IR 05000298/1982002
| ML20041C757 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 02/24/1982 |
| From: | Murray B, Wilborn L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20041C747 | List: |
| References | |
| 50-298-82-02, 50-298-82-2, NUDOCS 8203020538 | |
| Download: ML20041C757 (15) | |
Text
-
,
.
.
\\
U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
'
-
__
Report:
50-298/82-02
' License:
DPR-46 Docket:
50-298
.
Licensee:
Nebraska Public Power District (NPPD)
1414 15th Street.
,
Columbus, NE 68601
.
.
Facility:
Cooper Nuclear. Station (CNS)
Brownville, Nemaha County, NE
.
Inspection Conducted: January 11-15, 1982
.
Inspector:
b Apf 8/8(//82 gp.orenzoWilborn,Radi[tionSpecialist
/ Dath
,
Approved by:
B/sy/Bz Blaine ~Murray, Chief,FacfiitiesRadiation
' Date Protection Section Inspection Summary Inspection on January 11-15, 1982 (Report 50-298/82-02)
Areas Inspected:
Routine, unannounced inspection of the licensee's radioactive waste systems including liquid and gaseous effluent releases; records and reports of radioactive effluents; procedures for controlling effluent releases; testing of air cleaning systems; reactor coolant water quality; solid radioactive waste program; training and qualifications of radiochemistry personnel; radiochemistry sampling and analyses procedures; and audits performed by the licensee.
The inspection involved 60 on-site hours by one NRC inspector and the Chief, Facilities Radiation Protection Section.
Results:
No violations or deviations were identified. Four open items are
. discussed in paragraphs 6.b, 10.a(2), 10.b and 11.b.
0203020538 020225 PDR ADOCK 05000298 O
PDR i
,-
.
.,, -.
-.
.
.
.
DETAILS 1.
Persons Contacted
.
- L. C. Lessor, Station Superintendent i
R. J. Mcdonald, Acting Chemistry and Health Physics Supervisor R. Brungardt, Shift Supervisor J. Warren, Chemist
'
G. Ketner, Lead Chemistry Technician P. J. Borer, Engineering Supervisor V. L. Wolstenholm, Quality Assurance Supervisor D. Snyder, Chemistry Technician J. Mehser, Radwaste Operator
- D. Dubois, NRC Resident Inspector
- Denotes those present during the exit interview.
The inspectors also interviewed several other plant personnel during the inspection.
2.
Scope of Inspection The purpose of this inspection was to review the licensee's Radioactive Waste Systems for the period July 20, 1978, through January 14, 1982.
3.
Licensee Action on Previous Inspection Findings Actions had been completed on previously identified open and unresolved items regarding radwaste activities.
4.
Open and Unresolved Items Identified During this Inspection (0 pen) Open Item (50-298/82-02/01):
Verification of Gaseous Effluent Releases.
The licensee program did not include routine analyses to verify that Environment Technical Specifications (ETS) 2.4.3.a.1 and 2.4.3.a.4.d were not exceeded (see paragraph 6.b).
'
(0 pen) Open Item (50-298/82-02/02):
Charcoal Adsorber Tests.
The licensee's Technical Specification (TS) did not include current industry recommendations regarding laboratory tests for charcoal adsorbers.
(see paragraph 10.a(2)).
,
I i
--
-
.
, _ - _ -
- -.
-
.
-
.
,
(0 pen) Open Item (50-298/82-02/03):
Surveillance Tests for Non-Technical Specifications Filter Systems.
Filter systems associated with the Augmented Off Gas system (A0G) Radwaste Building, Reactor Building, Off-Gas System, Technical Support Center, and Operational Support Center had not been included for routine surveillance testing (see paragraph 10.b).
(0 pen) Open Item (50-298/82-02/04):
Calibration of Off-Gas and Stack Effluent Monitors.
Procedures did not include full scale calibration as recommended in ANSI-N323-1978 (see paragraph ll.b).
5.
Organization and Staff The following chart shows the NPPD Chemistry and Health Physics organization as it existed at the time of this inspection:
~
r Station Superintendent /
L. C. Lessor Ehemistry and Health Physics Supervisor
,
_ _.
