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' ATOMIC ENERGY COMMISSION." -Q Nyf ty;d t$
DIRECTOR ATE OP' REGULATORY OPER ATIONS
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.M.Q4W4 j*n John 8. Davis, Deputy Director for Field operations, II:nq
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QUALITY AS8tHUDICE PROGRAM POR OPERATIOMB h
II DISPECTION REPORT No. 75-07 LICENSE NO. DPR-16 y $/
' DOCKET No. 50-219 f i',s.'
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JERSET CENTRAL POWER AND LIGHT COMPAMT (Of8TER runr)
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TRACK No. F1409980 cA Concerning the referenced inspeettom, we reeouseend the enclosed draft.
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enforcement letter and Nottee of Proposed Imposition of Civil' Penalty
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, amounting to $19,000 for Dr. Knuth's signature.
. ;, :g We beliere that a more desirable alternative eomaists of issuanee of 's
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single violation with amamples, and have also anelosed a.sesond Appendin'.c *.4 ya. ~ b.s ;
.A-1 in this format for your eensideration.
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Ebalosures II and III describe the itsensee's prior commiitasats with
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J respeet to program completten and implementation, and. history of non "-
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i James P. O'Railly
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Draft of Enforeement Letter
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w/3 Appendises II. Chronology of Limensee History
.h Concerning quality Assuranos 1
3 III. Lisensee's History of Noncomplianse-25
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APR 2 51975 WS
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N'N Jersey Central Power and Light Company Attention: Dr. 8. Bertnoff hmMat i,
Madison Avenue at Puneh Bowl Reed l
Morristown, New Jersey 07960 1
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Gentlemen 4
j This refers to the inspection conducted on March 10-14, 1975, by Messrs.-
Enhlman, Greenman, Glasseock and Smith of our Region I offiae at your Oyster Creek Nuclear Generating Station of activities authorised by ABC License No. DPR-16, and to the discussions of our findings bald by Mr.
Brunner and other members of this office with Mr. Finfrock and other i
members of your staff at the sonalusion of the inspection, and to sub ' ]p.0 sequent telephone discussions between Mr. n=h1=== and Mr. Carroll on March 26, 1975 and between Mr. Drummer and Mr. Finfrock on April 1
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s Basedontheresultsofthisinspectionitappearsthataartainofyour;;
i activities were not conducted in full compliance with NRC requirements 4,
I as set forth in the Notice of Violation, emelosed herewith as Appendix h
y A.
The items of noncompliance identified in Appendia A are the result 3A' of your failure to implement the Operational Quality Assuranse Plan gi (FsAR' Amendment 71) transmitted to the Division of Resotor Lisensing by your letter dated Marsh 22, 1973, as supplansated and revised by se-mittal of FSAR A - h t 71 Revision i dated December 19, 1973 and FSAR Amand= ant 71 Revision 2 dated October 1, 1974.
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As you are aware from " Criteria for Determining Enforcement Action and l
Categories of Noncompliance with AEC Regulatory Requirements-Modifica -
tions" which was provided to you by a letter dated nana=ha, 31, 1974, the enforcement actions available to the ca==4mston in the exercise of l
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its regulatory responsibilities include administrative actions in the r
l form of written notices of violations, civil monetary penalties, and orders pertaining to the modification, suspension or revocation of a license.
After careful evaluation of the itens of noncomp14mana identi-i fied in Appendix A and the results of our inspection, this office proposes to impose civil penalties pursuant to geetion 234 of the Atomic Ener k Act of 1954, as amanded (42 U80-2282) and 10 CFR 2.205 in the amount of Nineteen Thousand Dollars ($19,000) as set forth in the " Notice of I
i Proposed Imposition of Civil Penalties", enclosed herewith as Appendix l'
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.ERESS
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' t In natition to the corrective actises regarding the specific items listed la Appendix A, we are concerned about the implementation of your 7
'n Operatimani t= Hey Assurance Program with respect to edberance to WASH 1283, Revisian 1 WASE 1284 and WASE 1309 in accordance with pages 24 and 24a of your Operational Quality Assurance Plan (FSAR Ammademmt 71).
Consessantly, in your reply, you should describe, in particular, those actions rahan or planned to completely iglement these standards, in-eluding a schedule for accomplishing the activities.
4 Your reply to this letter will be considered in determining whether any further enforcement action, such as modification, suspension, or revoca-tion of the license, is appropriate.
