Corrective actions, if required,'re

entered into

the Plant Tracking Log (PTL).

'Plant significant events

are being

investigated

and reported

on by the

NSAG.

A review of two of these

reports,

"NSAG Assessments

of Training Practices

on'hanges

and

Logkeeping" revealed that the reports

are very well written.

The

investigations

appear to-be comprehensive,

with a well defined

problem,

a complete description of the event causing the problem and

detailed

recommendations

for corrective actions.

The inspectors

found no full policy statement at the corporate level

on NSAG and no engineers

at the corporate

home office serving on

NSAG.

b.

Plant 0 erations

Committee

(POC)

The

POC is the onsite review-group required by Technical Specification (TS) 6.5.1.

POC guidance

and responsibilities

are

contained in Administrative Procedure

1.1.5,

and the TS.

The plant

administrative

manager is the permanent

secretary to the

POC and

maintains all of POC records.

The minutes of all meeting"held since

January

1,

1985

(12 meetings),

were examined by the inspectors.

The

committee is very active and appears

to be meeting all of its

responsibilities.

C.

Cor orate Nuclear Safet

Review Board

(CNSRB)

The

CNSRB is the offsite review group required by TS 6.5.2.

The

CNSRB guidance

and responsibilities

are contained in the Functional

Manual for Nuclear Operation,

Procedure

NOS-6 (Corporate Policy

Statement),

CNSRB Instruction No.

3 and the TS.

The inspector

examined

the minutes of all meetings

held since January

1,

1984

(four scheduled

meetings

to meet the

TS requirements

and several

special meetings),

to determine if the

CNSRB was meeting all of its

responsibilities.'he

wording of CNSRB Instruction No.

3 reads

as follows:

"The

CNSRB shall review:

The safety evaluations for (a) changes

to procedures,

equipment

'or systems

and (b) tests

or experiments

completed

under the

provision of 10 CFR 50.59 to verify that such actions did not

constitute

an unreviewed safety question."

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(1) Procedure

Changes:

Members are sent listings of procedure

changes

and deviations normally in the form of POC

minutes. If any member desires

Additional information

and/or meeting discussion, it will be arranged

by the

Executive Secretary.

The Executive Secretary will review

the changes

and deviations for, unreviewed safety questions

under the criteria.of '10

CFR '50.59

and document this

review.

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(2)

Modifications.'embers',are

provided for review as to

unreviewed safety questions

cover sheets-

and safety

'valuation

sheets

for changes

to systems

or equipment

(modifications).

The Executive",,Secretary will airange for

presentations

at meetings"on'any modification requested

by

any member.

He will document his review as by ',the.

criteria of 10 CFR 50.59.

(3)

Tests

and Experiments:

., A summary and safety evaluation

report will be sent to members for their review as to

unreviewed safety questions,

except for tests

associated

with the startup

program

and operabi:lity tests

subsequent

to repair or modification of a system or equipment.

All

tests

and experiments will be open for discussion at

meetings

and any deemed significant by any member will be

discussed utilizing a technical presentation.

The

Executive Secretary will document his review as being

under the criteria of 10 CFR 50.59."

As the instructions reveal,

the full committee is not reviewing all

of the required

documents but is making sure that an independent

review is being made.

With this exception the inspectors

determined

that the

CNSRB is meeting all of its required responsibilities.

Two violations were identified in this area

(85-11-01/02).

3.

Containment Inte rit Verification (397/85-12-02)

Closed

The radiation levels in the reactor water cleanup

(RWCU) vault was

determined to be from 60 to 200 mr so that the area

above the vault

should not be considered

a high radiation area.

At least the radiation

levels should not be considered

too high, for an operator to go into for 5

or 10 minutes to verify that the valves were closed without prior

approval by the Plant Operations

Committee

and the Plant Manager.

Proposed

TS changes

were submitted

on April 25,

1985, to except the

subject valves from the general surveillance

requirement.

This item is

closed.

One violation was identified in this area

(85-11-03).

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4.

Measurin

and Test

E ui ment

(M&TE)

a

~

Pro

ram Review

The quality assurance

program for the Control of Measuring

and Test

Equipment

(M&TE) is described in Section

12 of the

VPPSS Operational

equality Assurance

Pxogram Description Manual and Section 6.5 of

Nuclear Operation Standard

(NOS) No.

4 in the

MPPSS Functional

Manual for Nuclear Operation.

The inspector

review'ed the following

procedures

in order to determine whether the licensee

had

established

a program consistent with commitments.

(1)

WPPSS Plant Procedures

Manual

(PPM)

I

Administrative Procedure

No.

1.5'.'4 Rev. 5, "Control of

Measuring

and Test Equipment

Transfer Standards"

(2)

Maintenance Administrative Procedure

No. 10.1.5 Rev. 6,

"Scheduled

Haintenance

System"

MPPSS Standards

Laboratory Instructi~ons

(SLI)

l

SLI 2-2 Rev." 5, "Haster Xhventory Record"

8

SLI 2-3 Rev.

2, "Recall Master 'Files"

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SLI 2-6 Rev. 1, "Initial.'Inspectjon~and

Calibration"

SLI 2-10 Rev. 2, "Labeling (Applying Galibration

Stickers)",

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SLI 2-12 Rev.

1, "Out of Tolerance Reporting"

SLI 2-21 Rev.

0, "Records

Management"

In addition to the above procedures,

the inspector also reviewed

individual procedures pertaining to the calibration of crimpers,

Class

1, pressure

gauges,

colorimeters,

hydrometers,

and others.

The

inspector also discussed

the program with supervisors

responsible

for the various requirements

of the procedures.

Calibration is accomplished

through three methods at the

MNP-2 site.

M&TE is sent offsite to a Standards

Laboratory which is

located'n

the Plant Support Center.

Most of the

M&TE is calibrated at

the lab itself but some items are sent to evaluated

suppliers

to be calibrated.

In either case

the

M&TE is checked and/or

calibrated before return to the plant by the Standards

Laboratory.

Operation of the Standards

Laboratory is governed

by Standards

Lab Instructions

(SLI).

H&TE such

as torque wrenches,

calipers,

micrometers,

and dial

indicators are calibrated onsite by plant personnel.

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calibration is controlled by PPM 1.5.4, "Control of MSTE", and

performed in accordance

with the appendices

to that procedure.

M&TE such

as hydrometers,

crimpers,

pressure

gauges,

and others

are calibrated by Chemistry Lab and Instrumentation

and Control

(ISC) personnel in accordance

with procedures

in the Plant

Procedures

Manual.

These calibrations

and their frequencies

are controlled by PPM 10.1.5,

"Scheduled

Maintenance

System."

The inspector

concluded that the licensee's

gA program for MME has

provisions that include:

assignment

of responsibilities

to assure calibration and

control of MME,

criteria and responsibility for assignment

of calibration

frequency,

requirements

for labeling MME with the latest calibration

status

and due date,

an equipment inventory matrix which includes all MME used

on

safety-related

systems,

a system to assure

that new MME are

added to the inventory

matrix and calibrated prior to being placed in service,

a system to assure

that MME are recalled

and calibrated before

the calibration period has expired,

controls to preclude inadvertent

use of MME for which the

calibration period has expired,

controls assuring

the acceptability of items previously tested

or measured

using out-of-calibration MME and evaluation of the

cause of out-of-calibration status,

and

requirements

that calibrations

be performed in accordance

with

procedures,

manufacturer's

specifications',

or written

instructions.

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The program appears

to be adequate

to ensure that MME calibrated

and controlled in accordance

with requirements.

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The inspector

reviewed MME records to assure that ecjuipment usage

was propert

documented;

calibration records

were being maintained;

and the calibration and usage

program's

were'being controlled in

accordance

with procedures.

The inspector'". also'dis'cus'sed

procedural

requirements

for the control of MME with personnel

responsible for

the implementation of the requirements

and maintenance

of, the

records;

including:

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storage of MRTE and records

check-out procedures

(Test Equipment Log)

daily usage

records

standards

laboratory records

and reports

in-plant, calibration and records,

and

out-of-calibration analyses

(Deficiency Reports)

The inspector

reviewed plant gA surveillance reports

and corporate

gA audits to determine

the types of problems that the licensee

had

experienced

and what the corrective actions

were.

The inspector

also discussed

the findings of these reports with cognizant

gA

personnel.

The inspector performed visual inspections

of HGTE in use throughout

the plant to assure

that calibrated

equipment

was being used.

