ML20128L026
| ML20128L026 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 06/12/1985 |
| From: | Cantrell C, Hehl C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20128K994 | List: |
| References | |
| 50-395-85-21, NUDOCS 8507110200 | |
| Download: ML20128L026 (11) | |
See also: IR 05000395/1985021
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION It
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101 MARIETTd STREET, N.W.
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ATLANTA, GEORGI A 30323
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Report No.:
50-395/85-21
Licensee: South Carolina Electric and Gas Company
Columbia, SC 29218
Docket No.:
50-395
License No.: NPF-12
Facility Name:
V. C. Summer
Inspection' Conducted: May 1-31, 1985
Inspector:
%S _
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C. W. Hehl V
y
Datie Signed
Approved by:
ef4D A
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F. S. Cantrell, SecLtp' fKhief
Date Signed
Division of Reactor Projects
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SUMMARY
Scope: This routine, unannounced inspection entailed 166 inspector hours onsite
in the areas of plant tours; operational safety verifications; monthly surveil-
lance observations; monthly maintenance observations; followup on written reports
of non-routine events; licensee action on previous enforcement items; and
followup on operating reactor events.
Results: Two violations were identified - failure to implement the requirement
to accurately measure and record and apply the necessary correction factor for
electrolyte level during a monthly battery inspection; failure to promptly
classify and initiate required notifications for an event requiring declaration
of Notification of Unusual Event.
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
0. Bradham, Director, Nuclear Plant Operations
- K. Woodward, Manager, Operations
B. Williams, Supervisor of Operations
- M. Quinton, Manager, Maintenance
M. Browne, Manager, Technical Support
- B. Croley, Group Manager, Technical and Support Services
- S. Hunt, Assistant Manager, Surveillance Systems
- H. Sefick, Associate Manager, Station Security
- D. Nauman, Director, Nuclear Services
- M. Blue, Engineer, Nuclear Licensing
- M. Irwin, Nuclear Licensing Technician
- J. Connelly, Deputy Director, Operations and Maintenance
- D. Lavigne, Manager, Quality Control
- R. Campbell, Engineer, ISEG
- F. Zander, Manager, Nuclear Technical Education and Training
- G. Putt, Manager, Scheduling and Materials
- C. McKinney, Regulatory Compliance
- R. Fowlkes, Regulatory Compliance
- D. Fleming, Regulatory Compliance
Other licensee employees contacted included engineers,
technicians,
operators, mechanics, security force members, and office personnel.
Other Organizations
- Attended exit interview
2.
Exit Interview (30703)
The inspection scope and findings were summarized on May 31, 1985, with
those persons indicated in paragraph I above.
The inspector described the
areas inspected and discussed in detail the inspection findings.
Two
violations were identified:
Violation 395/85-21-01:
Failure to implement the requirements of
Electrical Maintenance 115.011 during performance of the monthly
battery inspection.
Violation 395/85-21-02:
Failure to implement the requirements of the
facility Radiation Emergency Plan in a timely manner following the
identification of an event requiring the declaration of Notification of
Unusual Event.
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During this inspection, the licensee did not identify as proprietary any of
the materials provided to or reviewed by the inspector.
3.
Licensee Action on Previous Enforcement Items (92702)
(Closed) - Violation (VIO) 84-11-02, Failure to Follow Procedures. This
violation resulted from personnel errors which caused an apparent loss of
operating shift awareness of safety system status. The inspector reviewed
licensee documentation regarding implementation of corrective actions
delineated in their response to the violation. The inspector was satisfied
that the corrective actions had been implemented.
(Closed) - VIO 84-27-01, Failure to Comply with Dress Requirements of RWP.
This violation occurred when a worker disregarded the requirements of the
RWP by not wearing a surgeon's cap during performance of decontamination
activities.
The inspector reviewed the licensee's corrective action
commitments and determined that this corrective action was adequate and had
been properly implemented.
(Closed) - VIO 84-25-02, Failure to Perform 10 CFR 50.59 Review of Drag Test
Procedure.
In inspector reviewed implementation of the licensee's
corrective action commitments.
These commitments were found to be accept-
ably implemented.
(Closed) - VIO 84-25-03, Failure to Perform Calibration of Load Cell. The
inspector reviewed implementation of the licensee's corrective action
commitments.
These commitments were found to be acceptably implemented.
(0 pen) - VIO 84-25-04, Failure to Have a Qualified Crane Operator During Use
of Spent Fuel Bridge Crane.
