ML20151B863

Insp Repts 50-277/88-05 & 50-278/88-05 on 880208-12. Violations Noted.Major Areas Inspected:Solid Radwaste & Radioactive Matl Shipping Program,Including Control, Radiochemistry & Implementation of Programs

ML20151B863
Person / Time
Site:	Peach Bottom
Issue date:	03/29/1988
From:	Bicehouse H, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20151B859	List: ML20151B856 ML20151B861 ML20151B863
References
50-277-88-05, 50-277-88-5, 50-278-88-05, 50-278-88-5, NUDOCS 8804110319
Download: ML20151B863 (12)

See also: IR 05000277/1988005

Text

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report Nos. 50-277/88-05

50-278/88-05

Docket Nos. 50-277

50-278

License Nos. OPR-44

DPR-56 Priority --

Category C

Licensee: Philadelphia Electric Company

2301 Market Street

Philadelphia, Pennsylvania 19101

Facility Name: Peach Botton Atomic Power Station

Inspection At: Delta Pennsylvania

Inspection Conducted: February 8-12, 1988

Inspectors: .

k 77/dec 2 5', /99f

H. J.VBicehouse Radiation Specialist date~

Approved by: G- .d 3 -29- 8 8

gW. J. Pascfak, Chief date

Effluents Radiation Protection Section

Inspection Summary: _I_nspection

n on February 8-12, 1988 (Combined Report

Nos. 50-277/88-05; 50-278/88-05)

Areas Inspected: Routine announced inspection of the licensee's solid

radioactive waste andgra6toactive material shipping programs including:

previously identified items, management controls, quality assurance / quality

control, radiochemistry and implementation of the programs. Mr. S. Maingi of

the Pennsylvania Department of Environmental Resources accompanied the

inspector on February 11-12, 1988.

Results: Apparent violations of 10 CFR 30.41(c) and Technical Specification 6.8 related to a shipment of 52 solidified oil drums to Quadrex-HPS, Inc. on

November 25, 1987 (Detail 9).

8804110319 880404

PDR ADOCK 05000277

0 DCD

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OETAILS

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1. Persons Contacted

During the course of this routine inspection, the following personnel were

contacted or interviewed:

1.1 Licensee Personnel

• F. H. Crosse, Radwaste Shipping Supervisor

• G. F. Daebler, Superintendent, Technical

• A. B. Donell, Quality Assurance Site Supervisor

M. Dragoo, Radwaste Projects Engineer

• J. E. Hesler, Radwaste Engineering Supervisor

• W. J. Knapp, Director, Radwaste Management Section (corporate)

• D. P. LeQuia, Superintendent, Plant Services

R. Lubaszewski, Radwaste Shipping Engineer

• J. F. Mitman, Senior Engineer, Radwaste

• D.L. Oltmans, Senior Chemist

Other licensee and contractor personnel were also contacted or

interviewed.

1.2 Pennsylvania Department of Environmental Resources

• S. Maingi, Nuclear Engineer

1.3 NRC Personnel

T. P. Johnson, Senior Resident Inspector

• L. E. Myers, Resident Inspector

"R. J. Urban, Resident Inspector

• Attended the exit interview on February 12, 1988

2. Scope

! This routine safety inspection reviewed the licensee's solid radioactive

waste (radwaste) processing and preparation and radioactive materials

i packaging and shipping programs (as implemented by the licensee) from

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October 25, 1986 through February 12, 1983. During that period, the

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licensee averaged 22 radioactive materials shipments per month

(predominantly solid radwaste materials sent for disposal at two Agreement

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State-licensed low-level waste burial sites). A total of 16 shipments

(including 13 radwaste and 3 other radioactive material shipments) were

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selected and reviewed relative to requirements in 10 CFR 71 and 49 CFR

l 170-189 and, for radwaste shipments, 10 CFR 20.311, 10 CFR 61.55-56 and

the licensee's technical specifications and approved procedures. In

addition, solid radwaste processing and preparation facilities and equip-

mant and previously identified items were reviewed.

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3. Previous Identified Items

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3.1 (closed) Unresolved Item (50-278/85-36-01): Fire Analysis For

Low-level Radwaste Storage Facility.