These

inspections

included

HSTE:

stoxed in the tool crib

used in the Standards

Laboratory

used in the Health Physics

and Chemistry Laboratory

used in the various Maintenance

Shops,

and

in use in various other areas

of the plant

No cases of non-calibrated

equipment being used were identified.

Control of MME is defined by Administrative Procedure

1.5.4,

"Control of Heasuring

and Test Equipment -,Transfer Standards."

This procedures

sets forth the requirements'nd

responsibilities for

control of the usage,

storage,

records,

and,calibration of MME.

A tool crib has

been establishedfor the'torage'f all HSrTE.

This

tool crib is controlled by, a storekeeper'wh6

distributes

and

collects

HSTE as it is needed

by plant personnel.

A Test equipment

Log and

a calibration record is maintaineg'n the,tool'icxib files

for each piece of MGTE to establish

equipment status'.

" Tiie Test

Equipment Log must be filled out each time,a piece of HGTE.is

checked out of the tool crib.

HRTE must, subsequently

be checked in

on the Test Equipment Log upon return to t!he tool crib;= 'Daily Usage

Records

are used to keep

an account of the work performed with a

piece of MME.

A Daily Usage Record is, filled out each" time

a piece

of MME is used to perform

a procedure,

test,

or work request.

These

records

are collected

and reviewed by Plant Engineering for

use of out-of-calibration MME and t'o perform analyses

on data in

the event

an out-of-calibration condition is identified.

From the review of records, visual inspections,

and personnel

discussions,

the inspectox

found the following in relation to the

control of ATE that are contrary to the requirements

outlined in

PPH 1.5,4.

While inspecting

contaminated

MME stored

on the 525 level of

the Radwaste Building, the inspector noticed the following

overdue-for-calibration test

guages

being stored together with

calibrated

equipment:

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Calibration Due Date

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32048

1/29/85

'-

'002390

,

8/20/84

C002414

4/12/85

C004247

3/07/85

C004271

4/07/85

AP 1.5.4 Section 6.E.2 states,

"A quarantine

locker shall be

used for all test equipment

removed

from service or awaiting

calibration."

A quarantine

locker has been established

in the

tool crib and is being used in accordance

with this

requirement.

However, the Radwaste Building storage

area

has

no quarantine

locker and equipment storage is commingled. It

is possible that overdue-for-calibration, equipment

could be

used to perform tests.

While reviewing the overdue-for-calibration report, which is

compiled

and distributed by the Standards

Laboratory,

and

associated

MME records,

the inspector noted that the following

equipment,

which were not checked

out on the Test Equipment

Logs, were missing from the tool crib.

Hone

ell Visicorder Plu -ins

E~No.

Cal Due Date

PTC Thermometers

EQ No.

Cal Due Date

C001795

4>153

C001801

C001803

41156

39260

C001796

C001799

C001802

C001808

C001809

C001811

ll/24/83

5/01/84

, 5/01/84

5/01/84

11/10/84

11/24/84

11/24/84

11/24/84

11/24/84

11/24/84

11/24/84

11/24/84

35210

35212

35215

40359

40360

40851

41166

41168

2/17/85

2/17/85

2/17/85

2/17/85

2/17/85

2/17/85

2/17/85

2/17/85

None of the items listed above could be located in the plant.

Plant personnel believe the Visicorder plug-ins to have been

shipped

back to the vendor with the visicorder frame.

They

also believe the

PTC Thermometers

to be stolen.

AP 1.5.4

Section G.E.1 states,

"When not checked out,

MME shall be

maintained

under controlled storage conditions."

The fact that

equipment is missing

and cannot

be found raises

doubt as to the

adequacy of the control of the storage

area (tool crib).

During the course of the inspection,

the inspector

noted

specific instances

of deficient lKTE control in the use of IRD

820 Vibration Monitors.

Monitor No.

38131

was signed in on the

Test Equipment Log in the tool crib on March 13,

1985,

and has

not been signed out since.

This monitor was subsequently

sent

to the Standards

Iab for calibration and returned to the

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mechanical

shop

on April 14,

1985, without documentation

to

prove its calibration date.

Whereupon, it was pressed

into

service again without a Test Equipment 'Log or Daily Usage

Records being maintained.",.These

actions

were taken, by

personnel

other than the tool crib'storekeeper

who has the

responsibility for shipments

to the tool crib for calibration.

Monitor No. 40928 is'ontinuously signed out to the control

room.

During the last period of check-out,

the monitor was

sent to the Standards

L'ab for'calibration.

On April 19,

1985,

the monitor was returned

from, the Standards

Lab to .the,

mechanical

shop where it was'put into use.

One Foreman stated

to the inspector that no,documeritation

was returne'd with the

instrument

and that the mechanical

shop

does not maintain

a

Test Equipment Log or Daily,'Usage, Records.

This'onitor is

signed out, stored in the control ..room,. and used by the

operating

crew for surveillance testing.

sf

AP 1.5.4 Section 6.E.3 states,

"A Test Equipment Log shall be

provided at the

M&TE tool cribs for use in. checking out or in

M&TE."

Section 6.F.l states,

"A M&TE Daily Usage Record shall

be provided at the

M&TE tool cribs with each piece of M&TE as

it is checked out for personnel

to complete during usage

each

day.

When an individual will no longer need the

M&TE (NOT TO

EXCEED FIVE CALENDAR DAYS) or at the end of each day, the

completed

record is returned with the

M&TE to its storage

site."

Without a Test Equipment

Log and Daily Usage Records,

there is no record of where the instruments

were used.

The problems with Test Equipment I,ogs and Daily Usage Records

were not limited to the previously mentioned

cases.

In at

least

31 other cases

there were no Test Equipment Log entries

for instances

when Daily Usage Records

were completed (i.e.,

equipment

was used without being checked out).

In twelve other

cases

there were no Daily Usage

Records

on file for equipment

that was checked out on Test Equipment Logs (i.e., equipment

was checked

out and possibly'sed

without a record of the use).

Problems with the control of M&TE and .records

were identified

in four Plant

(}A Surveillance Reports

over the past nine

months.

Surveillance Report No. 2-85-018 identified 27 ca'ses

where Daily Usage Records

were inadequately

completed.

Surveillance Report No. 2-84-269 identified an instance

where

a

piece of M&TE was used by various personnel

during issuance

to

only one of those personnel (i.e., incomplete Test Equipment

I,og).

Surveillance Report No. 2-84-227 identified twelve

instances

where

M&TE was used without either

a Test Equipment,

Log Entry or Daily Usage Records.

Surveillance Report No.

2-84-187 identified thirteen instances

where Test Equipment

Logs and Daily Usage Records

were not completed properly.

The

corrective action taken in all four cases

was to give training

sessions

to personnel.

In one instance

(No. 2-84-227),

AP 1.54

was revised for clarification (Rev. 5).

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From the review of the above mentioned onsite

(}A surveillance

reports, it is clear that management

had previous

knowledge of

the MME programmatic

breakdown.

But, due to the lack of

proper management

oversite of the surveillances

and the

corrective actions performed because

of their findings, the

breakdown

was not recognized.

5.

Surveillances

The inspector

concluded that MME is not being controlled in

accordance

with the approved procedure

(PPM 1.54).

Even though

no instances

were found of equipment being used while

out-of-calibration, the lack of control could eventually lead

to this occurrence.

The Test Equipment Logs and Daily Usage

Records

are the basis for implementing storage

and usage

controls for MME.

Likewise, they provide the basis for the

Plant Engineering Reviews for out-of-calibration conditions.

Continuing inconsistencies

and inaccurate

records

could lead to

incorrect analyses

and result in equipment being used while

out-of-calibration.

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One violation was identified in 'this area

(85-11-04).

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The licensee's

surveillance 'programs

for",the station batteries,

emergency

diesel generators,

RHR system'and

HPCS system

were examined;

by examining

the following surveillance'pr'ocedur'es'nd

comparing. them .with 'appropriate

section of the plant technical specifi,cation

as identified below:

Station Batteries

7.4.8.2.1.20

7.4.8.2.1.21

7.4.8.2.1.22

7.4.8.2.1.23

7.4.8.2.1.24

7.4.8.2.1.12

7.4.8.2.1.16

A

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Weekly Battery, Testing (for eight batteries)

quarterly Battery Testing

(24V batteries)

quarterly Battery Testing

(125V Div. 1/2 batteries)

quarterly Battery Testing

(125V Div. 3 battery)

quarterly Battery Testing

(250V battery) "

Eighteen Month Battery Testing

(E-BO-lA)

Eighteen Month Battery Testing (E-Bl-1)

Plant Technical Specification section 3/4-8, Electrical Power Systems.

