IR 05000269/2004006
| ML043010276 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 10/13/2004 |
| From: | Ogle C NRC/RGN-II/DRS/EB |
| To: | Rosalyn Jones Duke Energy Corp |
| References | |
| IR-04-006 | |
| Download: ML043010276 (38) | |
Text
ber 13, 2004
SUBJECT:
OCONEE NUCLEAR STATION - NRC SAFETY SYSTEM DESIGN AND PERFORMANCE CAPABILITY INSPECTION REPORT NOS.
05000269/2004006, 05000270/2004006, and 05000287/2004006
Dear Mr. Jones:
On September 3, 2004, the U. S. Nuclear Regulatory Commission (NRC) completed a safety system design and performance capability inspection at your Oconee Nuclear Station, Units 1, 2, and 3. The enclosed report documents the inspection findings which were discussed on September 2, 2004, with you and other members of your staff.
This inspection was an examination of activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved selected examination of procedures and representative records, observations of activities, and interviews with personnel.
Based on the results of the inspection, no findings of significance were identified.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Charles R. Ogle, Chief Engineering Branch 1 Division of Reactor Safety Docket Nos.: 50-269, 50-270, 50-287 License Nos.: DPR-38, DPR-47, DPR-55
Enclosure:
(See page 2)
DEC 2 Enclosure: NRC Inspection Report Nos. 05000269/2004006, 05000270/2004006, and 05000287/2004006 w/attachment: Supplemental Information
REGION II==
Docket Nos.: 50-269, 50-270, 50-287 License Nos.: DPR-38, DPR-47, DPR-55 Report Nos.: 05000269/2004006, 05000270/2004006, and 05000287/2004006 Licensee: Duke Energy Corporation Facility: Oconee Nuclear Station, Units 1, 2, and 3 Location: 7800 Rochester Highway Seneca, SC 29672 Dates: August 16 - 20, 2004 August 30 - September 3, 2004 Inspectors: F. Jape, Senior Project Manager (Lead Inspector)
J. Moorman, Team Leader R. Moore, Senior Reactor Inspector R. Cortes, Reactor Inspector D. Mas-Penaranda, Reactor Inspector A. Nielsen, Health Physicist (second week only)
J. Chiloyan, Consultant Accompanied by: C. Peabody, Nuclear Safety Professional Approved by: Charles R. Ogle, Chief Engineering Branch 1 Division of Reactor Safety Enclosure
SUMMARY OF FINDINGS
IR 05000269/2004-006, 05000270/2004-006, 05000287/2004-006; 08/16-20/2004 and 08/30/2004-09/03/2004; Oconee Nuclear Station Units 1, 2, and 3; Safety System Design and Performance Capability Inspection.
This inspection was conducted by a team of regional inspectors and a contractor. No findings of significance were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,
Revision 3, dated July 2000.
NRC-Identified and Self-Revealing Findings
No findings of significance were identified.
Licensee-Identified Violations
None.
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events and Mitigating Systems
1R21 Safety System Design and Performance Capability
The inspection team reviewed selected components and operator actions that would be used to prevent or mitigate the consequences of a steam generator tube rupture (SGTR) event. Components in the main steam (MS) system, emergency feedwater (EFW) system, makeup system, reactor coolant system (RCS), high pressure injection (HPI) system, and radiation monitoring system were included. This inspection also covered supporting equipment, equipment which provides power to these components, and the associated instrumentation and controls.
.1 System Needs
.11 Process Medium
a. Inspection Scope
The team conducted electrical system walkdowns, observed instrument indications, and reviewed selected operations surveillances to verify that the power supplies for the motor driven EFW pumps and HPI pumps would be available and unimpeded during accident/event conditions. Reviews were based on the Updated Final Safety Analysis Report (UFSAR) system descriptions and Technical Specification (TS) requirements.
Specifically, the team reviewed procedures for the operation, maintenance and testing of the EFW and HPI pumps as well as motor operated valves (MOVs) to verify proper design configuration and control. The team reviewed the EFW and HPI pump and MOV power supply calculations, operating lineup procedures, drawings, licensing and design basis information, surveillance procedures, and vendor manuals.
