IR 05000317/1980015
| ML19340E745 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 11/05/1980 |
| From: | Architzel R, Callahan C, Mccabe E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19340E740 | List: |
| References | |
| 50-317-80-15, 50-318-80-14, NUDOCS 8101150573 | |
| Download: ML19340E745 (13) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I 50-317/80-15 Report No.
50-318/80-14 50-317 Docket No.
50-318 DPR-53 C
License No.
DPR-69 Priority
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Category C
Licensee:
Baltimore Gas and Electric Company P.O. Box 1475 Baltimore, Maryland 21203 Facility Name:
Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Inspection at:
Lusby, Maryland Inspection conducted: September 1-29, 1980 Oiv lo 2-1 PC Inspectors:
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R. E. Architzel, Senior Res:1 dent Reactor Inspector /date sig ed
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YN C.J.Callahan,ResidentRgctorInspector-date signed date signed Approved by:
84 LDA k isIrlto E. G. McCabe, M.,
Chief, Meactor Projects cate signed Section No. 2, RO&NS Branch Inspection Summary:
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Inspection on September 1-29, 1980 (Combined Report Nos. 50-317/80-15 and 50-318/80-14)
Areas Insaected:
Routine, onsite regular and backshift inspection by the resident inspec-l l
tors (401ours, Unit 1; 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />, Unit 2). Areas inspected included the control room and the accessible portions of the auxiliary, turbine, service, and intake buildings; radia-tion protection; physical security; fire protection; plant operating records; maintenance activities; Offsite Safety Review Committee Activities, receipt of new fuel, emergency drill (September 16), Unit _1 Spent Fuel Pool modifications, and reporting to the NRC.
Noncompliances:
None in 9 areas, one in one area (Infraction - Failure to adequately inspect Unit-1 Spent Fuel Rack Installation - paragraph 10).
l Region I Form 12 (Rev. April 77)
8.1011so 6 7 3
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DETAILS 1.
Persons Contacted The following technical and supervisory level personnel were contacted:
A. Anuje, Engineer, Quality Assurance Department E. Bauer, Supervisor, Modifications and Computer G. Brobst, Acting General Supervisor, Chemistry J. Carroll, General Supervisor, Operations R. Denton, General Supervisor, Training and Technical Services R. Douglass, Manager, Quality Assurance C. Dunkerly, Shift Supervisor J. Gilbert, Shift Supervisor
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J. Hill, Shift Supervisor G. Hatfield, Engineer, Catalytic K. Key, Engineer, NED J. Lohr, Shift Supervisor J. Mihalcik, Senior Engineer, Nuclear Fuel Management N. Millis, General Supervisor, Radiation Safety J. Rivera, Shift Supervisor E. Reimer, Plant Health Physicist P. Rizzo, Senior Technical Specialist M. Roberson, Superintendent, Maintenance Modifications L. Russell, Plant Superintendent D. Zyriek, Shift Supervisor
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Other licensee employees were also contacted.
2.
Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (318/80-06-01):
Examine Breaker Indicating Light Status.
The licensee has examined this area and added Preventive Mainte-nance Cards to relamp switchgear semi-annually.
The inspector reviewed the following P.M.s, approved on September 23, 1980 which implement these checks:
Unit 1 Unit 2 1-3-E-S A-1 2-3-E-SA-1 1-4-E-S A-1 2-4-E-SA-1 1-5-E-SA-1 2-5-E-SA-1 1-6- E-S A-1 2-6-E-SA-1 (Closed) Noncompliance (317/80-04-02; 318/80-04-02):
Documentation of Training of Security Force Supervisors.
The inspector reviewed the licensee's actions stated in the fiay 30, 1980 response to this item.
This included the records management system to track personnel training status, Training and Qualification Status Records, and course certifica-tions to document requalification training given to Security Force Super-visors between April 15 - August 1,1980.
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(0 pen) Unresolved Item (317/80-14-01; 318/80-13-01) Main Vent Flow Rate Recorders.
During a previous inspection the licensee stated that Main Vent Flow was conservatively inputed to release calculations.
During this inspection the inspector observed Main Vent Flow rates (SCFM).
Unit 1 Unit 2 Observed 129,000 116,800 Used 131,500 107,500 The Unit 2 value being used was non-conservative in that the calculational methods assumed a lower flow rate than actual.
The licensee took action to change the computer software and procedural values for the Unit 2 flow rate.
This item remains open pending inspection of TMI-2 Short Term Les-sons Learned system improvements as required.
3.
Review of Plant Operations a.
Plant Tour At various times during the inspection the inspector made tours of the facility.
These included the Control Room, Auxiliary Building (all levels, no High Radiation Areas), Turbine Building, Outside Peripheral Area, Security Buildings, Health Physics Control Point's, Diesel Generator Rooms, Service Building and Intake Structure.