In their response to this violation, dated
November 2,1984, the licensee committed to upgrading and tracking of the
crane operator training programs.
This corrective action was to be
completed by January 31, 1985.
Inspector review of implementation of this commitment determined that
upgrading of the crane operator training program had occurred and that this
upgraded program was utilized to train the first group of crane operator
requiring training after January 31, 1985.
This first group of crane
operators to train under the upgraded program received their training
beginning February 20, 1985. Nuclear Education and Training (NE&T) Group
Manual,Section III.B.I.1, Rigging and Crane / Hoist Operator Training, is the
procedure governing conduct of this training.
Inspector review of this
procedure determined that it appeared adequate to control the training
addressed. Additionally, it was determined that although implemented on
February 20, 1985, it had not been formally reviewed and approved until
May 1, 1985. The companion training program manual, Rigger, and Crane and
Hoist Operator Qualification Manual, which implements the training program
described in the NE&T Section III.B.1.1, likewise was implemented for the
February 20, 1985 training, but as of the date of this review, May 28, 1985,
had not received formal review and approval.
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10 CFR 50, Appendix B Criteria VI, requires that measures be established to
control the issuance of documents such 'as instructions and procedures,
' , , including changes thereto, which prescribe activities affecting quality.
ANSI N18.7, 1976, paragraph 5.2.15, states that the administrative controls
and quality assurance program shall provide measures to contrcl and
coordinate the approval and issuance of documents, including ch2nges
thereto, which prescribe all activities affecting quality and that these
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measures shall assure that documents, including revisions and changes, are
reviewed and approved.
Paragraph 5.2.15 also states that ecch procedure
shall be reviewed and approved prior to initial use.
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The V.C. Summer Operational Quality Assurance Plan, Section 5.0, Document
Control, implements the requirements of 10 CFR 50, Appendix B, and ANSI
N18.7Property "ANSI code" (as page type) with input value "ANSI</br></br>N18.7" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., 1976, by specifying that organizational procedures be established to
control the review, approval and release for issuance and implementation of
the documents for which it is respons'.ble.
The Nuclear Education and Training Group Manual,Section I.B.16, Training
Manual Revelopment, implements the above requirements by deiineating a
controlled process for preparation, review and comment, approval, control
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and distribution of changes to that manual. As described in this section,
implementation of manual changes follows review and approval.
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Therefore the implementation of the aforementioned Section III.b.1.1 of the
Nuclear Education and Training Manual and its associated Qualification
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Manual prior to review and approval was nce' in compliance with the above
requirements.
Subsequent discussions with the licensee has determined that
these apparent noncompliancesjuere previously identified by onsite QA during
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a surveillance verification of th#s corrective action commitment for
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violation 84-25-04. The inspector reviewed documentation of this QA audit,
findings
and
associated
correspondence,
QA Type
II
Surveillance
rf '$ Audit II-16-84-C. The inspector's review determined that the licensee's QA
organization had previcurly identified these noncompliances and are
presently working to obtain a satisfactory resolution. Therefore, as is the
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NRC practice, no violation will be issued for these noncompliances.
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Inspector review of the 7,1censee's commitment with regard to tracking of
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crane operator quaiifications determined that a computer based tracking
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system was in place to accomplish this function. .but due to some errors
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introduced during the input of data, this tracking system did not at the
time of this inspection accurately reflect individual crane operator
qualification. As a result of this finding, the inspector made a spot check
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of personnel presently performing crane operations against the hard copy
record of their qualification.
No deficiencies were identified.
Discus-
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sions with training management determined that the apparent inaccuracy of
the computer tracking system had been previously identified by the Training'
Department and corrective action was in progress.
The licensee committed
resolving these tracking system deficiencies and verifying its accuracy by
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May 31, 1985.
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This item, VIO 84-25-04, will remain open pending followup on the tracking
system corrective action identified above, and inspector review of the
properly reviewed and approved Rigger, Crane and Hoist Operator Qualifi-
cation Manual.
4.
Operational Safety Verification (71707, 71710)
The inspector observed control room operations, reviewed applicable logs and
conducted discussions with control room operators during the report period.
The inspector verified the operability of selected emergency systems,
reviewed removal and restoration logs, and tagout records, and verified
proper return to service of affected components.
Tours of the control,
auxiliary, intermediate, diesel generation, service water and turbine
buildings were conducted to observe plant equipment conditions including
potential fire hazards, fluid leaks, and excessive vibrations, and to verify
that maintenance requests had been initiated for equipment in need of
maintenance. The inspector, by observation and direct interview, verified
that the physical security plan was being implemented in accordance with the
Station Security plan. No violations or deviations were identified in this
area.