The licensee's initial safety evaluation report failed to provide an

analysis of the consequences of a fire in a storage cell at the

licensee's low-level radwaste storage facility. Each storage cell

was designed to contain radioactive material in high integrity con-

tainers (HICs) as dewatered resin. On December 19, 1985, following

discussions concerning the possibility of fire in the storage cells,

the licensee revised the safety evaluation to include the following:

Dewatered resin has less than 0.5% freestanding water but con-

tains about 50% by weight interlattice water;

• Testing by Aerojet Energy Conversion Company (to design a resin

incinerator) has indicated that a substantial amount of supple-

mental fuel is required to burn resin because of the inter-

lattice water;

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• ? Trder to burn, the stored resin must be subjected to an

e>.ablished fire with sufficient supplemental fuel to vaporize

the wator; and

• Since the resin is stored in concrete storage cells with minimum

combustible material, supplemental fuel to support such a fire

wasn't available.

In addition, self-combustion of the resin due to chemical reactions

and hydrogen gas generation are controlled by the process and the

facility design. Based on these considerations, the licensee con-

cluded that there was little likelihood of resin involvement in a

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fire providing a substantial radioactive source term for offsite

consequences. The inspector noted that dewatered resins in polyethy-

lene HICs will not be stored in the facility in quantities approach-

ing design values unless the licensee is unable to use offsite burial

facilities. This item is closed.

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3.2 (Closed) Followup Item (50-278/85-36-02): Gas Generation In HICs

The licensee's passive vent design for the HICs was reviewed and

accepted by the South Carolina Department of Health and Enviror. mental

Control as adequate to prevent container breach during storage,

shipment and disposal. Administrative controls for the storage cells

include annual venting of any hydrogen gas generated during storage

within the cell Ventilation of the cell area continuously removes

any evolved gas preventing buildup to lower explosive limits. This

item is closed.

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3.3 (Closed) Followup Item (50-278/85-36-03): Preops Testing

Preoperational test results for the low-level radwaste storage

facility were reviewed and approved by the Plant Operations Review 1

Committee (PORC). Test exceptions were dispositioned and/or

corrected and also reviewed by the PORC. This item is closed.

3.4 (Closed) Followup Item (50-278/86-36-04): Operating Procedures

The licensee has developed and implemented controlled Radwaste

(RW-Series) procedures for the low-level radwaste storage facility.

This item is closed.

3.5 (Closed) Followup Item (50-277/86-21-01; 50-278/86-22-01):

Update Scaling Factors

The licensee has developed and implemented procedures to evaluate and

incorporate new scaling factors for hard-to-identify radionuclides as

additional vendor analysis reports are received. Review indicated

that the 1986 updates to scaling factors had been included. Discus-

sion indicated that the 1937 updates (received by the licensee in

January 1988) were being reviewed and evaluated for incorporation  !

into procedures. This item is closed.

3.6 (Closed) Violations (50-277/86-21-02; 50-278/86-22-02;

50-277/86-21-03; 50-278/86-22-03; 50-277/86-21-04; 50-278/86-22-04)

Iron-55 and Nickel-63 problems with shipment No. 45-86.

The licensee completed actions as described in the licensee's letters

dated December 31, 1986 and March 30, 1987. These actions included

re-evaluation of the activities, radionuclides and classification of

152 licensee shipments and updates to shipping and disposal records

and institution of revised procedures to prevent recurrence of the

problem. These items are closed.

4. Management Controls

, The licensee's organization, staffing, procedures and training were

reviewed relative to licensee commitments and technical specification

l requirements.

4.1 Organization

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The organizational structure of the licensee's solid radwaste proc-

essing and preparation (including oversight of contracted dewatering

services) and radioactive materials packaging and shipping activities

was reviewed and discussed with the licensee. The inspector noted

that the station organization was undergoing substantial change.

Three related functional areas, (i.e. health physics, chemistry and

radwaste), reported through their respective senior engineers to the

Superintendent-Services. The recently formed Radwaste Organization

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(under the Senior Engineer-Radwaste) consolidated waste processing,

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classification, inventory, minimization, planning and engineering I

activities and radioactive materials packaging and shipping into a

single organization. Although the licensee hadn't completed all  :

i aspects of the reorganization, the inspector noted that roles and  ;

4 responsibilities were being defined and long-standing radwaste

problems were being aggressively addressed by the new organization,

(e.g. a backlog of about 60,000 cubic feet of radwaste materials had

been' reduced to less than 10,000 cubic feet since August 1987).