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The following observations and determinations were made:
Radiation controls established by the licensee, including post-
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ing of radiation areas, conditions of step-off pads and disposal of protective clothing were observed.
Control Room manning was observed on several occasions during
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the inspection, including observation of shift turnover and panel walkdowns.
Systems and equipment in all areas toured were observed for
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the existence of fluid leaks and abnormal piping vibrations.
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Seismic restraints and hydraulic snubbers were examined on a sampling basis to verify adequate installation and fluid levels.
Plant housekeeping conditions, including general cleanliness
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conditions and storage of materials and components to preclude
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safety and fire hazards, were observed.
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Control Rocm and local monitoring instrumentation for various components and parameters were observed, including reactor power level, CEA positions and safety related valve position indication.
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Whether proper access controls were established.
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No unacceptable conditions were identified.
b.
Review of Operating Logs, Records A review of logs and records was made to identify significant changes and trends, to assure required entries were being mace, to verify Operating Orders conform to the Technical Specifications, to verify proper identification of abnormal conditions, and to verify conformance to r? porting requirements and Limiting Conditions for Operation.
The following records were reviewed for the report period:
Shift Supervisors Log
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Unit 1 Control Room Operators Log
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Unit 2 Control Room Operators Log Nuclear Plant Engineer - Operations Notes and Instructions
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Unit 1 and 2's Control Room Daily Operating Logs (sampling review)
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Service Building Operators Log (sampling review)
Radcon Smooth Log (sampling review)
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No unacceptable conditions were identified.
4.
Plant Maintenance During the inspection period, the inspector observed various maintenance and problem investigation activities.
The inspector reviewed these activi-ties to verify compliance with regulatory requirements, including those stated in the Technical Specifications; compliance with applicable codes and standards; required QA/QC involvement; proper use of safety tags; proper equipment alignment and use of jumpers; personnel qualifications; radiological controls for worker protection; fire protection; retest require-ments and ascertain reportability as required by Technical Specifications.
l The following activities were included during this review:
MR E-80-133, 9/22/80, Inspect Leads for 11,12, and 21 Emergency Diesel
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Generators (EDGs)
MR E-80-137, 9/23/80, Remove Portion of Counterbalance Touching Col-
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MR IC-80-2100, 9/24/80, Unit 2 ESFAS-Containment Isolation, System
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Trip The licensee initiated the maintenance actions associated with the EDGs based upon the request (September 20,1980) of the NRC's Operation Center.
A procedure for this inspection was provided in a telephone conversation.
A problem with field rotor leads in Diesel Generators had been reported i
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S to the NRC by the manufacturer (Fairbanks Morse).
The problem consisted of leads being frayed by the sharp ends of a clamp holding down the heads from the collector ring to the exciter.
Also, a rotor fan had been discovered bearing down on the leads on another unit.
The inspector observed a por-tion of the work on EDG-12, and reviewed photograph or work performed to remove a small portion (an about 1/2" triangle) of a counterbalance touch-ing one of the leads.
The Calvert Cliffs EDG's did not have fans which could bear on the leads and no evidence of fraying or wear surrounding the calmp for such leads was identified.
5.
Off Site Safety Review Committee (OSSRC)
The inspector reviewed the following activities of the OSSRC to verify that they were conducted in accordance with Technical Specifications and other regulatory requirements.
The OSSRC charter, revision a was reviewed.
The charter had recently
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been revised (September 12, 1980, OSSRC Meeting 80-10) to conform to organization changes delineated in license amendments Nos. 43 (DPR-43 and 26 (DPR-69).
The charter was consistent with T. S. requirements.
Group membership and qualifications as required by T.S.
The inspec-
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tor reviewed the membership roster dated September 11, 1980 and pre-vious roster dated August 28, 1980, both approved by the Vice-President-Supply. Alternates to these members were nominated during OSSRC Meeting 80-10 (September 12,1980), subject to appointment by te Vice President, Supply.
The inspector reviewed the existing alter-nate appointment letter dated October 30, 1979.
With respect to i
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qualifications, the inspector noted that the recent license amendments deleted membership by job title, and required technical experience (minimum 5 years) in one or more of the areas given T.S. 6.5.2.1.
The inspector reviewed a draft OSSRC " Competence Matrix" demonstrating the background of each member.
In addition, the -licensee stated that mem-ber resume were in the process of being updated.
The inspector stated that this area (Issuance of Competence Matrix and revising OSSRC l
resumees) would be followed by the NRC (317/80-15-01; 318/80-14-01).
The inspector noted that OSSRC meetings were convened at the frequency
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required by the T.S. and that quorum requirements were satisfied.
Minutes of the following meetins were reviewed in making this observation:
OSSRC Meeting No.
