ML20132E499

Insp Rept 50-341/85-29 on 850601-30.No Violation or Deviation Noted.Major Areas Inspected:Licensee Action on Previously Identified Items,Including Fire Prevention/ Protection Program Implementation & Mgt Meetings

ML20132E499
Person / Time
Site:	Fermi
Issue date:	07/26/1985
From:	Wright G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20132E498	List: ML20132E494 ML20132E499
References
50-341-85-29, NUDOCS 8508020003
Download: ML20132E499 (13)

See also: IR 05000341/1985029

Text

.

.

U. 5. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-341/85029(DRP)

Docket No. 50-341 Operating License No. NPF-33

Licensee: Detroit Edison Company

2000 Second Avenue

Detroit, MI 48226

Facility Name: Fermi 2

Inspection At: Fermi Site, Newport, MI

Inspection Conducted: June 1-30, 1985

Inspectors: P. M. Byron

M. E. Parker

D. C. Jones

R. A. Paul

Q L O /1A

Approved by: G. C. Wright, Chief -) /d b!

Projects Section 2C Date

Inspection Summary

Inspection on June 1-30, 1985, (Report No. 50-341/85029(DRP))

Areas Inspected: Routine, unannounced inspection by resident inspectors of

licensee action on previous inspector identified items; independent inspection;

maintenance; surveillance; operational safety - ESF system walkdown; fire

prevention / protection program implementation; allegations, management meetings,

SALP, and initial criticality. The inspection involved a total of 323

inspector-hours onsite by four NRC inspectors, including 82 inspector-hours

onsite during off-shifts.

Results: Five open items, three license condition attachments (one of which

was also an open item), and one noncompliance were closed. Two unresolved and

one open item resulted from this inspection. Within the areas inspected, no

violations, deviations, or significant safety issues were identified.

8500020003 850729

PDR ADOCK 05000341

0 PM

, - ,

_ . . _- _

'

.

.

DETAILS

9

1. Persons Contacted

• F. Agosti, Manager, Nuclear Operations

• L. Bregni, Licensing Engineer

J. DuBay, Director, Planning and Control

0. Earle, Supervisor, Licensing

R. Eberhardt, Rad-Chem Engineer

P. Fessler, Assistant Maintenance Engineer

• E. Griffing, Assistant Manager, Nuclear Operations i

4

W.'Jens, Vice-President, Nuclear Operations

W. Kaczor, Director, SAFETEAM (DECO)

R. Kunkle, Director, SAFETEAM (UTS)

S. Leach, Director, Nuclear Security

J. Leman, Maintenance Engineer

, -L. Lessor, Advisor to the Superintendent, Nuclear Production

, *R. Lenart, Superintendent, Nuclear Production

R. Mays, Director, Project Planning

• W. Miller, QA Supervisor, Operational Assurance

S. Noetzel, Site Manager

J. Nyquist, Assistant to Superintendent, Nuclear Production

G. Overbeck, Assistant Plant Superintendent

J. Plona, Technical Engineer

'

E. Preston, Operations Engineer

W. Ripley, Startup Director

C. P. Sexauer, Nuclear Production Administrator

i G. Trahey, Director, Nuclear QA

l * Denotes those who attended the exit meetings.

I

!

The-inspectors also interviewed others of the licensee's staff during -

this inspection.

2. Followup on Inspector Identified Items

a. -(Closed) Open Item (341/84003-06(DRSS)), and License Condition

Attachment 1, B.2.b: Fabricate and install an intrinsic germanium

detector system post-accident collimator prior to exceeding ~five l

percent power. The licensee fabricated several lead shield

'

collimators for accident condition use with the detector system,

and a calibration was performed for use with a multi-channel

'

analyzer. The licensee demonstrated the use of the collimators i

for the inspectors. ,The inspectors also reviewed selected sections I

of Radiological Engineering Report.No. 85-02, " Calibration of High-

Purity-Germanium Detector-for Use with~ Lead Collimators to Analyze

.High activity Post-Accident Samples."

,

2'

_ _ _. _. .

. - _ . , . _ .

.- - - --

.

.

- b. (Closed) Open Item (341/84039-01(DRP)), and License Condition

Attachment 1, B.1.a: Accessibility of safety-related valves for

serviceability and manual operation. This item identified numerous

inaccessible safety-related valves that would require ladders or

platforms to operate, inspect, and maintain the valves.