Diesel Generators

7.4.8.1.1.2.1

Monthly Operability Testing,

D-G one

7.4.8.1.1.2.6

HPCS Diesel Generator

Power Test

7.4.8.1.1.2.3

quarterly Removal of Water from the D-G, Fuel Storage

Tanks.

Plant Technical Specification Section 3/4-8, Electrical Power Systems.

RHR S stem

7.4.6.2.2,1

RHR System Valve Position Verification

7.4.5.1.8

RHR Loop A Operability Test

11

hh

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7.4.5.1.9

RHR Loop B Operability Test

7.4.5.1.10

MfR Ioop

C Operability Test

Plant Technical Specifications

Section 3/4-5, Emergency

Core Cooling

Systems

and Section 3/4-6, Containment

Systems.

7.4.5.1.6

HPCS,Valve Lineup

7.4.5.1.11

HPCS System Operability Test

Plant Technical Specifications

Section 3/4-5, Emergency

Core Cooling

Systems.

The effectiveness

of the program was evaluated

by examining frequency

and

thoroughness

of samples of the above surveillances

performed during the

past year. It is concluded that the surveillance

program appears

to be

adequate

and to function as planned.

No violations or deviations

were identified.

Maintenance

The licensee's

maintenance

program

was examined by reviewing the

following maintenance

procedures

which describe

both the corrective

and

preventive maintenance

programs.

1.3.7

'10.1.5

10.1.6

10.25.5

10.25.18

'aintenance

Work Request

(MWR)

Scheduled

Maintenance

System

Corrective Maintenance

Program

Station Battery Maintenance

and Load Test

Setting

DSH and

DSL Cards

on

PCP Battery Charger

The licensee's

computer

system,

the Power Plant Information Control

System

(PPICS)

as used in the maintenance

program was examined.

The

corrective maintenance

program which utilizes the

MWR program

was

reviewed.

The following MWRs completed during the past year for

performing corrective maintenance

on the station batteries,

emergency

diesel generators,

and the

RHR pump were. examined to determine

the

effectiveness

of the corrective maintenance

program.

Batteries

Diesel Generators

2-DG-ENG-lA1

2"DG-ENG-1A2

2-DG-ENG-1B2

2-DG-ENG-1C

MWR'

MWR'

MWR'

MWR'

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AY-1530,,AX-6062, fQ'.-6065

AY-1530,'X-6062,~'AX-6065

AY-15-30', PX-6063,

AX-,6059

AY-1822) AY-1824," AX-7267

HPSC-Bl-DG3

MWR's AX-8604, AY-3749, AW-6871 and AW-6873

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and AX-1237

and AX-,,1238-

'and AX-.1238

and AX-1242

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2-RHR-P-2A

MWR's AY-0518, AY-1613, AY-6117, AX-7591, AX-8604, AY-3749

2-RHR-P-2B

MWR's AX"8604, AY"4899, AY-3755

2-RHR-P-2C

MWR's AY-3749

The computer master

equipment list and the Scheduled

Maintenance

System

(SMS) program which typify the control and functionability of the

preventive maintenance

program were examined.

The review of Procedure

1.3.7, Maintenance

Work Request,

requires

the

plant gC Supervisor/Designee

to review

MWRs to determine

the requirements

for (}C inspections

and to review each work process for establishing

any

necessary

QC hold points.

However, it appears

as though the selection of

requiring

QC inspections of MWRs is conducted

on a random basis.

This

may be an area of weakness.

To this end the inspector

reviewing the gA/gC participation in plant

maintenance

of plant equipment by examining the following (}C inspection

reports:

84-024

84-057

84-061

84-085

84-156

MWR AY-1566,

RHR Pump No.

3

MWR AY-2954, D-G, Gen.

C

MWR AY-2959, D-G, Engine

1B2

MWR AY-2961, D-G, Gen.

1A&lB

MWR AY-5285,

RHR Valves

130AR241

The inspector also

examined

the gA/(}C procedure

PgA-03, Plant

Surveillance Activities and the following. gA surveillance reports.

2-83-70

Testing

and Startup of Standby

D-G Division, II

2-83-180

Replacement

of Divisions'

and

2 Batteries

and Racks ',

2-84-218

D-G-GEN-IB, Repair, Installation and

Testing'-85-046

Diesel Fuel Testing,

It is concluded that the licensee's

maintenance

program appears

to be

adequate

and the administrative controls for the program, function

properly.

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No violations or deviations

were identified.

Station Batteries

The installation of the eight Class

1 station batteries in the battery

rooms were inspected;

and the performance test results,

receiving

inspections,

maintenance

and miscellaneous

other records for the

batteries

were examined to determine their operability.

The battery

rooms were found to be clean

and orderly,

and the installation of the

batteries

and battery racks

appeared

to be thorough

and complete.

The following battery records for the eight Class

1 station batteries

were requested

by the inspector for examination during Tuesday/Wednesday

of the first week of the inspection:

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Receiving documentation.

ff

b.

Manufacture certifications.,

Manufacture's

performance test data.

'eekly

maintenance

records.

quarterly maintenance

records.

Startup/lineup tests report/results.'"

g.

Pre-Operational

test report/results.

The licensee

produced

the records piece-meal

over the two week inspection

period with the quarterly maintenance

records for Divisions,

1 and 2,

125V

batteries

'being delivered for examination,

the morning of the scheduled

exit meeting, April 26.

Also the licensee failed to produce'for

examination the manufacture's

capacity test data period and the weekly

maintenance

test records

(July 1983,

September

'l983) for Divi,sions

1 and

2 125V batteries.

The files of battery records presented

to the inspector for examination

were intermixed with numerous

other miscellaneous

battery records.

It

required several

hours by licensee

personnel

to sort out and identify the

proper records

requested

by the inspector before the examination of these

records

could commence.

The inspector noted that the records

were in

transition between construction

and operations for central storage.

Startup/Lineup test results

and pre-operational test results

were

produced for all eight, Class

1 station batteries.

The pre-operational

test included a,battery capacity test

and load profile test except in the

case of 24V batteries.

From these test results,

the operability of the

batteries

was determined.

The

18 month technical specification

surveillance to demonstrate

battery operability is scheduled

to be

performed

on the eight Class

1 station batteries

during the plant M-3

maintenance

shutdown scheduled for May/June

1985.

No violations or deviations

were identified.

Licensee

Pro

ram for Action on 0 erational Event Re orts

The inspector

examined the administrative controls for review and action

on reports of equipment malfunctions at other nuclear facilities.

Such

reports

included

NRC Bulletins and Information Notices,

INPO event

reports,

and manufacturer notifications of hardware deficiencies.

The

inspector

examined the review and action records associated

with 10

Information Notices,

5 Bulletins,

and 22 unresolved

actions associated

with event reports for the residual heat removal, high pressure

core

spray,

and diesel generator

systems, for the 1975 through

1985 period.

The inspector also

examined three vendor certified information manual

files at the plant, which are used by maintenance

personnel for repair

activities, to ascertain

incorporation of information relative to

hardware

changes

resulting from the event report corrective actions.

The Supply System reviews are conducted

by the onsite Nuclear Safety

Assurance

Group

(NSAG), staffed by five engineers

in accordance

with

technical specifications.

Action on the

NSAG recommendations

was

assigned

to the plant Technology Department,

or to other parts of the

organization

as appropriate.

The files were found to be orderly and

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retrievable via subject with similar items grouped to facilitate

correlation of similar issues.

A tracking system

was maintained to

reflect the status of review and corr'ective'actions.

'Of the 22

unresolved

items,

the

NSAG files indicated significant progress in

definition and implementation of most>

and the, unresolved

status

appeared

to be due to delayed

feedback of closure information'to the

NSAG.

Backlogs of reviews were acceptable,'"and

the backlog of action 'completion

by the plant staff appeared

reasonable

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Interview of records staff and inspection of vendor certified information

files (relative

NRC Bulletins 8-16 and 80-.'09)'ndicated

that information

was not included in these

maintenance

referen'ces

xe'lative'to specific

changes in hardware or hardware components.'s

example,'he'iles

did

not alert personnel that Rosemont

Model -1151/1152,pressure

transmitters

required

Code "E" components

to prevent overranging problems,

nor~that

Hydramotor Actuators required special spring material for some

applications. 's

a result

a February, 1985 revision to the. NSAG

procedures

now calls for consideration of the vendor manual file when

conducting

a review of event reports.