Date 80-09 8/1/80 l
80- 08 7/8/80
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90-07 6/26/80 l
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OSSRC Meeting No.
Date 80-06 6/20/80 80-05 5/29/80 80-04 2/8/80 80-03 1/22/80 80-02 1/13/80 80-01 1/8/80 79-14 11/29/79 The inspector noted that the following items were reviewed by
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the OSSRC (Meeting No. in parens).
a.
Safety-Analysis for the following Facility Changes by FCR Number (80-05) 79-1078, 79-10, 79-12, 79-1004 (80-07)
80-3002, 3, 4, and 5 (80-04) 80-3000 (80-02) 80-1000 (80-01)
79-3001 b.
Proposed Technical Specification Changes by FCR Number (80-05) 80-44, 80-48, (80-09) 80-72 (80-06) 80-1023 (80-03)79-125, 79-130,79-148, 79-88, 79-1037,79-109, 79-1044.
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Plant Operations and Safety Review Committee Meetings (PCSRC)
(80-05) POSRC Meetings Nos.79-169 through 80-74.
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24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> written reports (80-05) Unit 1 LER's 79-75, 80-02, 80-07, 80-10, 80-21.
The inspector noted that the OSSRC performs the majority of T.S. review functions semi-annually (T.S. minimum frequency).
This review is performed by delegating presentations to members in agendas published prior to the regularly scheduled meetings.
OSSRC also holds special meetings for items requiring immediate review.)
l The inspector questioned the licensee concerning implementation of the i
requirement for the OSSRC to review the safety evaluation for changes to l
procedures which are summarized or delineated in the FSAR.
The licensee stated that this area would be evaluated.
This item is unresolved (317/
80-15-02; 318/80-14-02) pending completion of the evaluation and reinspec-tion by the NRC.
6.
Review of Events Requiring One Hour Notification of the NRC
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The circumstances surrounding the following events requiring prompt (one hour) notification of the NRC via the dedicated telephone (ENS) were-t reviewed.
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On September 12, 1980 a contractor employee injured his hip in a
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fall from a ladder in the Cable Spreading Room.
He was taken to Calvert Memorial Hospital by ambulance.
Radioactive materials were not involved.
At 1:28 p.m. on September 10, 1980 the stop valves in the containment
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sump (Unit 2) gravity drain line were found open.
A containment pres-
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sure drop of about 0.05 psi (one fourth of a scale division) was noted.
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The stop valves, which receive an auto-shut Containment Isolation Signal, are routinely opened to drain the sump.
Frequency of drain-ing is used as an indicator of plant leakage.
In this case the valves apparently were left open less than 30 minutes.
The drains vent to the ECCS pump room, which had no ventilation system operating. Air samples taken in the pump room showed 1.5 E-8 uCi/ml, with less than 0.1 MPC particulate and 0.3 MPC iodine. A trash cleaner had been in the pump room for about 10 minutes during the event.
His TLD was read
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later in the day and showed 13 mrem for the quarter.
No area or stack monitor increases were detected during the event or when ECCS Pump Room ventilation was placed in operation about one hour later.
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ESFAS Actuation. A Containment Isolation Signal (CIS) was inadvertently
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initiated on Unit 2 about 11 a.m., September 24th, when an Instrument Technician accidently tripped a CIS Module.
During this time, trouble-shooting was in progress to determine the cause of a previous trip on all four ESFAS CIS channels.
The second trip (2 of 4 logic) initiated containment isolation contain-ment pressure was normal (less than 1.5 psig) although CIS initiates at 4 psig.
The trip was immediately reset and had no effect on plant operations.
The inspector expressed concern to the licensee regarding the repeti-tive nature of this type of event and the human engineering aspect of the adjacent trip and reset buttons.
The licensee acknowledged the inspector's comments and further stated that this area had also been identified during a Human Factor's Engineering Study which recently had been conducted at Calvert Cliffs.
The licensee stated that color coding was among the possible corrective actions being considered.
The cause of the single channel trips was later found to be a grounded lead from CIS trip (containment pressure) nodule ZF to (common line)
the isolation ampl.ifiers which feed the CIS Al and B1 Actuation Logics.
The lead was repaired, and the CIS system was returned to normal on September 26, 1980.
A contractor security guard who became ill on duty about 10 a.m. on
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September 1 was transported to Calvert Memorial Hospital by ambulance.
Radioactivity was not involved.
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At 6:45 a.m., September 5, the licensee discovered that physical inter-
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locks had not been installed to prevent moving the new Spent Fuel racks over the fuel assemblies in the Unit 2 pool.
The Technical Specifica-tion require these interlocks to be in place prior to moving a Spent Fuel Shipping cask (approximately 20 tons) to prevent motion within one cask length of a fuel assembly.
