ML20133E737
| ML20133E737 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 07/15/1985 |
| From: | Runyan M, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20133E731 | List: |
| References | |
| 50-348-85-25, 50-364-85-25, NUDOCS 8508080004 | |
| Download: ML20133E737 (14) | |
See also: IR 05000348/1985025
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION 11
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101 MARIETTA STREET, N.W.
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ATLANTA GEORGIA 30323
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Report Nos.:
50-348/85-25 and 50-364/85-25
Licensee: Alabama Power Company
600 North 18th Street
' Birmingham, AL 35291
Docket Nos.: '50-348 and 50-364
License Nos.:
Facility Name:
Farley Nuclear Plant
Inspection Conducted: June 3 - 7, 1985
Inspection at Farley site near Dothan, Alabama
Inspector:
houu
7 IS 06
,
M. F. Run9a#
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Date Signed
Accompanying Personnel:
M.-A. Scott, Region II
Approved by: MM M/
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C.-M. Upright,ycti
' Chief
Date $1gned
-Division of Reactor afety
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SUMMARY
Scope: This routine, unannounced inspection entailed 68 inspector-hours on site
in the areas of surveillance testing and calibration control program, measuring
and test equipment. program, and licensee action on previously identified inspec-
' tion findings.
Results: ' Four violations were identified - Failure to Perform Evaluation of
Out-of-Tolerance Measuring and Test Equipment, Failure to Establish Environmental
Controls for Calibration of Measuring and Test Equipment, Failure to Confirm
Adequacy of Calibration Frequency of Measuring and Test Equipment, Failure to
Control Access and Assure Accountability of Measuring and Test Equipment.
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B508080004 850718
ADOCK 05000348
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
B. Badham, Safety Audit and Engineering Review (SAER) Staff
- T. Cherry, I&C Supervisor
- R. Coleman, Systems Support Supervisor
L. Enfinger, Administrative Superintendent
T. Esteve, Planning Supervisor-
- H. Garland, Maintenance Superintendent
C. Hanks, I&C Control Technician
D. Heartline, Generating Plant Supervisor
- R. Hill, Operations Superintendent
D. Morey, Ass'stant Plant Manager, Operations
- C. Nesbitt, Technical Superintendent
J. Odom, Unit 1 Supervisor, Operations
'*W. Shipman, Assistant Plant Manager, Support
'J.
Stutchman, I&C_ Planner
L. Ward, Maintenance Superintendent
- W. Ware, SAER Supervisor
L. Wiger, I&C Engineer
- J. Woodard, Plant Manager
Other licensee employees contacted included technicians and office
personnel.
NRC Resident Intoector
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- W. Bradford, Senfor Resident Inspector
- Attended exit in ;erview
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2.
Exit Interview
The inspection scope and findings were summarized on June 7,1985, with
those persons indicated in paragraph 1 above. The licensee did not identify
as proprietary any of the materials provided to or reviewed by the
inspectors during this inspection.
The inspector described the areas
inspected and discussed in detail the inspection findings listed .below.
Violation:
Failure to Perform Evaluations of Out-of-Tolerance
Measuring and Test Equipment, paragraph 5.a.
The licensee accepted the failure to evaluate mechanical equipment
found out of tolerance but did not agree that similar evaluations were
required for permanently installed plant instrumentation found out of
calibration.
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Violation: Failure to Establish Environmental Controls for Calibration
of Measuring and Test Equipment, paragraph 5.b.
Violation:
Failure to Confirm Adequacy of Calibration Frequency of
Measuring and Test Equipment, paragraph 5.c.
Violation:
Failure to Control Access and Assure Accountability of
Measuring and Test Equipment, paragraph 5.d.
' Inspector Followup Item:
Certification of Individuals Qualified to
Calibrate Measuring and Test Equipment, paragraph 5.e.
3.
Licensee Action on Previous Enforcement Matters
This subject was not addressed in the inspection.
4.
Surveillance Testing and Calibration Control (61725)
References:
(a)
10 CFR 50, Appendix B, Quality Assurance Criteria for
Nuclear Power Plants and Fuel Reprocessing Plants
Quality Assurance Program
Requirements (Operation)
(c) ANSI N18.7-1972, Administrative Controls and Quality
Assurance for the Operational Phase of Nuclear Power
Plants
(d) Technical Specifications, Section 4
The inspectcr reviewed the licensee surveillance testing and calibration
control program required by references (a) through (d) to verify that the
program had been established in accordance with regulatory requirements,
industry guides and standards, and Technical Specifications. The following
criteria were used during this review to determine the overall acceptability
of the established program:
A master schedule for surveillance testing and calibration delineated
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test frequency, current status, and responsibilities for performance.