The team reviewed the water sources for components and systems required for the mitigation of the SGTR event. These included the borated water storage tank (BWST),the upper surge tanks (UST), and the hotwell. The team reviewed the availability, reliability, and adequacy of the water sources with respect to the anticipated water source requirements for the SGTR event. The team reviewed design criteria information, drawings, vendor manuals, and calculations to determine the minimum water levels for pump net positive suction head (NPSH) and tank volume to verify that the design and UFSAR accident analysis assumptions were consistent with system and equipment capability. Specifically, the team reviewed operating/lineup procedures, drawings, and surveillance procedures to determine the common valves associated with flow paths from the UST and hotwell to the EFW pump to verify proper configuration control. The review also included the minimum-flow flowpaths for the EFW pumps as well as vortexing considerations for both the UST and BWST. Additionally, the team reviewed foreign material exclusion (FME) problem investigation process reports (PIPs)for the UST, once-through steam generators (OTSGs) and BWST to determine if water supplies to the EFW and HPI systems would be obstructed by foreign material or tank degradation.
The team conducted walkdowns of instrumentation systems, observed instrument indications, and reviewed selected operations surveillance to verify that the process medium for the EFW would be available and unimpeded during accident/event conditions. Reviews were based on the UFSAR system descriptions and Calculation OSC-6116, SGTR: Event Mitigation Requirements.
In addition to the above, the team reviewed calibration procedures and calibration records for the level instruments used on the condensate storage tank (CST) and upper surge tank to verify that the procedures accurately incorporated set point values delineated in calculations of record.
b. Findings
No findings of significance were identified.
.12 Energy Sources
a. Inspection Scope
The team reviewed the electrical overcurrent, undervoltage, and ground protection relay settings for selected circuits to verify that the trip setpoints would not spuriously interfere with equipment fulfilling its safety function, and secondarily, that protection was provided. Specific relays reviewed were the overcurrent, undervoltage, differential and ground relays associated with the 4160 volt alternating current (4160VAC) buses and switchgears supplying power to EFW and HPI pump motors, as well as the 600VAC load centers (LCs) and motor control centers (MCCs) for power and control of HPI motor operated valves. Data sheets for the last relay calibration were reviewed to verify that the calibrations were within the calculated limits and that excessive drift was not taking place.
During the review of the 4160VAC, 600VAC, 208VAC and 125 volts direct current (125VDC) systems, the team focused on the appropriateness of design assumptions, adequacy of analytical models and methods, calculations, and acceptance criteria for surveillance and performance validation tests to verify that the AC and DC power sources were adequate to meet minimum voltage specifications for electrical equipment during and following an SGTR event. Among the reviewed components were the EFW, HPI pump motors and HPI motor operated valves. Specific pumps and valves reviewed were:
- EFW Pump Motor 1A
- EFW Pump Motor 1B
- HPI Pump Motor 1A
- HPI Pump Motor 1B
- HPI Pump Motor 1C
- HPI Isolation Valve, 1HP-410 The team conducted walkdowns, and control room and equipment status reviews of selected electrical energy sources to verify the availability during accident/event conditions. Reviews were based on design basis documents, system operation procedures, UFSAR, and TS requirements.
The team conducted walkdowns and equipment status reviews of selected energy sources to verify availability and reliability during accident/event conditions. Reviews were based on design basis documents, vendor manuals, system operating procedures, TS, and UFSAR requirements. Systems of focus included instrument air for the pneumatically operated valves used to mitigate an SGTR event such as the EFW flow control valves (FCVs) (1FDW-315, -316), turbine bypass valves (1MS-19,
-22, -28, -31), and back-up nitrogen supply to the former. The team reviewed valve lineup procedures, testing and maintenance history for the steam supply valves (1MS-82, -84, -93) and check valves (1MS-83, -85, -91) to the turbine-driven EFW pump (1C) to verify that the system design basis assumptions were consistent with the actual capability of the system. The team also reviewed operating procedures to verify proper steam isolation to the turbine driven EFW pump from the faulted OTSG.
b. Findings
No findings of significance were identified.