Sincerely, 1
i Donald F. Enuth, Director Office of Inspection and Enforcement Enclosurest 1.
Appendix A, Motice of Violation
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Appendix B, Notice of Proposed Imposition of Civil Penalties cc I. R. Finfrock, Jr., Vice President-Generation A. Z. Boismen, Counsel for Citizene Cosmaittee for Protection of the Environment i
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APPEREEK A hi Jersey Central Feuer and Light company Decket No. 5&219 i
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Attenties: Dr. S. Eartaaff
- License No. BPR-16 President Madison Areams at Punch Bowl Road Norristeus, New Jersey 07960.
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NOTIM OF TIOLATIGE Gentiament Based on the results of the NBC inspectism conducted on March 10-14, 1975, it appears that certain of-your activities were not la full een-p14mme= with NBC r=r1=H -- and the com41tions of your liemman as indfeated below:
A.
Contrary to 10 CFR 50, Appendix B, criterion VI, "Documsat Castrol",
measures established did.aet most requiressats. Exasyles imeladet 1.
FSAR Amendment 71, the Oyster Creek Operettamal Quality Assur-l anee Plan (0QAP),Section V, and Todaical Specifientian (TS) 6.2.D and 6.2.E. require FORC reviser and Station Superinten-dent approval which was not accomplished in that a draft Pee *!
precedure was ebeerved la ese by. the taspector em March 12, 1975 for the purpose of obtainine a radioactive Air Ejector off Gas Sample.
2.
The OQAP,Section V and TS 6.1.C.1.d required review of sur-l veillance procedures was not conducted for eight (8) of l
twenty-five (25) procedures sampled. FORC review of the eight (8)====ples was completed prior to the and of the inspection x
DU on March 14, 1975...Noneth=1ama, the 32% dimerepamey rate in PORC review of facility survei.11 mace procedures indicated by the semple takaa on March 12, 1975 regict2es generic corrective l
action.
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The 0QAP,Section V and TS 6..t.F required PORC reviser and i
Statica Superlatendent approval was not performed, in that a January 24, 1974 temporary change to Procedure 609, related to nitrogen pressure requirements for operatias eaata4====t l
1 solation components, did not receive the reqaired review and j
approval.
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The OQAP, section V requi m e= are not satisfied in that engineerlag drawings.for safety-related egeipment are not provided to or used at the Corporate Bagineering Offices as of perform design revians and aske
--1 March 13, 1975 where p. c day-to-day engineerlag decisions.
This infraction had the potential for causing or concributing to an occurrence related to safety.
(Civil Penalty = $4,000)
B.
Contrary to 10 CPR 50, Appendix B, Criterion II, " Quality Assurance Program", safety related mainta===a= activities are not sufficimatly controlled, in that as of March 14, 1975 there were no establinhad means of categorising job orders as being safety related.
This item is a deficiency.
(Civil Penalty = $1,000)
C.
Contrary to 10 CFR 50, Appendix B Criterian V " Instructions, Procedures and Drmrings".2 f
1.
Administrative controls over plant operatimes and main *===aa
$4 did not meet requirements. gzamples ine1=dae The OQAP,Section II required Safety System Boundary and a.
c1===ification Book was not in existence, thus the defini-l tion of what system parts and components are safety i
related was incomplete.
b.
The 0QAP,Section II requirements for establishing pro-cedural controls assuring compliame= with 10 CFR 50, Appendix B, Criterion XI post-emintenaneo testing to demonstrate satisfactory performance fa service has not l
been fulfilled, in that no mechanism has been established j
for defining tests required subsequent to routine main-tenance for which detailed procedures are not provided, and the respecuibility for decidias what post-maine====e=
testing is required in such cases is not assigned.
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The OQAP,Section V and T3 6.2.C requirements were not met, in that the diesel fuel leventory los entries whicli serve to documsat malat====*= ef =4=4=wn fuel Imgels established by the Technical speciffmations were not made as required by Procedure 301 for the period January 6 -
i February 3,1975, Station Battery "B" discharge test log entries required by Procedure 601 were not made em
,2 December 18-20, 1974, and Control Rod Drive System test-ing los entrias required by Procedure 603.3 were not made
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on January 27, 1975.
U This infraction had the potential for causing or contributing to en occurrence related to safety.
j (Civil Penalty = $3,000) 2.
