IR 05000266/1984017

Insp Repts 50-266/84-17 & 50-301/84-15 on 840924-28.No Noncompliance or Deviations Noted.Major Areas Inspected: Licensee Actions on Previous Insp Findings

ML20204H185
Person / Time
Site:	Point Beach
Issue date:	10/17/1984
From:	Choules N, Hasse R, Hawkins F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20204H181	List: IR 05000266/1984017 ML20204H176
References
50-266-84-17, 50-301-84-15, NUDOCS 8411120204
Download: ML20204H185 (10)

Text

'

.

.o U.S. NUCLEAR REGULATORY COMMISSION

REGION III

f 4 Reports No.- 50-266/84-17(DRS); 50-301/84-15(DRS)

,

. Docket Nos. 50-266; 50-301 Licenses No. DPR-24; DPR-27 Licensee: Wisconsin Electric Power Company

'

231 West Michigan

,A Milwaukee, Wisconsin 53203

'

Facility ame: Point Beach, Units 1 & 2 Inspection At: Two Creeks, Wisconsin

, Inspection Conducted: September 24-28, 1984-Inspectors: \t -R-%H Date

..- 0 N. Choules /#'/d ~N Date Approved By: F. C Hawkins, Chief / 0/ /"7 / 6 */

'

Quality Assurance Programs Section Dath s ,

Inspection Summary

. , .

. Inspection on September 24-28, 1984 (Reports No. 50-266/84-17(DRS);

'

' '

' 50-301/84-15(DRS))

Areas Inspected: Routine, announced inspection by regional inspectors of licensee actions on previous inspection findings. The inspection involved a total of 68 inspector-hours onsite by two inspectors including 0 inspector-hours onsite duriy off-shift Results: Of the 40 findings reviewed, 22 were close No new items of noncompliance or deviations were identifie ..)

, ,

> 4 84111'20204 841017 PDR ADDCK 05000266 G PDR

?

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

. _ _

.

DETAILS Persons Contacted Wisconsin Electric Power Company (WEPCO)

• • R. Link, Superintendent, Engineering, Quality, and Regulatory Services R. Franz, Administrative Specialist W. Herrman, Superintendent, Maintenance and Construction A. Pohl, Superintendent, Instrumentation and Controls

• J. Reisenbuechler, Superintendent, Technical Services T. Koehler, General Superintendent

• G. Maxfield, Superintendent, Operations

• F. Flentje, Supervisor, Staff Services N. Hoefert, Modifications Engineer

• • G. Krieser, Superintendent, Nuclear Quality Assurance Division

• • D. Stevens, General Superintendent, Quality Assurance Section The inspectors contacted other licensee personnel as a matter of routin USNRC

• R. Hague, Senior Resident Inspector R. Leemon, Resident Inspector

• Denotes those attending the exit interview on September 28, 198 ** Denotes those participating in the exit interview by telephon . Action on Previous Inspection Findings This inspection was conducted to determine the status of licensee actions on findings from a previous inspection (Report No. 266/83-21; 301/83-20).

The findings'from that inspection were extensive as evidenced by the detailed status of these findings presented belo In response to the findings of that inspection, the licensee has established three review groups to study and recommend corrective actions. These groups are the Intersection Review Group (ISRG), the Maintenance Review Task Force (MRTF), and the Modifications Review Task Force (MORTF).

-Two major efforts have been initiated, in part as a result of recommenda-tions made by the ISR A new Nuclear Power Department Policy Manual (NPDPM) is being issued to replace the current volume II of the QA Manua The NPDPM will document the Nuclear Power Department (NPD)

policy on the-implementation of the requirements of 10 CFR 50, Appendix In addition, a NPD QA Procedures Manual (QAPM) will be issued to ensure consistency in policy implementation and provide interface definition between organizational units of the NPD. The magnitude and basic nature of the changes'being made in the QA program has delayed the implementa-tion of-corrective action for some of the individual items identified during the previous inspectio The detailed status of these items is given below:

_ __ , _ _ _ _

3

.