The master schedule reflected the latest revisions of the Technical
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Specifications and operating license.
Responsibilities were assigned to maintain the master schedule up-to-
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date and to ensure that required tests were performed.
Detailed procedures with appropriate acceptance criteria had been
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approved for all surveillance testing requirements.
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The program defined responsibilities for the evaluation of surveillance
test data as well as the method of reporting deficiencies and
malfunctions.
The inspector also verified that similar controls had been established for
calibration of instruments used to verify safety functions but not
specifically identified in the Technical Specifications.
The documents
listed below were reviewed to verify that these criteria had been incor-
parated into the surveillance testing and calibration control program:
QAM, Chapter 5
Instructions, Procedures, and Drawings, Revision 22
QAM, Chapter 10
Inspection, Revision 22
QAM, Chapter 11
Test Control, Revision 22
QAM, Chapter 16
Corrective Action, Revision 22
QAM, Appendix A
Q-List, Revision 20
AP-5
Surveillance Program Administrative Control,
Revision 7
AP-11
Control and Calibration of Test Equipment, Test
Instrumentation, and Plant Instrumentation,.
Revision 5
AP-15
Maintenance Conduct of Operations, Revision 8
AP-51
Instrumentation and Control Group Conduct of
Operations, Revision 6
AP-57
Preservice and Inservice Inspections, Revision 3
The following site audit reports were' reviewed to identify those areas in
which the licensee had discovered problems with the surveillance testing and
calibration program:
84-15, Maintenance STPs, June 12, 1984
84-17, Operations STPs, July 11, 1984
84-21, Health Physics STPs, October 5, 1984
84-22, Chemistry STPs, October 19, 1984
84-24, Systems Performance STPs, January 2, 1985
85-06, Inservice Inspection - Unit 2, April 23, 1985
85-08, Technical Group STPs, May 2, 1985
The more significant problems were identified as noncompliances while those
of lesser importance were addressed as comments by the QA staff. Among the
types of noncompliances of greatest concern were:
Failure to comply with notes or line items in the TS.
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Procedural errors while performing surveillance tests.
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Certification
of qualification expired for persons performing
surveillance tests.
Corrective action on these and other items appeared to be complete and
expedient. Several of the comments appeared to be borderline noncompliances
but the inspector determined that corrective action was satisfactory in
these cases.
To verify implementation of the surveillance test program, the master test
schedule was reviewed. This schedule was broken into two parts; Schedule A
for test frequencies greater than one month, and Schedule B for monthly and
more frequent tests. .These manual schedules were updated monthly and sent
to the control room where test scheduling and compliance was monitored.
Test completion was documented on the schedules which were returned to the
Planning Group at the end of the month.
This was a unique but apparently
effective system for ensuring that all required tests were performed as
prescribed by the TS.
The schedules were randomly checked against the TS
for test inclusion and scheduling frequency as well as proper use of grace
periods.
The following surveillance test procedures and packages which include
inservice pump tests were reviewed for completeness and adequacy:
FNP-1-STP-215.3B
Main Feedwater FT-486 Functional Test, performed
October 8, 1984
FNP-1-STP-416
Baron Concentration Determination of the Refueling
Water Storage Tank, performed July 9, 1984
FNP-1-STP-408
Dissolved Oxygen Determination for the Reactor
Coolant System, performed August 24, 1984
FNP-1-STP-121
Power Range Axial Offset Calibration, performed
March 9, 1985
FNP-2-STP-121
Power Range Axial Offset Calibration, performed
December 12, 1984
FNP-2-STP-23.5
Component Cooling Water Pump 2B Annual Inservice
Test, performed November 22, 1983
FNP-2-STP-23.4
Component Cooling Water Pump 2A Annual Inservice
Test, performed March 2, 1985
FNP-2-STP-4.4
Charging Pump _2A Annual Inservice Test, performed
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February 20, 1985
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FNP-2-STP-4.1
Charging
Pump
2A
Inservice Test,
performed
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January 14, 1985
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FNP-1-STP-201.18B
Reactor
Coolant System TE-412A and TE-412D
Functional Test, performed November 25, 1984
FNP-1-STP-215.3A
Main Feedwater FT-486 Loop Calibration, performed
October 8, 1984
FNP-1-STP-201.18A
Reactor Coolant System TE-412A and TE-412D Loop
Calibration, performed November 25, 1984
Reference values for pump differential pressure and component vibration
datum (Pr and Vr, respectively) established during design and preoperational
testing in accordance with Sections III and XI of the ASME Boiler and
Pressure Vessel Code were not found in the surveillance tests examined.