No action had been taken to assure

that relevant information from prior reviews is incorporated into the

applicable vendor file.

The need for such information is variable

and

peculiar'o

each specific event report and its associated

corrective

action (e.g., deletion from the qualified equipment list and total

replacements

may or may not void the need to supplement

a file).

The

Operational (}uality Assurance

Manager committed to a review of the NSAG

event report files to ascertain if any of the items merit backfit of the

vendor files (85-11-05).

No violations or deviations

were identified.

Desi n Chan

es

and Modifications

The inspector interviewed personnel

and examined the Supply System

procedures

and instructions for contxol of design

changes

and

modifications, including the applicable

corporate policy statements

(NOS-23), Plant Procedures,

and Technology Directorate

(engineering

department)

procedures.

The inspector

examined

16 "Open" and ll "Closed"

Plant Modifications Records

(PMRs)

and associated

Design

Change

Packages

(DCPs), associated

with principal safety-related

systems

(residual heat

removal, high pressure

core spray,

and diesel generators)

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The procedures

were found to establish

contxol of design

change

requests,

responsibilities

and methods of design

and design verification,

responsibilities

and methods of design

document control, responsibilities

and controls for incorporation of design

changes

into plant procedures,

drawings,

and operator training programs,

10 CFR 50.59 evaluations.

The

PMR and

1ÃR review found evidence of design verification, definition

of installation and test requirements,

training/procedures/drawings

change evaluations,

10 CFR 50.59 reviews,

and general

completeness

of

records.

Additionally, the inspector

reviewed

150 maintenance

work

requests

in the work queue of the instrument, electrical,

and mechanical

shops,

to identify those originating from PMRs and to assess

quality

contxol and testing requirements

prescribed

by associated

PHRs.

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The following observations

were noted

as

a result of the above reviews:

a

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Definition of Testin

Re uirements

b.

The corporate policy NOS-23 assigned

responsibility to the Site

Engineering

Manager

(Technology Directorate) for specification of

testing requirements in the DCP.

The DCP is incorporated into the

PMR and an implementing Maintenance

Work Requests

(MWRs) prepared

by

the Plant Technology Department.

The Technology Directorate

Procedure

TI-2.1 requires

the design engineer to specify testing

~requirements

as appropriate,

and records

show that these

have been

defined in general

form, and implemented by the Plant Technology

system engineers

during preparation

of.,the MWRs.

However, neither

the Technology Directorate nor the Plant Technology Department

procedures

have provided guidance to the engineers

to implement

certain Operational

equality Assurance

Program Description Section

.11

"Test Control" requirements, i.e., to incorporate or reference

Test

Prerequisites,

Acceptance/Rejection

Criteria,

and Responsibilities

for Evaluation of Test Data~.

'Furthermore,

although Plant

Procedure

1.2.2 includes

a matrix of minimum"content for various

types of procedures, it omits, the above aspects

as applf.cable to

test procedures.

This'mission

was reflected in some'WRs,

which

included only abbreviated test requirements,

where testing

was

required in addition to" that, specified by more thorough permanent

plant operability ver'ification procedures.

No significant

deficiencies

were noted in the

MWRs in this regard,

however,

the

absence

of instructions in this 'area

appears

to be

a weakness in the

administrative controls of,"special testing'associated

with design

changes.

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The Administrative Manager, committed to Supply System evaluation of

the test procedure preparation'instructions

with respect

to the

quality assurance

program requirements

(85-11-06).

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Prioritization of (}ualit Control Ins ection Activities

Neither the design engineers

(in preparation of the DCPs) nor the

system engineers

(in preparation of the

MWRs) specify quality

control inspection hold points or other inspection requirements.

The quality control organization

reviews

MWRs and establishes

hold

points based

upon their own review.

The

MWR records

showed that the

inspection staff tended to invoke inspections

and hold points where

prestablished

inspection checklists already existed,

and tended to

not become involved in other activities,

some of which appeared

to

have high safety significance.

The inspector cited

MWRs AW-0926 and

0934

as

examples of work on safety-related

diesel generator

bearings

and

speed control logic, where inspection/verification activities

might be warranted.

Also noted

was planned additional work on

voltage adjustment potentionmeters,

where inadequacies

in control of

prior maintenance

work had resulted in NRC enforcement actions.

The plant equality Assurance

Manager noted that quality assurance

department staff were being given additional systems

related

technical training, which should help sensitize

them to the level of

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significance of work activities subject to inspection.

He committed

to management

review of quality assurance

staff performance in this

area

(85-11-07).

c.

Co

orate Review of Plant Modification Pro osals

The corporate policy procedure

(NOS-23) establishes

that any

employee

may initiate a proposed

design

change,

and that rejection

of any such proposal shall be documented with return to the

originator. It also requires that the Director of Power Generation

shall periodically review the file of rejected

PHRs.

There

was

no

documented

evidence of such

a review having been performed since the

issuance

of the procedure in March 1984, nor any files staff

recollection of such

a review.

The Director of Power Generation

stated that he had conducted

such reviews shortly after the

procedure

had been issued,

but not recently.

(The number of such

PHRs appears

to be only about

10 per year).

This appeared

to be one

example of a missed opportunity for corporate

management

to probe

into details of the plant administration.

With the consolidation of the Director of Power Generation functions

into the position of Assistant

Managing Director for Operations,

the

Deputy Managing Director stated that the policy NOS-23 would be

re-examined

to assess

whether this specific requirement

would be

retained in its present

form (85-11-08).

No violations or deviations

were identified.

10.

Gaseous

and li uid Effluent Control Pro

ram

This portion of the inspection focused

on the Technical Specification

requirements for measuring

and controlling effluent releases.

The following topical areas

were examined by review of procedures,

selective

examination of completed surveillances,

observation of work in

progress,and

discussion with licensee personnel.

The inspection focused

on activities conducted in the last quarter of 1984 and

1985 to date.

To ical Areas

Section

~Sub ect

a

b

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d

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h

3

k

Surveillance Testing Program

OBCH Imp3.ementation,

ODCH Changes

Semi-Annual Reports

Reactor"Coolant

Syst'm Chemistry

Instruments

Alarm'Set Point Calcula'tions

".

>Dose'rojection

Cal'culat:ions

Chemistry'aboratory

Audits

Radiological Environmental Jionitoring Program

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Independent Effort

IER Status

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Surveillance Testin

Pro

ram

Procedures

to implement

TS required surveillances

for radiation

monitoring instruments

and the standby

gas treatment

system were

examined.

The inspector verified that procedures

exist for each

part of TS 4.3.7

and 4.6.5.3; that selected

procedures

contain

acceptance

criteria where necessary;

that procedures

contain

adequate

guidance to return equipment to operable status;

and that

the general

degree of procedural

guidance is adequate.

Procedures

examined included:

7.1.4

7.4.3.7.1.9

7.1.1

HP/Chemistry Shift Channel

Check;

7.1.2

HP/Chemistry Daily Channel

and Source

Check;

7.1.3

HP/Chemistry Weekly Iodine, Particulate

and Tritium

Results;

HP/Chemistry Monthly Source

and Channel

Check;

Control Room Ventilation Monitor - Channel

Functional Test

(CFT);

7.4.6.5.3.1

Standby

Gas Treatment

System Operability Test;

7.4.3.7.12.5

Reactor Building Elevated Release

- Noble

Gas

Monitor - CFT;

7.4.3.7.12.6

Reactor Building Elevated Release

- Noble

Gas

Monitor - Channel, Calibrati'on.

In addition to series

7 surveillance procedures,

radiological

calibrations

are performed for effluent monitors, according to the

series

12 (chemistry procedures)'.

These'rocedures

were also

examined.

Based

on procedure

review', the inspector noted the following items.

,1

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Procedure

7.4.6.5.3.2,

which provides

foi."TS require'd flow testing

contains different acceptance, criter'ia than

TS "4.6.5.3(b)(3).

The

licensee

took immediate corrective action, by issuing

a procedure

change.

The inspector verified'hat the test

had not b'een performed

using the wrong criteria and that the system lineup test performed

during plant preoperational

testing pet the

TS required flow rate.