Inter faces with other sts'; ion organizations'(e.g. health physics,

chemistry, operations and quality assurance / quality control) appeared

to be improved in definition of roles and responsibilities and to be (

better understood by the radwaste staff. Roles of other groups,  ;

(e.g. Reactor Engineering regarding fuel pool disposal projects), had

also been defined. The reorganization had strengthened and clarified i

i the radwaste functions relative to those groups in ways that  ;

addressed long-standing weaknesses in control of those radwaste  ;

j operations.

l 4.2 Staffing l

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l The inspector reviewed staffing within the Radwaste Group and noted  !

that approximately 75% of the staff (including but not limited to i

senior technical / professional staff) was supplied by contractors 3

including Hydro Nuclear Services and Bechtel National, Inc. The  !

long-term stability of the staff was discussed with the licensee and

i the need for continuity of program was strrissed.  ;

l 4.3- Procedures

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i- The licensee has been extensively revising and updating existing

j procedures and developing new procedures to support solid radwaste

and shipping activities. The new Radwaste (RW) Procedure series

include

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100 Series procedures which are administrative in nature,

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200 Series procedures which deal with processing and packaging

radioactive materials;

300 Series procedures which deal with shipments of radwaste for  !

disposal;

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400 Series procedures providing instructions for shipping

non-waste radioactive material;

• 500 Series procedures for support functions; and

• 600 Series procedures covering plant radwaste system operations.

The inspector selected ten procedures for review relative to 10 CFR I

20.311, 10 CFR 61.55-56, 10 CFR 71 and 49 CFR 170-189 requirements: j

RW 110, "10 CFR 61 Compliance Program," Revision 0  !

(August 1, 1987);  !

• RW 200, "Control of Containers," Revision 2 (January 11,1988); p

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RW 260, "Operation of Resin Drying (0ewatering) System,"

Revision 3 (August 1, 1987);

• RW 300, "General Requirements for Exclusive Use Radwaste

Shipments," Revision 0 (December 29,1987).

• RW 330 "Radwaste Shipments to Barnwell," Revision 9

(December 29,1987);

' RW 380, "Response to Lost Radwaste Shipments," Revision 0 (July,

1987);

• RW 520, 10 CFR 61 Sampling," Revision 2 (November 11,1987);

' RW 540, "Movement of Radioactive & Non-Radioactive Material for

storage at Unit 1 or LLWSF," Revision 0 (May 18,1987);

RW 320.1, "Loading and Closing the HN-100 Series 2 or 3

Radioactive waste shipping cask," Revision 1 (January 8, 1988);

and

• RW 320,8 "Loading and Closing the CNSI 14-195H Radioactive Waste

Shipping Cask," Revision 1 (December 29,1987).

In addition to the procedures above, the licensee's computer programs

used to classify radwaste shipments and to select packaging were

reviewed.

Within the scope of these reviews, the following item was identified:

The licensee uses three MIDAS Fortran IV and one Lotus 1-2-3

Spreadsheet programs to calculate individual and total

radioactivities, classify radwastes, select packaging and

provide supporting calculations. The programs are supplemented

by additional review by Radwaste technical personnel to prepare

Waste Manifests and Radioactive Shipping Records. The MIDAS

Fortran IV programs are dated and follow nomenclature and

methods used prior to 1983 changes to 49 CFR requirements The

Spread Text program is current but misleading (e.g. 10 CFR

61.55, Table I isotopes are treated as though there are Class B

limits though Class B limits do not exist for Table I).

Discussions with the licensee indicated that the Bechtel PAKRAD

program will replace existing programs providing improved

radwaste and package selection classifications. Although errors

associated with the existing programs weren't noted to have

caused regulatory problems in the 16 shipments sampled,

implementation of the improved computer program for compliance

areas is recommended and will be reviewed during a subsequent

inspection 50-277/88-05-01; 50-278/88-05-01.

In other respects, the licensee's procedures were adequate.

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4.4 Indoctrination and Training

The indoctrination and training of personnel assigned to the Radwaste

organization were reviewed briefly relative to commitments in the

licensee's letter (dated September 28,1979) responding to NRC IE

Bulletin No. 79-19. Five members of the licensee's staff were ques-

tiened concerning annual retraining in 1987. All five had attended

the annual retraining.

