IR 05000280/2024001
| ML24116A308 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 04/30/2024 |
| From: | Matthew Fannon NRC/RGN-II/DRP/RPB4 |
| To: | Carr E Virginia Electric & Power Co (VEPCO) |
| References | |
| IR 2024001 | |
| Download: ML24116A308 (14) | |
Text
SUBJECT:
SURRY POWER STATION - INTEGRATED INSPECTION REPORT 05000280/2024001 AND 05000281/2024001
Dear Eric S. Carr:
On March 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Surry Power Station. On April 18, 2024, the NRC inspectors discussed the results of this inspection with Jim Shell, Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
A licensee-identified violation which was determined to be of very low safety significance is documented in this report. We are treating this violation as a non-cited violation (NCV)
consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Surry Power Station.
April 30, 2024 This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Matthew S. Fannon, Chief Reactor Projects Branch 4 Division of Reactor Projects Docket Nos. 05000280 and 05000281 License Nos. DPR-32 and DPR-37
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000280 and 05000281
License Numbers:
Report Numbers:
05000280/2024001 and 05000281/2024001
Enterprise Identifier:
I-2024-001-0032
Licensee:
Virginia Electric and Power Company
Facility:
Surry Power Station
Location:
Surry, VA
Inspection Dates:
January 01, 2024 to March 31, 2024
Inspectors:
D. Jung, Resident Inspector
S. Kennedy, Senior Resident Inspector
Approved By:
Matthew S. Fannon, Chief
Reactor Projects Branch 4
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting an integrated inspection at Surry Power Station, in accordance with
the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for
overseeing the safe operation of commercial nuclear power reactors. Refer to
https://www.nrc.gov/reactors/operating/oversight.html for more information. A licensee-identified
NCV is documented in report section: 71111.05.
List of Findings and Violations
Non-conservative Calculation for Cable Vault Low-pressure Carbon Dioxide Systems
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
NCV 05000280,05000281/2024001-01
Open/Closed
None (NPP)
The inspectors identified a Green finding and associated non-cited violation (NCV) of License
Condition 3.I, Fire Protection, associated with the licensee's failure to implement and maintain
in effect, the provisions of the approved fire protection program as described in the Updated
Final Safety Analysis Report (UFSAR), which resulted in a non-conservative calculation for
the low-pressure carbon dioxide system for the Unit 1 and Unit 2 cable vaults.
Additional Tracking Items
None.
PLANT STATUS
Unit 1 and Unit 2 operated at or near rated thermal power for the entire inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
their attached revision histories are located on the public website at http://www.nrc.gov/reading-
rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared
complete when the IP requirements most appropriate to the inspection activity were met
consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection
Program - Operations Phase. The inspectors performed activities described in IMC 2515,
Appendix DProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 2515,</br></br>Appendix D" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Plant Status, observed risk significant activities, and completed on-site portions of
IPs. The inspectors reviewed selected procedures and records, observed activities, and
interviewed personnel to assess licensee performance and compliance with Commission rules
and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
(1)
The inspectors evaluated the adequacy of the overall preparations to protect risk
significant systems from impending severe weather associated with a tornado watch
and flood warning on January 9, 2024.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1)
Alternate alternating current diesel generator following quarterly surveillance on
February 14, 2024
(2)
Unit 1 motor driven auxiliary feedwater pumps when the turbine driven auxiliary
feedwater pump was out of service due to excessive outboard bearing oil leakage on
February 15, 2024
(3)
1-VS-E-4B, B main control room chiller, during 'C' main control room chiller
maintenance on March 25, 2024
(4)
- 1 emergency diesel generator following monthly surveillance on March 26, 2024
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (8 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a
walkdown and performing a review to verify program compliance, equipment functionality,
material condition, and operational readiness of the following fire areas:
(1)
Diesel generator room number 3, fire zone 7, elevation 27 feet - 6 inches, on January
17, 2024
(2)
Unit 1B battery room, fire zone 10, elevation 9 feet - 6 inches on January 22, 2024
(3)
Alternate alternating current diesel room, fire zone 69, elevation 35 feet - 0 inches,
on February 12, 2024
(4)
Unit 1 cable spreading room, fire zone 46, elevation 45 feet - 3 inches, on February
21, 2024
(5)
Unit 2 cable spreading room, fire zone 47, elevation 45 feet - 3 inches, on February
21, 2024
(6)
Unit 1 cable vault penetration area, fire zone 1A, elevation 15 feet - 0 inches, on
February 29, 2024
(7)
Unit 2 cable vault penetration area, fire zone 2A. elevation 15 feet - 0 inches, on
February 29, 2024
(8)
Emergency service water pump house - low level, fire zone 28B, elevation 18 feet - 0
inches, on March 13, 2024
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
(1)
The inspectors evaluated the onsite fire brigade training and performance during an
announced fire drill on February 27, 2024. The simulated fire location was on the Unit
2 turbine building basement at the Unit 2 hydrogen seal oil skid.