(1) Concerning the manual operation of safety-related valves, the

licensee conducted a program that reviewed 217 safety-related

valves for accessibility. Of the 217 valves, 69 or 32 percent

required some form of accessibility aid The results of this

accessibility program are as follows

Temporary scaffolding and lar.ders have been installed in

several cases which will proside an interim resolution

until permanent design chang ss can be implemented.

Portable stands, air hoists, and rolling platforms have

been chained and locked in strategic locations for the

other cases, which will provide a more permanent accessi-

bility. All operators have a key to the locks and have

been briefed on the operation and the locations of these

devices.

(2) Although the accessibility of safety-related valves for

operation was the primary issue of concern, the licensee

has developed a program which will address the issue of

serviceability. The program will consider the same 217

safety-related valves as the operability program, but from

a maintenance perspective. This will be accomplished through

the Engineering Evaluation Request (EER) process which shall

provide an evaluation and design for the permanent installation

of serviceability aids. This item requires further review and

evaluation and is considered an unresolved item (341/85029-

01(DRP)) pending completion of the serviceability program and

_

subsequent NRC inspection.

The licensee has demonstrated adequate accessibility to all con-

cerned safety-related valves. This satisfies the license condition

for criticality and this item is considered closed.

c. (Closed) Open Item (341/84043-05(DRSS)): Complete Installation of

Standby Gas Treatment System (SGTS) sample line heat tracing prior

to exceeding five percent power. The heat tracing has been

installed, and the functional tests have been completed and

reviewed. The inspectors verified the installation of the heat

tracing.

3.

-

.

.

d. (Closed) Open Item (341/84043-10(DRSS)), and License Condition

Attachment 1, B.2.c: Complete a comprehensive review of technical

adequacy, commitment compliance, necessary corrective actions and

associated training for the accident radioactive effluent release

quantification program prior to exceeding five percent power. The

licensee has completed the comprehensive review of technical adequacy

and commitment compliance and taken corrective action by revising

certain emergency response and plant procedures. These actions are

described in a licensee internal document entitled " Accident Radio-

active Release Quantification Program," which the inspectors reviewed.

Also completed are the approval of revised procedures and the training

of personnel on these revised procedures.

e. (Closed) Open Item (341/85010-02(DRP)): Verification of the proper

operation of 24 single coil Target Rock solenoid valves. The 24

single coil Target Rock valves consist of 16 valves in the Post

Accident Sampling System, and 8 valves in the MSIV Leakage Control

System. Preoperational Test Procedure PRET.P3323.001, " Post

Accident Sampling System," included proper operation verification

for 14 of the valves. Plant Operations Manual (POM) Surveillance

Procedure 24.127.20, "MSIV Leakage Control System Local Valve

Position Indication Verification Test," included proper operation

verification for eight of the valves. POM Surveillance Procedure

43.401.383, " Local Leakage Rate Testing For Penetration X-215,"

included proper operation verification for two of the valves. All

single coil Target Rock solenoid valves operated properly. This

item is considered closed.

f. (Closed) Noncompliance (341/85021-01(DRP)): Inadequate implementa-

tion and review of Engineering Design Package EDP-1996 and the accompany-

ing Engineering Change Requests (ECR's) used to verify installation of

test, vent, and drain connection caps. This resulted in: (a) the EDP

verification sheet not adequately reflecting the EDP and its accompanying

ECR's, (b) not all test, vent, and drain (TVD) caps being installed, and

(c) Plant Operations Manual (POM) Procedure 47.000.77, " Test, Vent, and

Drain (TVD) Cap and Plug Verification," omitting a penetration (X-220)

which consists of eight TVD caps. The following licensee corrective

action was implemented:

(1) The EDP verification sheet was corrected to incorporate all

revisions to EDP-1996 and the walkdown was reperformed. Also,

the EDP Implementation Plan was revised as required by POM

Procedure 12.000.64, "EDP Implementation." The individual who

incorrectly implemented this procedure was instructed to read

the procedure again and fully acquaint himself with all of its i

requirements,

i

!

!

i

1

i

4

.

.

(2) Completion of PN-21 No. 992725 and the revised verification

walkdown documents that all caps are now installed in accordance

with EDP 1996 and ECP's 1996-1 and 1996-2. Surveillance Pro-

cedure 47.000.77 has been issued to administrative 1y control

the subject caps. Also, all associated plant drawings will be

updated in accordance with proper procedure to reflect as-built

conditions.