The source

check procedure

7.1.2"does

not contain acceptance

criteria.

The inspector noted that in one case,

the source

response

could be lower than the normal instrument

response.

The licensee

was aware of this situation and has initiated corrective action.

The TS definition of source

check does not imply quantitative

acceptance

criteria are required.

The inspector

observed portions of the daily instrument

checks

and

calibration of the liquid effluent monitor.

The inspector

observed

some technicians

were not fully knowledgeable of all radiation

monitoring system functions.

These

weaknesses

did not appear to

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t

impair the individual's abili'ty to perform chanqel

checks

and source

checks.

tl

t

This perceived

weakness

was identified to licensee

representatives.

Regarding radiological calibrations "of effluent monitors,

procedure

12.13.6,

"Reactor, Building Elevated Release Effluent

Monitor" provides for a radiologi'cal transfer calibration of this

monitor.

The procedure

incorporates linearity determinations,

adequate

acceptance

criteria, 'review of calibration data

and

.

provisions for return of the device to operational status.

Similar

procedures

exist for the other gaseous

effluent release

monitors.

Procedure

12.13.11,

"Radwaste Effluent Monitor" provides instruction

for a primary calibration as well as secondary

source calibration.

Calibration for other liquid monitors is provided in similar

procedures.

These procedures

considered with the instrument procedures

for

electronic calibration are considered

adequate

to implement the TS

calibration requirement.

No violations or deviations

were identified.

Offsite Dose Calculation Manual (ODCH)'m lementation

Technical Specification 6.8.l.i requires

a written program be

established,

implemented

and maintained for ODCH implementation.

Plant procedure

1.11.7 sets forth this program.

This procedure

defines responsibility for the following items required by TS:

alarm setpoints

on effluent monitors;

limiting liquid effluent concentrations;

liquid effluent dose calculations;

liquid radwaste

treatment

system operability;

outdoor liquid hold up tank use;

gaseous

effluent dose calculations;

ventilation exhaust

treatment operability;

total dose,

semi-annual report,

and

ODCH revisions.

Appropriate sections of TS, the

ODCH and procedures

are referenced

in procedure

1.11.7.

The inspector also

examined procedures written to implement these

program requirements.

The inspector verified that written, approved

procedures

are available to perform the surveillances

required by

technical specification:

4.11.1

Liquid Effluent;

4.11.2

Gaseous Effluents;

4.11.3

Solid Radioactive Maste.

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Procedures

examined in this area included the following:

Procedure

No.

7.4.11.1.1.1

7.4.11.1.2

7.4.11.1.1.3

7.4.11.1.3.1

7.4.11.2

7.4.11.2.1.1

7.4.11.2.1.2.2

Title

Determination of Radioactivity in Radioactive,Iiquid

Effluent Maste;

I

Cumulative, Dose Contributions

fr'om Ii'quid Effluents;

Post Release Analysis'rom Batch. Releases'-

guarterly;

I

Calculation of Dose

Due to Liquid Releases...

31 Day

Period;

Dose Calculationsfor Air Effluent

Radioisotopes'...31.

Day Dose;

Noble

Gas Particulate

and Iodine Sample Collection

and Analysis;

Monthly Gas

Grab Samples;

7.4.11.2.1.2.3

Grab

Gas

Samples Following Shutdown,

Startup

and

Thermal Power Changes;

7.4.11.3.1

Verification of Solidification, Solidification

Control and Test Specimens;

Notwithstanding exceptions

noted elsewhere in this report,

procedures

were found generally adequate

to implement

TS

requirements.

No violations or deviations

were identified.

Technical Specification 6.14.2 describes

the requirement for

reporting licensee initiated changes

to the

ODCM.

ODCM changes

made

by the licensee

and reported in the

1984 semiannual

reports

were

examined.

The inspector noted that. seven

changes

were identified in the 1984

'ffluent

reports.

Technical Specification 6.14.2.a.l,

6.14.2.a.2

and 6.14.2.a.3

states:

Sufficiently detailed information to totally support the

rationale for the change without benefit of additional or

supplemental

information.

Information submitted should consist

of a package of those

pages of the

ODCM to be changed with each

page numbered'nd

provided with an approval

and date box,

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together with appropriate

analyses

or evaluations justifying

the change(s);

2.

A determination that the change will not reduce

the accuracy or

reliability of dose calculations

or setpoint determinations;

and

3.

Documentation of the fact that the change

has been

reviewed

and

found acceptable

by the

POC.

The changes

submitted by the licensee in 1984 were corrections or

improvements

to the

ODCM.

Plant Operation

Committee

(POC) review

and approval

was described.

Supporting information was provided in

the change descriptions.

The inspector

n'oted that pages

submitted

as

changes

were numbered,

noted the amendment

number

and date but

did not contain an approval box.

W

SCN-84-97

and 84-98 changed

the ground dose factor for Sr-90 from

zero to the value for Y-90 listed in table E-6 of Regulatory

Guide 1.109.

For this change,

no accompanying

analyses-or

evaluations

were included in the submittal documenting

the

appropriateness

of using the value for, Y-90.

In addition, the

'submittals did not contain the required determina'tion,that

the

changes will, not reduce the accuracy or reliability.

The inspector

identified these matters to a licensee

representative

in a telephone

conversation

subsequent

to the. inspectio'n.

The importance of strict

adherence

to TS requirements

was discussed

at the exit'nterview.

Semi-Annual Effluent Re ort

J

Technical Specification 6.9.1.11

contains

a requirement to submit

the semi-annual

radioactive effluent release

report'60

days

'ollowing

January

1 and July

1 of each year.

Addi'.onal reporting

requirements

are also contained within that specification.

The

inspector

reviewed reports

submitted for 1984 to determine if the

reporting requirements

of TS and referenced

Regulatory

Guide 1.21,

"Measuring, Evaluating,

and Reporting Radioactivity

in...Effluents...," Revision

1 were satisfied.

The review identified one typographic error which was identified to

the licensee.

The inspector noted that calculations

are based in

large part on minimum detectable activity reporting levels.

For

example 'for 1984, only Cobalt-58,

Zinc-65, Tritium, Sodium-24,

Copper-64,

and Arsenic-76 exceeded

the

MDA for liquids.

Reported releases

based

on MDA values

accounted for at least half

the liquid activity released.

Gaseous

effluent releases

reported

for 1984 were very low, the maximum value being only 0.17 percent of

a TS limit.

The inspector

examined selected

records

used in production of the

semi-annual

reports.

Records

examined included the following for

the fourth quarter of 1984:

i P

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pp

1

IV

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'4

21

Procedure

12.11.1,

Data sheet 'la, "Effluent Gas

Sample Logs";

Computer printouts prepared

by the station radiochemist of weekly

and monthly gaseous

effluent releases;

Summary of doses

from WNP-2 gaseous

effluents (monthly);

Procedure

7.4.11.2,

attachment,

"WNP-2 Gaseous Effluent Honthly

Report";

Procedure

7.4.11

1

1 lp "Radioactive Liquid Release

Authorization".

Notwithstanding the exceptions

noted in Section

h of this paragraph,

data used for preparation of the semi-annual effluent report

calculations

was found consistent with plant effluent release

data.

Techniques

used to prepare

the semi-annual

report were discussed

with responsible

individuals and found generally acceptable.

This

inspection only considered

selective

review of input data for dose

projections

and reports

and did not attempt to validate

dose

calculation methodology.

Validations performed by the licensee

are

discussed

elsewhere in this report.

No violations or deviations

were identified.

Reactor Coolant

S stem Chemistr

The inspector

examined selected

reactor coolant system surveillances

performed to meet

TS requirements.

The review was conducted

by

verifying that hydrogen ion concentration

(ph), chloride,

conductivity and iodine dose equivalent analysis

were performed at

the required frequency from January

1,

1985 to date,

and that

parameters

were within the

TS limits.

Performance

of surveillance

procedure 7.4.11.2.1.2.3

which implements

TS requirements

to take

samples

following startups,

shutdowns

and thermal power changes

exceeding

15 percent in one hour was examined.

The inspector

verified that samples

were taken

as required for the period

January

1,

1984 to date.

The inspector noted that this procedure

did not identify the fact that samples

are required at least

once

per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for at least

seven

days unless

the dose equivalent

Iodine-131 concentration in coolant or the noble gas monitor

effluent activity has not increased

by more than

a factor of three.