.13 Instrumentation and Controls
a. Inspection Scope
The team reviewed the electrical control schematics for EFW control systems and pressurizer power operator relief valve (PORV) controls, to verify that the logic of operation satisfies the requirements of the plants design bases and licensing bases requirements. The team reviewed the controls for the motor driven EFW Pump A, low steam generator (SG) level start circuit, condensate system valve 1FDW-315, EFWDWP discharge valve to SG 1A, and pressurizer relief valve 1RV-67. In addition, the team reviewed surveillance procedures, calibration test records, and setpoint calculations for process instrument channels monitoring SG narrow range and wide range level, SG pressure, RCS pressure, pressurizer level, RCS temperature, and radiation monitors to verify that the setpoint calculations were documented accurately on the surveillance procedures for these instrument channels.
b. Findings
No findings of significance were identified.
.14 Operator Actions
a. Inspection Scope
The team reviewed plant operating procedures, emergency operating procedures (EOPs), abnormal procedures (APs), and annunciator response procedures (ARPs) that would be used for the identification and mitigation of an SGTR event. The team reviewed these SGTR related procedures to verify that appropriate guidance was provided to the operators for identification and mitigation of the event and procedures were consistent with the owners group guidelines, the station emergency procedures writers guide, the station UFSAR, and SGTR training provided to the operators. The team reviewed the EOP deviations from the owners group guidelines. A simulator SGTR event scenario was observed to assess the operators use of procedures and available instrumentation and controls for identification and mitigation. The team reviewed the design documentation and accident analysis assumptions which established the set points and time related tasks for EOPs for this event to verify this information had been appropriately incorporated into procedures. The team compared a sample of the requirements in Nuclear System Directive (NSD) 513, Primary-to-Secondary Leak Monitoring Program, to the implementing steps in Abnormal Procedure AP/1/A/1700/031, Primary to Secondary Leakage, to verify that the NSD requirements were properly translated into the working level procedure.
The team conducted in-plant walkdowns with station operators of procedures used to accomplish SGTR related actions outside of the control room to verify that the procedures would accomplish their stated objective in a reasonable time under conditions that would exist during the event. These actions included operation of atmospheric depressurization valves (ADVs), refill of the BWST, cross-connect of unit EFW, local manual action to open turbine building sump pump breakers, and line up of the EFW pump suction to the main condenser. Additionally, the team conducted in-plant walkdowns of tasks contained in the SGTR EOP and AP that would be performed by radiation protection technicians during the event. These tasks included locally measuring condenser steam air ejector flow (CSAE), obtaining a sample from the CSAE, and measuring radiation levels on the main steam lines.
b. Findings
No findings of significance were identified.
.15 Heat Removal
a. Inspection Scope
The team reviewed design calculations, drawings, and surveillance test procedures for selected equipment to assess the reliability and availability of cooling for equipment required to mitigate an SGTR event. The team conducted field walkdowns of the equipment to verify that operating conditions were consistent with design assumptions.
The equipment reviewed included HPI and EFW pumps and testing of these pumps at both full and minimum flow conditions. The team also reviewed design calculations, vendor manuals, and machinery history to verify that the HPI pump upper bearing oil cooler had adequate heat transfer capability using the low pressure service water system to remove heat from the thrust bearing housing during design bases accidents.
b. Findings
No findings of significance were identified.
.2 System Condition and Capability
.21 Installed Configuration
a. Inspection Scope
The team reviewed design drawings and performed walkdowns of portions of the Class 1E electrical distribution systems; including 4160VAC buses and switchgears, 600VAC load centers, 600VAC and 208VAC motor control centers, 120VAC and 125VDC panelboards applicable to the EFW and HPI pumps and valves. The purpose of the inspection was to assess general material condition, verify system alignments were consistent with design and licensing basis assumptions and to identify degraded conditions of SGTR mitigation equipment. The team reviewed the 4160VAC and 600VAC circuit breaker control logic design drawings applicable to the EFW and HPI pump motors and motor operated valves and performed field and control room walkdowns to verify that the installed local and remote circuit breaker control switches and breaker position indicating lights were consistent with design drawings.
