ML20128A222

Insp Repts 50-295/92-30 & 50-304/92-30 on 921214-930104. Violations Noted.Major Areas Inspected:Licensee Response to GL 89-10

ML20128A222
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	01/26/1993
From:	Doornbos R, Gainty C, Jeffrey Jacobson, James Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20128A183	List: ML20128A180 ML20128A203 ML20128A222
References
50-295-92-30, 50-304-92-30, GL-89-10, NUDOCS 9302020164
Download: ML20128A222 (16)

See also: IR 05000295/1992030

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U. S. NUCLEAR REGULATORY COMMISSION 1

REGION III

Reports No. 50-295/92030(DRS); No. 50-304/92030(DRS)-

Docket Nos. 50-295; 50-304 Licenses No.-DPR-39; No. DPR-48

Licensee: Commonwealth ~Bdison Company

Executive Towers West III *

1400 Opus Place

Downers Grove, IL 60515

Facility Name: Zion Nuclear-Power Station

Units 1 and 2

Inspection At: Zion Sito,-Zion, Illinois

Inspectors:

C.

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A. Gainty(

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Approved By:

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e als Processes Section-

Inspection Summarv

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Insnection cpnducted December 14.-1992 through January 4. 1993

(Recorts No.'50-295/92030(DRS);-No.-50-304/92030(DRS))

-Atpas Insoected; Announced safety-inspection-of tho' licensee's-

response to Generic Letter = (GL) 89-10,:-_" Safety-Related Motor-

Operated Valve (MOV) Testing and Surveillance" _ (2515/109).

Results: The' licensee has developed a-program which is-generally

consistent with the guidance'of GL'89-10. -The inspection-

disclosed.one violation (Section 2.a.(4)), three unresolved' items

(Sections 2.a. (3) , . and 2.a. (4) ) , and one open item-_(Section

2.b.(6)).

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The licensee demonstrated strengths in the following area:

O Use of a spring' pack tester-at each valve refurbishmentJto

improve' accuracy of torque switch settings prior to= VOTES

-tests.

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PDR ADOCK 05000295-

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- Inspection Summary ~

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The' licensee demonstrated weaknesses in the following area:  :

o The methods used to evaluate data from design basis testi'ng-

did not ensure that Movs could perform their safety function

under design basis conditions.

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TABLE OF' CONTENTS

P.aG9.

1. Persons Contacted.................................... 1

2. Inspection of the Program Developed in Response to

Generic Letter 89-10............................... 1

a. Generic Letter 89-10 Program Review.............. 1

(1) Scope of.the Generic Letter Program......... 1

(2) Design Basis Reviews........................ 2

(3) MOV Switch Settings......................... 2'

(4) Design Basis Differential-Pressure and

Flow Testing.............................. 4

(5) Periodic Verification of MOV Capability..... 7

(6) MOV Failures, Corrective Actions and

Trending..............-.................... 7

(7) Schedule.................................... 8

(8) Liberty Technologies 10 CFR Part 21 Review.. 9-

b. Associated Programmatic. Reviews..................- 9

(1) Design Controlifor Thermal overload-

Protection.................... ........... 9

(2)=MOV Setpoint Control........................ 9-

(3) Maintenance................................. 10

(4) Training.................................... 11

(5) Operating-Experience and Vendor

Notification.............................. 11

(6) Diagnostics................................. 11

(7) Walkdown.................................... 11

(8).Backseating of Valves....................... 12

,3 . Licensee Self-Assessment............................. 12

4. Open Items........................................... 11 2

5. Unresolved Items.....................:................ 12

- 6. Exit Meeting............................'............. 12

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DETAILS

1. . Persons Contacted

Commonwealth Edison ~ Company (CECO)'

1. R. Tuetken, Site Vice President

1. - T. Joyce, Station Manager

1. • R. Branson, Nuclear Engineering Department.

/*L. Cerda, MOV Coordinator

1. • J. Dempsey, Technical Staff

1. K. Dickerson, Regulatory Assurance

1. • K. Moser, Technical Staff

/*M. Pigon, Technical Staff

1. • B. Rybak, NED Mechanical & Structural Design _ Supt.

R. Ungeran, MOV Program Administrator

U. S. Nuclear Reculatory Commission (NRC)

1. J. Smith, Senior Resident Inspector

1. Denotes those attending the exit meeting on. December 22,

1992. '

• Denotes those participating in the-telephone conference -

January 4, 1993.

