IR 05000029/1985012

Insp Rept 50-029/85-12 on 850603-07.No Violation Noted. Unresolved Items Noted:Failure to Provide Documentary Evidence of Preventive Maint Activities for safety-related Equipment

ML20133G652
Person / Time
Site:	Yankee Rowe
Issue date:	07/16/1985
From:	Alba A, Dev M, Jerrica Johnson, Prell J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20133G637	List: IR 05000029/1985012 ML20133G634
References
50-029-85-12, 50-29-85-12, GL-83-28, NUDOCS 8508090019
Download: ML20133G652 (16)

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l U.S. NUCLEAR REGULATORY COMMISSION

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REGION I

Report N /85-12 Docket N l License N OPR-3 f

Licensee: Yankee Atomic Electric Company i 1671 Worcester Road l

Framingham, MA 01701 Facility Name: Yankee Rowe Generating Station l

l Meeting at: Framingham and Rowe, MA Meetingconductej: June 3 - A 198J Inspectors: I

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, . Prell', Reactor Engineer date signed J& d

. Alba, Reactor ngin er 7-H- ss-date signed l

M Dev, Reactor En61 e5F

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_hllYV

'date signed

_ Approved b . M 12. d J. Joinson, Chief, Operational 7[/6/frf date signed Programs Section, 08, DRS Inspection Summary: Announced Inspection conducted __on June 3 - 7, 1985 (Inspection Report No. 50-029/85-_121 Areas Inspected: Licensee's action to address the concerns identified in NRC Generic Letter 83-28, in the areas of Equipment Classification, Post-Maintenance

, Testing, and Vendor Interface. The inspection involved 135 hours0.00156 days <br />0.0375 hours <br />2.232143e-4 weeks <br />5.13675e-5 months <br /> by four

{ region-based inspector Results: Two unresolved items were identified: failure to provide documentary evidence of preventive maintenance activities for safety-related equipment stored in the warehouse and failure to establish a program for assuring that vendor furnished information for safety-related equipment is complete, correct and curren PDR ADOCK 05000029 G PDR

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DETAILS 1. Persons Contacted Yankee Atomic Electric Company (YAEC)

G. Baird Shift Supervisor E. Begeibing Maintenance Supervisor

• R. Boutwell Senior Technical Services Engineer

• L. Bozek QC Supervisor E. Carlson Maintenance Engineer

• B. Drawbridge Assistant Plant Superintendent

• R. Durfey Maintenance Engineer

• D. Ellis Plant Engineer S. Fournier Lead System Engineer M. Gilmore QA Engineer D. Hansen N & D Plant Engineering Department Manager J. Hazeitine Project Manager

• T. Henderson Technical Director

• B. Holmgren Lead Mechanical Engineer W. Jones Engineering Manager J. Kay Technical Services Manager

• P. Laird Maintenance Manager

• T. Long QA Engineer R. Martin Supervisor, Quality Design and Procurement R. Mitchell Maintenance Support Supervisor

• C. Melin Construction Engineer A. Parker QA Engineer

• J. Parker Senior Engineer W. Peterson Supervisor Quality Audit and Engineering

• D. Pike Manager Operation QA

• St. Laurent Plant Superintendent U. S. Nuclear Regulatory Commission

• H. Eichenholz, Senior Resident Inspector Philippine Atomic Energy Commission

• E. Racho Observer The inspectors also contacted other licensee administrative, engineering, operation, QA/QC, and technical personne * Denotes those present at the exit meeting on June 7, 1985.

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2.0 Inspection Summary 2.1 Background The reactor trip system, as part of the reactor protection system, is fundamental to reactor safety for all nuclear power reactor design Transient and accident analyses are predicated on the assumption that the reactor trip system will automatically initiate reactivity control systems on demand to assure that fuel design limits are not exceede The design and regulatory philosophies for attaining the high reliability required of the reactor trip system have been based primarily on the use of redundancy, periodic testing, and quality assuranc In February, 1983 the Salem Nuclear Power Station experienced 2 failures of the reactor trip system on demand. Regulatory and industry task forces were formed to determine the safety significance and generic implications of the events. Based on these findings, certain actions were required of all licensee These actions, transmitted in Generic Letter (GL) 83-28, fell into 4 areas: (1) post-trip review, (2) equipment classification and vendor interface, (3) post-maintenance testing, and (4) reactor trip system reliability improvement YAEC responded to Generic Letter 83-28 in letters dated November 5,1983, January 13, 1984, February 21, 1985 and March 19, 1985. This inspection included the areas of equipment classification, vendor interface and post-maintenance testin . Equipment Classification 3.1 Requirements / References

