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{{Adams | |||
| number = ML20245D994 | |||
| issue date = 06/19/1989 | |||
| title = Insp Repts 50-445/89-35 & 50-446/89-35 on 890503-0606. Violations Noted.Major Areas Inspected:Applicant Actions on Previous Insp Findings,Followup on Violations,Applicant Action on NRC Bulletins & Fuel Storage Racks | |||
| author name = Livermore H, Phillips H | |||
| author affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR) | |||
| addressee name = | |||
| addressee affiliation = | |||
| docket = 05000445, 05000446 | |||
| license number = | |||
| contact person = | |||
| document report number = 50-445-89-35, 50-446-89-35, NUDOCS 8906270294 | |||
| package number = ML20245D952 | |||
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | |||
| page count = 12 | |||
}} | |||
See also: [[see also::IR 05000445/1989035]] | |||
=Text= | |||
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APPENDIX B | |||
U. S. NUCLEAR REGULATORY COMMISSION | |||
OFFICE OF NUCLEAR REACTOR REGULATION | |||
, | |||
NRC Inspection Report: 50-445/89-35 Permits: CPPR-126. | |||
50-446/89-35 CPPR-127 | |||
Dockets: 50-445 Category: A2 | |||
50-446 | |||
Construction Permit | |||
Expiration Dates: | |||
Unit 1: August 1, 1991 | |||
Unit 2: August 1, 1992 | |||
Applicant: TU Electric | |||
Skyway Tower | |||
400 North Olive Street | |||
Lock Box 81 | |||
Dallas, Texas 75201 | |||
Facility Name: Comanche Peak Steam Electric Station (CPSES), | |||
Units 1 & 2 | |||
Inspection At: Comanche Peak Site, Glen Rose, Texas | |||
Inspection Conducted: May 3 through June 6, 1989 | |||
L/' { . | |||
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Inspector: ~ #" U | |||
H. / M,;llips | |||
S. Phi | |||
y | |||
, | |||
__ | |||
Senior Resident Inspector Date | |||
Construction | |||
/ | |||
Reviewed bye. 4fM/&hE - | |||
., | |||
_b[f; | |||
H. B. Livermore, Lead Senior Inspector Date | |||
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ADO V | |||
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iL LInspection Summary: | |||
l Inspection Conducted: May 3 through June 6, 1989 (Report | |||
50-445/89-35; 50-446/89-35) | |||
Areas Inspectedi Unannounced, resident' safety inspection of | |||
(1) . applicant's actions on previous: inspection findings, | |||
(2) follow-up on violations, (3) applicant action on NRC Bulletins, | |||
(4) allegation follow-up,.(5) review of commercial procurement for | |||
AFW components, (6) fuel storage racks, and.(7) general' plant areas | |||
.(tours). | |||
Results: . Within the areas inspected, one violation: ' failure to | |||
control design changes, paragraph 2.a. Three. unresolved items were | |||
identified.(two in paragraph 6.b and one in paragraph 6.c) | |||
concerning the procurement of commercial items. That is, the NRC | |||
. inspector questioned the decisions that these items (a part of a | |||
safety-related component) can not affect the component's ability to | |||
function and assure safe shutdown. The procurement area continues | |||
to exhibit symptoms that may indicate a continuation of weaknesses | |||
identified during the procurement of services for coating removal | |||
From Unit'1' service water piping. | |||
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DETAILS . | |||
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1. Persons ContactedL | |||
i | |||
*M. Axelrad, Newman and Holtzinger | |||
P' *D. P. Barry,1 Senior., Manager, Engineering,.SWEC | |||
*D. Bize, License' Support, TU Electric | |||
*H. D. Bruner, Senior Vice President, TU Electric | |||
*W. .J. Cahill, Executive Vice President, Nuclear, TU. Electric | |||
*H. M. Carmichael, Senior QA Program Manager, CECO | |||
'*J. T. Conly, APE-Licensing, SWEC a | |||
*W. G. . Counsil, Vice Chairman, Nuclear, TU Electric | |||
*S. Ellis, Performance and Testing, UT Electric | |||
*P. E. Halstead, QC Manager, TU Electric- | |||
*C'. B.-Hogg, Engineering Manager, TU Electric | |||
*R.:T.tJenkins, Manager,' Mechanical Engineering, TU Electric | |||
*J. J. Kelley, Manager, Plant Operations, TU Electric | |||
*J. J.:LaMarca, Electrical Engineering Manager, TU Electric | |||
*0. W. Lowe, Director of Engineering, TU Electric | |||
*S. G. McBee, NRC Interface, TU Electric | |||
*B. Packo, Licensing Engineer, TU ilectric | |||
; *S.-S. Palmer, Project Manager, TU Blectric | |||
*P. Raysircar,-Deputy Director, Unit 2, CECO | |||
*D. Real, Dallas Morning News | |||
*D. M. Reynerson, Director of' Construction, TU Electric | |||
*J. C. Smith, Plant Operations Staff, TU Electric | |||
*R. L. Spence, TU/QA Senior Advisor, TU Electric | |||
*J. F. Streeter, Director, QA, TU Electric | |||
*C. L. Terry, Unit 1 Project Manager, TU Electric | |||
The.NRC inspectors also interviewed other applicant employees | |||
during this inspection period. | |||
* Denotes personnel present at the June 6, 1989, exit | |||
meeting. | |||
2. Applicant's Action on Previous Inspection Findings (92701) | |||
g a. (Closed) Unresolved Item (445/8908-U-02): Silicone bronze | |||
h, bolts in auxiliary feedwater (AFW) motors changed without | |||
proper engineering authorization. The NRC inspector | |||
identified this deficiency and several other concerns | |||
relative to a material change that was made when the AFW | |||
motors were worked.on to correct the reversed ; | |||
unidirectional fans in Unit 1 motors. During this 1 | |||
maintenance activity, a Westinghouse (W) representative | |||
(consultant) stated that the silicon bronze bolts should | |||
be replaced with carbon steel bolts because the former had | |||
cracked and failed because of fatigue. W letter WPT-10729 | |||
stated they were unaware of any problems and had tried to | |||
contact the consultant who worked for them, but were | |||
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unable to locato him. W maintained that this was not a | |||
problem. This unresolved item is closed. | |||
The unauthorized material substitution is a violation of | |||
Criterion III Design Control which requires that design | |||
changes, including field design changes, shall be subject | |||
to design control measures commensurate with those applied | |||
to the original design and be approved by the organization | |||
that performed the original design. Two NCRs | |||
(89-02548/02547) required the carbon steel bolts to be | |||