The team performed field inspections of accessible SGTR mitigation mechanical equipment in the EFW, HPI, and main steam (MS) systems to assess observable material condition, identify degraded conditions, and verify the installed configuration was consistent with design drawings and design inputs to calculations. This review was also conducted to verify that selected valves and components in these systems were in their required position and that the valve line-up configuration was consistent with the design bases. For the HPI, and EFW systems, particular attention was placed on verifying selected valves and components that could cause a common mode failure in these systems. Among the selected components were the atmospheric dump valves (ADVs) (1MS-162, -164), the turbine bypass valves (1MS-19, -22, -28, -31), HPI suction valves (1HP-24, -25), HPI discharge valves (1HP-26, -27), and the EFW FCVs (1FDW-315, -316).
Additionally, the team reviewed FME PIPs, and system health reports for selected systems and met with selected system engineers to discuss system design basis and to evaluate identified degraded components. The team also reviewed human factors items in the walkdown areas (e.g. lighting, noise, accessability, labeling) to verify proper consideration had been given to these areas for SGTR mitigation actions.
The team examined the material condition of the level instruments on the UST and the protection and routing for redundant sensing lines. This review was performed to verify that the observable material condition was acceptable and that redundant instrumentation sensing lines were adequately routed and protected to prevent common cause failure of the instruments.
In addition, the team observed installed configuration and material condition for the following radiation monitoring instruments on all three units:
- RIA-16/17, Main Steam Line Area Radiation Monitors
- RIA-59/60, Main Steam Line Nitrogen-16 Detectors, Unit 1 only
- RIA-40, Condenser Steam Air Ejector Off-Gas Monitor The installed configuration was evaluated against UFSAR requirements and design calculation documents listed in the Attachment.
b. Findings
No findings of significance were identified.
.22 Operations
a. Inspection Scope
The team performed field walk downs of selected components specified in the SGTR EOP for which local manual operation was required to verify the equipment was accessible, required tools and ladders were available, and adequate lighting and indications were available for operation and determination of equipment status. These components included the EFW unit cross-connect valves, ADVs, main condenser vacuum breakers, backup nitrogen supply for EFW flow control valves, CSAE exhaust lines used for flow monitoring and radiation sampling, and locations for local radiation monitoring of main steam lines.
b. Findings
No findings of significance were identified.
.23 Design
a. Inspection Scope
Mechanical Design The team reviewed a sample of the TS, the UFSAR, calculations, and vendor manuals for the EFW (1A, 1B, 1C) and HPI (1A, 1B, 1C) pumps and valves to verify that vendor recommendations and licensing basis requirements had been appropriately translated into the surveillance requirements and design calculations. The team also reviewed operating experience (OE) of the EFW FCVs (1FDW-315, -316) and EFW minimum-flow lines potential for failure and isolation, respectively. The team reviewed NPSH calculations for the EFW, and HPI pumps to verify that adequate water head was available from each of the applicable water sources, both the USTs and the hotwell, and the BWST, respectively. Also, the team reviewed volumetric water level calculations to verify that vortexing considerations had been properly translated into the surveillance tests acceptance criteria and to the equipment monitoring activities. In addition, the team reviewed the EFW FCVs backup nitrogen tanks regulator setting controls to verify that backup nitrogen would be available if needed.
Electrical Design The team reviewed the AC and DC electrical power and control distribution system design to ensure the system would provide adequate power to the EFW and HPI pumps and valves. This included review of design bases, design changes, design assumptions, calculations of short circuits, voltage drops and relay setpoints.
Additionally, the team performed limited calculations to verify the appropriateness of the design values.
The team reviewed the uncertainty calculations for the following instrument loops associated with the SGTR accident and verified that plant instrument calibration procedures have accurately incorporated set point values delineated in the calculations of record for the following instruments channels: SG narrow range and wide range level, SG pressure, RCS pressure, pressurizer level, and RCS temperature.
b. Findings
No findings of significance were identified.
.24 Testing
a. Inspection Scope
The team reviewed a sample of records of preventive maintenance, functional performance and surveillance tests to verify that the tests were appropriately verifying the assumptions of the licensing and design bases and that the equipment was being properly maintained. This review included the testing of the 4160VAC emergency power switching logic and protective relay settings. The components reviewed included the 4160VAC main bus 1 and main bus 2 circuit breakers and associated overcurrent, undervoltage, differential, and ground relays.