2. Inspection of the Procram Develooed in Response to-Generig

Letter 89-10

a. Generic Letter 89-10 Procram-Review

The NRC inspectors reviewed " CECO-Response to Generic

Letter 89-10," submitted to.the NRC by letter dated

September 28, 1990. Additional commitments regarding

the= program were submitted toithe NRC_-by letter. dated

May 11, 1992. Zion implemented the-CECO corporate

level GL 89-10 program in accordance with Nuclear

Operations Directive NOD-MA.1, " Guidelines.for. Motor

Operated Valve (MOV) Testing, Maintenance'and

Evaluation," Revision--2,-by-Zion Station procedure. ZAP

400-09. The licensee had developed a program that was-

generally consistent with the GL as discussed in more

detail below.

(1) Scope of the Generic Letter Procram

The inspectors reviewed system drawings for safety

injection, containment spray,_ steam generator.

feedwater and-auxiliary feedwater, main steam,

containment spray,' component cooling, and residual

heat removal as a sample' check for the

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completenons of the scopo of the Gb 89-10 program.

There woro 328 safety related HOVs includod in the

program at Zion Station. The licensoo provided

written-justification for the exclusion of 40 MOVs

from the program. The justification was in

accordanco with the GL guidanco. The inspectors -

datormined that the scope of the licensoo's

program was consistent with GL 89-10.

(2) llenign 11 asis Rovigyg

(a) Difforential Pressure Reauirementn

The HRC inspectors examined det basis

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review dp requirements for a sa. 410 of MOVs

and evaluated the proceduros controlling the

performance of the design basis t 'lews. No

problems were noted.

(b) Reduced Voltaae capability

The method used for calculating degraded

voltage at the MOV motor terminals was

acceptable. The second level undervoltage

relay sotpoint at the 4.16 kV safety-related

bus was used as the starting point for

calculating degraded voltage at-the motor

control contor (MCC). This is a more

conservative method than the " lowest

expected switchyard voltago" previous.1v used-

as the basis for calculating degraded voltago

at the MCC.

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calculations of voltago drops in cables

between the MCC and the MOV motors were

confirmed to be accurato ay the inspectors.

The calculations disclosed an abnormally high

(up to 40 volts) drop in some cables. This

was determined to be acceptablu due to a

relatively high (about 420 volts)-degradod

voltage at the MCC. The higher MCC voltage

was made available by increasing the value at

which tho'socond level undervoltage relay

tripped.

(3) MOV Switch Settingg

Sizing MOVs and setting'of MOV switches was

evaluated and was datormined to be an--evolving

process. A targot thrust window was calculated

for MOVs that had-enough margin'to use tho' Valve

operational Test Equipment System (VOTES). For

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some MOVs, modifications were planned to improve

the available margin. This initial approach was

acceptable, however, careful evaluation of test

data is important in order to validate the

assumptions that went into the calculations. Some

of the assumptions ir cludo valvo f actor, stem

coefficient of friction, amount of degradation in

stem friction over the maintenance interval, and

rato of loading.

The results from the dp testing at Zion appeared

to indicato higher stem friction factors, higher

valvo factors, and grontor offects from load

sensitive behavior for some McVs than was

originally assumed. The licensco had compiled

data from all six Ceco sitos and estimated that an

averago valvo factor was between 0.4 and 0.5 as

compared to the 0.3 value typically assumed in

uizing calculations. The licensoo had not

addressed rate-ot-loading in its program.

Itowever, an effect from rate-of-loading was

apparent in the tost data. The NRC incpectors

informed the licensco that it will be expected to

add additional margin to its calculations to

envelop this offect, when applicable. It is the

intent of GL 89-10 that test data be evaluated for

applicability to the overall MOV program.

Upon completion of its ovaluation of the backlog

of MOV test dcta, Ceco will be expected to

incorporate the results of the assessment of the

test data into its sizing and switch setting

methodology in accordance with GL guidance. For

examplo, the thrust windows for the tested MOVs-

will need to be corrected where the thrust

requirements were found to be greater than

predicted. .For those MOVs that will not be tested

under dynamic conditions, test results from valves

similar in type and service, must be considered in

the ovaluation of valve capability.