replaced with the silicon bolts that were originally | |||
authorized (445/8935-V-01). | |||
b. (Closed) Open Item (445/8908-O-05): During a previous | |||
inspection,'the NRC inspector found that instrumentation | |||
tubing for flow transmitters in the Unit 1 reactor coolant | |||
loop had been bent. This item was referred to | |||
TU Electric. They stated that they were aware of bent | |||
tubing and the damage would be documented on a NCR. The | |||
item was left open pending the roccipt of NCRs. | |||
TU Electric submitted files to the NRC with nine NCRs that | |||
documented more damage than the NRC inspector had found. | |||
It appears that the proper controls are in place for | |||
identifying and correcting such deficiencies. This item | |||
is closed. | |||
c. (Closed) Open Item (445/8909-0-01): FSAR flow diagram | |||
error. During a walkdown of the Unit 1 safety injection | |||
system, the NRC inspector determined that | |||
drawing 2323-M1-0261, Amendment 67 showed two isolation | |||
valves that were labeled with the same valve No. 1-S1-048 | |||
in 12-inch piping run (12-1-031-151R). The NRC inspector | |||
reviewed TU Electric files that were submitted to confirm | |||
that needed changes were made. The NRC confirmed that | |||
appropriate action to change the FSAR drawing and | |||
identify the valves correctly was taken. This item is | |||
closed. | |||
3. Follow-up on Violations (927021 | |||
e. (Closed) Violation (445/8727-V-01a): TU Electric found | |||
that Unit 2 AFN fans in the motors were backwards, but | |||
failed to check and ccrrect Unit i fans. The NRC | |||
challenged the assumption that the AFW fans were correct * | |||
in Unit 1 because they passed preoperational testing. In | |||
response, the fans were checked and were found to be | |||
I | |||
backwards. These cond3tions were docu:uented on | |||
nonconformance reports (NCRs) and were correctly installed | |||
in accordance with work orders C87-0003441/0003442. This , | |||
item is closed. : | |||
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b. (Closed) Violation (445/8727-V-01c; 446/8720-V-01A): The | |||
interface between the AFW pump and motor was not | |||
established in the applicable specification. As a result | |||
of this confusion about the direction of motor and pump | |||
shaft rotation / coupling, the unidirectional fans were | |||
installed backwards. | |||
TU Electric issued design changes to Specification | |||
2323-ES-lD and 2323-MS-7 to clearly indicate the direction | |||
of rotation. All other safety-related motors were checked | |||
for similar deficiencies. In addition, all project | |||
specifications were reviewed. This item is closed. | |||
4 .- Applicant Action on NRC Bulletins (92703) | |||
a. (Closed) IEB 78-08, " Radiation Levels from Fuel Element | |||
Transfer-Tubes": This bulletin was issued as a result of | |||
personnel. exposures during the first refueling outage at | |||
another nuclear plant. The exposure occurred inside the | |||
reactor building because labyrinth-type shielding access | |||
was not controlled. The bulletin required licensees to: | |||
(1) review shielding design, (2) assure access control, | |||
(3) assure that radiation hazard signs are posted, | |||
(4) identify radiation streaming when design was reviewed, | |||
and (5) provide a response to the NRC. TU Electric | |||
received this bulletin when the construction phase was in | |||
progress and no response was required. Regardless, these | |||
design issues and administrative controls were addressed | |||
in Final Safety Analysis Report, questions 531.10, 331.21, | |||
and the answers; health physics Procedure HP1-600 and | |||
Station Administrative Procedure (STA)-660. This item is | |||
closed. | |||
b. (closed) IEB 79-13 and Revisions 1 and 2, " Cracking in | |||
Feedwater System Piping": This IEB followed the discovery | |||
of pipe cracks at another nuclear plant after that plant | |||
was shutdown'to investigate leakage inside containment. | |||
The cracking occurred at the feedwater nozzle to piping | |||
welds on the steam generators at different plants. Thir , | |||
IEB required radiographic and ultrasonic examination of i | |||
steam generators fabricated by Westinghouse or combustion | |||
Engineering. Gupports/snubters that were not | |||
volumetrically examined since 1979, and others were to be i | |||
visually examined during the next fuel outage. Revision 1 ! | |||
of the IEB revealed failure by fatigue, assisted by ! | |||
4 | |||
corrosion. | |||
Certain applicants for a license were required to perform , | |||
nondestruct3ve examination (NDE) of the subject I | |||
nozzle-pipe welds and visual inspection after hot i | |||
' | |||
functional testing and were to perform inspections after | |||
l the first refueling outage. Revision 2 refined the | |||
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required inspections and required the applicant to perform l | |||
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inspections after hot functional testing, but before fuel | |||
loading. (This IEB should have applied to Comanche Peak | |||
Unit 1 since hot functional testing had been completed.) | |||
During a previous inspection of this IEB, the NRC | |||
inspector considered this IEB open pending the receipt of | |||
answers to questions about which of the following were | |||
applicable: (1) were all nozzle-pipe welds radiographer | |||
for both units, (2) was ultrasonic-testing done, (3) what | |||
were the technical conclusions, and.(4) should TU Electric | |||
make a report on an IEB such as this when action is | |||
required. | |||
TU Electric provided a file (TSL-890-68 dated March 30, | |||
1989) that comprehensively addressed the issues in this | |||
IEB. This IEB is closed. | |||
c. (Closed) IEB 79-17 and Revision 1, " Pipe Cracks in | |||
Stagnant Borated Water Systems at PWR Plants": This IEB | |||
was issued after cracks were found in stainless steel | |||
piping which contained oxygenated, stagnant or essentially | |||
stagnant borated water at another plant. The NRC | |||
inspector reviewed a file which showed these issues were | |||
properly considered during ASME Section XI examinations. | |||
Water chemistry control Procedures CEM-506, 509, 511, and | |||
517, also help control chemicals that may be detrimental | |||