The team also reviewed MOV bench and motor power monitor (MPM) test results to verify the capabilities of the MOV actuators are adequate to provide the required thrust under degraded voltage conditions. The components reviewed included the HPI motor operated valves HP-26, HP-27, HP-409, HP-410 and associated motor and starter circuits.
The team reviewed records of preventive maintenance, surveillance tests, maintenance history, head curves, and performed field walkdowns of selected components in the HPI, EFW, and MS systems to verify that the tests and inspections were appropriately verifying that the assumptions of the design and licensing bases were being maintained.
This review included testing of HPI and EFW pumps discharge pressures and flowrates during full and recirculation flow conditions, relief valve pressure set points; and analysis of pump bearing oil samples. A more detailed list of the components is provided in the
.
The team reviewed valve stroke time testing, MOV thrust capability with differential pressure included, and post-maintenance testing to verify that the tests and inspections were appropriately verifying the assumptions of the licensing and design bases; that the equipment was being properly maintained; and that performance degradation would be identified during tests.
The team reviewed alarm setpoint calculations, maintenance history, and calibration records for Unit 1 radiation monitoring instruments, RIA-16/17, RIA-59/60, and RIA-40.
Radiation monitoring equipment operability was reviewed against requirements contained in the UFSAR and applicable design basis drawings and procedures listed in the Attachment.
In addition, the team reviewed data sheet records for SG narrow range and wide range level, SG pressure, RCS pressure, pressurizer level, and RCS temperature instruments.
The reviews were performed to verify that the plant surveillance procedures had correctly incorporated acceptance criteria and instrument uncertainties that were specified in the instrument loop uncertainty calculations of record. Also, the team reviewed records of completed surveillance tests and preventive maintenance that were performed on these instruments in order to verify that the related problems were being adequately corrected.
b. Findings
No findings of significance were identified.
.3 Selected Components
.31 Component Degradation
a. Inspection Scope
The team reviewed PIPs and surveillance records to assess the licensees actions to verify and monitor the safety function, reliability and availability of selected components.
Components included in this review were the 4160VAC Class IE type HK switchgears auxiliary switches and type CO relays. The team held interviews with licensee personnel to review licensees actions to address vendor recommended breaker and relay refurbishment and replacement. A list of reviewed PIPs is provided in the
.
The team reviewed selected systems with Maintenance Rule functional failures, maintenance records, testing documentation, work orders, condition reports, and performance trending of selected components in the HPI, EFW, MS, RCS, instrument air, and nitrogen backup systems to assess the licensees actions to verify and maintain the safety function, reliability, and availability of selected components. Among the selected components were air operated valves, MOVs, main steam safety valves, ADVs, pumps, and air compressors. A more detailed list of components reviewed is provided in the Attachment.
Additionally, the team assessed potential common cause failure mechanisms due to maintenance, parts replacement, and modifications to verify that components that were relied upon to mitigate an SGTR event were not degrading to unacceptable performance levels. The team reviewed the licensees analysis of an OE item related to main steam safety valve cotter pin failures to verify that actions were taken in accordance with OE recommendations. The team also reviewed the turbine driven EFW pumps steam supply piping to verify inclusion of steam traps to prevent turbine overspeeding.
The team reviewed preventive maintenance records, testing documentation, calibration records, and work orders for SG narrow range and wide range level, SG pressure, RCS pressure, pressurizer level, RCS temperature and radiation monitoring instruments to assess the licensees actions to verify and maintain the safety function, reliability, and availability of the components in the system.
b. Findings
No findings of significance were identified.
.32 Equipment Protection
a. Inspection Scope
The team performed field walkdowns of selected components in the HPI, MS, and EFW systems to verify that the components were adequately protected from the potential effects of missiles, flooding, impacts from other equipment such as scaffolds, and high or low outdoor temperatures.
b. Findings
No findings of significance were identified.
.33 Component Inputs/Outputs
a. Inspection Scope
The team reviewed the EFW FCVs to verify fail safe position of open valves in accordance with the design bases for SGTR.