Within the scope of this review, no deviations were noted.

5. Quality Assurance / Quality Control

The application of the licensee's quality assurance / quality control pro-

gram to solid radwaste processing and preparation and radioactive

materials packaging and shipping activities was reviewed.

5.1 Waste Generator Quality Control

Specific quality control requirements are mandated by 10 CFR 00.311

to assure compliance with 10 CFR 61.55-56. RW series procedures were

reviewed to determine if appropriate quality control checks were

included to ensure classification of radwaste shipments under 10 CFR

61.55 and proper radwaste form under 10 CFR 61.56. Thirteen radwaste

shipments were reviewed for implementation of the procedural

holdpoints (under current RW or previous HP0/C0 series procedures),

verification of dewatering for resin shipments and verification of

hardness for solidified oils. Audit No. AP 86-111 HPC, "PBAPS 10 CFR

61 Compliance," (November 3 through December 11,1986), was reviewed

to determine its inclusion of attributes related to 10 CFR 61.55-56

compliance, management review of the audit and resolution of findings

and recommendations. The inspector noted that the licensee had

narrowed the scope of the audit coverage to improve the technical

depth in each area of review in response to earlier comments in the

1986 NRC Inspection of this area. Appropriate inspection holdpoints

were included in procedures and witnessed by quality control

personnel suitably knowledgeable in the radwaste area for the

thirteen shipments reviewed. Audit No. AP 86-111 HPC adequately

covered attributes of 10 CFR 61.55-56 and had receivad appropriate

management review and resolution of findings.

Within the scope of this review, no violations were identified. The

licensee was implementing an effective quality control program under

10 CFR 20.311.

5.2 Radioactive Materials Shipper Quality Assurance / Quality Control

10 CFR 71, Subpart H requires the establishment of a quality assur-

ante program for the packaging and transportation of radioactive

materials. A commission-approved Quality Assurance Program (under 10

CFR 50, Appendix B) is acceptable provided it is estaolished,

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maintained and implemented for transport packages. The licensee

elected to apply the established 10 CFR 50, Appendix B program to

packaging and shipping activities. RW and HP0/C0 series procedures

(previously used) were reviewed to determine quality control

attributes verified in receipt and shipping inspections of transport

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packages. Implementation of those procedures was verified for the

sixteea radioactive materials shipments reviewed. Under 10 CFR

71.12, applicable items of the package's Certificate of Compliance

must be reviewed and those were verified for shipments made pursuant

to 10 CFR 71.12. Surveillance activities of shipping procedures were

also reviewed. Audit No. AP 86-02 HPC, "PBAPS Radioactive

Waste / Material Storage, Handling and Shipping," was reviewed for

inclusion of attr;butes needed to ensure compliance with 10 CFR 71.

The inspector noted that the audit team members were technically

qualified in radioactive materials shipping requirements.

Within the scope of this review, no violations were noted. The

licensee had applied applicable portions of the Commission-approved

10 CFR 50, Appendix B program to shipping activities.

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5.3 Process Control Program

Under Technical Specification 3/4.8, the licensee is reouired to have

a Process Control Program (PCP). Under the PCP, solid radwaste

sampling and testing requirements are established. The licensee's

application of the PCP to centrifuge dewatering, oil solidification

and vendor dewatering operations was reviewed and discussed with the

Radwaste Engineering Supervisor and a member of his staff. The bases

for the program in each area was reviewed and appropriate

implementation was verified for the radwaste shipments reviewed.

Within the scope of this review, no violations were noted. The

i licensee had provided an effective PCP for each of the radwaste

! processes reviewed.

l 6. Radiochemistry

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The "Low-level Waste Licensing Branch Technical Position on Radioactive

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Waste Classification," (May, 1983, Revision 0), suggests an acceptable

sampling and analysis program for power reactors to meet 10 CFR 61.55

Waste Classification requirements for hard-to-identify radionuclides and

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allows the use of scaling or correlating factors to gamma-emitting radio-

nuclides. Licensee fuel performance and reactor coolant system

radioactivities were reviewed to determine the general adequacy of the

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licensee's sampling and vendor analysis program for hard-to-identify

radionuclides. The licensee had generat=d and shippod Class A and Class B

solid radwastes and had sampled the radwaste streams in 1986 and 1987.