J. V. Sayer
-
I
-
r l
Chemist Health Physicist J. Warren j
- R. J. Mcdonald
'
~
r ~d Health Physics Technician
-
l Lead Chemistry Technician '
i Lea
[
G. Ketner L
- _ L._futtler c
_ a
,
Chemistry Technician
-
Health Physics Technician i
D. Snyder
!
J. Hinz M. Wright J. Morris K. Fike S. Pucket I
-
~~ ~
~ - -
T. J. Chard l
P. R. Windham M. Boggs
-.
- Acting Chemistry and Health Physice Supervisor during this inspection.
The inspectors reviewed training and qualifications for the radiochemistry staff.
The licensee has an established training program for radiochemistry personnel.
The inspectors noted radiochemistry staff stability, in that the staff has not changed since the previous radioactive waste systems inspection.
No violations or deviations were identifie r-
.
a
.
,
6.
Radioactive Effluent Releases a.
Liquid The inspectors examined the licensee's liquid effluent releases to determine compliance with the Environmental Technical Specifications (ETS) 2.4.1.b.1 through 2.4.1.b.5 and 3.4.1.b.1 through 3.4.1.b.8.
The following procedures and forms were included in the licensee's liquid radioactive waste program:
' Procedure 8.8.11, " Liquid Radioactive Waste Discharge
-
Authorization"
-
Procedure 8.8.7, " Liquid Waste Discharge Preparation and Analysis" Chemistry Form 8.4.5.1.6-B, " Laboratory Analysis - As required"
-
Chemistry Form 8.4.5.3.4-B, "Radwaste Discharge
-
Composite-Monthly" Chemistry Form 8.4.5.3.4-A, "Radwaste Discharge Dissolved
-
Fission and Activated Gases-Monthly" Procedure 8.8.1.25, " Radiochemistry Analysis Strontium and
-
Yttrium" Chemistry Form 8.4.5.3.5-B, "Radwaste Discharge
-
Composite-Quarterly" The inspectors reviewed selected releases made during 1980 and 1981.
No violations or deviations were identified.
b.
Gaseous The inspectors examined the licensee's gaseous effluent releases to determine compliance with the ETS 2.4.3.a.1 through 2.4.3.a.9.b and 3.4.3.a.1 through 3.4.3.a.8.
The following procedures and forms were included in the licensee's gaseous radioactive waste program:
-
Chemistry Form 8.2.0.0.1-8, " Turbine and Reactor Vent Daily Readings"
-_, _. _ _ _ _
. ~. - _ _, _. _.. _ _
.
.
'
l
.
.
!
Chemistry Form 8.2.0.0.1-A, "ERP and Augmented Daily Readings"
-
Procedure 8.8.8, " Vent Monitors Particulate, Iodine Cartridge,
-
and 100 cc Of f-Gas"
-
Procedure 8.5.2.5, " Gamma Spectrometer (TN-11, GeLi)"
-
Computer Print-out, " Particulate and Iodine Vent Release Summary"
-
Chemistry Form 8.4.12.2.5-A, "Off-Gas and Building Vent-Strontium Composite"
-
Chemistry Form 8.4.12.2.5-8, "Off-Gas and Building Vent-Tritium Composite"
-
Procedure 8.8.1.25, " Radiochemistry Analysis Strontium and Yttrium"
-
Procedure 8.8.1.31, " Radiochemistry of Tritium"
-
Chemistry Form 8.4.12.1.2-A, "Off-Gas Weekly Isotopic Analysis"
-
GeLi System Computer Print-out, "ERP Gaseous Sample"
-
Chemistry Form 8.4.11.1.5, " Alpha Analysis of Vents"
-
Procedure 8.6.2, "(GE) ERP Radiation Monitor and (NMC) Vent Monitor Calibration"
-
Data Forms, " Quarterly Vent Calibrations" The inspection included a review of the licensee's program for verifying that Technical Specification limits were not exceeded.
The inspectors noted that the licensee's program did not include docur.entation that would demonstrate that the limits specified in ETS 2.4.3.a.1 and 2.4.3.a.4.d were not exceeded.
These ETS address the release rate of noble gases and tritium, except for halogens and particulates with half-lives longer than eight days.
ETS 2.4.3.a.1 and 2.4.3.a.4.d specifies the method to be used in calculating the noble gases and tritium release limits.
The inspectors did not identify any gasous releases that exceeded ETS limits.