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NRC Generic Letter 83-28, " Generic Implications of Salem ATWS Events"

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Yankee Atomic Electric Company Technical Specifications, Section 6

" Quality Assurance Criteria for Nuclear Power Plants...." ,

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ANSI N18.2-1973 including addendum (1975), " Nuclear Safety Criteria for the Design of Pressurized Water Reactor Plant"

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ANSI N45.2.2-1972 " Packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants"

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ANSI N45.2.4-1972, " Installation, Inspection and Testing Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations"

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IEEE-279-1971, IEEE Standard, " Criteria for Protection Systems for Nuclear Power Generating Stations"

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IEEE 308-1974, IEEE Standard, " Criteria for Class IE Electric System for Nuclear Power Generating Stations"

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Yankee Operational Quality Assurance Program (YOQAP)-I-A, Rev 15

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Administrative Procedure (AP) - 0224, Rev 5, " Handling, Storage and Shipping"

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AP-0204, Rev 8, " Safety Classification of Systems, and Components and Services"

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YAEC Letter to NRC, FYR 85-38, Dated March 19, 1985 3.2 Documentation Review

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YAEC Plant's Safety Classification System Manual, Rev 52, Dated April 16, 1985

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Engineering Manual WE-002, Rev 5, " Design Document Control"

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Engineering Manual WE-003, Rev 5, " Indoctrination of Personnel"

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Engineering Manual WE-004, Rev 4, " Training"

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Engineering Manual WE-100, Rev 12, " Engineering Design Change Request"

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Engineering Manual WE-101, Rev 6, " Plant Design Change Request"

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Engineering Manual WE-102, Rev 7, " Design Criteria"

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Engineering Manual WE-105, Rev 7, " Drawings",

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Engineering Manual WE-106, Rev 5, " Procedures and Instructions,

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Engineering Manual WE-200, Rev 8, " Material and/or Service Purchase Request"

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Engineering Manual WE-201, Rev 5, " Non-Conformance Reports",

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Yankee Project Procedure - 005, Rev 0, " Control of Supply Requisitions and Purchase Orders"

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Yankee Project Procedure - 006, Rev 1, " Engineering Design Change Requests",

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Yankee Project Procedure - 007, Rev 2, " Plant Design Change

. Requests"  :

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Yankee Project Procedure - 008, Rev 0, " Material and/or Service '

Purchase Requests"

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Yankee Project Procedure - 009, Rev 0,"Nonconformance Reports", j i

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Yankee Project Procedure - 011, Rev 0, " Documentation of Personnel '

. Training",

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Yankee Project Procedure - 021, Rev 0, " Control of Procedures and

j Instructions"

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Yankee Administrative Proceduro - AP-0211, Rev 12 Major, " Material l

and Service Procurement Program" i

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Yankee Administrative Procedure AP-0020. Rev 3 Major, " Operating i Information Review"  !

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Yankee Operating Procedure, OP-4525, " Surveillance Inspection of Rod

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Drive ACB's" 3.3 Program Review and Implementation

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Licensee responses to U.S. NRC GL 83-28 paragraphs 2.1 and 2.2 related to i equipment classification and vendor interface are contained in Yankee i letter FYR 84-09, dated January 13, 1984. The inspector reviewed the

licensee equipment classification program in conjunction with the i response letter FYR 84-09, and the plant procedures and instructions referenced in paragraph 3.2 to determine the adequacy of:

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the criteria and source documents which form the basis for the scope

of the quality assurance program

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the extent to which the Westinghouse Owners Group (WOG), Institute

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for Nuclear Power (INPO), Nuclear Plant Reliablity Data System

, (NPRDS) or other industry reporting systems findings and recommen-

! dations are included in the YAEC Equipment Classification and Vendor ,

j Interface program j

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the assignment of responsibility for reviewing safety-related !

activities, including plant procedures and instructions, design and

, analyses, preventive and corrective maintenance, plant modification, l j and operation

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the training and indoctrination provided to the personnel performing

safety-related activities and equipment classification

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6 3.4 Program Implementation l

The reactor trip breakers installed at Yankee are Westinghouse Type 08-25

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switchgear. These are similar in design to Type DB-50 circuit breakers, i except that the 08-25 does not utilize the undervoltage trip attachment.