The licensco stated that, in determining the

acceptability of a limited population of MOVs, it

had relied on the results of a study by Kalsi

Engineering on the capability of Limitorque

actuators to withstand thrust greater than the

published ratings. The study was used cnly as an

interim measure and modification of the MOVs was

planned. The Kalsi study had been endorsed by

Limitorque for those licensees that have the

report and have addressed the caveats contained in-

the report, liowever, Ceco did not have a

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documented ovaluation addressing tha caveats of

the Kalsi report. Ceco has committed to address

this issue in response to the LaSallo MOV

inspection (50-373/92023; 50-374/92023). This

will be considered an unrosolved item for Zion,

pending NRR's review of the LaSallo responso and  ;

considering any issues specific to Zion's limited

uso of the study (50-295/92030-01(DRS); 50-

304/92030-01(DRS)).

(4) Drolgn Basis Difforpntial Pressuro._nnd Plow

T101109

Approximately 17 MOVs had boon dp tested at the

time of tho inspection, all during thu Unit 1-

Spring 1992 outago. The inspectors woro concerned

that the dp test results had not boon ovaluated to

ensure that the MOVs could perform their safety

functions under design basis conditions. The only

acceptance critorion utilized for the dp tests was

that the MOV cycled properly under test dp and

flow conditions. The inspectors explained that

sinco most of the dp tests woro performed at loss

than full dp, an engincoring evaluation of the

test results was requirod-in o* dor to demonstrato

design basis capability of each'Mov. In responso

to the inspectors' concerns, the licensoa

committed to perform an engineering ovaluation of

the 17 dp tosts in accordanco with Ceco document

"Whito paper 108" within a 10 wook timo framo and

to use the draft " VOTES Test Report Review Guido,"- '

Revision 1, dated April-21, 1992'for ovaluation of

the Unit 2 dp touting during the current outage.

The failure to ovaluato test results for theil7 dp

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tests is considered a violation of'10 CFR 50

Appendix B, critorion XI, Tost Control (50-:

295/92030-02(DRS); 50-304/92030-02(DRS)).

The inspectors reviewed the results of soveral dp-

tests and observed that in ono caso, the corporato

offico had calculated the valvo factor for MOV

ICC0685 to bo in-excess of 10. Since the thrust

calculation for this MOV was based on a valvo

factor ofl0.3, the inspectors woro concerned that

the high valve factor may impact the operability -

of the MOV. Further ovaluation by the inspectors

identiflod that the VOTES traco showed ovidence-of

. disc guide drag or some other abnormality that'had

boon'proviously notod:by.'he t VOTES technician,lbut'

was-not.ovaluated. In response to tha. inspectors'

concerns, the licenseo evaluated the test results

and tracos and dotorrined that MOV 1CC0685 was

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operable, but marginal, and required stem i

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lubrication overy 9 months instead of tho original

36 month interval. The inspectors considered the -

licensoo's evaluation to bo acceptable.

During both static and design basis testing, the

actual measured motor current for sono MOVs '

exceeded the nameplato. locked rotor current and

appeared to indicato that the locked rotor current

was higher than originally assumed. The offect of

degraded voltago for each MOV included in tho  :

calculation of capability was based on the ,

nameplato locked rotor current, which is normally

a reasonable assumption. However, where the

measured current, corrected to rated voltago, is

higher than locked rotor' current, than that'

current should be considered in ovaluating the

worst caso condition under degraded voltage. The

inspectors woro concerned that the licenson had

not taken stops to evalunto now information with '

respect to the degraded voltago calculations and

capability for each MOV. In responso to the

concerns, the licenseo identified the affected

population (approximately 50 tests) and committed

to ovaluate the offect of the highor locked rotor

curront on MOV capability within 10 weeks. The

inspectors considorod the failure to ovaluate the

offect of the higher than expected motor. current ~

to be an unrosolved item, pending the licensoo's

review (50-295/92030-03(DRS); 50-304/92030-

03(DRS)).

The licansco evaluated static VOTES testing using.

the draft " VOTES Test Report Review-Guide." 'In-

most static tests reviewed, certain items marked

"no" in the guide were documented and

dispositioned onsito or forwarded to the corporato 1

offico for resolution. This'mothod seemed to work  :

well in general, however, in the case of MOV.