O (Closed) Unresolv'ed Item (266/83-21-01; 301/83-20-01): Failure of the Quality Assurance Committee to perform a semiannual review of the status and adequacy of the QA Program as committed in the FSA *

Section 1.8 of the FSAR states that management review of the status and adequacy of the QA program is accomplished in part by a semi-annual review by the Quality Assurance Committee (QAC). An audit conducted during May 1983 by an independent contractor at the request of the QAC found that the QAC had not'been effectively discharging this responsibility. This finding was confirmed by the-NRC inspection noted above. .The licensee has taken extensive

' corrective action in response to these finding The QAC had been realigned and now consists of WEPCO officers. The ISRG submitted a set of: recommendations to the QAC addressing methods to improve management assessment of the QA progra The QAC approved these recommendations in their meeting on August 14, 198 Briefly, the recommendations as approved are as follows:

(1) .The internal. audit program will be expanded to ensure coverage of.all quality related activities (see Paragraph 2.u below).

Periodic summaries of the deficiencies identified by these audits (and perhaps the results of INPO and NRC inspections)

- would be prepared and submitted tc, upper managemen (2) A nonconformance control system including periodic trend analyses will be established. The trend analyses will be submitted to upper managemen (3) A corrective action system will be established with periodic

. status reports submitted to upper managemen (4) An annual audit will be performed of selected areas by an outside entity to provide an independent evaluation of program adequac The status and results of these programs will be routinely reviewed by the QA The' inspector is satisfied that these actions constitute appropriate corrective action. Full implementation will be verified by the routine inspection program and closure of other open items identi-f_ied in paragraphs 2.d, 2.u, and 2.v of this repor (0 pen)' Noncompliance (266/83-21-02; 301/83-20-02): Failure to provide training to maintenance and instrumentation and control (I&C)

-pe rsonnel performing QC. inspections. As an interim corrective action, a memorandum was issued to maintenance and I&C personnel which reiterated their responsibilities when performing inspection JThe licensee has solicited and evaluated proposals for conducting an

. inspection training course. While the purchase order has not been issued, the first round of training is expected to be completed by January 1985.' This item remains open pending completion of this

' training.

U

.

m

'

.

' (0 pen) Unresolved Item (266/83-21-03; 301/83-20-03): Failure'to provide training to personnel performing activities affecting quality.- The licensee has prepared a training matrix for all ,

personnel in the Nuclear. Power Department (NPD). A core of ~ 16-hours of training in QA will be given to all NPD personne This includes training on the requirements of 10 CFR 50, Appendix B, the FSAR, specified administrative procedures, certain other chapters of 10 CFR, and several ANSI standards. Specific organizations within NPD will receive up to 16-hours additional training in standards and codes 1 specific to their area of. responsibility. The program is expected to be implemented by January 198 This item remains open pending verification of program implementatio d. -(0 pen) Open. Item (266/83-21-04; 301/83-20-04): Weaknesses in the corrective action program. A procedure entitled " Corrective Action Request System" has been drafted _as part of the new NPD QA Procedures Manual. This procedure is intended to provide a vehicle for solving recurring problems where the capabilities are outside the identifying grou It will'also provide a mechanism to keep upper management informed of significant problems and their resolution. A tracking system will be included in the new work request system (see para-graph 2.e) to track actions taken to correct deficiencies identified during surveillance tests. The tracking. system for deficiencies identified during' audits performed by PBNP personnel and other corrective action. documents (NCR's, etc.) will also be formalize This item remains open pending implementation of the actions noted abov (0 pen) Open Item (266/83-21-05; 301/83-20-05)i Weaknesses in the Work Request (WR) procedure and'WR form. The licensee had completely revised the WR procedure PBNP 3.1.3 (" Maintenance / Work Request") to address the-inspector's and others concerns, A revised WR form had not been completed nor_had the revised procedure been implemente This item will' remain open pending completion of the new WR form and implementation of the revised procedur (0 pen) Open Item (266/83-21-06; 301/83-20-06): Weaknesses in the control of technical manuals, preventative maintenance, ignition control,' machinery history procedures, and procedures for the preparation of special and routine maintenance procedures. Proce-

dures PBNB 2.2.3 (" Component Instruction Manual) and PBNP 5. ( Preventative Maintenance Program") had been revised to describe responsibilities for certain items in the areas of component instruc-tion control and preventative maintenance program. Procedure PBNP 3.'4.1, (" Ignition Control Procedure") had been revised to require

~the-fire watch to be familiar with the closest form of communication such that the control room could be contacted in the event of an c '

emergenc The licensee had not revised Procedure PBNP 5.7, (" Machinery _ History")_to require a periodic review. Instead, the licensee uses it as needed when equipment fails or a review of past failures is required. The inspector has no further questions

regarding this specific matter. The licensee had not revised proce-

.dures used for the preparation of routine and special maintenance

'

-~ _ _ . _ . _ ._.,,. _ _. _ ..,_ ._ _ _ . _ . . _ . - _ . . _ . . _ _ _

.. -- -

l .