However, the licensee's did not include periodic documentation that would demonstrate compliance with the ETS.
The licensee stated during the exit interview on January 15, 1982, that their program would be revised to include routine verification of'
t ETS 2.4.3.a.1 and 2.4.3.a.4.d.
This item is considered open pending l
1mplementation of the proposed revision (82-02/01).
!
-
.
The inspectors discussed the interpretation of " monitoring" contained in ETS 2.4.3.a.6.a with the licensee.
ETS 2.4.3.a.6.a states:
"During releases of gaseous wastes through the main stack, the following conditions shall be met:
The gross radioactivity monitor, the iodine activity monitor and particulate activity monitor shall be operating."
The following two systems had been installed on the stack to monitor gasous effluents:
(1) A NMC system that provided real-time data for noble gas (gross radioactivity monitor), iodine, and particulate activity, and (2) a GE system that provides real-time noble gas data along with an iodine sampler cartridge and a particulate sampler filter.
The iodine cartridge and particulate filter are collected and analyzed weekly.
The licensee stated that the NMC iodine monitor had been plagued by spurious alarms due to interference from short half-live noble gases.
As a result, the entire NMC system was taken out of service in August,1980 and presently only functions as a back-up monitor.
The inspectors noted that NUREG-0473, Revision 2, Radiological Effluent Technical Specifications For BWR's, requires:
(1) a noble gas activity monitor for continuous monitoring, and (2) an iodine cartridge and particulate filter which are collected and analyzed weekly.
The inspectors stated that since the licensee's GE monitoring system satisfies NUREG-0473, no additional monitoring requirements were necessary.
No violations or deviations were identified.
7.
Records and Reports of Radioactive Effluents The inspectors reviewed records and reports required by 10 CFR 50.36a.(a)(2)
and ETS 5.4.1.
The inspectors noted that licensee's semi-annual reports conformed to the format recommended in Regulatory Guide 1.21.
No violations or deviations were identified.
8.
Procedures For Controlling Effluent Releases The inspectors examined the licensee's procedures for controlling the release of liquid and gaseous effluent.
.
.
a.
Liquid Procedures require that Chemistry Form Attachment A to Procedure 8.8.11, " Liquid Radioactive Waste Discharge Authorization," be
. completed prior to each batch release.
This form is designed to record such data as:
Radiochemistry Analysis Results
-
- Maximum Allowable Discharge Flow Rate
- Operational Check of Liquid Monitor
- Total Volume Released
- Total Activity Released
- Authorization The licensee's records indicated that liquid radioactive waste releases were made in accordance with applicable procedure and release permit requirements.
No violations or deviations were identified.
b.
Gaseous The licensee's records indicated-that gaseous radioactive waste-releases were in accordance with applicable procedures.
No violations or deviations were identified.
9.
Reactor Coolant Water Quality The inspectors reviewed sampling and analysis results to determine-compliance with Technical Specifications 3.6.B and 4.6.B.
The following procedure and forms were used for the test results:
- Procedure 8.7.1.5, " Test For Boron (Potentiometer Titration)
(Low Range)"
- Chemistry Form 8.4.1.1.1, " Reactor Water - 4 Hour Analysis"
- Chemistry Form 8.4.1.1.4-A, " Isotopic Analysis and Alpha"
- Chemistry Form 8.4.1.1.4-B, " Isotopic Analysis and Boron" No violations or deviations were identifie.
.
10.
Air Cleaning Systems a.
Technical Specification Items (1) Standby Gas Treatment System (SBGT)
Technical Specifications 3.7.B and 4.7.B contain test requirements for the SBGT.
The licensee's records indicated that leak and efficiency tests were performed during March and April 1981.
Test results were recorded on the following Surveillance Requirement (SR) forms:
SR 6.2.1.5.2, "SBGT Auto-Initiation"
-
- SR 6.3.19.1, "SBGT Operability Test"
- SR 6.3.19.2, "SBGT 202 AP and Heater Output Test"
- SR 6.3.19.3, "SBGT-HEPA Filters Efficiency and Leak Test"
- SR 6.3.19.4, "SBGT Charcoal Filter and Fan Capacity Test"
- SR 6.3.19.5, "SBGT Charcoal Filter Carbon Analysis - Methyl Iodine" No violations or deviations were identified.