ICC9438, the inspectors were concerned withLthroo

items marked "no" where there was no documented

ovaluation by either site or corporato. Section

2.6 of the guide indicated that, when_zero' marks

on the VOTES traces woro not within 5% of each

other, NED (corporato) was to be contacted.' In

Section 3.1, the measured thrust at."C16" (maximum

- thrust) excooded-the calibration rango; however,

for best fit straight lino calibration, Liberty

does not allow extrapolation beyond the

calibration range. In Section 3.12, the disc

pullout' force was measured to ho 94.6% of C16

instead of 80% as assumed in the-sizing

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methodology. In response to the inspectors'

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concerns, the licensee committed to review and-

evaluate the above items within 10 weeks. This is

considered an unresolved item pending NRC review

of the licensee's evaluation (50-295/92030-

04(DRS); 50-304/92030-04(DRS)). *

In general, the dp test results indicate that

soveral assumptions utilized for MOV capability-

ovaluations were not conservative. It is

recognized that bounding all factors considered in

the evaluation of MOV. performance may not be

practical or appropriate and may lead to an

unrealistic compounding of conservatisms.

However, it is tho intent of Gb 89-10 that values '

of individual factors:be evaluated such that, when

combined, provide reasonably conservative bounds

on actuator performance. Results from the

testing, corrected in accordance with the October ,

1992 10 CFR part 21 report from Liberty

Technologies, are summarized below.

(a) Stem friction factors varied between 0.0233

and 0.4514 during design basis testing and

did not appear to be bounded by the 0.15 stem

friction factor that was assumed for most GL- 89-10 program MOVs'in a non-degradedL

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condition. .

(b) Flex-wedge gate valve factors varied between

0.1967 and 1.2643 during design basis testing

(not including the reported valve factor of

10.156 for 1CC0685). Of the five gate valves

tested, two were bounded by the 0.3 valve ,

factor that was assumed for most gate valves.

(c) Globo valves exhibited valve factors that-

varied between -0.1473 and-0.2538. Since l.t i

is not theoretically possible to have a1 globe

valve with a valve factor less than11.0, the '

data may indicate inaccuracies in the

measurement of dp or'some other parameter.

Generic.difficultica in measuring test

. parameters may affect the data generated forf ;

all-design basis tests. Further . .

investigation-into this issue is appropriate.

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(d) Load sensitive behavior had not boon

accounted for in the methods for setting

torque switches. However, load sensitive

behavior wad observed during most of the

design basis tests and varied between -35.0%

and 66.7%.

(5) Par.iodie Verification of MOV Cap. ability

The Zion MOV program and the corporate program

both indicated that static testing would be used

for periodic verification to assure that proper ,

switch settings are maintained throughout the life

of the plant. However, the licensee had no

objective evidence to establish a reliable '

correlation'octween static tests and dynamic tests

performed at full flow and full differential

presca c< Tre licensee must establish such a

correlat ivu pefore static testa can be used for '

this pureaew

The station's schedule for periodic testing of

MOVs appeared to follow the, guidance of GL 89-10;

however, the station's program document did not.

The station's program is the formal document-

prescribing the activities to be-performed in

response to GL 89-10. That program is expected to

represent the practice being followed. However,

the wording in the program did not follow the

guidance of GL 89-10 in some areas.- For example,_

it excused the periodic verification of some

safety related MOVs (identified as category _2)

provided they received-preventive maintenance on

at least a ten year cycle. The period recommended-

by GL 89-10 for verification of=the capability.of

each MOV in the program was every third refueling

outage or every five years. Tius program should

reflect this period. Any deviation-from this

guidance should be justified on the basis of "

actual experience and' documented.-

(6) JiOV Failures. Corrective Actions and Trendina

The inspectors reviewed corrective actions taken

for a number of recent deviation: reports, and

other MOV-failures. In most cases,.the root cause

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determination and corrective actions were complete.

and well_ documented. However, the inspectors were

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concerned about a number of failures-that resulted '

from binding of auxiliary contacts in the McCs.

l According to licensee records, there had'been 28

L failures attributed to sticking auxiliary contacts

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in MOVs and other components since 1989. As a

result of the failure of a switch gear ventilation

fan in November 1989, the licensee identified

through consultation with the manufacturer, that

periodic lubrication of the plunger was necessary

to prevent binding. The licensee revised the PM

proceduro used for MCC maintenance at that time,

but failed to recognize that not all McCs for MOVs

were in the PM program until further MOV failures

occurred in 1992. In responso to the inspectors'

concerns, the licensee reviewed the population of

MOVs that had not been properly lubricated and

determined that (1) all plant McCs were in the PM

program, (2) all Unit 2 safety related MCCs will

be lubricated by the end of the current outaga,

(3) all Unit 1 safety related MCCs were scheduled

to receive PM during the Fall 1993 outage, and (4)

the Unit 1 MOVs woro determined to be operable

based on the quarterly surveillance testing

program. The inspectors considered the licenson's

approach to be acceptable.