to the stainless steel piping. This item is closed. | |||
d. (Closed) IEB.79-24, " Frozen Lines": This IEB was issued | |||
after frozen lines were discovered in safety-related | |||
systems at an operating plant. Specifically, there was no | |||
flow through the recirculation line from the pump | |||
discharge to the borated water storage tank because a line | |||
was exposed to outside weather and froze. Even though | |||
redundant heat tracing was on the line, the freezing | |||
occurred because of prolonged subfreezing temperatures and | |||
a defect in the insulation. | |||
The NRC reviewed this IEB on previous occasions. The last | |||
m | |||
review identified three questions about the protection of | |||
H lines: (1) is distribution of heat in tunnels uniform and | |||
effectiva, (2) did the design change authorization (DCA) | |||
require a FSAR change, and (3) should a 50.55e evaluation | |||
be me.de? | |||
TU Electric provided information that answered the | |||
questions .and satisfied the NRC inFpector'S Concerns. | |||
Most importantly it was learned that EBASCO evaluated the | |||
Environment of the lines and concluded | |||
(Calculation 1-EB-3020-1) that the tunnels were heated | |||
effectively. This item is closed. | |||
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5. A11egtion Follow-up - (99014) ] | |||
(Closed) Allegation (OSP-84-A-0010 and RIV-84-A-0146): NCRs | |||
were signed off before work was completed. When the Technical | |||
Review Team (TRT) was on site in 1984 they were to look into | |||
this item. | |||
During this inspection period, the NRC inspector was asked to | |||
reinspect a portion of this allegation. Specifically, die | |||
alleger stated that he or she was asked to sign off on an NCR I | |||
written on a gouge in a flange on a 12-inch diameter spool ) | |||
piece before the defect was corrected. The NRC inspector found | |||
insufficient information concerning this matter. That is, the | |||
description of the concern was so vague'that the piping and the | |||
NCR could not be identified. The TRT personnel may have had | |||
the same problem. In that the deficiency was documented and | |||
several individuals were involved, there is no reason to | |||
conclude that appropriate action was not taken. This item is | |||
closed. | |||
6. Review of Commercial Grade Items Used to Repair Safety-Related | |||
Components (35065, 38073) | |||
a. Background | |||
The NRC reviewed NRC Information Notices (88-97, 89-18, | |||
89-22, and 89-39) which described substandard valve parts, | |||
steel parts / materials, and certification of fasteners and | |||
NRC Generic Letter 89-02 which addressed three effective | |||
characteristics for controlling the procurement of | |||
commercial grade products. It also discussed the | |||
dedication of commercial items after receipt to allow them | |||
to be used in safety-related components. The NRC staff | |||
conditionally endorsed the guidelines in EPRI NP-5652, | |||
" Guideline for the Utilization of Commercial-Grade Items | |||
in Nuclear Safety-Related Applications (NCIG-07)." l | |||
b. Review of Procurement Activities | |||
The NPC inspector reviewad TU Electric | |||
Procedure ECE 6.02-02, " Engineering Review of Procurement | |||
Documents," Revision 4, and changes EDCN-01 through 03, | |||
dated January through April 1989. It described ' | |||
procurement Codes A, C, N and V. Code A and V require ! | |||
'IU Electric or the vendor to apply a QA program in | |||
accordance with 10 CFR 50, Appendix B, while Code C and H ; | |||
do not. For a commercial purchase, QA Code C, form 7.1 of | |||
this procedure contains three blanks which must be checked i | |||
to answer whether an item is a basic component that is i | |||
necessary to assure (1) the integrity of the reactor I | |||
coolant pressure boundary (RCPB), (2) the capability to ! | |||
shutdown the reactor and maintain it in a safe shutdown | |||
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condition, cn: (3) the capability to prevent or mitigate | |||
the consequences of an accident (10 CFR 100.11). If the | |||
answer is no to each (1-3), then no quality assurance | |||
requirements (10 CFR Appendix B) need be imposed in the | |||
purchase order and an item that is a part of a | |||
safety-related component can be purchased commercially. | |||
The NRC inspector reviewed 42 purchase orders for | |||
components under the control of TU Electric operations to | |||
select a sample of Code C procurement for January - | |||
February 1988. Purchase Orders 661-76900; 74968; 74960; | |||
74953; 74954, 74946, 74955, 74993, 74994, and'74985 were | |||
items purchased under QA - Code C. That is, the vendor | |||
was not required to provide these items under a 10 CFR 50, | |||
Appendix B, QA program and 10 CFR 20 defects reporting | |||
requirements. The NRC inspector questioned the | |||
correctness of the determination of whether the item (a | |||
part of a component) were required for or could affect | |||
safe shutdown function. If the items were required for or | |||
could affect safe shutdown, quality assurance should have | |||
been required. The following are examples where the NRC | |||
questioned the TU Electric justification for deciding no i | |||
Appendix B QA program or Part 21 defect reporting | |||
requirements were needed. | |||
(1) Purchase Order 661-74955 was issued November 16, | |||
1987, for items to be installed in six auxiliary | |||
feedwater (AFW) pumps in Unit 1 and 2. During | |||
. | |||
preoperational testing a test deficiency report | |||
(ME-84-010) was issued because the outboard bearings | |||
exceeded acceptable temperatures. Design | |||
modification 87-1-026 was issued for upgrading | |||
bearing cooling lines, but was revised because | |||
engineering decided that Ingersoll Rand | |||
Bulletin 60-87 would correct the problem. This was | |||
reported to the NRC as a significant construction | |||
deficiency in SDAR CP-87-50. The SDAR stated that i | |||
this condition could cause a loss cf all AFW pumps. | |||
Thrust bearing disc springs, shims, "O" rings, and | |||
end covers were procured through a purchase order | |||
that was classified as a commercial purchase without | |||
any requirement to dedicate or upgrade the item to | |||