.

procedures to require hold points to be inserte This will be

-< accomplished with the implementation of the revised WR procedure (see. paragraph 2.e). This item will remain-open pending revision of these procedure (0 pen) Open Item (266/83-21-07; 301/83-20-07): Independent verifica-tion of Instrument and Contral (I&C) Valves following maintenance on instruments performed during power operation had not been addresse The licensee had established requirements for independent verifica-

'

tion of. I&C: valves and identified the instruments which required '

verification in procedure PBNP 6.5, ("I&C Independent Valve Position Verification and Documentation"). However, the calibration proce-dures for these instruments had not been revised. Revision of these procedures is scheduled to be completed by December 31, 198 This item will remain-open pending revision of these procedure , (Closed) Noncompliance (266/83-21-088; 301/83-20-08A&C): Failure  ;

to specify procedures for repair of a safety injection pump and  ;

other maintenance activities. The revised WR request procedure

~

(PBNP 3.1.3) requires the preparation of.a work plan and require-ments for maintenance procedures.- Implementation of this procedure should ensure that maintenance procedures are.specified. In the

-

interim, the licensee has' discussed with maintenance supervisory

. personnel the-NRC concerns in this area to preclude oversight (0 pen) Noncompliance.(266/83-21-08A; 301/83-20-088): Lack of a procedure for the setting of torque switches-on limitorque valve The licensee had prepared a general procedure PBNP 5.8, (" Maintenance Instruction'- MI") to' control the preparation of maintenance instruc-tions. The-licensee committed to preparing a maintenance instruction-for-setting limitorque switches by January'30, 1985. This item will remain open pending preparation of this maintenance instructio l ' (Closed) Noncompliance (266/83-21-08C): Failure to document the independent technical review of a plant modification. Review of

~ ~

E Modification Request 82-114 showed the licensee had obtained the required signatures for the technical revie (Closed) Noncompliance-(266/83-21-08D; 301/83-20-08D): No procedure or requirements' existed for independent. verification of jumpers and

,

'

. . lifted leads. The licensee had revised procedure PBNP 4.16, (" Temporary Modifications") to require independent verification of

. temporary modifications including jumpers and lifted leads. Review of the jumper and lifted lead log indicated the requirements of the

. procedure had been implemented.

'

1.- -(Closed) Noncompliance (266/83-21-09; 301/83-20-09): Failure to -

y store completed maintenance requests and surveillance tests in fire rated vaults or have duplicate records. The licensee had microfilmed

.these records and. established duplicate records. The licensee plans

.

to microfilm these records on a regular schedul ~

, . _ . - , _ . _ . - _ _ _ .._.._..u.._,____._.__.____. *

. (Closed) Open Item (266/83-21-10; 301/83-20-10): Inadequate instructions in procedure RMP-25 for the repair of the waste gas compressor. The licensee had revised RMP-25 (" Repair of Waste Gas Compressor K1A-(K1B)") to reference the applicable technical manual for repairing the compresso .(Closed) Open Item (266/83-21-11; 301/83-20-11): The design change program did not meet the requirements of ANSI N45.2.11. The licensee had prepared procedure QP 3.2 (" Design Control") which addressed the requirements of ANSI N45.2.1 (0 pen) Open Item (266/83-21-12; 301/83-20-12): Weaknesses in design change procedure PBNP 3. The licensee had completely revised procedure PBNP 3.1.2 (" Modification Request (MR)") to address the inspector's and others concerns. A revised MR form had not been completed nor had the revised procedure been implemented. This item will remain open pending completion of the new MR form and imple-mentation of the revised procedur (Closed) Open Item (266/83-21-13; 301/83-20-13): Weaknesses in the procedure for control of lifted leads and jumpers (temporary modifi-cations). The licensee had revised procedure PBNP 4.17 (" Temporary Modification") to require the following for. temporary modifications which may effect safe operation: Manager's Supervisory Staff (MSS)