The trending program had the capability to collect

data on a number of paramotors, including thrust

at torque switch trip, maximum thrust, and other:

parameters that should become useful as more data

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is collected. Failures were also trended both by

cause and by component to attempt to identify

potential problem areas. This was considered to

be a good approach, especially due to' considerable

MOV coordinator involvement. However, the

trending for indication of when a refurbishment

would be required was based mostly on the results

of grease inspections. No periodic refurbishments

woro planned.- This could limit tho-effectiveness

of the station personnel to detect degradation-

prior to failure. Some forms of wear may not be

detectable until the actuators are virtually

inoperable. In such a caso, periodic visual

inspecticns may provide a measure of added

assurance.

(7) Sched412

The licensee committed to implementation of all GL.

89-10 actions by the end of the fifth. refueling

outages, beginning with-the 1991' outages. The-

schedule was beyond the time frame recommended by

the GL and there were no plans to dynamically test

MOVs where'at least 80% of design basis dp and

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flow could not be achieved. This position and the

implementation schedule for GL 89-10 will'be

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reviewed by HRR to determino acceptability. The

18 inseo has determined that 132 MOVs are

prmcticable to test. At the time of tho  ;

inspection, 17 dp tests had boon completed on Unit

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(8) Liberty Technoloalos 10 CPR Part 21 Review

During a mooting with the NRC staff in April 1992,

CECO committed to ovaluato the data from tests of

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motor-operated valvos (MOVs) performed at its

facilition in response to GL 09-10. In accordance

with 10 CFR Part 21, Liborty Technologies notified

the NRC staff and nuclear power. plant 11consoos in

October 1992 of a generic issue rogarding the

accuracy of its VOTES diagnostic equipment. At

tho time of the inspection at Zion, CECO had

completed a proliminary evaluation of the MOV test

data including an initial effort at addressing the

offect of the increased inaccuracy of the VOTES

equipment. In an internal memorandum dated

October 29, 1992, CECO stated that its.

consideration of the increased inaccuracy of the  :

VOTES equipment would be completed within six  ;

months of recolpt and validation of now VOTES '

software, received in December 1992. Tho.licensoo

indicated plans to adhere to this schedulo during

the inspection.

b. Associated Procrammatic Reviews

The NRC inspectors reviewed other licensco programs

associated with MOVs.

(1) Desian Control for Thermal Overload Protection [

The NRC inspectors reviewed the methods for design f

control of thermal overloads (ToL) .- .The method by ,

which most TOLs in the-plant were selected was

acceptable. The procedure for selection of future

TOLs was reviewed and found to offer some

additional conservatism. TOLs selected by either

method conform to NRC guidance. ,

(2) MOV Sotooint Control

The NRC inspectors reviewed-documentation and "

discussed the MOV sotpoint control program with' ,

cognizant licensoo' personnel. Zion-has devoted  !

considerable recourcos to this area as a result of

previous inspection-findings. The MOV sotpoint '

control program was considered to be acceptable.

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(3) Maintenance

The nominal proventive maintenance-(PM) frequency '

was 36 months, which excooded the manufacturer's

(Limitorque) recommended frequency for stem

lubrication of 18 months. The exact effects of

the extended maintenance frequency are not known;

however, some additional degradation and increased i

stem factors would be expected. The licenseo

planned to perform some static as-found diagnostic

testing to justify their position. Such

justification would be better supported by as-

found design basis testing because of

uncertainties in the relationship betwoon the

performanco of MOVs under static and design basis

conditions.

The NRC inspectors reviewed the licensee's

practico in the area of valvo stem packing

adjustments. Procedure ZAP 400-04 specified to_ '

perform VOTES testing following packing

adjustments if the thrust margin is narrow,

othorwise, a motor curront signature test was

performed after packing adjustmonts. _Since the

MOV coordinator is involved with the work analyst-

in datormining the appropriato post maintenance

testing for all MOV maintenanco, this.should

provido adequate control.- In general,.tho MOV .

coordinator's close involvement in planned ,

maintenanco, post maintenance testing (PMT), and

static and dp-testing was considered to be a

positive aspect ofl the program.