71111.07A - Heat Exchanger/Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
(1)
1-CC-E-1B and 1-CC-E-1C, component cooling heat exchangers (Work Order (WO)
38204338066 and WO38204338067) on March 1, 2024
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1
Sample)
(1)
The inspectors observed and evaluated licensed operator performance in the control
room during the performance of 2-OP-FW-002, Turbine Driven Auxiliary Feedwater
Pump Startup and Shutdown and the return to service of 2-CW-P-1D, Unit 2 1D
circulating water pump, on February 2, 2024.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
(1)
The inspectors observed a licensed operator requalification training activity involving
scenarios which included Unit 1 manual reactor trip due to 'A' reactor coolant pump
seals #1 and #2 leak, followed by 'B' steam generator tube rupture on February 27,
2024.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (3 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following
structures, systems, and components (SSCs) remain capable of performing their intended
function:
(1)
Unit 1 'B' low-head safety injection pump (1-SI-P-1B) switch on February 5, 2024
(Corrective Action (CA) 12301857)
(2)
Unit 1 computer enhanced rod position indicator E05 on February 23, 2024
(CA12352671)
(3)
Engine oil leak on 1-SW-P-1C, emergency service water pump C, on March 11,
2024 (Condition Report (CR) 1244698)
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the
following planned and emergent work activities to ensure configuration changes and
appropriate work controls were addressed:
(1)
Unit 1 emergent risk due to 'B' low-head safety injection pump (1-SI-P-1B) switch
replacement on January 8, 2024
(2)
Units 1 and 2 elevated risk due to #3 emergency diesel generator maintenance on
January 17, 2024
(3)
Unit 1 emergent risk due to main control room air handling unit (1-VS-AC-2) high
vibration on February 7, 2024
(4)
Unit 1 elevated risk due to crane lift near the high-level intake structure and
mechanical equipment room #4 service water strainer maintenance package on
February 28, 2024
(5)
Unit 2 elevated risk due to B train high-high consequence limiting safeguards logic
test on March 14, 2024
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (7 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the
following operability determinations and functionality assessments:
(1)
CR1247399, 01-SI-RV-1845A, low-head safety ejection pump 1A discharge to hot
legs relief valve, lifted during test run at 3 liters per minute on January 3, 2024
(2)
CR1249156, 01-AS-SV-100, auxiliary steam supply header safety valve, opened
before its relief setpoint on February 2, 2024
(3)
CR1250004, 02-SW-FI-253B, charging pump service water pump B flow indicator,
low side vent valve is seized closed on February 2, 2024
(4)
CR1246202, #2 emergency diesel generator battery charger lead disconnected on
February 6, 2024
(5)
CR1251038, 1-FW-P-2, Unit 1 turbine driven auxiliary feedwater pump, outboard
bearing oil leak on February 15, 2024
(6)
CR1251233, 01-SW-RM-120, circulating water system discharge tunnel radiation
monitor, trending performed unsatisfactorily on February 26, 2024
(7)
CR1250078, 02-RM-RI-227, Unit 2 containment high range radiation monitor, alert
setpoint above the required setpoint on February 27, 2024
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1
Sample)
The inspectors evaluated the following temporary or permanent modifications:
(1)
SU-24-00105, Temporary Modification to Gag Safety Valve 01-AS-SV-100, Unit 1