Personnel training and classification requirements were not i
met. Examples include:
i He OQAP,Section V and Precedure 102 requirements for a.
implementation of tr=4=ing activities were not met, in that Maintenance Department training was not conducted in accordance with the Oyster Creek Training Manual.
Rouever, the licensee revised Procedure 102 to indicate Ofpi, !
trai=4=g practices in existence. This action was com-plated prior to the completion of the inspection.
l b.
H e OQAP,Section II and ANSI N45.2.6-1973, Section 2.2 and 3.1 requirmeents were not met, in that site persoons1 engaged in maintenance testing, awa=4== tion, and certifi-cation activities do not have the required certification l
or definition of capability levels, with the exception of l
QA auditors and welding and NDE personnel.
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h is item is a deficiency.
(Civil Penalty = $2,000) 3.
Record storage requirements are not met, in that storage facilities physically meeting OQAP,Section II and ANSI f
N45.2.9-1974 requirements have not been provided.
h is item is a defirimary.
(Civil Penalty = $1,000) i i
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Engfaaering and Quality Assurance review requirmeents were not met. Examples imelanda:
M e 0QAP Section.Y required pr - d=eal controls have not s.
been established to assure that 0QAF,Section III and 10 CFR 50, Appendix B Criterion III Design Baviews consider the Design Bases defined in 10 CFR 50.2(u) for facility equipment changes, praamdural changes, and tests or experiments, or.for assuring required drawing control, design interface identification and control, coordination between participating design organisations, and verifica-tion of design adequacy.
b.
The 0QAF,Section VI requirements are not being, met, in that procedural controls establishing the responsibility for== hine 10 CFR 50.59 safety evalostions for modifica-tions, tests, and experiments are not provided, nor do procedures provide for the processing of such items to assure that TS 6.1.C.1.d(2) and (4) and 6.1.C.1.e(4) required committee reviams are accomplished.
The OQAP,Section V requirements are not being mat, in c.
that procedaral controls have not been established to assure accomplishment of Generation Department Procedure M
2001 required Mmy Assuranes review of procurement 1
doctaments. (No inadeqoseles were detected in procurement l
doctaments).
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The OQAP,Section V and Instruction SQA-1-74-G-004 re-j quired QA review of twelve (12) safety-related job orders processed during February, 1975 was not conducted.
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This infraction had the potential for causing or contributing to an l
i occurrence related to safety.
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(Civil Penalty = $3,000)
D.
Contrary to 10 CFR 50, Appendix B, Criterion VIII, " Identification and Control of Materials, Parts and Components", the OQAP, Section i
VIII required identification and control over materials used in two l
(2) of seven (7) safety-related job orders was not maintained.
Specific job orders identified without material control were 8648, Core Spray System, and 8626, Fuel Pool Filter.
l This iten is a deficiency.
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E.
Contrary to 10 CFR 50 Appendix E, Criterian XVI, " corrective Aetica", the 0QAP, Appendix A defiasd safety-related h==ta j$
Transfer System was returned to servies following work om October 25, 1974, with three (3) 1Amatified maneauformemens unresolved.
1 This infraction had the potential for caustas or contributing to an occurrence related to safety.
i (Civil Penalty = $3,000)
F.
Contrary to 10 CFR 55, App==dir A, Item 4a; to 10 CFR 50.54(1-1);
and to the Oyster Creek Operator Req==11Ficatica Program, none of the twenty (20) lie =amed operators /semier operators received an a'
aanmal examination prior to Deender 17.-1974 as required. Boe-ever, the last operator took and successfully. passed his annual 1
awa=4==tima on March 13, 1975, prior to the completion of this inspection.
5 This item is a defietaaey.
(Civil Femm1ty = $1,000)
FOR THE NUcts.An REGULATOEr Col 0ESSION i
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Donald F. Kauth, Director Offies of Inspection and Enforcement i
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APPENDIX A-1 Jersey Central Power and Light Company Docket No. 50-219 Attentions Dr. S. Bartnoff License No. DPR-16 i
President Madison Avenue at Punch Bowl Road Morristown, New Jersey 07960 NOTICE OF VIOLATION Gestisment Based on the results of the NRC inspection conducted on March 10-14, 1975, it appears that certain of your activities were not in full compliance with NRC regulations and the conditions of your License as indicated below.