(2) Control Room
. Technical Specifications 3.12.A and 4.12.A contain test requirements for the control room.
The licensees records indicated that leak and efficiency tests were performed during March 1981.
Test results were recorded on the following SR forms:
- SR 6.3.17.1, " Control Room Ventilation" j
- SR 6.3.17.3, " Control Room Emergency Fan Filter Train P Tests" (
- SR 6.3.17.4, " Control Room Emergency Fan HEPA Filter Leak Tests"
- SR 6.3.17.5, " Control Room Emergency Fan, Charcoal Leak, Charcoal Sampling and Fan Capacity Testing" The inspectors noted that the March 1981 Laboratory Test conditions to establish iodine removal efficiency on the Control Room charcoal adsorbers provided by the licensee's vendor did not agree with the criteria specified in Technical Specification 3.12.A.2.b.
The following table compares some of the Technical Specification requirements versus those used by the vendor:
-
i
.
Technical Specification Vendor
3 Inlet Iodine Concentration 0.05-0.15 mg/m 1.78 mg/m-Relative Humidity
> 95%
94%
Temperature
> 125 F 30 C (87 F)
It should be noted the Tcchnical Specifications required an iodine removal efficiency of > 90% whereas the 1981 test indicated a value
> 99.9%.
On January 13, 1982, the licensee contacted their vendor who in turn provided the reason for furnishing the above_ test results.
Evidently, the vendor had been confused regarding proper test parameters for charcoal samples and requested guidance from Nuclear Regulatory Regulation (NRR), Effluent Treatment Systems Branch (ETSB).
In August 1981, ETSB provided written guidance to the vendor that recommended that the latest industry standards should be used during charcoal adsorber testing.
ETSB referenced ANSI N509-1980, Nuclear Power Plant Air Cleaning Units and Components and ASTM D 3803-1979, Standard Test Methods for Radioiodine Testing of Nuclear Grade Gas Phase Adsorbents.
ANSI N 509-1980 and ASTM D3853 recommend test conditions of 30"C and 70% relative humidity.
However, the licensee's Technical Specifications were based on Regulatory Guide 1.52 and ANSI-N509-1976.
The above matter was discussed with NRR.
Since confusion existed regarding which' test procedures should be used, the decision was made not to issue a violation against Technical Specification 3.12.A.2.b.
This information was provided via telephone to the licensee on January 25, 1982 at which time the licensee stated that.
Technical Specifications 3.7.B, 4.7.B, 3.12. A and 4.12. A would be amended to included the latest industry standards.
This item is considered open pending implementation of the proposed amendment (82-02/02).
No violations or deviations were identified.
o
.-.-
.
-
.
.
b.
Non-Technical Specification Filer System Discussions with the licensee revealed that the following filter systems were not_ included as part of a routine surveillance test program:
Radwaste Building
.
Augmented off gas system
.
Reactor Building (Reactor Cleanup phase Separator)
.
Of f-Gas Delay Line
.
Operational Support Center (I&C Area)
.
Technical Support. Center
.
The licensee stated during the exit interview on January 15, 1982, that testing requirements for the above systems would be evaluated in order to satisfy the recommendations of Regulatory Guide 1.52 and 1.140 and latest industry standards.
This item is considered open pending further review (82-02/03).
No violations or deviations were identified.
11.
Effluent Control Instrumentation a.
Liquid ETS 2.4.1.3.a, 2.4.1.3.b, 3.4.1.b.7, 3.4.1.b.8, and Table 4.2.0 contain requirements for radioactive liquid effluent monitoring systems.
The following systems monitor radioactive liquid effluents:
i Monitor Identification Liquid Waste Monitor RMP-RM-1 Service Water Monitor RMP-RM-351 Reactor Cooling Water RMP-RM-352 Functional tests and calibration results were recorded on the following SR and radiochemistry calibration forms:
~ '
"~ ~ ^ ' - '
.
i
-
.
.
.
-
SR 6.2.4.1, " Daily Surveillance Log"
-
SR 6.3.7.4, " Service Water and Reactor Cooling Water Monitor Calibration and Functional Tests" SR 6.3.7.7, " Liquid Radwaste System Calibration / Functional Tests" Form 8.4.5.1.6-C, Radwaste Discharge Monitor Efficiency Calculation Form 8.4.5.3.5-A, Radwaste Discharge Monitor Laboratory Analysis --
Quarterly Calibration Form 8.4.2.5, REC Monitor Calibration - Laboratory Analysis No violations or deviations were identified.
b.