The inspector pointed out to a licens'ee 'representative

that the

procedure

did not fully implement the surveillance'equirement

in

that no provision was

made to take more than one sample 'or to check

the effluent monitor or iodine concentration.,

Performance

of

chemistry surveillances,and

chemistry control" is considered

acceptable.

i"

)

No violations or deviations-vere, identified.

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f.

Instruments

Maintenance histories

and operability records

were examined for

several effluent monitors.

By review of the following documents,

the inspector

concluded that gaseous

effluent monitoring

instrumentation operability is acceptable

and that surveillances

are

performed

as required by Technical Specification.

PPM

Title

7.'1. 1

7.1.2

HP/Chemistry Shift Channel

Checks, January-

April 19,

1985.

HP/Chemistry Daily Channel

and Source

Check, February

- April 19,

1985.

7.1.4

HP/Chemistry Monthly Source

and Channel

Check,

January - April 19,

1985.

7.4.3.7.1.9

Control Room Ventilation Radiation Monitor - Channel

Functional Test,

January - April 1985.

The inspector also

examined

computer records of surveillances

performed

on several

instruments in 1984.

l

g.

Alarm Set oint Calculations

The inspector verified for selected

instruments that surveillances

required are entered in the lice'nsee's

master schedule.

L'alibration

procedures

were examined

and found acceptable

as

described in Section

1 of;this paragraph.

No violations or deviations were'identified.

Technical Specification 3.11.2.1- sets

fort'.h the requi'rement to

control the instantaneous

gaseous

effluent dose'ate.

Calculation

of alarm setpoints

to implement'his'emi'rement's

described. in the

licensee's offsite dose calculation manual

(ODCM) section 3.6.1,

"Calculation of Gaseous Effluent Monitor Alarm Se'tpoints".

This

procedure

describes

three requirements

for the calculation:

monthly isotopic analysis of effluent releases

are performed;

partitioning of releases

to the three

gaseous

effluent release

points are considered;

both skin and whole body dose alarm setpoints will be

calculated with the most limiting selected.

The inspector

examined

the licensee's

calculations

to verify proper

implementation of this requirement.

The inspector also

examined the

licensee's

methods for controlling instrument setpoints.

The

inspector

examined similar items for the liquid release point.

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Dose Pro ection Calculations

I

No violations or deviations

were

identified.'S

Implementation of TS 6.8.1

was examined by review 'of the required

procedures.

PPH 1.11.5,

"equality Assurance

Program for Effluent

Monitoring" is provided to meet the top tier pro'cedural

requirement.

Implementation of PPM 1.11;5,

step 1.11.5.3.6.d

regarding quality

control of effluent monitors states."

Independent verification of a

substantial fraction of computations

are performed by a second

individual."

Computations

required for effluent monitoring are not defined by

procedure

1.11.5.

Technical Specification 3/4.11.1

and 3/4.11.2

contain requirements

to control, calculate'and

report releases

based

upon effluent monitor readings

and sample results.

These

calculations

were examined

by the inspector.

The inspector also

examined procedures

established

to implement these calculations

as

described in section

b of this paragraph.

Calculations to implement

TS 3/4.11.1

and 3/4.11.2 are performed by

the station radiochemist using the 7.4.11 series of surveillance

procedures

and various

computer programs

developed at the station

which are run on small computers.

These calculations

are also

performed by Radiological Programs,

which is part of the support

services

organization,

at the plant support facility (PSF).

Radiological Programs

uses

NRC approved

codes

GASPAR and IADTAP to

calculate

doses to the offsite population.

The station performs

simpler calculations

using the methodology of the offsite dose

calculation manual

(ODCM).

The two techniques

produce differing

estimates

of the

same values using the

same liquid effluent data

and

slightly different initial data for noble

gas releases.

The

differences

are not significant provided the systems

used operate

properly but make it difficult to directly compare

the results.

Plant procedures

directing calculations permit the use of computer

programs

as

a substitute for hand calculations.

Review of the

procedures

involved revealed

no quality control instructions

when

computer programs

are used.

In addition,

PPM 1.11.5 provides

no

additional guidance in this regard.

NRC Regulatory Guide 4.15,

Section C.6.4 provides

guidance

on quality control when computers

are utilized.

Section 6.4 states

in part, "For computer calculations,

the input

data

should be verified by a knowledgeable individual.

All computer

programs

should be documented

and verified before initial routine

use.

The inspector attempted

to determine if step 1.11.5.3.6.d of

PPM 1.11.5

was being implemented with respect

to TS 3.11.1

and

3.11.2 calculations.

H

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The following findings were identified which outline deficiencies in

this area.

t

Documentation of the liquid release

calculations

and two gaseous

release

calculation programs

use'd during 1984 and

1985 to",da'te,were

examined.

Documentation of marginal quality was'available

for

liquid release

calculations.

Documentation for the gaseous

release

calculation programs

was not available.

The secondgaseous

effluent

release

computer program which was recently implemented,did'ave

documentation in preparation.

E

During the inspection,

the inspector'was 'not presented, satisfactory

evidence that independent verification of a subst'antial-fraction

of

computations

were performed by a second

$iidividual,, Independent

verification of overall computational results

was performed by a

comparison of the results

obtained by Radiological Programs

independent

of those performed by the plant staff.

Licensee

representatives

maintained that these

comparisons

served to meet the

intent of PPM 1.11.5.

These

comparisons

were performed but not

formally documented.

These

comparisons

did serve

a useful purpose

in that several errors in computer programs

were identified and

corrected.

The identification and correction of errors

was not documented

using

plant reporting systems

such

as problem reports,

nonconformance

reports or other means.

One error in computer calculations pointed out to the inspector

resulted in substantial

underestimate

of a dose parameter

required

to be calculated

by the TS.

This error, while known to the

responsible individual, remained unreported for three months.

These

errors

were identified in computer programs in use for performing

TS

required calculations.

Performance

of calculations to verify computer programs

were

performed to some extent.

The inspector

was not offered evidence

that verification of computer programs

was performed by a second

individual.

Documented tests,

containing test computer runs,

comparing expected

output to actual

computer output. were not

available.

These tests

were undergoing completion during the

inspection period for the second

gaseous

effluent release

computer

program.

This program

was implemented for use prior to completion

of the test effort.

The inspector did not attempt to validate the licensee's

dose

calculations that were performed at the site or by Radiological

Programs at the plant support facility.

The inspector did review portions of calculations

performed by both

parties.

Review of monthly data

and calculations

performed at the

plant revealed

a problem with computer calculations for the liquid

effluent doses.

The responsible

licensee

representative

reviewed

the problem and took corrective action.

S

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Projected

doses for liquid effluent releases

calculated

by plant

staff and by radiological programs

were compared for the fourth

quarter of 1984.

These

were found in good agreement

on

a monthly

and quarterly basis.

The inspector

compared calculations of release

rates

and curies

released

performed by the plant with those performed by radiological

programs using the Radiological Effluent Management

(REM) program.

The inspector identified a problem with these calculations.

Investigation by the licensee

revealed

an error in one equation used

in the computer

code used by Radiologica1 Programs.

The licensee

representative

assured

the inspector that this, code had not yet been

validated

and that this code

was not used ta perform any of the

semi-annual

release

report calculations.

The inspector noted that written verification packages

were

available for codes

used by'adiological programs.

Regarding

regulatory guide 4.15 section C.6.4 computer data input

verification, the licensee

representative

at the plant stated that

computer input data is checked after input,'with the'origi'nal data

sheets.

The inspector noted that this) was not,a procedural

requirement

and that

no, place, was provided,for any..individual to

sign-off that such

a check had been. completed'.,

The. inspector

could

not verify that these'hecks'ad

'been performed.

(

4'

The licensee

has developed'omputer

programs to,perform'S required

calculations.

Failure to adequately'ocument

the codes, their

validation and the v'erificati'on, of 'input data re'present

poor

implementation of quality control requirements

in"this, a'rea.

Ongoing informal activities have served to identify'some problems in

this area but these

problems

have not been appropriately

documented.

Based

on findings identified during the inspection,

the licensee

was

prepared at the exit interview -to offer a substantial

commitment

towards program verification.

The commitment offered by the

licensee

described

steps

to be taken tovdocument

and verify computer

codes prior to use.

These

steps

describe

an acceptable

method of

verification.