5.
Surveillance Observation (61726)
During the inspection period, the inspector verified by observation / review
that selected surveillances of safety-related systems or components was
conducted in accordance with adequate procedures, test instrumentation was
calibrated, limiting conditions for operation were met, removal and
restoration of the affected components were accomplished, test results met
requirements and were reviewed by personnel other than the individual
directing the test, and that any test deficiencies identified during the
testing were properly reviewed and resolved by appropriate management
personnel.
No violations or deviations were identified in this area.
6.
Maintenance Observation (62703)
Station maintenance activities of selected safety-related systems and
components were observed / reviewed to ascertain that they were conducted in
accordance with regulatory requirements.
The following items were
considered in this review: the limiting conditions for operations were met;
activities were accomplished using approved procedures; functional testing
and/or calibrations were performed prior to returning components or systems
to service; quality control record were maintained; activities were
accomplished by qualified personnel; parts and materials used were properly
certified; and radiological controls were implemented as required. Mainte-
nance Work Requests were reviewed to determine status of outstanding jobs to
assure that priority was assigned to safety-related equipment which might
affect system performance.
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On May 3,
1985, the inspector observed Electrical Maintenance personnel
performing a monthly preventative maintenance inspection on station safety
related battery XBA-1A and a daily preventative maintenance on station
safety related battery XBA-18.
The governing procedure for performance of these preventative maintenance
inspections is Electrical Maintenance Procedure (EMP) 115.011, Battery
Inspection. The procedure in use on May 3,1985 was EMP 115.011, Revision
4, issued March 26, 1985.
EMP 115.011, step 7.2, requires, as part of the
monthly inspection, that the electrolyte level below the full mark be
measured and recorded for each cell. EMP 115.011, step 7.2.3, requires that
the level correction factor be determined for each cell and the specific
gravity measurement be adjusted to obtain the corrected specific gravity.
Attachment 10.1 to EMP 115.011 specifies that a correction of 0.00375 be
subtracted from the specific gravity measurement for every one-eighth inch
of level below full.
Inspector review of the data taken during the May 3,1985 performance of
EMP 115.011 determined that the electrolyte level of each cell had not been
accurately measured and recorded in that the data sheet failed to identify
that the cells listed below had electrolyte levels below full.
Cell
Electrolyte Level (inches below full)
3
-1/8
4
-1/8
10
-3/8
31
-1/4
47
-3/16
50
-1/4
The corrected specific gravity readings recorded on the EMP 115.011 data
sheet did not correct for these deviations from full.
Technical Specification 6.8.1.a.
requires that the applicable procedures
recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February
1978 be established, implemented and maintained. Appendix "A" of Regulatory
Guide 1.33 recommends procedures for performing maintenance.
EMP 115.011
implements this requirement for the periodic preventative maintenance
inspection of the station batteries. The above noted failure to accurately
measure and record the individual cell levels and apply the required level
correction factors to obtain the corrected specific gravity for the above
cells is a failure to adequately implement EMP 115.011.
This failure to
adequately implement EMP 115.011 is a violation (85-21-01).
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-7.
On Site Followup of Written Reports of Non-routine Events (92700)
The inspector reviewed the following Licensee Event Reports (LERs) to
ascertain whether the Licensee's review,~ _ corrective action, and report of
the identified event and associated conditions were adequate and in
conformance with regulatory requirements, Technical Specifications, license
conditions, and licensee procedures and controls.
-(Closed)
LER 84-022, Failure to Maintain Required Boration Flow Path.
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(Closed)
LER 84-021, Degraded Kaowool Fire Wrap.
(Closed)
LER 83-144, Erratic Behavior of Powe- Ranga Nuclear Instrument.
(Closed) LER 84-050, Actuation of RPS With Plant in Mode 3 Due to Personnel
Error.
(Closed)
LER 85-005, Reactor Trip Resulting From MSIV Closure Caused by
Faulty Test Switch.
(Closed)
LER 85-003, Reactor Trip on High Flux Positive Rate. This LER
reported the February 28, 1985 startup during which a reactor trip occurred
on high flux positive rate trip.
The inspector reviewed and verified
implementation of the corrective action identified in the LER. The results
of this review were satisfactory.
(Closed) LER 83-136, Isolation of RHR System While in Mode 5.