(3) The preparer and the technical reviewer reanalyzed all informa-

tion used to generate Procedure 47.000.77 and corrected the

procedural _ deficiency. They were then instructed by their

immediate supervisors of the importance of checking and

auditing large amounts of technical data systematically and

logically to preclude recurrence of this type of error. The

licensee has guidelines to follow in writing procedures which

are used to ensure correct technical and work content. The

individual was also instructed to acquaint himself with all

the requirements of this procedure.

The plant drawings shall be updated to reflect the as-built condition

of the TVD connection caps by November 30,1985. This item is con-

sidered closed.

g. (Closed) License Condition 2.c.(12): Operability of the permanent

liquid radwaste treatment system prior to exceeding five percent

power. The licensee has completed the preoperational tests and

demonstrated that the system is operable. The system has been

turned over to operations. Several test exceptions which do not

affect the operability of the system remain open. A selected review

of preoperational test results (G1120.001 and G1125.001) was made by

the inspectors. In addition the inspectors walked down several

sections of the liquid radwaste system.

h. (Closed) License Condition 2.c.(16): Operability of the Post-

Accident Sampling System (PASS), THI Action Item II.B.3. The

SER, Supplement No. 5 dated March 1985, states that the applicant

must demonstrate the capability of promptly obtaining a reactor

water coolant sample in the case of an accident, and that the PASS

meets all the requirements of Task Action Item II.B.3 and is

therefore acceptable. Since the SER was written, the licensee has:

demonstrated the PASS operable; approved POM procedure 78.000.14

which provides detailed instructions for the collection and analysis

of samples obtained by the PASS; provided training in the required

procedures; and performed a time and motion study to demonstrate

that PASS samples can be collected, transported, and analyzed in

accordance with NUREG 0737, Regulatory Guide 1.97, and GDC-19 dose

criteria. Selected review of the procedures, training records, and

the time and motion study was made by the inspectors.

5

j

.

.

.

3. Independent Inspection

a. Temporary Solid Radwaste System

The licensee intends to use a portable solid radwaste treatment

system (NUS) to meet their technical specification requirements

until the completion of the preoperational tests and final approval

of the permanent solidification system. The system, which is

l located in the radwaste building, is operable and will be used by

NUS contractor personnel in accordance with approved licensee

procedures. The licensee tested the portable system by solidifying

88 cubic feet of mixed bed bead resin from floor drain and waste

collector tanks to verify the system met the licensee acceptance

criteria. Selected results of these tests were reviewed by the

inspectors; no problems were noted. The inspectors also: discussed

the results of a licensee conducted ALARA review of the temporary

system with radwaste personnel; walked down the system to verify

installation; and observed selected components to identify potential

radiological problem areas. No significant problems were identified.

In a letter to the licensee from the NRC dated July 3, 1985, NRR

approved the licensee Process Control Program (PCP) for the

temporary radwaste system. Based on the acceptance of the PCP, the

demonstration test of the system, and the inspector's review of the

system, it appears the portable system will function as described in

the vendor's topical report (NUS Topical Report PS-53-00378) which

was submitted to the NRC by the licensee.

No violations or deviations were identified in the review of this

program area.

b. Onsite Storage Facility (OSSF)

The licensee's onsite storage facility is described in Section 11B.1

of the FSAR. The facility is intended to provide interim storage

capacity for an amotint of waste which could be generated in five

years of plant operation. -During this inspection, and a previous

inspection (Report No. 50-341/85017(DRSS)), tours and discussions

concerning the OSSF were made. The tours were made to verify that

selected systems and components (including area radiation and

effluent monitors) were installed in accordance with the FSAR and to

identify any potential radiological problem areas. No problems were

noted.

During these tours and discussions with the licensee, special atten-

tion was given to the handling, decontamination, smearing, and

surveying of dry active and solidified waste drums; to the HVAC

,

6

4

• e

i

.

.

system; to the design features to ensure ALARA; and to the portable

solid radwaste system located in the truck bay area of the OSSF.

Radiation protection features of the OSSF include: protective

barriers around the stored waste to prevent uncontrolled releases to

the environment, remote handling of the waste drums, routing of all

potentially contaminated drains from the OSSF to plant liquid

radwaste system (the licensee verified each floor drain from the

OSSF is routed to the liquid radwaste system), and monitoring and

filtration of gaseous and particulate effluents.