safety-related. In this case, the engineer decided | |||
that the function of the item would not be needed to | |||
assure RCPB integrity, safe shutdown, or fer accident | |||
prevention / mitigation. The NRC inspector questioned | |||
' | |||
and challenged this conclusion because (1) the item | |||
can affect the quality of an ASME Code component and | |||
(2) the item will affect the capability to safely | |||
shutdown or maintain safe shutdown. This matter was | |||
identified and discussed with TU Electric at the end | |||
of the inspection and will be unresolved until | |||
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TU Electric resolves the apparent conflict between | |||
safety implications described in TXX-6954 versus the | |||
" Basic Component" justification in the " Procurement | |||
Document Review Summary" (445/8935-U-02). | |||
(2) Purchase Order 661-76900S was issued May 18, 1989, | |||
for bonnet seals in ASME Code Valve 1AF-0038 which is | |||
a Borg-Warner check valyc in the AFW system. The | |||
decisions on this item were similar to those | |||
discussed above. However, the NRC inspector | |||
questions if a formal written ovaluation was | |||
performed to support the decision that failure of | |||
this seal will not affect safe shutdown. No such | |||
engineering evaluation was provided to the NRC (only | |||
references were made to the Specification MS-20.1, | |||
Revision 2, and the vendor manual). This item is | |||
unrosolved until TU Electric produces an engineering | |||
justification that failure of the seal material will | |||
not affect the function.of the valve (445/8935-U-03). | |||
(3) Purchase Order 661-74954 was issued for electronic or | |||
electrical printed circuit boards used in a | |||
safety-related application. The original requisition | |||
was for a commercial procurement. This error was | |||
caught and a nonconformance was written. The point | |||
here to be considered is that other'such errors in | |||
judgement may have allowed components to be purchased | |||
commercially because they were thought to not affect | |||
the functioning of components. There is no | |||
indication that TU Electric has addressed this issue < | |||
and has audited a large number of such procurement. | |||
This item is considered a part of the unresolved item | |||
discussed in paragraph 6.c below. | |||
c. Review of TU Electric Audit | |||
During this inspection period, the NRC inspector reviewed | |||
TU Electric Audit TSU-89-01 involving a commercial | |||
procurement. The original audit scope was to perform a | |||
i | |||
surveillance of Hot Functional Testing of Unit 1. | |||
However, because charging valve FCV-321 demonstrated | |||
arratic behavior and could not control the charging rate | |||
to the pressurizer the auditors followod the actions taken | |||
to correct this problem.. Test Deficiency Report 7298 was | |||
issued and the deficiency was traced to resolution. After | |||
the auditor followed-up, the following are the preliminary | |||
audit findings: | |||
. Maintenance discovered that the controller tubing was | |||
tubed into the wrong ports of the valvo. No | |||
nonconformance was written. They just fixed the | |||
problem. | |||
1 | |||
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W . Startup discovered a new design for the plug and' trim | |||
cage of.the. valve and' decided to use the new design | |||
to avoid retesting'. They found that Union Electric | |||
could provide.the parts Unmediately. | |||
~ | |||
. A QA - Code "A" requisition was issued. -QA Code A | |||
requires the vendor to be.on TU Electric's approved | |||
vendor list. | |||
. TU. Electric's procurement QA personnel' rejected the | |||
requisition because QA' requirements were not included | |||
and the subject vendor (Union Electric) was not on | |||
the approved list. | |||
. The requisition was changed to QA - Code N | |||
(nonsafety-related) and was designated as | |||
'' | |||
'undesignated spares (parts). As Code N purchases | |||
could not be used in a safety-related system it was | |||
necessary to change to Code C (nonquality | |||
components / parts which have some quality | |||
requirements).- Note: The NRC inspector believes | |||
this definition is confusing TU Electric personnel | |||
and should be clarified. | |||
.. | |||
.- Accordingly, a series of moves were made to change | |||
the QA Code N to Code C to allow the valve to be i | |||
' | |||
changed to the new design. . One move included | |||
., removing.the ASME tag (NPT) from the Copes Vulcan | |||
valve. Design Change Authorization 85385 was issued | |||
to make all of this happen, but according to the | |||
auditor this violated ASME Section XI, | |||
subsection lWA-7220 which requires components to be | |||
evaluated before replacement / installation. | |||
. In addition to the above, the TU Electric auditor | |||
noted that 10 CFR,-Part 21, requirements were not | |||
invoked, appropriate documentation was not required, | |||
and the QC inspector was unaware of the change from a | |||
temporary modification to permanent plant design. | |||
Also, the missing tag was not noted. | |||
The preliminary information discussed above is a real time | |||
example of how the procurement process can be bypassed. | |||
Prior to this inspecticn, the NRC inspector discussed such | |||
potential abuses of the QA Code classification in a | |||
presentation on procurement (that was made by TU Electric | |||
to close previous NRC concerns). At the time, the NRC | |||
inspector was told that commercial procurement. vere | |||
controlled by the quality organization's audit of a small | |||
percentage of the commercial procurement. | |||
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The NRC inspector subsequently reviewed the final audit | |||
(TSU-89-01) report-and interviewed the TU Electric QA | |||
manager with respect to the audit of commercial | |||
procurement. The NRC inspector considers this item to be | |||
unresolved and has requested a meeting with TU Electric to | |||
discuss TSU-89-01, the apparent problems, and audits of | |||
commercial procurement to assure that safety-related | |||
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components and items installed in components are procured | |||
to appropriate regulatory requirements (445/8935-U-04). | |||