The following will be examined in a subsequent

inspection:

documentation

and verification of programs in use;

procedural

changes

to implement this commitment;

provisions for verification of computer input data;

Based

on the licensee's

commitment t'o improve in this area,

a notice

of deviation from Regulatory Guide

4'5 was considered

not

appropriate.

(Open,

85-11-09).

Chemistr

I,aborator

The inspector

examined implementation of the licensee's

laboratory

analytical control (IAC) program.

Plant procedure

11.2.7 contains

the program requirements.

The inspector noted that only four key

parameters

have been

implemented for the spike sample program which

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26

each technician is required to perform every six months.

These

parameters

are chloride, silica, organic phosphate

and boron.

The

inspector discussed

with licensee

representatives

the need to

consider including more parameters

in this program.

Acceptance criteria for the spike sample

are calculated

using the

statistical t-test.

Use of this test leads to acceptance

criteria

of sample

mean plus or minus

12 standard deviations'he

inspector

noted that while statistically valid, this technique

did not appear

appropriate for plant use

and suggested

that the acceptance

criteria

be redefined.

The licensee representative

agreed to consider this

matter.

The inspector noted that no program had been established

to trend

spike sample results.

No requirement exists in this area.

The inspector

examined the routine use of standards

called for by

the LAC.

This area

was found acceptable.

The inspector noted that no chemistry procedure is available to

describe responsibilities for review of work.

A plant procedure is

available.

In addition,

some chemistry procedures

did not contain

provision for supervisory acceptance

while others did.

This matter

was identified to licensee

representatives.

The inspector

examined

the licensee's

cross

check program which

consists of blind samples

supplied by a commercial laboratory,

the

EPA and

NRG.

Review of this data revealed that the chemistry lab routinely

reported values for Strontium isotopes

that were low by more than

a

factor of 2.

In addition, Iron-55 agreement

was poor.

This was

identified in a March 1984 corporate audit.

Results of an NRC cross

check sample recently completed did not show improvement.

The licensee indicated that they were aware of this problem and had

initiated several

actions to improve their performance in this area.

At the exit interview, the licensee

repres'entative

committed to

provide

a written submittal to the

NRC describing the plan to

improve performance in this area.

Audits

Annual audits required by TS'6;5.2.8.j,

k-, l and

m were verified to

have been performed or scheduled

as required.

An audit performed in

1984 to meet the requirement of 6.5.2:8'.j

and

m was

exami'ned by the

inspector.

The audit appeared

comprehensive in scope,

concerns

and

quality findings were identified, these'ere

responded

to by audited

organizations.

Corrective actions

were examined

and".accepted

by the

auditing organization.

,

4

1

The inspector noted that two,concerns

were, independently identified

in the course of this inspection.

>In the'ase

of concern 9,

"Records for effluent monitoring are'not-being

consistently logged

I

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27

and filed in plant records", it appears

that the corrective action

only addressed

NPDES records.

Minor problems with other chemistry

records

were also identified to and discussed

with licensee

personnel during the inspection.

In the case of concern

14 regarding inter laboratory cross-checks

discussed

in section

h of this paragraph,

the corrective action had

not been totally effective for Strontium analyses.

An audit of ODCM implementation required

on

a bi-annual frequency,

and the annual audit of quality assurance

for effluent and

environmental monitoring was being performed during this inspection

period.

The inspector attended

the audit entrance briefing for

information purposes.

No violations or deviations

were identified.

k.

Radiolo ical Environmental Monitorin

Pro

ram

(REMP)

Technical Specification 6.9.1.10

and

TS 3/4.12.2 implement the

10 CFR 50 Appendix I.IV.B.1,2&3 requirements

to: provide data

on

releases;

provide data

on radioactive material in'he environment

, and doses

to individuals;

and changes

in land use in unrestricted

areas.

Environment

Air

Mater

Soil and Sediment

Fish

Milk

Produce

4

Based

on examination of the report,

submitted April 23,

1985, the

inspector

concluded that the report'was

on time and contained

information consistent with the requirements

of: TS 6.9.1.10;

TS 3/4.12.1;

and

TS 3/4.12.2.

The annual

REMP report submittedto

meet. these

requirements

was

examined.

The licensee

samples

the following media

as specified in

TS 3/4.12.1 - Table 3.12-1.

I

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Media

~Anal is

Direct

Radiation,'art'iculate,

Iodine,'amma,

Gross Beta,"Tritium

Gamma

',

Gamm'a,

Iodin'e

Gamma

'I

No violations or deviations

were identified.

l.

Inde endent Effort

1.

Technical

S ecifications

The inspector identified a potential problem with TS 3/4.11.2.4

Gaseous

Radwaste

Treatment

S stem.

No action is specified if

the radiation monitor becomes

inoperable while the system is in

bypass

mode.

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This matter

was discu'ssed

at the exit.

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2.

Dosimetr

Staff and

uglification

I

interview.

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(}ualification of staff performing'ersonnel

radiation dosimetry

was examined.

Technicians

involved in" this~ area all exceeded

three years

experience in health physics.

Supervisory

and

professional technical personnel

also

had adequate

experience.

Based

upon discussion with,personnel,

staffing in this area to

meet the

TLD processing

requirements

appeared

adequate.

m.

Licensee Event Re ort Status

The following LER's are closed

based

on in office examination by a

regionally based inspector.

Number

Event

84-105

84-089

84-078

84-077

84-074

84-069

84-066

84-063

84-073

84-128

84-30

Control Room Air Intake Monitor spike

Scram generated

during surveillance testing

Control Room Air Intake Monitor spikes

Control Room Air Intake Monitor spike

Release

of wrong tank to environment

Control Room Air Intake Monitor spike

Control Room Air Intake Monitor spike

Control Room Air Intake Monitor spike

Control Room Emergency Filtration Start on Chlorine

Monitor Signal

Control Room Emergency Filtration Start on Chlorine

Monitor Signal

Control Room Air Intake Monitor spike

The matter of the control room air intake monitor spiking due to

induced signals

and corrective action taken by the licensee

was

reported in NRC Inspection Report 50-397/84-28.

No violations or deviations

were identified.

11.

~Trainin

a.

General

The inspector

reviewed the organization of the technical training

department

and the general

methods of operation

and the status of

the maintenance

and non-licensed training programs including

licensee 'progress

towards achieving

INPO accredidation of the

training department.

The inspector

examined

the licensee's

administrative procedures

regarding personnel training to verify

that

a documented training program had been established

consistent

with the Technical Specification,

FSAR Chapter

13, Regulatory

Guide 1.8 Rev.

1-R,

and ANSI N18.1 requirements.

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The following procedures

were reviewed:

Nuclear Operation Standard

(NOS)-5 Rev. 2, "Personnel Training,

Qualification and Certification"

f

Technical Training Manual:

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Section 4.1 Rev. 0,'."General

and Technical Support,

Training - Program Summaries"

Section 4.3 Rev. 0,

"VNP-2 Nuclear License Training-

Program Summaries"

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Section 5.3 Rev.

0,

l'VNP-2 Equipment Operator Training

Program Description"

PPM 1.8.1 Rev. 2, "Training Program

Administration"'PM

1.8.2 Rev. 4, "General Employee Training"

PPM 1.8.3 Rev. 2, "Operations

Department Training"

PPM 1.8.4 Rev.

4, "Certification of Plant and Support Contract

Personnel"

PPM 1.8.5 Rev.

3, "Maintenance

Department Training"

PPM 1.8.6 Rev.

1, "Technical Training Department"

The inspector identified that for the replacement

of maintenance

personnel,

a review of past experience

and training was not being

performed by both the Department

Manager

and the Plant Training

Coordinator

as described in FSAR Chapter

13 Section 13.2.2.C,

"Requalification and Replacement

Training for Other Plant Personnel

(Maintenance,

HP/Chemistry, Technical)."

At present,

the licensee

department

managers

have the responsibility for reviewing past

experience

and training of replacement

personnel

and determining

required training commensurate

with job duties.

The licensee

has

committed to review and take actions to correct this conflict.

No violations for deviations

were identified.

b.

Maintenance Trainin

The inspector

reviewed the licensee training program for maintenance

personnel.

The inspector's

review consisted of discussions

with

supervisors

and personnel

responsible for program implementation

and

a tour of the maintenance

training building.

The inspector

determined that the licensee's

maintenance

training program required

the appropriate training and refresher training commensurate

with

job duties.