One ALARA problem was noted in that no shielding had been provided

in the radwaste barrel readout area, nor had provisions been made to

read out the barrels remotely. The licensee stated they would

review the read out system and make improvements where feasible.

This program area requires further review and evaluation and is

considered an open item (50-341/85029-02(DRP))

No violations or deviations were identified in the review of this

program area.

c. SAFETEAM

The Office of Investigation (OI) reviewed the investigative results

of SAFETEAM concerns based on issues raised during the licensing

process of another utility. June 11-13, 1985, OI investigators

reviewed the SAFETEAM investigators' packages for those concerns

which had been identified as wrongdoing. The wrongdoing concerns

had been forwarded to Region III as they had been identified. OI

investigators expanded the scope of their review when they returned

June 18-20, 1985, to include the completed investigative packages of

those concerns which the investigators deemed as potential wrongdoing

based on the description listed in the SAFETEAM computor printout.

The review included listening to the tapes, reading the transcription,

and reviewing the documentation in the packages.

The Director of OI, members of his staff, and NRR attended a

briefing at the site on June 19, 1985, by the licensee and the OI

investigators.

1

As a result of the OI concerns, a task force composed of individuals

from NRR, I&E, and Region III were at the site June 27 and 28, 1985,

to perform a more detailed investigation of SAFETEAM concerns for

technical merit and a comparison of the SAFETEAM off ort with that of

a similar undertaking by another utility.

The inspectors supported the OI and task force efforts.

In conjunction with this effort, the inspectors and the licensee

performed an inspection of the safety-related SAFETEAM findings at

the request of Region III. The inspectors reviewed the SAFETEAM

findings to determine if investigative effort adequately addressed

the concern and if the corrective action had been completed.

i

i

i 7

!

l

f

.

.

.

Also, the licensee performed an independent inspection of the

SAFETEAM findings to verify adequacy of investigation and corrective

acti'on. Through discussions with the licensee, the licensee agreed

to review fifty percent of the hardware and software safety-related

concerns. The inspectors reviewed a sampling of the remaining fifty

percent of the safety-related concerns. The results of these

inspections will be documented in Inspection Report 50-341/85037.

No violations or deviations were identified in the review of this

program area.

d. Operational Readiness

The licensee continues to make progress in its preparations for

power ascension. Fire detector installation, fire door inspection,

and the off gas system appear to be the most significant critical

path items.

Senior Region III management met with licensee management twice

during the inspection period to review the status of items affecting

initial criticality and power ascension, license conditions and

other areas of mutual interest.

No violations or deviations were identified in the review of this

program area.

e. Independent Operational Readiness Assessment Inspection

A Region III team composed of experienced resident inspectors per-

formed an operational readiness inspection at Fermi 2 during

June 17-22, 1985. The purpose of the team inspection was to observe

the licensee's operations and review proceduras to identify strengths

and weaknesses. The team concluded that there were no significant

weaknesses observed and the plant was ready for power ascension.

This inspection is documented in Inspection Report 50-341/85031(DRP).

No violations or deviations were identified in the review of this

program area.

4. Fire Prevention / Protection Program Implementation

The inspectors observed the progress of License Condition 9.e. which

requires that prior to exceeding five percent power, all early warning

fire detectors shall be installed and all fire door assemblies shall be

labeled or listed by a nationally recognized testing laboratory. The

inspectors additionally performed a more detailed examination of the

corrective action by the licensee on a sample basis to determine if the ,

programmatic requirements were being met. i

' l

No violations or deviations were identified in the review of this program I

)

area.

'

!

l

.

8

_

.

.

5. Monthly Maintenance Observation

Station maintenance activities of safety-related systems and components

listed below were observed to ascertain that they were conducted in

accordance with approved procedures, regulatory guides, and industry

codes or standards and in conformance with Technical Specifications.

The following items were considered during this review: the limiting

conditions for operation were met while components or systems were

removed from service; approvals were obtained prior to initiating the

work; activities were accomplished using approved procedures and were

inspected as applicable; the procedures used were adequate to control

the activity; quality control records were maintained; activities were

accomplished by qualified personnel; parts and materials used were

properly certified; radiological controls were implemented; and fire

prevention controls were implemented.