review, independent verification of installation and removal, and the periodic review of the jumper bypass log. Similar control of mechanical jumpers was also require (0 pen) Noncompliance (266/83-P.1-14; 301/83-20-14): Failure to perform 10 CFR 50.59-safety reviews of plant modifications to the-facility as described in the FSAR but not classified as safety-related. The licensee had issued a temporary instruction which described the types of modifications which require 10 CFR 50.59 reviews. The requirements of this instruction will be included in a procedure which will provide guidance for preparation of 10 CFR 50.59 review This procedure was being prepared. This item will remain open pending completion of the procedur (Closed) Unresolved Item (266/83-21-15; 301/83-20-15): Lack of an inventory control system for measuring and test equipment (M&TE) and traceability of micrometer calibrations in the maintenance and construction department. The maintenance and construction depart-ment has implemented an inventory control system for M&TE under its control. Gage blocks used for micrometer calibration have been calibrated with traceability to NBS standard (0 pen) Noncompliance (266/83-21-08E; 301/83-20-08E): Lack of a procedural requirement in the maintenance and construction depart-ment to perform an evaluation of M&TE found out of calibratio Procedure PBNP 5.5 (" Control of Measuring and Test Equipment") was revised to require an evaluation when M&TE is found out of calibra-tion. iiuwever, the procedure does not specify who performs the evaluation, who approves the evaluation, or what is to be addressed

_

_ , _ . -. -_-

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

~

. .

m

.% i i

in the evaluation. This item. remains open pending further revision of PBNP 5.5 to incorporate the information noted above. This item was inadvertently closed in Inspection Report No. 50-266/84-11; 50-301/84-0 '

, (Closed) Unresolved Item (266/83-21-16; 301/83-20-16)

Lack of

-

~ calibration. status marking on micrometers. Calibration status is now attached to the micrometer <

. (0 pen) Noncompliance (266/83-21-17A; 301/83-20-17A): Failure of Engineering,- Quality, and Regulatory Services (EQRS) to perform

- . audits under the direction of a designated lead auditor as required

'by ANSI N45.2.23. . The new QA Policy Manual will specify that th Nuclear Quality ~ Assurance Department will perform audits covering the 18 criteria of 10 CFR 50, Appendix B. These audits will be-conducted in accordance with the requirements of ANSI N45.2.2 ,

, L Audits conducted by EQRS will.be considered supplemental and will

not necessarily be conducted under the requirements of the standar This is consistent with Section 1.8 of the FSAR. The inspector agrees that this program satisfies the requirements of 10 CFR 50,

-Appendix B and Section 1.8 of the FSAR. This item will remain open pending issuance and implementation of the QA Policy Manua I (0 pen) Open Item (266/83-21-18; 301/83-20-18): No documented delineation of authority or responsibility between NQAD and EQRS relative to audits. This item will be resolved with the.implementa-tion of the new QA Policy Manual (see item 2.u above). This item

will remain open pending issuance and implementation of the QA Policy

Manua , (Closed) Noncompliance.(266/83-21-17B; 301/83-20-178): Failure of b NQAD to include evaluation' statements in their audit report Procedure QAI 6 (" Conduct of NQAD Audits") has been revised to require the inclusion of evaluation statements in audit report ~

' (Closed) Noncompliance (266/83-21-17C; 301/83-20-17C): Failure to-respond to audit findings within 30 days. Procedures PBNP 3. (" Administration of Quality Assurance Audits and Surveillances") and '

QAI PB-7.1 (" Documentation and Disposition of Observed Deficiencies")

have been revised to provide for escalation to higher levels of management when audit findings are not responded to within 30 day The inspector is satisfied that this escalation will prompt timely y responses to audit finding (Closed) Open Item (266/83-21-19; 301/83-20-19): Weaknesses in the

-

Laudit program. The identified weaknesses were the lack of documented

. qualifications of EQRS personnel to audit technical areas, lack of detail in the EQRS audit procedure, lack of automatic escalation of

.