Contrary to Criterion II, Appendix B, 10 CFR 50 and the Oyster Creek Operational Quality Assur e e Plan (FSAR Amendmant 71), an operational quality assurance prog.am complying with requirements l
of the Code of Federal Regulations and the Oyster Creek FSAR has not been carried out at the Oyster Creek Facility at a time con-sistent with accomplishment of safety-related activities. Numerous g
Items of Noncompliance with 10 CFR 50, Appendix B, Criteria II, Y, VI, VIII and IVI were identified, with several of these a2so being contrary to the Oyster Creek Technical Specifications. Th u e, when viewed collectively, show a breakdown in management and procedural controls with respect to Quality Assurance implementation.
Illus-trative examples include 1.
Conducting a safety related activity involving sampling of offgas activity with an unapproved procedure; 2.
Returning a safety related system as defined in Operational Quality Assurance Plan, Appendix A,Section III.f, (Condensate Transfer) to operation without required resolution of QA identified nonconformances; and 3.
Failure of station management (PORC) to conduct required re-views of surveillance procedures and temporary changes as well as examples of plant personnel failure to adhere to approved procedures concerning activities affecting quality.
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.. l This violation has the potential for causing or ce,fcributing to an occurrence related to safety.
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(Civil Penalty - $5,000) 4 FOR THE MUCLEAR REGULATORY COIMISSION I
4 Donald F. Knuth, Director Office of Inspection and
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APPENDIX 5 M
NOTICg 0F PROPOgED DIP 0gITION OF CIVIL PENALTIES Q[
- Jersey Central Power and Light Company Attention Dr. 8. Bartnoff President Madison Avenue at Punch Bowl Road Morristown, New Jersey 07960 License No. DPR-16 Gentlemen This office proposes to impose a civil penalty pursonat to Section 234 i -- -
of the Atomic Energy Act of 1954, as====w (42 USC 2282), and to 10 CFR 2.205 in the cumulative amount of Mineteen Thousand Dollars ($19,000.)
for the specific items of noncompliance set forth in Appendix A to the cover letter.
In proposing to impose civil pensities pursuant to this section of the Act and in fixing the proposed amount of the pensities, the facts identified in the statement of considerations published in the Federal Register with the rule making action which adopted 10 CFR 2.205 (36 FR 16894) August 27, 1971, have been taken into account.
You may within twenty days (20) of the date of this notice, pay the eiwil penalty in the amount of Nineteen Thousand Dollare ($19,000) er 4
you may protest the imposition of the civil penalty in whole, or la i
part, by a written answer. Should you fail to answer within the time specified, this office will issue an order imposing the civil penalty in l
the amount proposed above.
Should you elect to file an answer pro-testing the civil penalty, such answer may (a) deny the viohtions l
listed in the Notice of Violation in whole or in part, (b) demonstrate j
extenuating circumstances, (c) show error in **
Notice of Violation or js (d) show other reasons why the penalty should not be imposed. In addi-L tion to protesting the civil penalty in whole or in part, such answer l
may request remission or mitigation of the penalty.
i Any written answer in accordance with 10 CFR 2.205 should be set forth separately from your statement or explanation in reply pursuant to 10 j
CFR 2.201, but you may incorporate by specific reference (e.g., giving page and paragraph numbers) to avoid repetition.
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Your attention is directed to the provisions of 10 CFR 2.205 regarding, la particular, failure to answer and ensuing orders; answer, considera-ties by this office, and casming orders; request for hearings, hearings and ensuing orders; compromise; and collection. Upon failure to pay any i
civil penalty dus, which any be _l::g tly determined in accorda=a=
with the applicable provisions of 10 CFR 2.205, the matter may be referenced to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234e of the Atomic Energy Act of 1954, as===ded (42 USC 2282).
This notice is sent to you pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice" Part 2 Title 10, Code of Federal Regulations.
Section 2.201 requires you to submit to this office within twenty (20) days of your receipt of this notice a written statement or explanation in reply including (1) corrective actions which have been enhan by you and the results achieved; (2) corrective actions which will i
l be taken to avoid further violations; and (3) the date when full compli-2 ance will be achieved.