Gaseous ETS 2.4.3.a.5, 2.4.3.a.6.a, 2.4.3.a.6.b, 2.4.3.a.7, 3.4.3.a.8, 3.4.3.a.9, and Table 4.2.0 contain requirements for_ radioactive gaseous monitor radioactive gaseous effluent releases:
Monitor Identification
- Elevated Release Point (ERP) (GE)
RMP-RM-50A and 50B ERP (NMC)
RMP-RM-2A, 28, and 2C-(Out of service since August 1980)
!
- Off-Gas RMP-RM-150A and 1508
- Radwaste Building RMV-FIS-6A and 6B
- Augmented Radwaste Building RMV-RM-9A, 9B and 9C Control Room RMV-RM-1A, 1B and 1C
'
-
- Turbine Building RMV-RM-5A, SB and SC
- Reactor Building Vent (GM)
RMP-RM-452A and 4528
- Reactor Building Vent (NMC)
RMV-RM-3A, 3B and 3C
,
Test and calibration results were recorded on the following SR and radiochemistry calibration' forms:
l
'
,
i
,
--,-,., -,
-
. -.--
-r_-..m
, -,
e
.,
.,,,,,
c
.,,, +,
e.
.. ~ -
-... _,.
-,,~
... - -,
- ~ -
.
.
.
- SR 6.2.4.1, " Daily Surveillance Log" SR 6.2.6.1, "Off-Gas System Auto Isolation Test"
-
SR 6.3.7.1, "ERP (GE) Calibration and Functional Test"
-
- SR 6.3.7.2, "Off-Gas Monitor Calibration and Functional Test"
- SR 6.3.7.5, " Reactor Building Vent Calibration and Functional Test"
- SR 6.3.7.8, "ERP (NMC) Calibration and Functional Test"
- SR 6.4.6.1, " Reactor Building (NMC) Calibration and Functional Test" SR 6.4.6.2, "Radwaste Building Monitor Calibration and Functional
-
Test"
- SR 6.4.6.3, " Control Building Monitor Calibration and Functional Test"
- SR 6.4.6.4, " Turbine Building Monitor Calibration and Functional Test"
- SR 6.4.6.5, " Augmented Radwaste Monitor Calibration and Functional Test" Form 8.5.11.1.5-A, NMC Vent Quarterly Calibration TG Bldg-Particulate Form 8.5.11.1.5.B, NMC Vent Quarterly Calibration TG-Bldg-Gas Form 8.5.11.1.5-C, NMC Vent Quarterly Calibration TG-Blda-Gas Form 8.5.11.2.5-A, NMC Vent Quarterly Calibration Rx Building-Particulate Form 8.5.11.2.5-B, NMC Vent Quarterly Calibration Rx Building-Iodine-Form 8.5.11.2.5-C, NMC Vent Quarterly Calibration Rx Building-Gas Form 8.5.11.8.5-A, NMC Vent Quarterly Calibration Augmented Radwaste -
Particulate Form 8.5.11.8.5-B, NMC Vent Quartelrly Calibration Augmented Radwaste -
Iodine-i Form 8.5.11.8.5-C, NMC Vent Quarterly Calibration Augmented Radwaste-Gas
.
Form 8.5.11.6.5-A, NMC Vent Quarterly Calibration Control Room -
Particulate
!
!
!
I l
l I
,
.
--
.
.
.
.
.
i
Form 8.5.11.6.5-B, NMC Vent Quarterly Calibration Control Rocm Iodine Form 8.5.11.6.5-C, NMC Vent Quarterly Calibration Control Room -
Gas Form 8.5.12.3.5-A, NMC Vent Quarterly Calibration ERP-Particulate Form 8.5.12.3.5-C, NMC Vent Quarterly Calibration-Gas Form 8.4.12.1.5, SJAE OFF-Gas Calibration Form 8.4.12.3.5, ERP Vent Pipe Monitor The inspectors noted that the off-gas monitors and stack noble gas monitors (GE system) were not tested over the full range of the instruments. The off-gas monitors (RMP-RM-150A and 150B have a full scale read-outs of about 1-E+06 mr/hr.