. late. audit responses to higher management, and lack of consistency in the reporting of persons contacted in NQAD audit reports. The

'

licensee is upgrading the training documentation for EQRS personne :In addition, formalf audit training is being pr vided to EQRS personnel by the NQAD. *The EQRS audit procedure, PBNP 3.3.2, has

7

c , , - ,e-.r-- .w, y,,,. y,,y-, ,,,,e-,-.,,-c... ,...,,_r,.,

-

=r-ree--*~-w-,v-+,,v-ew-me--+-r~,r--

,. _ _ . _ _ _ _ _ _ _

s y , ,

M been revised to include more detail including the use of audit'

checklists. . Automatic escalation of late audit responses has been provided (see paragraph 2.x above). Guidance'on ti.3 content of NQAD audit reports has been given to NQAD auditors including documentation of persons contacted. The inspector is satisfied.that these

' concerns have been responsibly addressed and has no further ques-tions'in this are i .(Closed) Noncompliance--(266/83-21-20; 301/83-20-20): General plant housekeeping problems. The inspector reviewed this item with the

'NRC; Senior Resident Inspector at-the site. This item is closed based on his observations of general' plant cleanliness and house-keeping practices over the last yea a (0 pen) Unresolved Item (266/83-21-21; _301/83-20-21): Lack of documented requirements for. final inspections of open systems prior to closing the systems. The licensee had reviewed this item and established the need for.a procedure to establish documentation requirements for. inspections' prior _to the closing of open system .The. licensee committed to having this procedure prepared by LJanuary 30, 1985. This item will remain open pending preparation of the procedur .bb. ' (Closed) Noncompliance (266/83-21-22A; 301/83-20-22A): Failure to use the correct revision of procedures during maintenance surveill-

- .ance testing. As stated in the licensee response to this item dated April 2, 1984, maintenance surveillance tests had been audited and updated where. required. The history files for maintenance procedures had been updated and the Staff Services Section was controlling the '

revision ~and distribution of mainten'ance procedure c (Closed) _ Noncompliance (266/83-21-22B; 301/83-20-228): Failure to

' incorporate Drawing Change Notices (DCNs) into controlled drawing .A review of control room drawings indicated that DCNs were being incorporated as required. The licensee was also using a checklist attached to the control room drawings which is signed off when drawings located in the auxiliary feedwater pump room and auxiliary

' building have had DCNs incorporate dd. '(Closed) Noncompliance (266/83-21-22C; 301/83-20-22C): Controlled-copies.of procedures ICP 2.3, ICP 2.15, and ICP 10.2 located in the control room and available for use were not the latest revisio .The. inspector verified that the corrective action discussed in the

. licensee's response to this item had been completed. I&C no longer maintains ICP procedures in the control room. Procedure PBNP 6.1.2.C (" Revision Control.(Instrumentation and Control)") had been revised to require distribution of I&C procedure to the I&C department only. This action should ensure that outdated copies of I&C procedures are not maintained in the control room or at other location =.

,

.. .

ee.- -(C1osed). Noncompliance (266/83-21-22D; 301/83-20-220): The

Maintenance Department ~did not maintain indices of maintenance

. procedures. Procedure indices have been developed and procedure history files updated. .The Staff Services Section now maintains control of the indices and procedure revision Copies of the indices have.been placed on the. file cabinets in the Maintenance Department which contain maintenance procedure ff. .(Open) Noncompliance (266/83-21-22E, 301/83-20-22E): The Instrument and Control Department did not_ annotate or update drawings in the  !

shop when DCNs were'i a ued. The licensee was still in the process of. completing corrective action for this ite The I&C department was incorporating DCNs into. drawings but this action was not complete. An administrative procedure is under preparation which will describe the overall control of drawings and the incorporation of-DCN This was originally scheduled to be completed by September 30, 1984, but due to the major revision of the design change program, the procedure has not been completed. The licensee

~

committed to completing _this procedure by January 30, 1985. The incorporation of_DCNs into drawings is scheduled to be completed by November 30, 1984. This item will remain open pending completion of-the abov !

g (0 pen) Unresolved Item (266/83-21-23; 301/83-20-23): Failure to conduct biennial review of procedures. Procedure PBNP 2.1.2,

" Periodic Procedure Review", has been revised to provide better guidance and documentation requirements relative to these review However, the organizational level at which these reviews must be conducted has not~been adequately defined. The licensee agreed to address this. issue. This item remains open pending clarification

'that these reviews must be conducted at the same organizational

~

level;as the original approval hh. ~(Closed) Noncompliance (266/83-21-24A; 301/83-20-24A): Failure of the Offsite Review Committee (OSRC) to audit all provisions of the Technical Specifications. The OSRC has delegated its audit responsibilities to the NQAD. The audits'will be conducted under the cognizance of the OSRC. .The audit reports will'be provided to the OSRC and its' chairman will be afforded the opportunity to attend the exit meetings.~ The NQAD has prepared a Quality Assurance-Project Plan entitled "PBNP Technical Specification Audit Program".