The YAEC reactor trip breakers are tripped solely by shunt trip devices

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and, as such, modification of an automatic shunt trip attachment per NRC GL 83-28 requirements is not applicable. The inspector verified that Yankee has classified the breakers and the shunt trip attachments as safety-related, and that the plant procedures for maintenance, surveillance and testing of these breakers comply with the requirements applicable to Type 08-50 breaker The Yankee equipment classification program for safety-related structures, systems and components is delineated in Yankee Operational Quality Assurance Program Manual (Y0QAP-1-A). The program addresses quality assurance requirements for all safety-related activities, including maintenance, design, analysis, procurement, and operational activities. All safety-related plant's fluid system components are class-ified relative to their importance to nucicar safety as either safety class-1, safety class-2, safety class-3, or safety class in accordance with ANSI N18.2-1973 and its addendum of 1975. The equipment classifi-i cation program also addresses quality assurance requirements for Class IE l and non-class IE electrical, control and instrumentation equipment in

! accordance with IEEE Standard 274-1974. YAEC Systematic Evaluation Program (SEp) Topical Report III-1 listed all systems and components

, significant to plant safety. Based on these guidelines, YAEC has deve-i loped the " Plant Safety Classification Manual", which identifies system I boundaries, instead of a computerized equipment list. Y0QAP-1-A,

Appendix 0 lists all structures, systems and components and other items requiring quality assurance. The associated quality assurance activities for these items are incorporated in the corresponding plant procedure Yankee has established Plant Procedures and Instructions to perform safety-related activities including maintenance, plant modification and conceptual plant changes, procurement, and operational activities. The inspector, selectively reviewed the following safety-related plant design change requests (PDCRs), material purchase requisitions (MPRs) and engineering design change change requests (EDCRs) to verify their adherence to appli-cable plant procedures and compliance to 10 CFR 50.59 requirements:

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EDCR 82-19, Taps for Hot-Shutdown Systems

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EDCR 82-21, Hot-Shutdown System Instrumentation

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EDCR 83-25, Shutdown Cooling Valve Interlock

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EDCR 84-303, Replacement of Instrumentation Terminal Block with Spilce

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PDCR 82-012, Reactor Protection Permissive Circuit

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PDCR 83-008, Removal of Containment Isolation System Timing Test Circuit

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PDCR 83-015 Removal of Pressurizer WR Level to Pressurizer NR Level Converter from Service

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PDCR 84-04, Fuel Element B-636 Repair

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PDCR 84-09, Replace MS-PS-418 With a Manual Knife Switch

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MPR 80-12, Q/A-32, lh" Globe Valve, SW 12501

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MPR 81-12, 0/A-21, 5" Diameter A276 T304 SS Conduit

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MPR 82-10, Q/A-27, 3/4" Stainless Steel Pipe, HT #467393

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MPR 85-534, MC-P-200, Relay 2K2A The inspector verified that the completed work order packages had incorpor-ated the concurrences and recommendations of engineering, plant managem$nt, nuclear safety division, QA, and PORC reviews. The documentation was com-plate and adequat Yankee has implemented an adequate level of management control for quality control activities relative to safety-related program development, preven-tive and corrective maintenance, design analysis, procurement, testing and surveillance, and operation. This control also provides adequate measures to identify potential failures, malfunctions, deficiencies, and nonconfor-mances. In addition, the licensee has established provision for tracking LERs, NRC Bulletins, Information Notices and Generic Letters, Vendor Bul-letins, INP0 Significant Event Reports (SER), and INPO Significant Opera-ting Experience Reports (SOER).

The licensee is an active participant in the INPO Nuclear Utility Tasks Action Committee (NUTAC) program and reviews and implements their recom-mendations based on their merit to the plant safety. Also, the licensee incorporates the Westinghouse Owners Group (WOG) recommendations, and other current safety issues into the plant review program, in accordance with the plant Administrative Procedure AP-0020, " Operating Information Review".