The training department

consists

of many electrical,

instrument,

and mechanical visual aids to assist

the instructor in

training.

Currently the maintenance

training department is

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Overall the system operating procedures

appeared

to be adequate

for

use by properly trained

and qualified individuals.

Detailed information and quality of the procedures

varied.

The HPCS

procedure

was found to be more detailed,

informative and consistent

with other available

documents;

than the

RHR procedure

seemed

to

include only that information required to accomplish the designated

activities.

The inspector indicated to the licensee

representatives

that the

HPCS procedure

was more in line with what the inspector

considered

as

a good procedure

and the KB procedure

was

one of low quality.

The inspector also indicated that discussions

with responsible

personnel indicated differing opinions

as to the level of detail

expected

to be included in a system operating procedure.

The

licensee

indicated that this subject material would be addressed

in

a timely manner to assure all individuals responsible for

preparation,

review and approval would be cognizant, of managements

expectations in this area.

The inspector also directed the licensee attention to a precaution

in the

RHR procedure

which requires

the Reactor Operator to hold the

pump switch in the stop position during an electrical power

interruption when the system is in the shutdown cooling mode of

operation.

This action is to preclude

a water hammer event in case

the coolant level in the

RHR heat exchanger

had dropped.

The

inspector questioned

the practicability and appropriateness

of the

procedural solution to the potential problem on

a long-term basis.

The licensee

indicated the matter would be evaluated

to determine if

a design

change to the system would be more appropriate

to preclude

such

an event.

The procedure for controlling deviations to established

plant

operating procedures

provides that other persons

may verify their

copies of procedure deviations against

the master maintained by the

administrative

department

or the copy in the control room.

The

inspector

observed that the control room',copy of deviation forms are

not replaced

by copies bearing the management

signed

forms showing

that the required

subsequent

review and approval of the deviation,

unless

the original was

changed in which case,

the signed

changed

form is filed in the control, room.

The licensee

representatives

indicated that the matter would be ev'aluated

and necessary

measures

initiated, if appropriate,

to assure that .verification of other

procedures

are against

the latest

approved revisions.

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The inspector indicated that: procedure form"and content description

in Chapter

13 of the

FSAR may be inconsistent" with, Chapter

17

(gA

Topical Report).

The"'description in Chapt'er'3

has'been'ncorporated

in the plant procedure

governing preparation of plant

procedures;

e.g.

1

Pursuant to Chapter

13 of the FSAR only surveilla'nce

procedures

are

required to have acceptance

criteria.

.However, 'all procedures

examined included appropriate

acceptance

criteria as required under

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undergoing

a job-task-analysis

of maintenance

personnel

as part of

the process

towards achieving

INPO accreditation.

The inspector

reviewed

on a sample basis individual training files

and interviewed

a few ISC, technical

and instrument technicians.

The inspector verified annual general

employee training, on-the-job

training, formal classroom training, procedure training, industry

experience training and prenatal radiation exposure training for

female employees.

The inspector attended

the general

employee training short course

and

PPM 1.3.7 Rev. 6, "Maintenance

Work Request"

procedure

change

training.

Appropriate handouts

were provided to the students

and

the instructors

appeared

to have

an adequate

knowledge of the

subject matters being taught.

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No violations or deviations

were identified.

Non-Licensed

0 erator Trainin

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The inspector

reviewed. the licensee's

'non-Licensed

operator training

program,

spoke with licensee personnel

and reviewed, training

schedules.

The inspector also reviewed

on a sample basis individual

training records for five equipment operators.

Based

on this review the inspector

concluded the equipment operator

training was being conducted in conforman'ce

with, the licensee's

procedure

and policies.

/

No violations or deviations

were identified.

12.

Plant Procedures

The inspectors

examined the following listed. system Operating Procedures

to ascertain

whether or not the procedures

were adequate

for use by a

licensed reactor operator.

Residual Heat Removal System

(RHR),

PPM 2.4.2

High Pressure

Core Spray System

(HPCS),

PPM 2.4.4

Emergency Standby

AC Generator,

PPM 2.7.2

Critical 120V AC Distribution System,

PPM 2.7.5

Uninterruptible Power Supply System,

PPM 2.7.4

The inspector's

examination included

a review of selected

drawings;

vendor manuals; training material; related

abnormal,

Emergency

and

surveillance procedures;

and Administrative procedures for preparation,

review, approval

and use of the plant procedures

including approved

procedure deviation forms.

Based

upon the inspectors

review of the above mentioned material

and

related discussions

with responsible

licensee

personnel

the following

observation

were made to licensee

management.

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the provisions of the licensee's

(}A program.

The licensee

indicated

this matter would be examined

and assure

that appropriate

measures

are in place to assure

compliance with the

QA requirements.

e.

The inspector

examined the caution tags

on the reactor control

panels.

All tags were found to be consistent with plant procedure

requirements.

The Reactor Operators

who interfaced with the inspectors

during the

examination of the procedures,

demonstrated

a high proficiency in

their knowledge of the plant systems

and

how the various

documents

inter-related.

g.

An examination of readily accessible

valves in the RIB system,

revealed that the valves were properly identified and positioned for

operation of the reactor at power.

No violations or deviations

were identified.

13.

gualit

Assurance Audit Pro

ram

Records

and procedures

of the (}uality Assurance

(gA) audit program were

examined for the year 1984,

and discussions

relating thereto

were held

with QA management

and audit personnel.

The following observations

and

findings resulted.

I

a.

Sco

e and Schedule of Audits

gA audits

are scheduled

on a calendar year basis.

The proposed

audit schedule is developed

by the gA,'audit staff,

and subsequently

presented

to the Corporate Nuclear'afety Review Board

{CNSRB) for

review and discussion pri'or to'pproval by management:,

During 1984

a total of 14 audits

were conducted of activities at

WNP-2.

The scope of activities subjected 'to audit, in'eluded 'all

those which are required by the facility t.'echnical s'pecifications

to

be performed under cognizance

of the

CNSRB;

As such,

the scope of

audits

covers the performance,

training and qualifications of WNP-2

operations staff as well as support organizations

and the oversight

and review committees

required of the technical specifications.

b.

ualifications of Audit Personnel

Records of the qualifications of audit personnel

were examined

and

found to be in accordance

with applicable industry and regulatory

standards

for such personnel.

C.

Documentation

and Resolution of Audit Pindin

s

Reports of gA audits

were selectively examined in detail for the

year

1984.

The reports reflected

a well planned

and thorough audit

process.

Deficiencies,

when identified within the organizations

or

activities audited were clearly documented in terms of those

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conditions not conforming to licensee

imposed or applicable

regulatory requirements.

The audit findings were directed to appropriate

management

levels of

the organizations

audited for formal (written) response

and

resolution.

A goal of 120 days,

from the time of identification of adverse audit

finding to resolution

and closeout,

has

been established

by QA

management.

For the period 1984, the average period for closeout of

audit findings was

123 days - closely approaching

the goal

established.

To closeout

an audit finding the

QA staff carefully

evaluates

the management written response

for adequacy in terms of

not only correcting the deficient condition but also steps

proposed

to prevent recurrence.

Records revealed it not unusual for the

QA

staff to find the initial response

to audit findings to be

unacceptable,

requiring additional response

'by the management

of the

organization audited.

After reaching satisfactory resolution in the written response(s)

to

the audit findings, the

QA staff verifies implementation of

corrective actions generally through reaudit,,prior to final

closeout of audit findings.

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As

a part of each audit the QA'taff, in addition to documenting

specific adverse

findings wher'e applicable,

makes

a determination of

the overall effectiveness,'of the',activity'audited'.

This

determination is documented in the repor't of the audit, thus

providing an overall assessment.

of the effectiveness

of activities

and organizations

audited for senior licensee

management.

1t

No violations or deviations from NRC requirements,

were identified

within the

QA audit program activities e'xamined.

It.was concluded

that

a viable and effective. QA audit program had been

implemented

with regard to operational activities at the VNP-2 facility, and

that the program enjoys healthy support of senior licensee

management.

No violations or deviations

were identified.

4.

On April 19 and 26,

1985,

an exit meeting

was conducted with the licensee

representatives

identified in paragraph

A.

The inspectors

summarized

the

scope of the inspection

and findings as describe in this report.

The

licensee

acknowledged

the violations identified in the areas of control

of M&TE, the offsite committee,

the onsite committee,

and primary

containment integrity.

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