~

The plan includes a three year audit matrix. The plan calls for .

'

annual _ audits of all areas of the Technical Specifications as a

~m inimum and coverage of all line items-in each area within three

-

' years. _The first audit for the current 3 year plan has been i

. conducted. The inspector _is satisfied that-this item has been l adequately. addressed and corrective action has been implemente i (0 pen) Noncompliance (266/83-21-24B; 301/83-20-248): Failure of the OSRC to. audit actions taken to correct deficiencies in facilities or methods of operation. As.noted in paragraph 2.hh above, the OSRC has delegated its audit . responsibilities- to the NQAD. This specific audit is included in the audit matrix and is scheduled to be

'

performed in the near future. This item is considered open pending the completion of the audi '

_

_ _ . _ _ _ _ _ . _ , _ . , . _ _ _ _ - _ , . . , . _ _ _ _ - _

, . - ._- . - - . _ . .

A

• , ,

,

' j (C1osed) Noncompliance'(266/83-21-17D; 301/83-20-170): .

Failure of

-

"the'0SRC to conduct. audit's in accordance with the requirements of

'

-

ANSI N45.2.12, " Requirements for Auditing of Quality Assurance o Programs for Nuclear Power Plants". As noted in~ paragraph 2.hh above, the 0SRC has delegated its audit responsibilities to the NQAD.' The NQAD performs its audits in accordance with the; require-ments of ANSI N45.2.12. 'The inspector is satisfied that this

! constitutes effective corrective actio k (Closed).0peniItem'(266/83-21-25; 301/83-20-25): Weaknesses,in the

. operation of the OSRC. The. identified weaknesses included the

potential for. concurrent OSRC/NRC review of proposed changes to the

. Technical Specifications,~ lack of comprehensive OSRC audits, failure

'

,

to track open items through implementation, and the lack ~of an OSRC j

'

charter. The inspector reviewed.0SRC meeting minutes and confirmed that. reviews of proposed Technical. Specification changes are timely

'

and that the potential for change approval by the NRC and implementa-tion by PBNP prior to OSRC review is acceptably small. Resolution of

0SRC audit problems are discussed in paragraphs 2.hh, 2.ii, and 2.jj

'

above. The need.to. track open items through implementation will be

'

-~

o bviated by the annual audit of actiona taken to correct deficiencies in facilities or methods of operation (see paragraph 2.11 above). An

0SRC charter was approved.during the OSRC meeting held on May 13-15, 198 These actions adequately address the inspector's concern .

1 (0 pen) Noncompliance (266/83-21-26;.301/83-20-26): Failure to implement'a program to control items with a limited shelf-lif Procedure PBNP 3.3.3 (" Shelf Life Control Program") has been issued y establishing a' shelf life program. The prograr also addresses the

~

maintenance of items in storage. Full. implementation-is expected by January 1, 1985. This item remains open pending NRC review of ~;

program implementatio mm. -(0 pen) Unresolved Item (266/83-21-27;-301/83-20-27): Complete _and

-

~ timely. corrective action'in response to an internal audit of

~

!" procurement practices. An internal audit performed under the ,

guidance of-a contracted lead auditor resulted in seven findings-

'

in the procurement area. These included the failure to properly route purchase. requests, failure to post 10'CFR 21 requirements, lack of procurement department procedures relating to quality related. records, and the lack of receiving inspection procedures and documentatio The licensee has initiated corrective action measures including the issuance of receiving inspection procedures, the assignment ~of a materials inspector-to the PBNP staff and the

'

posting of.10 CFR 21 requirements. However, not all corrective actions have been-fully implemented. This item remains open pending

full implementation of corrective action m - Exit Interview

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

on' September 28, 1984, and summarized the purpose, scope, and findings of

'the inspectio _

'

L

,

, ~~..r _ .. .--,m ,,,,,,.-..-,,-m . - . , - . . , . _ , ,-., ~. _.__,.------,~.,-.-m.,_.,_.