This event
resulted in a licensee commitment to generate APN power distribution lists
to enhance operator anticipation of plant instrumentation responses during
transients where power is lost to or removed from vital instrument power
supply panels. Inspector review determined that the committed to APN feeder
lists had been generated.
(Closed) LER 85-001, Rod Control System Failure.
8.
Onsite Followup of Operating Events
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a.
At 5:20 a.m. on May 9, 1985, in accordance with the facility Radiation
Emergency Plan, a Notification of Unusual Event (N.U.E.) was declared.
The condition resulting in the N.U.E. was the simultaneous inopera-
. bility of both emergency diesel generators (DG) for a period of greater
than one hour. The Unit was in Mode 3 (Hot Standby) at the time of
this event. At 1:30 p.m. on May 9,1985, the necessary repairs and
testing to return DG "A" to operability were completed and the N.U.E.
was terminated. Preceding this event, the plant had been shutdown for
a preplanned maintenance outage which began on April 29, 1985.
On
May 1,1985, at the time the DG's were declared inoperable, the unit
was c' a heatup to rated temperature and pressure in anticipation of a
reacter startup and return to power.
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At 7:30 p.m. on May 8, 1985, during routine surveillance testing of DG
"A", in accordance with Surveillance Test Procedure (STP) 125.002, the
automatic voltage regulator failed.
During surveillance testing, the
DG started satisfactorily and achieved the desired voltage and
frequency within the required 10 seconds.
During the subsequent
attempt to synchronize with the off site grid, the control room
operator determined that remote automatic voltr.ge control was not
functioning properly.
Local control of the automatic voltage regulator was attempted, but was
likewise unsuccessful. DG "A" was shutdown and subsequently declared
The automatic voltage regulator (AVR) circuitry is locked into a preset
position during operation of the DG in response to an Engineered
Safeguard Feature (ESF) signal. Following each shutdown of the DG, the
AVR returns to this preset position such that on a subsequent restart
of the DG, it will achieve the require voltage to satisfactorily power
its associated ESF equipment.
The manual voltage regulator was
unaffected by the above failure of the automatic circuitry.
With one DG inoperable, Technical Specification (TS) 3.8.11 requires
that the other DG be demonstrated operable within one hour.
At
7:50 p.m. on May 8,1985, DG
"B" was started and proper voltage and
frequency were obtained within the required 10 seconds. As usual for
the starting of large pieces of equipment at V.C. Summer, a local
operator was positioned in the DG room to record locally available data
and to monitor equipment performance.
Discussions with licensee
personnel determined that just prior to securing the DG following the
successful operability start, the operator reported hearing a loud
bang.
Upon investigation, the local operator found water on the side
of the DG in the vicinity of cylinder no. 1.
The DG was immediately
shutdown and declared inoperable. Initial licensee investigation into
the DG "B" failure found several ounces of water in the no. 1 cylinder.
No water was found in the remaining other eleven cylinders.
Following unsuccessful initial attempts to return either DG to operable
status, at 5:20 a.m. on May 9,1985, the licensee declared the N.U.E.
The NRC Emergency Operations Center was notified of the N.U.E.
at
5:45 am on May 9, 1985.
Subsequent troubleshooting of the DG
"A" determined that the AVR
potentiometer had mechanically " frozen" in position near one end of its
travel causing diodes controlling the potentiometer drive motor and the
drive motor to fail. A replacement AVR was obtained from the licensee
warehouse and installed, but this AVR was found to have a defective
drive motor.
With no other AVR's available on-site or readily
obtainable from the vendor, the AVR from DG "B"
was removed and
installed in DG "A".
Following successful post-maintenance test and
the performance of a successful STP operability test, at 1:30 p.m. on
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May
9,
1985, DG
"A" was declared operable and the N.U.E. was
terminated.
In accordance with vendor recommendations, the no. I cylinder liner,
cooling jacket, cylinder head and injector were removed from DG "B" and
subjected to hydrostatic testing to identify the source of the water in
leakage. Hydrostatic testing of these components determined that the
fuel injector cooling jacket had developed a cooling water leak near
the tip of the injector which projects into the cylinder through the
head. This injector had been installed approximately a week prior to
its failure during a scheduled 18 month inspection of DG
"B", which
included replacement of all injectors.
Following this 18 month
inspection, DG "B" had successfully completed the full load 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run
described in TS 4.8.1.1.2.d.7.
The failed injector was "new" at the
time of installation.