7. Fuel Storage Racks (50095) | |||
Two NRC inspectors had previously reviewed Unit 1 | |||
specification,. procedures, work instructions, and drawings for , | |||
Unit 1 racks. The completed work was also inspected for ' | |||
configuration and the appearance and size of welds. Records | |||
including travelers, design changes, and inspection reports | |||
were reviewed. | |||
1 | |||
During this inspection period, the NRC inspector, visually | |||
inspected the racks to assure that they had not been damaged or | |||
substantially changed. The inspector has no further questions | |||
about the storage racks. ! | |||
8. General Plant Inspections (55050, 50073) | |||
At various times during the inspection period, the NRC i | |||
inspector conducted independent and planned inspections I | |||
(regular and backshift) of the Unit 1 reactor containment, | |||
safeguards, auxiliary, electrical control, and diesel generator | |||
buildings. All accessible rooms in these buildings were | |||
inspected to observe current work activities with respect to | |||
major safety-related equipment, electrical cable / trays, | |||
mechanical components, piping, welding, and removal of debris | |||
from seismic gap between buildings. The housekeeping, storage, | |||
and handling conditions inside these buildings and various | |||
outside storage areas were also inspected. Fire | |||
prevention / protection measures were observed during the subject | |||
inspections. No violations or deviations were identified. | |||
9. Unresolved Items | |||
Unresolved items are matters about which more information is : | |||
required in order to ascertain whether they are acceptable ! | |||
items, violations, or deviations. Three unresolved items | |||
disclosed during the inspection are discussed in paragraphs 6.b | |||
(two) and 6.c (one). | |||
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10. Exit Meeting (30703) | |||
An exit meeting was conducted June 6, 1989, with the | |||
applicant's representatives identified in paragraph 1 of this | |||
report. No written material was provided to the applicant by | |||
the inspectors during this reporting' period. The applicant did | |||
not identify as proprietary any of the materials provided to or | |||
reviewed by the inspectors during this inspection. During this | |||
meeting,.the NRC inspectors summarized the scope and findings | |||
of-the inspection. | |||
1 | |||
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}} |
Latest revision as of 02:15, 1 February 2022
ML20245D994 | |
Person / Time | |
---|---|
Site: | Comanche Peak ![]() |
Issue date: | 06/19/1989 |
From: | Livermore H, Phillips H Office of Nuclear Reactor Regulation |
To: | |
Shared Package | |
ML20245D952 | List: |
References | |
50-445-89-35, 50-446-89-35, NUDOCS 8906270294 | |
Download: ML20245D994 (12) | |
See also: IR 05000445/1989035
Text
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APPENDIX B
U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
,
NRC Inspection Report: 50-445/89-35 Permits: CPPR-126.
50-446/89-35 CPPR-127
Dockets: 50-445 Category: A2
50-446
Construction Permit
Expiration Dates:
Unit 1: August 1, 1991
Unit 2: August 1, 1992
Applicant: TU Electric
Skyway Tower
400 North Olive Street
Lock Box 81
Dallas, Texas 75201
Facility Name: Comanche Peak Steam Electric Station (CPSES),
Units 1 & 2
Inspection At: Comanche Peak Site, Glen Rose, Texas
Inspection Conducted: May 3 through June 6, 1989
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Inspector: ~ #" U
H. / M,;llips
S. Phi
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Senior Resident Inspector Date
Construction
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Reviewed bye. 4fM/&hE -
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H. B. Livermore, Lead Senior Inspector Date
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iL LInspection Summary:
l Inspection Conducted: May 3 through June 6, 1989 (Report
50-445/89-35; 50-446/89-35)
Areas Inspectedi Unannounced, resident' safety inspection of
(1) . applicant's actions on previous: inspection findings,
(2) follow-up on violations, (3) applicant action on NRC Bulletins,
(4) allegation follow-up,.(5) review of commercial procurement for
AFW components, (6) fuel storage racks, and.(7) general' plant areas
.(tours).
Results: . Within the areas inspected, one violation: ' failure to
control design changes, paragraph 2.a. Three. unresolved items were
identified.(two in paragraph 6.b and one in paragraph 6.c)
concerning the procurement of commercial items. That is, the NRC
. inspector questioned the decisions that these items (a part of a
safety-related component) can not affect the component's ability to
function and assure safe shutdown. The procurement area continues
to exhibit symptoms that may indicate a continuation of weaknesses
identified during the procurement of services for coating removal
From Unit'1' service water piping.
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DETAILS .
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1. Persons ContactedL
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- M. Axelrad, Newman and Holtzinger
P' *D. P. Barry,1 Senior., Manager, Engineering,.SWEC
- D. Bize, License' Support, TU Electric
- H. D. Bruner, Senior Vice President, TU Electric
- W. .J. Cahill, Executive Vice President, Nuclear, TU. Electric
- H. M. Carmichael, Senior QA Program Manager, CECO
'*J. T. Conly, APE-Licensing, SWEC a
- W. G. . Counsil, Vice Chairman, Nuclear, TU Electric
- S. Ellis, Performance and Testing, UT Electric
- C'. B.-Hogg, Engineering Manager, TU Electric
- R.:T.tJenkins, Manager,' Mechanical Engineering, TU Electric
- J. J. Kelley, Manager, Plant Operations, TU Electric
- J. J.:LaMarca, Electrical Engineering Manager, TU Electric
- 0. W. Lowe, Director of Engineering, TU Electric
- S. G. McBee, NRC Interface, TU Electric
- B. Packo, Licensing Engineer, TU ilectric
- *S.-S. Palmer, Project Manager, TU Blectric
- P. Raysircar,-Deputy Director, Unit 2, CECO
- D. Real, Dallas Morning News
- D. M. Reynerson, Director of' Construction, TU Electric
- J. C. Smith, Plant Operations Staff, TU Electric
- R. L. Spence, TU/QA Senior Advisor, TU Electric
- C. L. Terry, Unit 1 Project Manager, TU Electric
The.NRC inspectors also interviewed other applicant employees
during this inspection period.