These values are an integral part of component test acceptance criteria. Pr
and Vr values were indicated as being located in the surveillance test data
book in the control room.
Existing site procedures did not identify use,
control, or alteration of the surveillance test data book.
In reviewing the test data package for surveillance test FNP-2-STP-23.5
(performed November 22, 1983), it was identified that new post repair
baselines for Pr and Vr were established for component cooling water pump
(CCWP) 28.
The Inservice Test Program Manual, FNP-2-M-019, and the
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Inservice Plan for Pump and Valve Testing Manual, FNP-2-M-008, reference
Section XI of the ASME Boiler and Pressure Code but do not contain all of
the testing and testing time requirements of Section XI.
Although site
procedures do not contain the specific 96-hour retest requirement for new
baseline of Article IWP-3000 of Section XI, CCWP 2B was retested during the
time allowed.
The licensee is required to establish a calibration program for installed
process instrumentation associated with safety-related systems or functions.
The calibration of these instruments was controlled within the preventive
maintenance program.
The following plant instruments were chosen at random
from several surveillance test procedures to verify their inclusion in the
calibration program:
Charging Pump 2B
Charging Flow
FI-122
Suction Pressure
PI-152A
Discharge Pressure PI-152B
RHR Pump 2A
Flow
FI-605A
Suction Pressure
PI-601A
Discharge Pressure PI-600A
Auxiliary Feedwater Pump 2B
Suction Pressure
PI-3211BB
Discharge Pressure PI-3213BB
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Containment Spray Pump 28
Suction Pressure
PI-946A
Discharge Pressure PI-946B
The above instruments were included in the program. Scheduled calibration
frequencies appeared consistent with good engineering practice.
Within this area, no violations or deviations were identified.
5.
Measuring and Test Equipment (M&TE) Program (61724)
References:
(a)
10 CFR 50, Appendix B, Quality As:urance Criteria for
Nuclear Power Plants and Fuel Reprocessing Plants
Quality Assurance Program
Requirements (Operations)
(c) ANSI N18.7-1972, Administrative Controls and Quality
Assurance of the Operational Phase of Nuclear Power
Plants
(d) Regulatory Guide 3.30, Quality Assurance Requirements
for the Installation, Inspection, and Testing of
Instrumentation and Electric Equipment, August 11, 1972
(e) ANSI N45.2.4-1972, IEEE Standard, Installation, Inspec-
tion, and Testing Requirements for Instrumentation and
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Electric Equipment During the Construction of Nuclear
Power Generating Stations
The inspector reviewed the M&TE program required by references (a) through
(e) to verify that the program had been established in accordance with
regulatory requirements and industry guides and standards. The following
criteria were used during this review to determine the overall acceptability
of the established program:
Responsibility was delegated and criteria established to assign and
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adjust calibration frequency for each type of M&TE.
An equipment inventory list identified all M&TE used on safety-related
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components, the calibration frequency and standard, and the calibration
procedure.
Formal requirements existed for marking the latest calibration date on
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each piece of equipment.
The program assured that each piece of equipment was calibrated on or
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before the date required or stored in a location separate from
inservice M&TE.
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Written requirements prohibited the use of M&TE which had not been
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calibrated within the prescribed frequency.
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When M&TE was found out of calibration, the program required documented
evaluations to determine the cause of the out-of-calibration condition
and_the acceptability of items previously tested.
The program assured that new M&TE was added to the inventory lists and
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calibrated prior to use.