! Review of radiochemistry data showed that substantial changes in fission

l product and activation product concentrations had not occurred without

subsequent sampling and revision of scaling factors. Radiochemical data

j sufficient to characterize new radwaste processes had been provided.

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Within the scope of this review, the licensee was meeting suggested

sampling and analysis frequencies.

7. Solid Radwaste Processing / Preparation

The licensee collects, processes, temporarily stores and prepares dry

active waste, def onizer resins, oils and radioactive hardware for offsite

disposal at Agreement State-licensed disposal sites. Considerable change

had occurred since the last inspection:

In July 1987, the licensee switched from use of 55 gallon

polyethylene HICs to much larger HICs for wet wastes;

Vendor-supplied dewatering services were used for the larger HICs in

place of the installed centrifugation system in the Radwaste

Building;

Modifications were under way to install the azeotrophic distillation

and polyester solidification process known as AZTEC for operation in

1939;

• Increasing use of the low-level radwaste storage facility

necessitated intrasite shipment of dewatered large HICs and dry

active waste; and

Radwaste shipments were made to an offsite vendor for

decontamination / recycle and repackaging / disposal operations.

In addition, the licensee was conducting a campaign to characterize,

prepare for shipment and dispose of accumulated solid radwaste (some

of which had been onsite since 1983). Future planning includes

vendor-supplied solidification of decontamination resins used in the

Unit 3 pipe replacement project and additional disposal of activated

components stored in the fuel pools.

The changes to radwaste processing operations which involved modifi-

cations to existing plant equipment were reviewed relative to

requirements in 10 CFR 50.59 and concensus standards provided in

ANSI /ANS 55.1 - 1979, "American National Standard for Solid

Radioactive Waste Processing Systems for Light Water Cooled Reactor

Plants."

7.1 Modification No. 1750A

This modification provided interface piping and an enclosure building

to support operation of a resin dewatering system behind the Unit 2

Reactor Building. The dewatering process include / v eping a resin

slurry into a large HIC and using an air-driven y sum pump to

extract free-standing liquid. The inspector toured the operation,

reviewed procedures and valve alignments and examined the safety

evaluation prepared by the licensee to support the modification. The

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safety evaluation was reviewed and approved by the PORC (Meeting No.

87-70) under 10 CFR 50.59 and station technical specifications.

Within the scope of this review, no violations were noted.

7.2 AZTEC

General Electric Company developed a volume reduction and radwaste

solidification system which uses an azeotrophic distillation

mechanism (to remove water from wet waste) and a polyester

solidification process (to provide a suitable waste form). The process has

been reviewed and accepted by the NRC and the States of South

Carolina and Washington. Since the modification to use this process

was incomplete, the process control aspet:s of the system and the

disposal of toluene were discussed with the licensee. The review of

the licensee's modification to house the operation, safety review and

licensing requirements and normal operation were postponed pending a

licensee decision on use of the process.

7.3 Low Level Radwaste Storage Facility

The switch from 55 gallon HICs to larger HICs allowed the licensee to

use a transfer cask for dewatering and intrasite transfer of the

resulting dewatered resins. Final preparations for shipment could he

i conducted at the licensee's low level radwaste storage facility. On

February 10, 1983, the inspector toured the facility and observed a

transfer of a dewatered HIC from the transfer cask to a shipping cask

in the facility's truck bay area. NU problems were noted during this

review.

The inspector reviewed licensee records for radioactive material

inventory in the facility and noted that stored inventory was well

within the facility's design capacity and waste form / packaging were

also suitable for the facility. The total inventory stored in the

facility amounted to approximately 146 curies.

7.4 Unit 3 Turbine Storage Area

On February 10, 1988, the inspector and the Senior Resident Inspector

toured the locked high radiation area at the Unit 3 Turbine deck.

The area contained approximately 185 drums (about 1300 cubic feet) of

stored radioactive materials. Radiation readings associated with the

drums ranged from about 40 millirems per hour to about 60 rems / hour

contact. The licensee had set up a tent and temporary shield wall to

process each drum for eventual disposal. Discussions with the

licensee indicated that the licensee planned to characterize, process

! and ship for disposal as much of the radwaste as possible. However,

i many of the drums contained radioactive materials for which the

l licensee had little information necessitating examination and

j pr(paration activities. The inspector noted that some of the drums

had been onsite since about 1983 and had been stored previously in

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the Unit 2 Turbine locked high radiation area. Although the licensee

was making a considerable effort to reduce radwaste volume stored

onsite, the lack of necessary information on the drums in storage was

hampering the effort.