- Denotes personnel present at the June 6, 1989, exit
meeting.
2. Applicant's Action on Previous Inspection Findings (92701)
g a. (Closed) Unresolved Item (445/8908-U-02): Silicone bronze
h, bolts in auxiliary feedwater (AFW) motors changed without
proper engineering authorization. The NRC inspector
identified this deficiency and several other concerns
relative to a material change that was made when the AFW
motors were worked.on to correct the reversed ;
unidirectional fans in Unit 1 motors. During this 1
maintenance activity, a Westinghouse (W) representative
(consultant) stated that the silicon bronze bolts should
be replaced with carbon steel bolts because the former had
cracked and failed because of fatigue. W letter WPT-10729
stated they were unaware of any problems and had tried to
contact the consultant who worked for them, but were
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unable to locato him. W maintained that this was not a
problem. This unresolved item is closed.
The unauthorized material substitution is a violation of
Criterion III Design Control which requires that design
changes, including field design changes, shall be subject
to design control measures commensurate with those applied
to the original design and be approved by the organization
that performed the original design. Two NCRs
(89-02548/02547) required the carbon steel bolts to be
replaced with the silicon bolts that were originally
authorized (445/8935-V-01).
b. (Closed) Open Item (445/8908-O-05): During a previous
inspection,'the NRC inspector found that instrumentation
tubing for flow transmitters in the Unit 1 reactor coolant
loop had been bent. This item was referred to
TU Electric. They stated that they were aware of bent
tubing and the damage would be documented on a NCR. The
item was left open pending the roccipt of NCRs.
TU Electric submitted files to the NRC with nine NCRs that
documented more damage than the NRC inspector had found.
It appears that the proper controls are in place for
identifying and correcting such deficiencies. This item
is closed.
c. (Closed) Open Item (445/8909-0-01): FSAR flow diagram
error. During a walkdown of the Unit 1 safety injection
system, the NRC inspector determined that
drawing 2323-M1-0261, Amendment 67 showed two isolation
valves that were labeled with the same valve No. 1-S1-048
in 12-inch piping run (12-1-031-151R). The NRC inspector
reviewed TU Electric files that were submitted to confirm
that needed changes were made. The NRC confirmed that
appropriate action to change the FSAR drawing and
identify the valves correctly was taken. This item is
closed.
3. Follow-up on Violations (927021
e. (Closed) Violation (445/8727-V-01a): TU Electric found
that Unit 2 AFN fans in the motors were backwards, but
failed to check and ccrrect Unit i fans. The NRC
challenged the assumption that the AFW fans were correct *
in Unit 1 because they passed preoperational testing. In
response, the fans were checked and were found to be
I
backwards. These cond3tions were docu:uented on
nonconformance reports (NCRs) and were correctly installed
in accordance with work orders C87-0003441/0003442. This ,
item is closed. :
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b. (Closed) Violation (445/8727-V-01c; 446/8720-V-01A): The
interface between the AFW pump and motor was not
established in the applicable specification. As a result
of this confusion about the direction of motor and pump
shaft rotation / coupling, the unidirectional fans were
installed backwards.
TU Electric issued design changes to Specification
2323-ES-lD and 2323-MS-7 to clearly indicate the direction
of rotation. All other safety-related motors were checked
for similar deficiencies. In addition, all project
specifications were reviewed. This item is closed.
4 .- Applicant Action on NRC Bulletins (92703)
a. (Closed) IEB 78-08, " Radiation Levels from Fuel Element
Transfer-Tubes": This bulletin was issued as a result of
personnel. exposures during the first refueling outage at
another nuclear plant. The exposure occurred inside the
reactor building because labyrinth-type shielding access
was not controlled. The bulletin required licensees to:
(1) review shielding design, (2) assure access control,
(3) assure that radiation hazard signs are posted,
(4) identify radiation streaming when design was reviewed,
and (5) provide a response to the NRC. TU Electric
received this bulletin when the construction phase was in
progress and no response was required. Regardless, these
design issues and administrative controls were addressed
in Final Safety Analysis Report, questions 531.10, 331.21,
and the answers; health physics Procedure HP1-600 and
Station Administrative Procedure (STA)-660. This item is
closed.
b. (closed) IEB 79-13 and Revisions 1 and 2, " Cracking in
Feedwater System Piping": This IEB followed the discovery
of pipe cracks at another nuclear plant after that plant
was shutdown'to investigate leakage inside containment.
The cracking occurred at the feedwater nozzle to piping
welds on the steam generators at different plants. Thir ,
IEB required radiographic and ultrasonic examination of i
steam generators fabricated by Westinghouse or combustion
Engineering. Gupports/snubters that were not
volumetrically examined since 1979, and others were to be i
visually examined during the next fuel outage. Revision 1 !
of the IEB revealed failure by fatigue, assisted by !
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corrosion.
Certain applicants for a license were required to perform ,
nondestruct3ve examination (NDE) of the subject I
nozzle-pipe welds and visual inspection after hot i
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functional testing and were to perform inspections after
l the first refueling outage. Revision 2 refined the
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required inspections and required the applicant to perform l
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inspections after hot functional testing, but before fuel
loading. (This IEB should have applied to Comanche Peak
Unit 1 since hot functional testing had been completed.)
During a previous inspection of this IEB, the NRC
inspector considered this IEB open pending the receipt of
answers to questions about which of the following were
applicable: (1) were all nozzle-pipe welds radiographer
for both units, (2) was ultrasonic-testing done, (3) what
were the technical conclusions, and.(4) should TU Electric
make a report on an IEB such as this when action is
required.