The documents listed below were reviewed to verify that these criteria had
been incorporated into the M&TE program:
Control of Measuring and Test Equipment
QAM, Chapter 12
Control of Measuring and Test Equipment,
Revision 22
QAM, Chapter 16
Corrective Action, Revision 22
AP-11
Control and Calibration of Test
Equipment, Test Instrumentation,
and Plant Instrumentation, Revision 5
AP-15
Maintenance Conduct of Operations,
Revision 8
AP-51
Instrumentation and Control Group
Conduct of Operations, Revision 6
The inspector reviewed site audit report 84-18, Control of Meastring and
Test Equipment, July 23, 1984, to identify problems the licensee had found
with their program. The findings included improper storage of instruments,
not marking contaminated tools, a test procedure not requiring the recording
of test equipment used and calibration due date, and the test equipment
master schedule'not containing the calibration procedure number or the last
calibration date.
It appeared that the licensee had corrected these
deficiencies.
Implementation of the licensee's M&TE program was assessed in the I&C and
Mechanical calibration labs.
In the I&C lab, the following items of M&TE
were selected randomly to determine the adequacy of storage and the
effectiveness of documentation accounting for the equipment:
FNP-IRD-6003
Vibration Meter
FNP-LNRS-0150 Ratio Test Set
FNP-FDM-1139
DVM Fluke 8020A
FNP-LNK-3030
. Kelvin Bridge L&N
FNP-LNC-3055
Control Loop Tester
FNP-GRS-5000
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FNP-BFM-5141
2.5 gpn Flowmeter
FNP-FDM-1155
DVM Fluke 8600A
FNP-ATTG-8345 100 psi Gauge
The above equipment was either properly stored or documented as being
checked out or at another location with the exception of the 100 psi gauge.
This piece of- equipment was listed as missing.
This appeared to be an
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isolated case.
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The following calibration procedures were reviewed:
Fluke 8600A DMM Calibration Check, Revision 3
IMP-007~
Heise Gauge Calibration, Revision 0
Hickok 3300 Digital Multimeter, Revision 0
Keithley Picoampere Source Model 261 Calibration Check,
Revision 2
Wallace and Tiernan FA-187 Precision Manometer Calibration,
Revision 1
The above calibration procedures appeared adequate in that they clearly
defined a step-by-step procedure and criteria by which to determine the
. acceptability of the device. . A problem concerning test conditions for
calibration is discussed as a violation below.
The licensee is required to evaluate previous tests performed with M&TE
- later found out of tolerance during calibration. The following evaluations
were reviewed:
Date Found
Evaluation
ID No.
Instrument Type
Out-of-Tolerance
Completed
HTG-8501
Heise Test Gauge
9/18/84
1/18/85
ATG-8573
Ashcroft Gauge
1/25/85
4/08/85
HTG-8507
Heise Test Gauge
1/27/85
5/08/85
HTG-8096
Heise Test Gauge
4/02/85
Open
HTG-8586
Heise Test Gauge
5/12/85
Open
The timeliness of conducting these reviews is discussed as a portion of a
violation described below.
A similar inspection was performed in the Mechanical Tool Room where the
following tools were randomly selected from the master index:
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SMI6760
Outside Micrometer
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BSD6301
Dial Indicator
BSJB6216
Jo Block
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SDG6209
Depth Gauge
BCT6726-
Crimping Tool
STW6420
Torque Wrench
PDT6700
Power Dyne Torque Wrench
Storage of the above equipment appeared adequate and items not located in
the shop were well documented as to their status.
Calibration stickers
agreed with the information provided on the master index.
The following
calibration procedures were reviewed:
GMP-33.0 Torque Tester, Model TT-7045 Calibration Check Instructions,
Revision 1
GMP-33.1 Torque Tester, Model TT-7085 Calibration Check Instructions,
Revision 0
GMP-34.1 Calibration Check for Metric Dial Indicators (Strain Gauge),
Revision 0
GMP-35.0 Calibration Check of Outside Micrometers and Micrometer
Depth Gauges, Revision 1
GMP-35.1 Calibration Check of Inside Micrometers, Revision 0
GMP-36.0 Torque Wrench Calibration Check Instructions, Revision 0
These procedures appeared adequate to control the quality of calibration
activities with the exception of environmental controls as discussed in a
violation below.
Within this area, four violations and one inspector followup item were
identified and are discussed in the following paragraphs.
a.
Failure to Perform Evaluations of Out-of-Tolerance Measuring and Test
Equipment
The licensee is committed to ANSI N45.2.4-1972. Section 2.5.2 states
that when inspection and testing equipment are found out of calibra-
tion, an evaluation shall be made of the validity of previous
inspection or test results and of the acceptability of items previously
inspected or. tested.