At the time of this event, pre-installation
hydrostatic testing of injectors was not a vendor recommended action
nor an action required by the licensee's procedures. The licensee is
adding to their procedures a requirement to hydrostatically test each
injector prior installation.
Prior to reassembly of DG "B",
the no. I cylinder liner and head were
subjected to liquid penetrant examination; the cylinder cooling water
jacket, head cooling jacket and replacement fuel injector were
hydrostatically tested; the no. 1 piston examined and piston rings
replaced. No damage to these components was identified.
Following reassembly of DG "B", a vendor recommended "run-in" of the
diesel was performed and a successful STP operability test was
performed.
At 3:30 p.m. on May 11, 1985, DG "B" was declared operable.
During this event, the inspector monitored and observed the licensee's
troubleshooting and maintenance activities.
These activities were
conducted in accordance with properly reviewed and approved procedure
and performed by qualified individuals. No deficiencies were observed
during these activities. As a result of this occurrence, a special
inspection was conducted by a team of Region II inspectors. The scope
and results of this inspection are presented in IE Report 395/85-24.
The facility Radiation Emergency Plan, (REP), Table 4-1, identifies
Emergency Action Levels (EALs) which are used to describe each of the
four emergency classes. These EALs are composed of plant parameters
(such as system status) that can be used to give relatively quick
indication to the operating staff of the severity of a situation. The
purpose of the EALs is to provide the earliest possible notification of
actual or potential accident situations.
REP, Table 4-1,
Item 8,
identifies "Both Diesel Generators In Operable for 1 1 hr" as a
detection method for an EAL associated with the N.U.E.
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Station Administrative Procedure (SAP) 200, Conduct of Operations,
requires that -the Shift Supervisors implement established procedures
for normal operations and emergency conditions.
The REP further
clarifies these responsibilities in that the Shift Supervisor, as the
Interim Emergency Director, is responsible for classifying the
emergency and notifying offsite organizations and agencies.
As identified above, by approximately 7:50 p.m. on May 8,1985, both
emergency diesel generators had been declared inoperable, therefore, at
approximately 8:50 p.m. on May 8,1985, the EAL identified in the REP
for declaration of N.V.E. existed. This declaration of N.U.E. did not
take place and notifications to offsite organizations and agencies did
not take place until nearly 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> later. This is clearly a failure
to adequately implement the intent of the REP to, in a timely manner,
classify the occurrence and initiate required notifications.
TS 6.8.1 requires that Emergency Plan Procedures be established,
implemented and maintained. The facility REP was established to meet
this requirement. The above noted failure to adequately implement the
requirements of the REP is a violation (85-21-02).
b.
At 4:08 p.m.
on May 11, 1985, following restoration of the DG as
described above, a reactor startup was initiated in preparation for
returning the unit to power operations.
As required by General
Operating Procedure (GOP)-3, at 5:00 p.m. on May 11, 1985, the reactor
was shutdown by emergency boration and inserting control rods following
criticality at a control rod height (control rod bank C at 69 steps)
below the required Rod Insertion limit (control rod bank C at 118
steps) for the existing plant conditions. The estimated critical rod
position calculation performed for this startup had predicted
criticality at a rod height of 65 steps on control rod bank D.
Initial review of this startup by the licensee and Westinghouse did not
resolve the apparent discrepancy between the actual and predicted
critical rod height. As result of this initial review, Westinghouse
recommended that a subsequent restart of the unit proceed utilizing the
known critical condition data from the aborted startup and compensating
with boron to achieve the desired rod height for criticality.
Following Plant Safety Review Committee concurrence with this
Westinghouse recommendation, a successful startup was performed and
criticality achieved at 3:55 a.m. on May 12, 1985.
On May 13, 1985, a special NRC inspection of this event was initiated,
the results of which are presented in IE Report 395/85-27.
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9.
In-Office Review
The following items were evaluated by the Reactor Safety, Radiation Safety
and Safeguards, and Reactor Projects Regional staff.
Based on this review
and the results of the . latest Resident and Region based inspection
activities in the affected functional areas, . the following items were
determined to require no additional specific followup and are closed.
a.
Inspector Followup Items (IFI):
(82-23-01) Complete Discrepancy Items Noted in TE-1, Rev. 2
(82-04-09) Revise Liquid Scintillation Procedure for H-3 Counting
b.
Part 21 Report:
(P21 82-01) Electrical Control Panels
c.
Unresolved Items (URI):
(82-13-01) Installation of Locking Devices
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