TU Electric provided a file (TSL-890-68 dated March 30,
1989) that comprehensively addressed the issues in this
IEB. This IEB is closed.
c. (Closed) IEB 79-17 and Revision 1, " Pipe Cracks in
Stagnant Borated Water Systems at PWR Plants": This IEB
was issued after cracks were found in stainless steel
piping which contained oxygenated, stagnant or essentially
stagnant borated water at another plant. The NRC
inspector reviewed a file which showed these issues were
properly considered during ASME Section XI examinations.
Water chemistry control Procedures CEM-506, 509, 511, and
517, also help control chemicals that may be detrimental
to the stainless steel piping. This item is closed.
d. (Closed) IEB.79-24, " Frozen Lines": This IEB was issued
after frozen lines were discovered in safety-related
systems at an operating plant. Specifically, there was no
flow through the recirculation line from the pump
discharge to the borated water storage tank because a line
was exposed to outside weather and froze. Even though
redundant heat tracing was on the line, the freezing
occurred because of prolonged subfreezing temperatures and
a defect in the insulation.
The NRC reviewed this IEB on previous occasions. The last
m
review identified three questions about the protection of
H lines: (1) is distribution of heat in tunnels uniform and
effectiva, (2) did the design change authorization (DCA)
require a FSAR change, and (3) should a 50.55e evaluation
be me.de?
TU Electric provided information that answered the
questions .and satisfied the NRC inFpector'S Concerns.
Most importantly it was learned that EBASCO evaluated the
Environment of the lines and concluded
(Calculation 1-EB-3020-1) that the tunnels were heated
effectively. This item is closed.
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5. A11egtion Follow-up - (99014) ]
(Closed) Allegation (OSP-84-A-0010 and RIV-84-A-0146): NCRs
were signed off before work was completed. When the Technical
Review Team (TRT) was on site in 1984 they were to look into
this item.
During this inspection period, the NRC inspector was asked to
reinspect a portion of this allegation. Specifically, die
alleger stated that he or she was asked to sign off on an NCR I
written on a gouge in a flange on a 12-inch diameter spool )
piece before the defect was corrected. The NRC inspector found
insufficient information concerning this matter. That is, the
description of the concern was so vague'that the piping and the
NCR could not be identified. The TRT personnel may have had
the same problem. In that the deficiency was documented and
several individuals were involved, there is no reason to
conclude that appropriate action was not taken. This item is
closed.
6. Review of Commercial Grade Items Used to Repair Safety-Related
Components (35065, 38073)
a. Background
The NRC reviewed NRC Information Notices (88-97, 89-18,
89-22, and 89-39) which described substandard valve parts,
steel parts / materials, and certification of fasteners and
NRC Generic Letter 89-02 which addressed three effective
characteristics for controlling the procurement of
commercial grade products. It also discussed the
dedication of commercial items after receipt to allow them
to be used in safety-related components. The NRC staff
conditionally endorsed the guidelines in EPRI NP-5652,
" Guideline for the Utilization of Commercial-Grade Items
in Nuclear Safety-Related Applications (NCIG-07)." l
b. Review of Procurement Activities
The NPC inspector reviewad TU Electric
Procedure ECE 6.02-02, " Engineering Review of Procurement
Documents," Revision 4, and changes EDCN-01 through 03,
dated January through April 1989. It described '
procurement Codes A, C, N and V. Code A and V require !
'IU Electric or the vendor to apply a QA program in
accordance with 10 CFR 50, Appendix B, while Code C and H ;
do not. For a commercial purchase, QA Code C, form 7.1 of
this procedure contains three blanks which must be checked i
to answer whether an item is a basic component that is i
necessary to assure (1) the integrity of the reactor I
coolant pressure boundary (RCPB), (2) the capability to !
shutdown the reactor and maintain it in a safe shutdown
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condition, cn: (3) the capability to prevent or mitigate
the consequences of an accident (10 CFR 100.11). If the
answer is no to each (1-3), then no quality assurance
requirements (10 CFR Appendix B) need be imposed in the
purchase order and an item that is a part of a
safety-related component can be purchased commercially.
The NRC inspector reviewed 42 purchase orders for
components under the control of TU Electric operations to
select a sample of Code C procurement for January -
February 1988. Purchase Orders 661-76900; 74968; 74960;
74953; 74954, 74946, 74955, 74993, 74994, and'74985 were
items purchased under QA - Code C. That is, the vendor
was not required to provide these items under a 10 CFR 50,
Appendix B, QA program and 10 CFR 20 defects reporting
requirements. The NRC inspector questioned the
correctness of the determination of whether the item (a
part of a component) were required for or could affect
safe shutdown function. If the items were required for or
could affect safe shutdown, quality assurance should have
been required. The following are examples where the NRC
questioned the TU Electric justification for deciding no i
Appendix B QA program or Part 21 defect reporting
requirements were needed.
(1) Purchase Order 661-74955 was issued November 16,
1987, for items to be installed in six auxiliary
feedwater (AFW) pumps in Unit 1 and 2. During
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preoperational testing a test deficiency report
(ME-84-010) was issued because the outboard bearings
exceeded acceptable temperatures. Design
modification 87-1-026 was issued for upgrading
bearing cooling lines, but was revised because
engineering decided that Ingersoll Rand
Bulletin 60-87 would correct the problem. This was
reported to the NRC as a significant construction
deficiency in SDAR CP-87-50. The SDAR stated that i
this condition could cause a loss cf all AFW pumps.
Thrust bearing disc springs, shims, "O" rings, and
end covers were procured through a purchase order
that was classified as a commercial purchase without
any requirement to dedicate or upgrade the item to
safety-related. In this case, the engineer decided
that the function of the item would not be needed to
assure RCPB integrity, safe shutdown, or fer accident
prevention / mitigation. The NRC inspector questioned
'
and challenged this conclusion because (1) the item
can affect the quality of an ASME Code component and
(2) the item will affect the capability to safely
shutdown or maintain safe shutdown. This matter was
identified and discussed with TU Electric at the end
of the inspection and will be unresolved until
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TU Electric resolves the apparent conflict between
safety implications described in TXX-6954 versus the
" Basic Component" justification in the " Procurement
Document Review Summary" (445/8935-U-02).