The following maintenance activity was observed:

Reactor Water Cleanup (RWCU) Recirculation Pump Rotating

Assembly-Removal and Installation

Removal of RWCU recirculation pump "A" rotating assembly was performed

to replace seals and the impeller. Plant Operations Manual (POM)

Maintenance Procedure 35.000.68, Revision 1 dated February 21, 1979,

"RWCU Recirculation Pump Rotating Assembly-Removal and Installation,"

was used to provide detailed instructions for removal, disassembly,

inspection, assembly, and installation of the RWCU pump. The inspectors

witnessed portions of this maintenance and identified several areas of

concern.

a. Sections 7.1.4.1 through 7.1.4.4 of Procedure 35.000.68 describe

the steps used in draining the bearing housing oil. This was to be

done prior to the removal of the back pull-out section of the pump.

However, this was not done, resulting in the oil draining out onto

the floor during transfer to the rolling cart, and oil draining out

onto the rolling cart which, in turn, tracked the oil as it was

rolled to the workshop.

b. Sections 7.1.7 and 7.1.8 and Reference 3.10 (POM Procedure

32,000.06, " Rigging") of Procedure 35.000.68 provide instructions

for the use of. a chain hoist and suitable sling. The hoist and

sling are used to support the back pull-out when the casing stud

nuts are removed and to facilitate simplified removal of the back

pull-out section. However, the maintenance personnel transferred

the back pull-out section to the rolling cart by hand. This

resulted in three men lifting and carrying the heavy and awkward

pump to the cart with oil draining significantly (see preceding

paragraph). Also, Procedure 35.000.68 requires that reference 3.10,

POM Procedure 32.000.06 " Rigging," is to be "used". Section 3.0,

" Rigging Preplanning," of this procedure states "... determine the

weight of the load." The inspectors observed that the licensee did

not observe this requirement of the procedure.

9

_.

.

.

l

c. The note on page 3 of Procedure 35.000.68 states, " Procedure steps

may be performed out of sequence with the prior approval of the

DECO Maintenance Foreman (as a minimum). This statement is

,

applicable until fuel load." However, section 7.5.11 which states. .

"to refill the bearing house with Shell Vitrea Oil," was performed

af ter Sections 7.5.12 and 7.5.13. Therefore, the procedure was

performed out of sequence which is a failure to adhere to procedural

requirements.

d. There is no procedural step requiring the removal of the casing

studs. Removal of the back pull-out section is obstructed by the

casing studs and might cause damage to the studs, the pump shaft,

the motor shaft, or the coupling hubs. This item has been discussed

with the licensee.

e. There are two alignment screws on the pump that are used to align

the pump shaft with the motor shaft. These screws, once the pump is

properly aligned, are maintained in their proper positions during

operation by tightening down the nut on each screw. However, the

inspector observed that this had not been done and subsequently

requested the maintenance personnel resolve the problem. In a

discussion with the System Engineer and the Assistant Maintenance

Engineer it was concluded that the vibration during operation could

have shifted the alignment of the pump and, in turn, possibly caused

damage to the pump.

f. The RWCU pumps receive reactor water at a temperature of up to

575* F. This high temperature on the pump side may present a

coupling alignment problem due to thermal expansion. This issue

is not addressed in the coupling alignment section of Procedure

35.000.68. The licensee is performing an analysis that shall

resolve this issue.

The inspector will perform additional inspection of this program area to

determine if there is a widespread problem. This shall be accomplished

by further inspection of the adequacy of the licensee's maintenance

supervision and performance of maintenance activities. The above

concerns in this program area are considered to be an unresolved item

(341/85029-03(DRP)) pending further evaluation as to whether these

items are isolated cases are are more widespread.

!

6. Monthly Surveillance Observation

The inspectors observed surveillance testing required by technical speci-

fications and verified that: testing was performed in accordance with

adequate procedures, test instrumentation was calibrated, limiting condi-

tions for operation were met, removal and restoration of the affected

components were accomplished, test results conformed with technical

specifications and procedure requirements and were reviewed by personnel

other than the individual directing the test, and any deficiencies identi-

fled during the testing were properly reviewed and resolved by appropriate

management personnel.

10

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

. . . .

.

.

The inspectors also witnessed portions of the following test activities:

Local Leakage Rate Testing for Penetration X-13A

RHR Pressure Isolation Valve Leakage Test

Local Leakage Rate Testing for Penetration X35B,C,D,E,F

No violations or deviations were identified in the review of this program

area.

7. Operational Safety Verification

The inspectors observed control room operations, reviewed applicable

logs, and conducted discussions with control room operators during the

period from June 1 to June 30, 1985. The inspectors verified the

operability of selected emergency systems, reviewed tagout records, and

verified proper return to service of affected components. Tours of the

reactor building and turbine building were conducted to observe plant l

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.