The following areas of noncompliance with this
requirement were identified and are discussed in the following
paragraphs:
Required evaluations are not typically performed for mechanical
equipment
such as
torque wrenches and micrometers.
The
controlling procedure AP-11, Control and Calibration of Test
Equipment,
Test
Instrumentation
and Plant Instrumentation,
Revision 5, only requires evaluations as such to be performed by
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the I&C Group.
AP-15, Maintenance Conduct of Operations,
Revision 8, Section 7.4, mentions the requirement to perform the
evaluation but does not provide guidance or a format for their
performance.
As a result, evaluations were only occasionally
performed and they were not maintained as quality records.
Evaluations are not performed when an installed process instrument
is found out of tolerance. In this case, an installed instrument
used to verify acceptance criteria for a safety-related surveil-
lance test is performing the same function as a portable item of
M&TE and subject to this requirement. As an example, if a pump
discharge pressure gauge is found out of tolerance, the validity
of the last pump operability test is in question and an evaluation
is required to determine whether the test should be re performed.
Test results derived from installed process instrumentation
determined to be out of tolerance could, when reevaluated,
identify an unsafe condition which requires further action in
accordance with 10 CFR 50 regulations or TS requirements.
Measures have not been established to assure that out-of-tolerance
evaluations are completed within a reasonable time period. Though
ANSI N45.2.4 does not specify timeliness of evaluations, this is
an important consideration because invalid settings, test data, or
calibrations could invoke TS limiting conditions for operation.
The I&C Control Technician in charge of the lab has determined on
his own that these evaluations should be completed in three weeks.
However, this time limit is not in a procedure and the istue has
not been evaluated by higher levels of management. Also, this
informal time constraint is often exceeded as several evaluations
were observed to have taken approximately three months to
complete.
Some plants have established a seven-day . limit which
has been generally accepted as a reasonable time to screen
out-of-calibration M&TE results to determine prior use and
immediate action needed en safety-related components.
Failure to perform and control evaluations of out-of-tolerance M&TE is
identified as violation 348, 364/85-25-01.
b.
Failure to Establish Environmental Controls for Calibration of
Measuring and Test Equipment
10 CFR 50, Appendix B, Criterion II, states that activities affecting
quality shall be accomplished under suitable environmental conditions.
For the calibration of certain items of M&TE, vendor manuals specify
conditions under which calibration activities should take place.
However, in the I&C and the maintenance calibration facilities,
measures had not been established to assure proper environmental
controls for calibration.
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In the I&C calibration lab, two examples of vendor calibration
requirements were given for the Fluke 8600A and 8120A digital
multimeters. Calibration test conditions were 23 5 degrees C at less
than 80-percent humidity and 25 5 degrees C at less than 70 percent
humidity, respectively.
Although temperature and humidity were
continuously measured on a strip chart recorder, administrative limits
had not been established and personnel who perform calibrations do not
check or record conditions while performing calibrations. On at least
one occasion in the last year, humidity exceeded 70 percent in the lab.
Though Fluke test conditions were almost always met based on strip
chart records, measures had not been established to preclude calibra-
tion in the event that they were not met. Also, there may be other
pieces of equipment that were sensitive to temperature and humidity and
which may require conditions not currently being provided. A complete
review of all potentially affected equipment should be completed as
well as the establishment of administrative limits to control
environmental conditions during calibration.
In the maintenance shop, the same problem existed with the exception
that temperature and humidity indication was not provided. Provisions
had not been established to control temperature for the calibration of
precision measuring equipment nor were requirements in place to ensure
that the internal temperature of the field instrument and shop standard
had stabilized and equalized prior to calibration.
In addition,
calibration was performed in three separate locations each with its own
environmental
characteristics.
Failure to control
environmental
conditions for the calibration of M&TE is identified as violation 348,
364/85-25-02.
c.
Failure to Confirm Adequacy of Calibration Frequency of Measuring and
Test Equipment
The licensee is committed to ANSI N18.7-1972 which states in Section
5.3.6 that procedures shall be provided for proper control and periodic
calibration and adjustment of measuring and test equipment to maintain
accuracy within necessary limits, and to confirm the adequacy of
calibration frequency.
Procedure AP-11, Section 4.6.2.2, states that
equipment data obtained from calibration checks shall be analyzed to
optimize calibration check intervals.