(2) Purchase Order 661-76900S was issued May 18, 1989,
for bonnet seals in ASME Code Valve 1AF-0038 which is
a Borg-Warner check valyc in the AFW system. The
decisions on this item were similar to those
discussed above. However, the NRC inspector
questions if a formal written ovaluation was
performed to support the decision that failure of
this seal will not affect safe shutdown. No such
engineering evaluation was provided to the NRC (only
references were made to the Specification MS-20.1,
Revision 2, and the vendor manual). This item is
unrosolved until TU Electric produces an engineering
justification that failure of the seal material will
not affect the function.of the valve (445/8935-U-03).
(3) Purchase Order 661-74954 was issued for electronic or
electrical printed circuit boards used in a
safety-related application. The original requisition
was for a commercial procurement. This error was
caught and a nonconformance was written. The point
here to be considered is that other'such errors in
judgement may have allowed components to be purchased
commercially because they were thought to not affect
the functioning of components. There is no
indication that TU Electric has addressed this issue <
and has audited a large number of such procurement.
This item is considered a part of the unresolved item
discussed in paragraph 6.c below.
c. Review of TU Electric Audit
During this inspection period, the NRC inspector reviewed
TU Electric Audit TSU-89-01 involving a commercial
procurement. The original audit scope was to perform a
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surveillance of Hot Functional Testing of Unit 1.
However, because charging valve FCV-321 demonstrated
arratic behavior and could not control the charging rate
to the pressurizer the auditors followod the actions taken
to correct this problem.. Test Deficiency Report 7298 was
issued and the deficiency was traced to resolution. After
the auditor followed-up, the following are the preliminary
audit findings:
. Maintenance discovered that the controller tubing was
tubed into the wrong ports of the valvo. No
nonconformance was written. They just fixed the
problem.
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W . Startup discovered a new design for the plug and' trim
cage of.the. valve and' decided to use the new design
to avoid retesting'. They found that Union Electric
could provide.the parts Unmediately.
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. A QA - Code "A" requisition was issued. -QA Code A
requires the vendor to be.on TU Electric's approved
vendor list.
. TU. Electric's procurement QA personnel' rejected the
requisition because QA' requirements were not included
and the subject vendor (Union Electric) was not on
the approved list.
. The requisition was changed to QA - Code N
(nonsafety-related) and was designated as
'undesignated spares (parts). As Code N purchases
could not be used in a safety-related system it was
necessary to change to Code C (nonquality
components / parts which have some quality
requirements).- Note: The NRC inspector believes
this definition is confusing TU Electric personnel
and should be clarified.
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.- Accordingly, a series of moves were made to change
the QA Code N to Code C to allow the valve to be i
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changed to the new design. . One move included
., removing.the ASME tag (NPT) from the Copes Vulcan
valve. Design Change Authorization 85385 was issued
to make all of this happen, but according to the
auditor this violated ASME Section XI,
subsection lWA-7220 which requires components to be
evaluated before replacement / installation.
. In addition to the above, the TU Electric auditor
noted that 10 CFR,-Part 21, requirements were not
invoked, appropriate documentation was not required,
and the QC inspector was unaware of the change from a
temporary modification to permanent plant design.
Also, the missing tag was not noted.
The preliminary information discussed above is a real time
example of how the procurement process can be bypassed.
Prior to this inspecticn, the NRC inspector discussed such
potential abuses of the QA Code classification in a
presentation on procurement (that was made by TU Electric
to close previous NRC concerns). At the time, the NRC
inspector was told that commercial procurement. vere
controlled by the quality organization's audit of a small
percentage of the commercial procurement.
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The NRC inspector subsequently reviewed the final audit
(TSU-89-01) report-and interviewed the TU Electric QA
manager with respect to the audit of commercial
procurement. The NRC inspector considers this item to be
unresolved and has requested a meeting with TU Electric to
discuss TSU-89-01, the apparent problems, and audits of
commercial procurement to assure that safety-related
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components and items installed in components are procured
to appropriate regulatory requirements (445/8935-U-04).
7. Fuel Storage Racks (50095)
Two NRC inspectors had previously reviewed Unit 1
specification,. procedures, work instructions, and drawings for ,
Unit 1 racks. The completed work was also inspected for '
configuration and the appearance and size of welds. Records
including travelers, design changes, and inspection reports
were reviewed.
1
During this inspection period, the NRC inspector, visually
inspected the racks to assure that they had not been damaged or
substantially changed. The inspector has no further questions
about the storage racks. !
8. General Plant Inspections (55050, 50073)
At various times during the inspection period, the NRC i
inspector conducted independent and planned inspections I
(regular and backshift) of the Unit 1 reactor containment,
safeguards, auxiliary, electrical control, and diesel generator
buildings. All accessible rooms in these buildings were
inspected to observe current work activities with respect to
major safety-related equipment, electrical cable / trays,
mechanical components, piping, welding, and removal of debris
from seismic gap between buildings. The housekeeping, storage,
and handling conditions inside these buildings and various
outside storage areas were also inspected. Fire
prevention / protection measures were observed during the subject
inspections. No violations or deviations were identified.
9. Unresolved Items
Unresolved items are matters about which more information is :
required in order to ascertain whether they are acceptable !
items, violations, or deviations. Three unresolved items
disclosed during the inspection are discussed in paragraphs 6.b
(two) and 6.c (one).
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10. Exit Meeting (30703)
An exit meeting was conducted June 6, 1989, with the
applicant's representatives identified in paragraph 1 of this
report. No written material was provided to the applicant by
the inspectors during this reporting' period. The applicant did
not identify as proprietary any of the materials provided to or
reviewed by the inspectors during this inspection. During this
meeting,.the NRC inspectors summarized the scope and findings
of-the inspection.
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