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The inspector reviewed the training and indoctrination of the nuclear i safety division personnel performing safety-related activities of design

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] and analysis, procurement, and plant modification. The inspector deter- p mined that the personnel interviewed during this inspection were adequately  ;

J trained and were knowledgeable of QA requirements relative to their areas of responsibilitie I l

i' 3.5 Findings

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l No violations were identifie ;

l Post-Maintenance Testing i

! 4.1 References / Requirements

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Required Actions Based on Generic Implications of Salem ATWS Events

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ANS 3.2/ANS1 N18.7-1976, Administrative Controls and Quality '

Assurance For The Operational Phase of Nuclear Power Plants

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Yankee Atomic Electric Company (YAEC) letter to the U.S. Nuclear [

Regulatory Commission (NRC) dated November 5,1983, (FYR 83-94),

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" Response to Generic Letter 83-28"

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YAEC letter to the U.S. NRC dated January 13,1984, (FYR 84-09),

.l " Additional Information in Response to Generic Letter 83-28" i t

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YAEC letter to the U.S. NRC dated June 22,1984, (FYR 84-70),

l " Vendor Interface Program" r

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YAEC letter to the U.S. NRC dated March 19,1985, (FYR 85-38),

" Generic Letter 83-28, Items 4.2.1 and 4.2.2"

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Yankee Operational Quality Assurance Manual (YOQAP-1-A) August 15,

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1977; Appendix 0, Classification of Structures, Components and

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Operating Procedure (0P) - 4525, Revision 6, Surveillance

! Inspection of Rod Drive ACB's

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OP-4515, Revision 8, Operating Test of Primary Protective Relays  !

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OP-4502, Revision 6 Determination of the Steam Generator Safety j Valve Setpoints using The Crosby Test Device

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OP-4501, Revision 8, Quarterly Check Of The Station Batteries l

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OP-4601, Revision 14, Nuclear Instrumentation Channels Functional j Test

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OP-4618, Revision 4, Calibration of the HPSI Pump Time Delay Relays l

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OP-4636, Operability Testing of the Accumulator Trip Valves

SI-TV-604, SI-TV-605 and SI-TV-606

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OP-5104, Revision 7, Safety Related Valve Maintenance

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OP-5101, Revision 6, Maintenance of Motor Operator Valve

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OP-5103, Revision 5, Inspection and Maintenance of Safety Relief

Valve

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OP-5237, Revision 3, Installation of Control Rod Drive Mechanism l

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OP-5356, Pumps and Valves Program

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OP-5200, Revision 7, Main Coolant Check Valve Repair ,

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OP-5201, Revision 6, Main Coolant Stop Valve Motor Operator

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OP-5202, Revision 5, Replacement of Pressurizer Heater Bundles  ;

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OP-5206, Revision 5, Inspection and Testing of Pressurizer Heaters

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OP-5207, Revision 6, Maintenance of Pressurizer Solenoid Relief Valve

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OP-5212, Revision 5 Maintenance of Main Coolant Stop Valves  ;

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OP-6210, Revision 7, Maintenance of the Primary Plant Instrumentation

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OP-6218, Revision 0, Maintaining Equipment Qualification of Rosemount 1153 Transmitters .

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OP-6450, Revision 8, Maintenance of CIS Valves  !

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Administrative Procedure (AP)-5000, Revision ll, Maintenance j Department Sarve111ance Schedule

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AP-5002, Revision 8, Maintenance Department Corrective and  ;

i Preventive Maintenance Program

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AP-5010, Revision 4, Maintenance Department Routine Corrective  !

Maintenance

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AP-0205, Revision 8, Maintenance Request

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AP-0214, Revision 9, Maintenance and Change of Safety Classified Systems, Components, or Structures

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AP-2007, Revision 15, Maintenance of Operations Departmental Logs l - --

AP-0207, Revision 6, Equipment Control t l ,

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AP-0017, Revision 8, Switching and Tagging of Plant Equipment

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AP-6003, Revision 8, I & C Department Maintenance Program i --

AP-6007, Revision 4, I & C Department Corrective Maintenance  !

4.2 Program Review l The references in Section 4.1 were reviewed to determine that YAEC has j i

established a post-maintenance and modification testing program for  ;

safety related equipment which included the following:

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written procedures for controlling post-maintenance activities  !