The team performed field walkdowns of condensate storage tank level tansmitters 1-C-LT-0016A and 1-C-LT-0016P as well as upper surge tank level transmitter 1-C-LT-0036-1A to assess suitability of the environment in terms of temperature and humidity anticipated under accident conditions. In addition, the team reviewed environmental specifications for the standby shutdown facility (SSF) SG pressure transmitters (Rosemount 1154) to verify that the instruments were suitable for their application. The team reviewed environmental qualification requirements in the vendor manuals for a sample of instrument loops listed below.
- Condensate Storage Tank level (1-C-LT-0016A,-0016P)
- Upper Surge Tank (1-C-LT-0036-1A)
- SG NR Lvl (1-FDWLT-0053-P,-0066,-0080,0008-A)
- S/G WR Lvl (1-FDWLT-00070P,-0055-P,-0082,-0051)
- SG Pressure (1-FDWP-0231)
- RCS Pressure (3-RC-PT-0224)
- Pressurizer Level (3-RC-LT-0072,-0004-P1,-P2,-P3)
b. Findings
No findings of significance were identified.
.34 Operating Experience
a. Inspection Scope
The team reviewed the licensees applicability evaluations and corrective actions for industry experience issues related to turbine driven EFW pumps, MOVs, check valves, and instrument air system failures. The team also reviewed the licensees evaluations of operating experience reports applicable to the SGTR event to verify that applicable insights from those reports had been applied to the appropriate components.
The team specifically reviewed the following events:
- IN-2003-13, Steam Generator Tube Degradation at Diablo Canyon.
- NSAL-03-5, Steam Generator Sludge Lance Tube Wear
- IN 03-05, Failure To Detect Freespan Cracks in PWR Steam Generator Tubes.
- OE 15901, Steam Generator Sludge Lance Damage to U-Tubes
- IN 2002-21, Axial Outside-Diameter Cracking Affecting Thermally Treated Alloy 600 Steam Generator Tubing
- OE11624 - All Three Auxiliary Feedwater Pumps Declared Inoperable Due to the Potential to Plug Their Suction Strainers
- OE12078 - Turbine Driven Emergency Feedwater Pump Trip Following a Plant Trip
- IN 2002-10, Non-Conservative Water Level Setpoints on Steam Generators
- SEN 213, Steam Generator Tube Failure - Indian Point Unit 2
b. Findings
No findings of significance were identified.
.35 Foreign Material Exclusion Control Program And Loose Parts Monitoring
a. Inspection Scope
The team reviewed procedural guidelines and performance records for the loose parts monitoring system to verify that these systems were operational and were being used to monitor for loose parts in the RCS. In addition, the team reviewed records of foreign material control activities to verify that this program was being utilized.
b. Findings
No findings of significance were identified.
.4 Identification and Resolution of Problems
a. Inspection Scope
The team reviewed a sample of PIPs initiated over the past two years for systems, structures, or components required to mitigate an SGTR event to confirm that the licensee was adequately identifying, evaluating, and dispositioning adverse conditions.
The specific documents reviewed are listed in the Attachment.
The team reviewed a sample of PIPs initiated over the past three years for SG narrow range and wide range level, SG pressure, RCS pressure, pressurizer level, RCS temperature and radiation monitors instruments to verify that the licensee was adequately identifying, evaluating, and dispositioning adverse conditions.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
4OA6 Meetings, Including Exit
The lead inspector presented the inspection results to Mr. R. Jones, Site Vice President, and other members of the licensee staff, at an exit meeting on September 2, 2004. The licensee acknowledged the findings presented. Proprietary information is not included in this inspection report.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- G. Davenport, Regulatory Compliance Manager
- L. Nicholson, Safety Assurance Manager
- J. Smith, Regulatory Compliance
- J. Weast, Regulatory Compliance
NRC (attended exit meeting)
- C. Casto, Director - Division of Reactor Safety
- G. Hutto, Resident Inspector
- J. Moorman, Team Leader, NRC Region II
- E. Riggs, Resident Inspector
- M. Shannon, Senior Resident Inspector
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
None.