For the NUCLEAR REGULATORY C000 FISSION i
i@$J Donald F. Knuth, Director Office of Inspection and Enforcement l
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EXCERPTS 1
OYSTER CREEK QUALITY ASSURANCE 1
4 Date I:.3 Movember 8, 1972 Region I (J. P. O'Reilly) ltr to.'CP&L (R. H. Sina) re Ostober 13, 1972 Management Meeting at IE 1.
Noteworthy quote:
"It is our understanding...that your formal Quality Assurance Plar. will be approved and issued by November 15, 1977, and that the der i
tailed implementing procedures required by your plan will be issued by January 15, 1973. It is 4
i further understood that all aspects of your 5 pro-gram as required by the above plea will be fully i
implemented by March 31, 1973."
December 8, 1972 JCP&L ltr (I. R. Pinfrock) to Region I (J. P. O'Railly).
Noteworthy Quote: "We have found that we have under-estimated the time it would take to approve and fasse i
our formal ' Quality Assurance Plan'...every possible effort uoald be nede to complete this plan by December 15, 1972."
March 15, 1973 JCP&L submitted FSAR Amendment 71, Operating quality I-Assurance Plan.
(Major revision of previous amendment)
September 17, 1973 J. P. O'Railly Note to File re September 14, 1973 tele-phone calist to the President of JCP&L (Dr. Bartnoff) re % for Operations, especially staffing; and to the President, GPU (Mr. Coomba) re support provided by CPU.
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December 18, 1973 USANC (J. C. Davis, DDFO) ltr to JCP&L (Dr. S. Bartnoff, President) re Ikyvember 5, 1973 Management Meeting at i
Region I.
Noteworthy Quote:
"We understand..'.that...
implementing precedures for the Quality Assurance Pro-gram are being prepared, and that the GPU organisation is providing additional support at the facility in deficient areas."
December 19, 1973 JCP&L submission of FSAR Ar.andment 71 Revision 1.
(A major revision) i e
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I Date Item l
January 18, 1974 JCP&L (S. Bartmoff, President) Itr to USAEC-DRO-BDF0 2"
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(J. C. Davis). h eauerthy quote: "Recognising that an Operational Quality Assurance Program is important and should be established at the earliest date, l.
Jersey Central Power and Light Company is presently establishing a program which reflects both the urgency and expanded requirements being placed on utility operational quality assurance programs today." This letter also indicated that procedure issue would be-gin in April 1974.
October 1, 1974 JCP&L submiastom of PSAR Amame=ent 71, Revision 2.
(Omanges about 20% of the pages in the 04AP)
March 10-14, 1975 Inspection at Oyster Creek verified that QA Program is not implemented.
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APR 2 51975 Memo to File JERSEY: CENTRAL' POWER AND LIGHT COMPANY OYSTER CREEK (DOCKET No. 50-219) a i
TRAINING DISCUSSIONS,WITH OPERATORS On December 12, 1974 another memo to file, same subject,'was generated by the Project Inspector Mr. Greenman.
In that memo, Mr. Greenman documented certain disparaging remarks made by operators interviewed with respect to preparation of instructors and the quality of the lectures in the Operator Requalification Program.
.I, reviewed this item during the course of this inspection. 'Along with the two (2) operators previously interviewed by Mr. Greenman, I sampled an additional six (6) operators / senior operators.- The two-(2) operators previously interviewed repeated essentially the same opinions as those they had previously expressed. However, I feel that their opinions can be reasonably discounted in light of the following facts:
(1) none of the other operators / senior operators shared'their opinions, or if shared, they did not express them to me; (2) these two (2) licensed operators are assigned to the same shift and, if dissatisfied, would have considerable time to develop the same " opinion";
(3) contrary to their expressed opinions that the operator requal program was not preparing them for their annual examination, both they and all of the other operators took and successfully 4
passed (over 70%) their annual examination.
(Actual examina-i tion statistics are documented in Report 50-219/75-07, Details,Section I, Paragraph 6a(9))
Since IE does not evaluate the examination for content, the adequacy of the annual examination was not determined. However, Mr. Jerry Holman of the Operator Licensing Branch has been informed of the contents of both the December 12,-1974 memo of Mr. Greenman, and the contents of this memo.- Mr. Holman stated the RL personnel would pay particular attention 4
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In addition, Mr. Holman is to receive a copy of this memo and the 50-219/75-07 report prior to the scheduled April RL visit to the site.
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William A. Ruhlman Reactor Inspector cc: McCabe Greenman Caphton O'Reilly Holman l
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