The refurbishment _of MOV-operators and tho' ,

calibration testing of several Limitorque spring

packs was observed. No significant irregularities

wero dotected. . ' Calibration testing was:a-regular

portion-of refurbishment and was used to_ confirm-

that-there was no degradation of spring. pack'

mechanical characteristics and to provido

individual (rather than generic) information for

each spring pack. Having this information

available improved the~ accuracy:with which MOV

thrust or torque was predicted = prior to VOTES

testing.- Making use of'this method of-improved-

MOV-performance control is considered-a~ strength.

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(4) Training

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The MOV training program for electrical and

mechanical mairitenance personnel was reviewed and

found to be acceptable in-content, duration,  ;

examination difficulty, and record maintenance.-

(5) Qngratina Experience and' Vendor Notification

The NRC inspectors reviewed applicable procedures

and discussed the process for handling various

information notices, VOTES Hot Tips, customer -

Service Bulletins, Limitorque Maintenance' Updates,

and vendor notifications. Steps had been taken to

ensure that information received was screened,

evaluated and maintained by appropriate ,

organizations and that appropriate actions were

planned. The Zion program for the processing and

control of operating exp3rience and vendor

notifications was found to be acceptable.

(6) Dinanostics

The VOTES system was used to test MOVs under both

static and dynamic conditions. During the VOTES

testing, one parameter that_is measured is-inrush

current data, which'was measured with an

uncalibrated probe. Since this reasured data is

important in validating locked rotor current

assumptions used in the capability assessments, i

the inspectors were concorried with the use of an

uncalibrated probe. Xn response to the

inspectors' concerns, the licensee committed to

obtain and use a calibrated current probe as soon-

as the probe is available and procedure revirions

are completed. This item is considered an open

item -(50-295/92030-05 (DRS) ; 50-304/92030-05(DRS)).

(7) ILalh519ED

The inspectors performed a general inspection of

the plant as well as a detailed inspection of-

MOVs. In generale. housekeeping appeared to bei

good. There was no obvious inconsistency.in

lubrication of valve stems, even on several valves

on which the bodies and bonnets were heavily

rusted. 1

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. . _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ - _ - _ - - _ - _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - - _ _ - _ - _ _ _ _ _ _ .

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(8) Backseatino of Valvos )

The licensco routinely backsoats four valvest

1RH8701, 1RH8702, 2RH8701 and 2RH8702. Although J

olectrical b3cksoating is generally conaldered to I

bo harmful to valvoa, thoso MOVs are exceptions. ]

The manufacturer's instruction manual recommendu ,

backsoating those valvos and backsoating thrust i

critoria are proscribed. Under thoso conditions,

backscating is acceptablo. ,

3. Licensco Self Angessment

'

Efforts in this area were acceptable, but limited in scopo.

Self-assosoment carried out in the area of the GL 89-10  ;

program concentrated on MOV sotpoint control. Thio.lo an

important area and ono in which Zion has experienced.

difficulties in tho.past. Although the assessnont was

performed with appropriate depth and objectivity, it covered

only a small portion of the program. For examplo, the

engincoring ovaluation of MOV test data was not examined.

Failure to promptly evaluato data could result in long term-

use of an MOV-that toat data indicated to bo inoperable.

Self-asanoament in thin area might have averted the

violation included in this report. Additional coverage of-

the remaining portions of the program in expected.

4. Qggn.Itong

open itoma are matteru that have boon discussod'with the.

licensoo, which will be reviewed further by the-inspector,

and which involvo some action on the part of the NRC,

licensoo, or both. An open item disclosed during the

inspection is discussed in Sections 2.b.(6)

5. Unrosolved Items

Unrosolved items are matters-about.which more information in-

required in order to ascortain whether they are acceptable

items, items of noncomplianco, or deviations. Unrosolved

~

items disclosed.during-this inspection are discuased in.

Sections-2.a.(3) and 2.a.(4) of this report.

6. Exit Mgotinq

r

The inspectors mot with licensee representativos (denoted in

Section 1) at the conclusion of the inspection on'

December' 22,-1992. -In-addition, a follow-up'tolophone:

conference was hold betwoon licensoo~representativos and the

Region III office on January 4, 1993;- The inspectors

summarized the purpose and scope of the inspection andithe

findings.- The inspectors informed the licenson-of'tho1

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violation,'three unresolved items, and one open item ,

'

identified during this inspection. The inspectors also-

discussed the likely informational content of the inspection l

report with regard to documents or processes reviewed by the i

inspectors during the inspection. Several documents wore

identified as-proprietary but were not noted in this report. ,

?

e

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