This implies that calibration
records should be examined periodically to determine whethar items of
M&TE should be calibrated more frequently or, in the case where
failures are very rare, less frequently. The licensee had failed to
established measures to assure the performance of this function in a
systematic or effective manner.
The calibration history of a device
was not compiled tabularly and calibration records were scattered
throughout the document control system. A method of analyzing calibra-
tion history was not prescribed and, as a result, calibration trend
analysis was not performed.
A specific example of this problem
involves the Keithley Picoampere Source Model 261. The vendor manual
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informs the user to calibrate this device every three months. The
licensee changed the frequency to every six months _in 1978, evidently
because it had to be sent off site for a month to be calibrated. Thus,
-by increasing the time between calibrations, it had a higher use
factor.
However, the licensee did not have a technical evaluation or
trend analysis to support this change.
The inspector reviewed the
following calibration certificates for Kiethley Model 261 M&TE:
Serial No.
Calibration Date
As Found Condition
86962
4/03/80
Out of tolerance
86962
10/20/80
Wires burned open
86962
10/22/82
Out of tolerance
4028
07/16/84
In tolerance
Although this was a small sample of the total (six calibrations were
performed on three sources yearly), it clearly indicated that a
six-month frequency may not be acceptable.
Failure to confirm the
adequacy of calibration frequency of M&TE is identified as violation
348, 364/85-25-03.
d.
Failure to Control Access and Assure Accountability of Measuring and -
Test Equipment
Criterion XII, states that measures shall be
. established to assure that measuring and testing devices used in
activities affecting quality are properly controlled.
In the I&C
calibration lab, access control is not provided.
As a result,
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reliability of equipment documentation and shop standard security were
not assured. The lab was unlocked around the clock and staffed by I&C
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personnel only periodically on the day shift. The lab is located in an
area where visitors and contractor personnel had unescorted access.
This created several situations that could be adverse to quality.
Equipment checkout documentation was vulnerable to an honor system
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which may be violated by plant personnel or by personnel working for
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another organization. When equipment was found out of calibration, the
licensee does not have assurance that every prior use of that equipment
was identified which is needed for the required evaluation. Extremely
sensitive shop calibraticn standards were left unattended on desk tops
without any security against potential tampering.
Tampering with a
shop standard, whether advertently or not, may not be known for several
years depending on the calibration frequency.
A countless number of
flawed calibrations of field equipment may occur and seriously degrade
the safety of the plant. M&TE could be removed from the lab without
being signed out and used after exceeding its calibration interval
without a means of locating it.
Failure to control access and assure
accountability of M&TE is identified as violation 348, 364/85-25-04.
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e.
Certification of Individuals Qualified to Calibrate Measuring and Test
Equipment
The licensee could not demonstrate a qualification program or formal
training for personnel who routinely calibrate M&TE.
In the I&C lab,
journeymen perform the calibrations by using procedures and by
observing others. In the mechanical lab, any mechanic was assumed to
be qualified to calibrate M&TE. This informal approach to training and
qualification may not be sufficient to assure the repeatability and
.acctracy of M&TE calibrations. The licensee acknowledged this concern
and provided the following response to the inspector following the
inspection:
Intracompany
correspondence,
FNP-85-0624,
Certification and
Re-Certification of Personnel Performing Calibration of Equipment
or Instruments, dated June 12, 1985. This response stated that
personnel performing calibrations meet the Level II Qualification
requirements of FNP-0-AP-31 and are certified to perform
activities associated with their respective classification,
including calibrating or establishing the validity of calibration
of measuring equipment.
The response further stated that
calibration activities performed by these personnel fall well
within the skills of the classification; therefore, no periodic
training is necessary.
Until the qualification requirements of FNP-0-AP-31 are reviewed and
are observed to be adequate, the item is identified as Inspector
Followup Item 348, 364/85-25-05.
7.
Licensee Action On Previously Identified Inspection Findings (92701)
(0 pen) Inspector Followup Item 348, 364/85-21-02:
Cheater Bar Usage.
At the time of this inspection, a composite audit report had been
issued with the cheater bar noncompliance identified as an open item.
The appropriate corporate and site personnel had not responded.
(0 pen) Inspector Followup Item 348, 364/85-21-03:
10 CFR 21 Requirements.
Administrative Procedure 62 had been amended to incorporate the
necessary changes.
The procedure is at the corporate office for
approval.
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