8. Radwaste Generator Requirements

The inspector reviewed thirteen radwaste shipments made by the licensee

against each of the following radwaste generator requirements:

Waste Manifests under 10 CFR 20.311(d)(4) and 20.311(b) and (c);

Waste Classification under 10 CFR 10.311(d)(3) and 10 CFR 61.55;

Waste Form and Characterization under 10 CFR 20.311(d)(3) and 10 CFR

61.56;

Waste shipment labeling under 10 CFR 20.311(d)(2) and 10 CFR 61.55;

• Tracking of raddaste shipments under 10 CFR 20.311(d), (e), (f) and

(h); and

Adherence to disposal site license conditions for Agreement State

licenses under 10 CFR 30.41.

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The basis for determination of waste class, (e.g. sampling, vendor

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analyses, scaling factors for hard-to-identify radionuclides and

calculations) was also reviewed for each shipment. The basis for

concluding that a suitable waste form was provided was also reviewed for

each shipment of dewatered or solidified radwaste materials.

Within the scope of this review, no violations were noted. Adequate

technical bases were noted for Class A and B routine shipments. The

licensee had taken appropriate samples, updated scaling factors using

accepted methods and implemented the classification program consistent

with NRC regulatory guidance. The process control program, routine tests

of process parameters and process quality control inspection holdpoints

were implemented for the thirteen shipments.

9. Radioactive Materials Shipping Requirements

Sixteen radioactive material shipments (i.e. thirteen solid radwaste and

three other radioactive materials shipments to other licensees), were

reviewed relative to criteria provided in 10 CFR 71 and 49 CFR 170-149 to

i determine if transportation requirements had been met. General

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requirements for transfer of radioactive materials under 10 CFR 30,41, 10

CFR 40.51 and 10 CFR 70.42 and adherence to licensee procedures under

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Technical Specification 6.8 were also reviewed. Performance relative to

these criteria was determined by:

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review of procedures, procurement documents, certificates of

compliance and radioactive shipping records;

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interviews and discussions with licensee personnel concerning

shipment prepar.cion, placarding, radiation / contamination survey

, techniques, labeling, securing shipments and other matters; and

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direct observation of licensee's shipment No. 12-88 made on February

10, 1988.

Within the scope of this review, the following violation was identified:

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10 CFR 30.41(c) requires, in part, that each licensee transferring

byproduct material verify that the recipient's license authorizes

receipt of the type, form and quantity of the byproduct material to

be transferred. Technical Specification 6.8 requires, in part, that

procedures be implemented. Licensee's Procedure HP0/C0-17 requires

verification of the recipient's license prior to transfer.

Contrary to these requirements, on or about November 25, 1987, the

licensee transferred 52 solidified drums of waste oil (as shioment

No. 82-87) containing an estimated 53.51 millicuries of tritium to

Quadrex-HPS, Inc. in Oak Ridge, Tennessee. The Tennessee Radioactive

Material License, (Number R-01037-L7), did not authorize the recipient

to possess tritium in the form of solidified oil at that time.

Amendment 38 to that Tennessee Radioactive Material License

authorized receipt of the drums for repackaging and subsequent

disposal on December 8, 1987 and was issued as a temporary amendment

(to expire on January 8, 1988) to allow receipt of the licensee's

shipment. Subsequent recalculation by the licensee reduced the

estimated tritium content of the shipment to 0.25 millicuries and a

revised radioactive shipping record was sent to Quadrex-HPS, Inc. on

December 1. 1987. However, the licensee failed to verify that the

recinient could receive tritium contained in oil solidified in

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Environstone prior to shipping on November 25, 1987. That failure

constitutes a violation of 10 CFR 30.41(c) and Technical

Specification 6.8. (50-277/88-05-02; 50-278/88-05-02)

10. Exit Interview

The inspector met with the licensee's representatives (denoted in Detail

1) at the conclusion of the inspection on February 12, 1988. The

inspector summarized the scope and findings of the inspection as described

in this report.

At no time during the inspection was written material provided to the

licensee by the inspector. No information exempt from disclosure under 10

CFR 2.790 is discussed in this report.

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