auxiliary header safety valve, on January 18, 2024
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system
operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (6 Samples)
(1)
EMP-P-RT-38, Protected Relay Maintenance for Emergency Diesel Generator No. 3
Differential Relay, on January 17, 2024 (WO38204222978)
(2)
Unit 1 'B' low-head safety injection pump (1-SI-P-1B) switch replacement on January
23, 2024 (WO38204340600)
(3)
2-OP-FW-002, Turbine Driven Auxiliary Feedwater Pump Startup and Shutdown,
following change out of oil on February 2, 2024
(4)
0-ECM-0306-02, 480V Motor Control Center Breaker Assembly Operational Check,
following Unit 1 boric acid transfer pump switch repair on March 4, 2024
(5)
2-PT-2.33B, Emergency Bus Undervoltage and Degraded Protection Test J Train,
following C phase degraded voltage relay replacement on March 20, 2024
(6)
0-ECM-0102-10, Emergency Service Water Pump Diesel Engine 24 Volt Start Battery
Maintenance, following battery replacement on March 24, 2024 (WO38204321575)
Surveillance Testing (IP Section 03.01) (3 Samples)
(1)
2-IPT-FT-RC-P-457, Pressurizer Pressure Protection Loop P-2-457; 2-IPT-FT-RC-L-
461, Pressurizer Level Protection Loop L-2-461; and 2-IPT-FT-FW-L-476, Steam
Generator Level Protection Loop L-2-476, on February 1, 2024
(2)
0-OSP-AAC-001, Quarterly Test of 0-AAC-DG-0M, Alternate AC Diesel Generator, on
February 12, 2024
(3)
2-NPT-SI-013, Ultrasonic Examination of Safety Injection Piping on February 27,
2024
Inservice Testing (IST) (IP Section 03.01) (2 Samples)
(1)
1-OPT-CH-001, Charging Pump Operability and Performance Test for 1-CH-P-1A, on
March 2, 2024
(2)
1-OPT-RS-007, Containment Outside Recirculation Spray Pumps Motor Operated
Valves Stroke Test, on March 6, 2024
71114.06 - Drill Evaluation
Required Emergency Preparedness Drill (1 Sample)
(1)
The inspectors observed and evaluated the conduct of an emergency preparedness
drill scenario involving the degradation of two fission product barriers which led to the
declaration of site area emergency on March 19, 2024.
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01) (2 Samples)
(1)
Unit 1: October 2022 through September 2023
(2)
Unit 2: October 2022 through September 2023
IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (2
Samples)
(1)
Unit 1: October 2022 through September 2023
(2)
Unit 2: October 2022 through September 2023
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (2 Samples)
(1)
Unit 1: October 2022 through September 2023
(2)
Unit 2: October 2022 through September 2023
71152A - Annual Follow-up Problem Identification and Resolution
Annual Follow-up of Selected Issues (Section 03.03) (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program
related to the following issues:
(1)
Unit 1 cable spreading room fire protection concerns (CR1239083, CR1240793,
CR1241526)
INSPECTION RESULTS
Non-conservative Calculation for Cable Vault Low-pressure Carbon Dioxide Systems
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
NCV 05000280,05000281/2024001-01
Open/Closed
None (NPP)
The inspectors identified a Green finding and associated non-cited violation (NCV) of License
Condition 3.I, Fire Protection, associated with the licensee's failure to implement and maintain
in effect, the provisions of the approved fire protection program as described in the Updated
Final Safety Analysis Report (UFSAR), which resulted in a non-conservative calculation for
the low-pressure carbon dioxide system for the Unit 1 and Unit 2 cable vaults.