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criteria and responsibilities for review and approval of post-maintenance testing

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methods and responsibilities for performing functional testing  ;

following maintenance and prior to returning to service

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administrative controls for assuring that records of post-maintenance testing activities are properly controlled, reviewed and documented 4.3 Implementation Review The licensee's post-maintenance and modification testing program was i examined to verify proper implementation. Included in this examination l was: .

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the review of 30 administrative and operating procedures related to i maintenance activities l

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the review of eight completed Maintenance Request (MR)  ;

packages within the electrical, mechanical, and instrumentation and j control maintenance department ,

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the witnessing of maintenance and post-maintenance testing

activities related to the low pressure surge tank cooling pump j circuit breaker

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the review of the preventive maintenance (PM) checklist matrix

! against Technical Specification and other PM requirements

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the review of three safety related Plant Design Change Requests (PDCR) and Engineering Design Change Requests (EDCR): PDCR 83-016, Primary Seal Witer Tank Fill Line; PDCR 83-002, Replacement of MC

Flow Test Meters; EDCR 84-303, Replacement of Instrument Terminal l

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the basis for determining the minimum testing requirements to prove i equipment reliability j

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the review of the MR log for verifying proper classification and control of maintenance activities

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discussion with maintenance, technical, and operations personnel ,

regarding the post-maintenance testing program '

i Based on the above, the inspector determined that the program was being implemented in a quality manner.

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! 4.4 Findings No violations were identified.

l 5.0 Vendor Interface l l i

5.1 References / Requirements l --

Administrative Procedure AP-0224, Rev 5, " Handling, Storage and i Shipping"

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ANSI N45.2.2-1972 " Packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants"

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USNRC Regulatory Guide 1.38, Rev. 2

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YOQAP-11-A, Rev. 15, " Yankee Operational Quality Assurance Manual"

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AP-0075, Rev. O, " Vendor Equipment Technical Information Program"

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AP-0020, Rev. 3, " Operating Information Review"

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AP-211, Rev. 12 " Material and Service Procurement Program"

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AP-0204, Rev. 8, " Safety Classification of Systems, Components and Services"

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YAEC Approved Vendors List Control Copy No. 1

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Safety Classifications of Systems Manual, Controlled Copy 14

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10 CFR 50 Appendix B, " Quality Assurance Criteria for Nuclear Power Plants..."

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AP-5000, Rev. 11, " Maintenance Department Surveillance Schedule"

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00A-X-1.1, Rev. 6, " Operations Quality Inspection Checklist"

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Yankee Project Procedure 8, Rev. O, " Material and/or Service i Purchase Requests"

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YAEC Letter to USNRC, dated November 5,1983, (FYR 83-94), " Response i to Generic Implications of Salem ATWS Events"  !

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ANSI N18.2, 1973, " Nuclear Safety Criteria for the Design of Stationary Pressurized Water Reactor Plants"

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ANSI N18.2a-1975, " Revision and Addendum to Nuclear Safety Criteria for the Design of Stationary Pressurized Water Reactor Plant ANSI 18.2-1973"

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Project Commitment Tracking and Responsibility System 5.2 Program Review .

l The inspector reviewed applicable procedures and documents to ensure that l the Licensee's vendor interface program provided for the following:

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Approved and Qualified vendors list had been establishe ;

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Purchase Requests had been used appropriately

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Quality assurance criteria had been incorporated in procurement documents l

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Updated plant procedures are being used

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Safety - related items issueo for installation had proper inspection documenta+ ion

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Appropriate records are retained, such as procurement documents and certificates of conforman:a

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An information review process was used

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Items were stored according to their specified level of stur:ge and preventive maintenance was performed according to established requirements 5.3 Implementation The inspector toured the warehouse to determine that storage conditions were acceptable and to verify that the appropriate established require-ments, such as those listed in Section 5.1 were implemented. The inspector examined the documentation for the following items:

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1" SS. Globe Valve HT# 212 Safety Class 1 MPR 75-9 Q/A 9

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1 1/2" Globe Valve SW 12501 PO 299606 Safety Class 2 Storage Level 2 MPR 80-12 Q/A 32

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3/4" Stainless Steel 80 Pipe Heat # 467393 MPR 82-10 Q/A 27

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Damper Motor

! Safety Class ERQA PO# 104651

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Serial # M845A1027

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Charging Pump Stuffing Blocks 5" PIA A276 SS Cond A Barstock