During the inspection period the inspectors verified that surveillance

tests were conducted, containment integrity requirements were met, and

emergency systems were available hs necessary.

The inspectors, by observation and direct interview, verified that the

physical security plan was being implemented in accordance with the

station security plan.

The inspectors observed plant housekeeping / cleanliness conditions and

verified implementation of radiation protection controls. During the

inspection, the inspectors walked down the accessible portions of the

Low Pressure Coolant Irjection System and Core Spray System to verify

operability by comparing system lineup with plant drawings, as-built

configuration or present valve lineup lists; observed equipment condi-

l tions that could degrade performance; and verified that instrumentation

was properly valved, functioning, and calibrated.

These reviews and observations were conducted to verify that facility

operations were in conformance with the requirements established under

technical specifications, 10 CFR, and administrative procedures.

I

No violations or deviations were identified in the review of this program

area.

8. Allegation

An anonymous allegation was made to Region III stating that frequent door

checks by security personnel increase the potential for radiation exposure

and therefore are contrary to ALARA guidelines.

'

11

.

This allegation was discussed with licensee personnel, who walked down

each vital area door which is routinely checked by security personnel.

The results of the licensee's review indicated that of all vital area

doors which are routinely checked by security personnel, only one is

located in a potential radiation area (between the auxiliary and off-gas

buildings), and none are located in high radiation areas. Entries into

areas posted and controlled as radiation areas are routine and are not

normally cause for significant ALARA concerns. No significant ALARA

~

concern was identified in this case.

This allegation was not substantiated.

No violations or deviations were identified in the review of this program

area.

9. Systematic Assessment of Licensee Performance (SALP)

A mid-term SALP was performed prior to the Commission briefing for the

full power license. The assessment period was frcs October 1, 1984, to

June 30, 1985. Major activities which occurred during the assessment

period were the completion of preoperational testing, initial fueling and

initial criticality. The SALP Board met on June 28, 1985, to review the

assessments, rate each functional area, and make recommendations as to

both licensee and NRC attention. The mid-term SALP will be presented on

July 2, 1985, at Newport, Michigan, and documented in Inspection Report

50-341/85027.

No violations or deviations were identified in review of this program

area.

10. Initial Criticality

The licensee achieved initial criticality on June 21, 1985, at 5:19 a.m.

EDT. The event was witnessed by the Deputy Regional Administrator -

Region III, the assigned Section Chief, and a regional inspector in

addition to the Senior Resident Inspector. Criticality was achieved

within two steps of the predicted step of the rod pull sequence.

Additional details of this event are documented in Inspection Report

50-341/85036(DRS).

No violations or deviations were identified in review of this program

area.

11. Management Meetings

A management meeting was held at Region III on June 14, 1985, at the

request of the licensee. The licensee discussed their proposed

reorganization of Nuclear Operations. The current organization is

considered to be structurally flat in that all organizations, with the

exception of Quality Assurance, report directly to the Manager of Nuclear

Operations. The licensee determined that the current organizational

12

a

.

.

structure was unwieldy to manage and has proposed a more streamlined

organization. The new organization has been segregated into four

functional groups, Plant, Engineering, Services, and Regulation and

compliance, all reporting to the Manager of Nuclear Operations. This

should result in a more manageable and responsive organization. In

addition, the new organization incorporates " institutional memory" in the

proposed staffing.

The licensee plans to implement the new organization after the issuance

of the full power license.

12. Unresolved Items

Unresolved items are matters about which more information is required in

order to ascertain whether they are acceptable items, violations or

deviations. Unresolved items disclosed during the inspection are

discussed in Paragraphs 2.b. (2), and 5.

13. Open Items

Open items are matters which have been discussed with the licensee, which

will be reviewed further by the inspector, and which involve some action

on the part of the NRC or licensee or both. An open item disclosed

during the inspection is discussed in Paragraph 3.b.

14. Exit Interview

The inspectors met with licensee representatives (denoted in Paragraph 1)

on June 24, 1985,.and informally throughout the inspection period and

summarized the scope and findings of the inspection activities. The

inspect:+ also discussed the likely informational content of the

inspection report with regard to documents or processes reviewed by the

inspector during the inspection. The licensee did not identify any such

documents / processes as proprietary. The licensee acknowledged the

findings of the inspection.

13