Description: On August 24, 2023, the inspectors performed a walkdown of the Unit 1 cable
vault, Fire Zone 1, elevation 15 feet. The inspectors identified several penetrations on the
west wall that were not sealed. The licensee determined that the unsealed penetrations on
the west wall led to a void space between the Unit 1 cable vault and the Unit 1 safeguards
building basement. The west wall (or false wall) leading to the void space is not an
Appendix R fire barrier but was being credited as a boundary for the low-pressure carbon
dioxide system for the cable vault. The Appendix R fire barrier is the wall between the Unit 1
cable vault void space and the Unit 1 safeguards building. The concern is that carbon dioxide
could leak into the void space and impact the ability of the low-pressure carbon dioxide
system to perform its function to suppress deep seated fires in the cable vault.
Calculation CE-1853, Volumes of Requested Rooms, was used to determine the volume of
the cable vault but did not include the volume of the void space. In 2008, the results from CE-
1853 were used as a design input in Calculation ME-0828, Cable Vault and Tunnel
Calculations for Surry Units 1 and 2 Fire Protection, which resulted in a non-conservative
calculation. Calculation ME-0828 determined that the total carbon dioxide required to
suppress a fire in the Unit 1 cable vault, accounting for known leakage paths, was 4262
pounds. ME-0828 stated that the amount of carbon dioxide supplied was 4271 pounds. This
results in a positive margin of 9 pounds. However, if ME-0828 is adjusted to include the
volume of the void space, approximately 1000 cubic feet, the minimum carbon dioxide
required would result in a deficit (negative margin) of 74 pounds.
Additionally, on August 24, 2023, while following up on the issue identified by the inspectors,
the licensee identified a penetration in the Unit 1 safeguards building basement that was not
sealed. The degraded penetration was located on the fire barrier wall between the Unit 1
safeguards building basement and the Unit 1 cable vault void space. This degraded
penetration is dispositioned as a licensee-identified violation in the Inspection Results section
of this report. The issue is noted here since the as-found condition, as identified by the
inspectors, could have resulted in the loss of carbon dioxide not only to the void space but
through the void space to the Unit 1 safeguards building basement. The licensee repaired the
degraded penetration on the Unit 1 safeguards building basement fire barrier; however, the
inspectors took this degraded condition into account in determining the significance of the
finding associated with the non-conservative Calculation ME-0828.
The licensee declared the carbon dioxide system for the Unit 1 cable vault non-functional and
established an hourly fire watch in accordance with Technical Requirements Manual (TRM)
3.7.8. The licensee reviewed Calculation ME-0828 and identified conservatisms associated
with the conversion factor for carbon dioxide loss rate, an error in the total height of the
volume of the cable vault, and CO2 actual discharge time versus the designed requirement
time. The licensee identified enough conservatisms in the calculation to confirm functionality
of the Unit 1 cable vault low-pressure carbon dioxide system with the volume of void space
included in the total cable vault volume and exited TRM 3.7.8. Including the degraded
conditions identified by the inspectors and the licensee, the revised preliminary calculation
resulted in 76 pounds of carbon dioxide supplied above the required amount.
On August 28, 2023, the licensee performed an extent of condition review in the Unit 2 cable
vault and identified similar conditions and performed similar actions as for Unit 1.
The inspectors concluded that the licensee did not maintain Calculation ME-0828 in
accordance with the requirements of CM-AA-CLC-301, Engineering Calculations, Attachment
1, Fundamental Expectations, which stated, in part, that assumptions shall be justified and
bounded by the station design basis. The design bases layout of the void space is detailed in
Drawing 11448-FC-24D, Plan and Details, Elevation 15 feet - 0 inches, Auxiliary Building.
The inspectors noted that CM-AA-CLC-301 is the administrative procedure for engineering
calculations including calculations for fire protection systems.
Corrective Actions: The licensee declared the low-pressure carbon dioxide system in the Unit
1 and 2 cable vaults non-functional, entered the associated TRM action statement, and
performed a preliminary recalculation to justify functionality. The licensee initiated a corrective
action assignment to finalize the calculation.