2" x 6 1/2 x 7" A240 7304 SS Plate l Safety Class II MPR 81-12 Q/A-21 i

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Limitorque Motor Stock #6340-0-028 PO# 104138 Q/A # 84-6 Q/A3 Serial # IXFB32447A1WK Safety Class

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Shaft Stock # 22PV131057 PO# 104836 Q/A # 84-12 Q/A Mark # 4X9-5410X13A-379 Safety Class II The following procedures were reviewed to assure that they had incorporated vender technical informatio OP-4525, "ACB Surveillance for Rod Drive"

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OP-5101 Rev. 7, " Maintenance of Motor Operated Valves Breaker 1 & 2"

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OP-5201 Rev. 7, " Main Coolant Stop Valve Motor Operator Maintenance" 5.4 Findings The licensee is committed to ANSI N45.2.2-1972 which states in part "Rota-ting electrical equipment shall be given insulation resistance tests on a scheduled basis..." and " Shafts of rotating equipment shall be rotated on a periodic basis...". The licensee revised AP-0224, Rev. 5 June 1984 to incorporate the above requirements into their procedure for storage of safety related items. Upon examination of the licensee's piocurement and storage program, the inspector was unable to find any evidence of the abov For example, the licensee could not furnish the inspector with any evidence that the shaft on Limitorque Motor, Serial # IXFB32447A1WK had been rotate However, on June 19, 1985, the licensee sent a letter to the NRC Region I office stating that this was ti.e only item received in storage in the past year which appeared to require preventive maintenance in the areas in question. The licensee made a determination that the above motor did not require its shaft to be rotated and that an insulation resistance test was not yet neede Since the inspector was unable to verify the implementation of a preven-tive maintenance program in these areas, this is an unresolved item which will be reviewed in a subsequent inspection. (50-029/85-12-1)

Paragraph 2.2.2 of GL 83-28 states, in part, "For vendor interface,11cen-sees and applicants shall establish, implement and maintain a continuing prograni to ensure that vendor information for safety-related components is

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complete, current and controlled throughout the life of their plants, and appropriately referenced or incorporated in plant instructions and proce-dures..." AP-0020, Operating Information Review, helps assure that vendor information is controlled and properly reviewed for incorporation into plant procedures. In a YAEC letter to the NRC the licensee endorsed the Vendor Equipment Technical Information Program (VETIP) developed by Nuclear Utility Task Action Committee (NUTAC). This program will help assure that any new information is properly reviewed and disseminated. The inspector found that the two above programs failed to provide assurance that the licensee's vendor information is current and complete as required by para-graph 2.2.2 of GL 83-28. In a memorandum to YAEC dated April 9, 1985.nthe NRC requested further information on how the licensee plans to establish and maintain an interface between vendors and itself. This is an unre-solved itt.m awaiting resolution between the NRC and YAEC on an acceptable vendor interface program for safety related material. (50-029/85-12-2)

6.0 QA/QC Overview Three QA Organization entities: Quality Assurance Design and Procurement, Quality Assurance Audit and Engineering, and Operation Quality Assurance Group perform overview of all safety-related activities at YAEC. The in-spector sampled safety-related EDCRs, PDCRs, MRs and MPRs for review and determined that QA/QC involvement was adequate. Audits conducted for pro-curement and preventive maintenance activities of safety-related compo-nents and the resolution of deficiencies identified therein were timely and adequat The inspe: tor also discussed with the licensee representatives the QA Audit schedule related to plant operation and, QA program implementation relative to Post-Maintenance Testing. The inspector reviewed audit reports Y83-06, 1983, Y84-06, 1984, Y85-06, 1985 for Post-Maintenance Testing and deter-mined that audits were conducted on schedule; audit checklists were com-prehensive; corrective action was implemented in a timely manner; and QC hold points were exercise .0 Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable, deviations or violation Two unresolved items are discussed in Paragraph 5.4.

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8.0 Management Meetings Licensee management was informed of the scope and purpose of the inspection at an entrance meeting conducted June 3, 1985. The findings of the inspec-tion were discussed with licensee representatives during the course of the

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inspection. An exit meeting was conducted June 7, 1985 at the conclusion of the inspection (see Paragraph I for attendees) at which time the findings were presented to licensee managemen !

At no time during this meeting was written material provided to the licensee.

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l

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t . I