Surveillance Requirement 6.3.7.2., Off-Gas Radiation Monitor Functional Test, and Form 8.4.12.1.5, SJAE Off-Gas Calibration, indicated that the maximum calibration reference point was about 100 mr/hr.
The GE noble gas monitors (RMP-RM-50A and 50B) have full scale read-outs of about 0.1-E+06 counts per minute (CPS). Surveillance Requirement 6.3.7.1, ERP Process Radiation Monitor (GE) Calibration Functional Test and Form 8.4.12.35, ERP Vent Pipe Monitor, showed a maximum calibration point of about 1.2E+04 cps.
The above data indicate that calibration / response test reference points were less than 10% of the full scale read-out.
ANSI-N323-1978, Radiation Protection Instrumentation Test and Calibration recommends that radiation detection instrumentation be calibrated at approximately 20% and 80% of full scale.
The licensee stated during the exit interview on January 15, 1982, that their calibration program would be evaluated in order to consider the recommendations of ANSI-N323-1978. This item is considered open pending further review (82-02/04).
No violations or deviations were identified.
.
!
!,
___.
_
_
. _ -
,
- .
.
.
.
12.
Plant Tour The inspectors toured the plant on January 12, 1982.
Special attention was given to radwaste activities and effluent monitors.
The inspectors visited each detector / sampler location for those monitors identified in paragraphs 11.a and 11.6 and observed their associated read-out instrumentation in the control room.
The inspectors verified that, except for the NMC stack monitor (see paragraph 6.b), the monitors and recorders were in service and operating.
No violations or deviations were identified.
13.
Analytical Measurements a.
Equipment Operation and cai,;iation Procedures The inspectors reviewed the licensee's procedures covering operation and calibration of the various laboratory counting equipment.
Specifically, the following procedures were reviewed:
- Chemistry 8.2.1, " Chemistry Analysis and Instrument Calibration Schedule
- Chemistry 8.2.2, " Process Sample System"
- Chemistry 8.5.2.1, " Gamma Spectrometer"
- Chemistry 8.5.2.2, " Wide Beta II Chemistry 8.5.2.3, " Liquid Scintillation System"
-
- Chemistry 8.5.2.4, "Well Counter"
- Chemistry 8.5.2.5, " Gamma Spectrometer (TN-11) GeLi" Chemistry 8.3, "Contro1~ Parameters and Limits"
-
Chemistry 8.4, " Routine Sampling Procedures"
-
The above procedures require that each piece of equipment be calibrated at least annually and reference checked daily and/or prior to use.
The licensee stated that a problem existed during the summer with heat and the GeLi system; however an investigation is underway to resolve this problem prior to next summer.
No violations or deviations were identified.
b.
Quality Control (QC) Program For Laboratory Counting Equipment
,
i The following procedures outline the QC Program associated with the laboratory counting equipment:
,
i i
e
.
-
.,
- Chemistry 8.1, " General Laboratory Instructions"
- Chemistry 8.2.1, " Chemistry Analysis and Instrument Calibration Schedule" Chemistry 8.2.2, " Process System System"
-
- Chemistry 8.2.4, " Split and Spiked Sampling"
- Chemistry 8.3, " Control Parameters and Limits"
- Chemistry 8.4, " Routine Sampling Procedures" Po violations or deviations were identified.
14.
Audits The inspectors examined reports of audits performed by the licensee.
The licensees records indicated that audits of radiochemistry activities were performed June 2, 1980 and June 22, 1981.
The licensee's records identified several minor discrepancies which were corrected in a timely manner.
No violations or deviations regarding the licensee's audit program were identified.
15.
Licensee Event Re, torts (LERs) and Nonconformance Reports (NCRs)
The inspectors examined the licensee's follow-up action regarding applicable LERs and NCRs for the period covered by this inspection.
The inspectors considered the licensee's corrective action to be adequate to close these LERs and NCRs.
16.
Exit Interview The inspectors met with the NPPD representative denoted in paragraph 1 at the conclusion of the inspection on January 15, 1982.
The inspectors discussed the purpose and scope of the inspection, and discussed the findings. See paragraphs 6.b, 10.a.(2), 10.b and 11.b for the licensee's position regarding four open items.