Corrective Action References: CR1236252, CA12063265, and CA12082541
Performance Assessment:
Performance Deficiency: The inspectors found that the licensees failure to implement the fire
protection program in accordance with licensee procedure CM-AA-CLC-301, which resulted
in non-conservative calculation, was a performance deficiency within the licensees ability to
foresee and prevent.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Protection Against External Factors attribute of the
Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure
the availability, reliability, and capability of systems that respond to initiating events to prevent
undesirable consequences. Specifically, the calculation deficiency resulted in negative margin
for amount of carbon dioxide needed to suppress a fire in the cable vaults, which resulted in a
reasonable doubt of functionality in the as-found condition of low-pressure carbon dioxide
system. This issue is similar to more than minor example 3.h. in IMC 0612, Appendix E, in
that, the licensee revised the calculation to solely obtain favorable results.
Significance: The inspectors assessed the significance of the finding using IMC 0609
Appendix FProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0609</br></br>Appendix F" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Fire Protection and Post - Fire Safe Shutdown SDP. In accordance with IMC 0609, Appendix F, Attachment 2, Degradation Rating Guidance, the inspectors assigned a
low degradation rating due to the revised preliminary calculation resulting in concentration
above the required amount. Specifically, the revised preliminary calculation resulted in
approximately 76 pounds of carbon dioxide above the required amount. In accordance with
IMC 0609, Appendix F, Attachment 1, Significance Determination Process Worksheet, Step
1.3 - Low Degradation Deficiencies, the finding screened to very low safety significance
(Green). In addition, the inspectors verified that the non-conservative calculation for the fixed
suppression system did not adversely affect the ability of the system to protect any equipment
important to safe shutdown.
Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to
this finding because the inspectors determined the finding did not reflect present licensee
performance.
Enforcement:
Violation: License Condition 3.I, Fire Protection, states in part, The licensee shall
implement and maintain in effect the provisions of the approved fire protection program as
described in the Updated Final Safety Analysis Report UFSAR Section 9.10.1, Design
Bases, states in part, Compliance with these criteria is contained in the following
documents Fire Protection Program documents and the associated Administrative
Procedures describe the administrative and technical controls. CM-AA-CLC-301,
Engineering Calculations, Attachment 1, Fundamental Expectations, stated, in part, that
assumptions shall be justified and bounded by the station design basis. The design bases
layout which included the void space is detailed in Drawing 11448-FC-24D, Plan and Details,
Elevation 15 feet - 0 inches, Auxiliary Building.
Contrary to the above, from at least 2008 to August 24, 2023, the licensee failed to implement
and maintain in effect, the provisions of the approved fire protection program as described in
the UFSAR, resulting in a calculation that did not justify functionality of the low-pressure
carbon dioxide for Unit 1 and Unit 2 cable vaults. Specifically, the licensee did not ensure that
design inputs regarding the layout of the cable vaults were incorporated into the calculation.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Licensee-Identified Non-Cited Violation
This violation of very low safety significance was identified by the licensee and has been
entered into the licensee corrective action program and is being treated as a non-cited
violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: License Condition 3.I, Fire Protection, states in part, The licensee shall
implement and maintain in effect the provisions of the approved fire protection program as
described in the Updated Final Safety Analysis Report UFSAR Section 9.10.1, Design
Bases, states in part, Compliance with these criteria is contained in the following
documents Fire Protection Program documents and the associated Administrative
Procedures describe the administrative and technical controls. Licensee procedure CM-AA-
FPA-100, Fire Protection/Appendix R (Fire Safe Shutdown) Program, states, in part,
Penetration seals must provide equal or greater fire rating than that of the fire barrier.
Contrary to the above, on August 24, 2023, the licensee identified a degraded fire penetration
on the fire barrier wall between the Unit 1 safeguards building basement and the Unit 1 cable
vault that did not provide the required three hour or greater fire rating. The licensee repaired
the degraded penetration, which had existed for an unknown period prior to identification.
Significance/Severity: Green. The inspectors assessed the significance of the finding using
IMC 0609 Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The finding was
determined to be of very low safety significance (Green) because there is an adequate
automatic suppression system on either side of the fire confinement element in accordance
with IMC 0609, Appendix F, Attachment 1, Step 1.4.4: Fire Confinement, Question 1.4.4-B.
Corrective Action References: CR1236265
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On April 18, 2024, the inspectors presented the integrated inspection results to Jim
Shell, Plant Manager, and other members of the licensee staff.