The licensee concluded that this failure did not violate the T.S. intent because the individual Fuel Racks weigh less (14 tons) than a cask and impact loads would be much less because of the large surface area of the racks compared to a fel cask. Motion of loads greater than 1600 lbs. over fuel assemblies is prohibited by the T.S., however, no actual travel of Fuel Racks over fuel was made.
This event was in violation of the licensee's crane operations procedure and the licensee stated that a review would be made by the POSRC.
The inspector stated that completion of the review and actions taken to prevent recurrence would be followed (317/80-15-03) by the NRC.
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7.
IE Bulletin Followup
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The inspector reviewed licensee actions taken in response to the following IE Bulletins (IEBs) in order to determine that the written response was submitted within the required time period, that the re:ponse included the information required including adequate corrective action commitments, and that licensee management had forwarded copies of the response to respon-sible onsite management.
The review included discussions with licensee personnel and observations and review of items discussed below.
80-11, Masonary Wall Design.
The' September 23, 1980 supplement response
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to this Bulletin was reviewed that three stacked shield block walls, constructed without mortar or reinformcement, in close proximity to safety-related equipment.
The walls were removed.
The inspector dis-cussed this issued with the licensee and stated that, in addition to
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the Bulletin response, a Licensee Event Report (LER) should be sub-
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mitted concerning this event.
The licensee further stated that action would be taken to clarify reporting requirements within the Nuclear Engineering Department.
This area is unresolved pending submission of the LER and NRC review of the licensee's action (317/80-15-03; 318/80-14-03).
8.
Receipt of New Fuel The inspector observed fuel receipt inspections being performed for new fuel assemblies 16118, 16001, and 16120.
The inspector noted that these inspections were being perfonned in accordance with Fuel Handling Proce-dure FH-1, Revision 15, dated August 13, 1980, which was available at the l
job location.
Receipt inspectors were verified to have been certified by review of Level I Visual Examination Quizzes Fuel /CEA Handling and Inspec-tion Supervisor and Inspector Quizzes and documentation of satisfactory performance of a practical test.
No unacceptable conditions were identified.
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Emergency Drill
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On September 15 the inspector attended a planning session for the September 16 General Emergency Drill.
The drill, which involved plant personnel from the Emergency Control Center (ECC), provided a scenario, communications and field data to the State of Maryland and local govern-ments of Calvert, St. Mary's and Dorchester counties.
The inspector observed various portions of the drill from the ECC.
He also made selected observations and held discussions with Maryland State Police and Maryland Department of Health and Mental Hygene, Division of Radiation Control (DRC) personnel who were in various field positions in Calvert Count to simulate evacuation and record environmental measurements.
No unacceptable conditions were identified.
10.
Spent Fuel Pool Modtfications for New Spent Fuel Storage Racks a.
References The inspector reviewed documentation and observed work involving the receipt, handling, installation, checking, and testing of the new Spent Fuel Storage Racks.
The following documents were reviewed.
SWP-80-479-C, dated September 3, 1980, Radiological Working
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Condition Requirements to Lay Out and Repair Spent Fuel Pool BG&E letter to NRC dated January 15, 1980, CCNPP Units Nos.1
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& 2 Spent Fuel Pool Modification Supplementary Information BG&E letter to NRR dated May 20, 1980, CCNPP Units Nos.1 and 2
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Spent Fuel Pool Modification BG&E letter to NRR dated July 7,1980, CCNPP Units Nos.1 and 2,
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Spent Fuel Pool Modification Licensing Submittal Report for CCNPP, Unit 1 High Density Spent
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Fuel Pool Storage Racks, NES Document 81A0564, Revision 1, dated 5/24/79 Nuclear Design Analysis Report for CCNPP, Unit 1, High Density
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Spent Fuel Storage Racks, NES Document 81A0567, Revision 2, dated 3/1/79 Procedure Specification ENG-PPS-2432, Handling, Packaging and
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Shipping of Nuclear Fuel Storage Racks, Metal Products Corpora-tion, dated February 14, 1980
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Procedure for the Installation of Calvert Cliffs Unit No.1 High
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Density Fuel Storage Racks, NES Document 80A2742, Revision'1 dated 7/10/80 BG&E Purchase Order 33203-GX dated 7/12/78, Change 1 dated 4/3/79,
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Change 2 dated 7/12/79, Change 3 dated 8/14/80, Spent Fuel Racks Specification Number SP-267, High Density Fuel Racks for Unit 1
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dated 1/26/78 QAP-2, Initiating Purchases and Controlling Spare Parts, Revi-
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sion 39, dated 7/2/80, Section 19, Receipt and Storage of Safety Related Items Maintenance Request M-80-7404 Installation of Unit No.1 Spent
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Fuel Storage Racks, dated 8/25/80 Facility Change Request 77-1022, Urit No.1 Spent Fuel Storage
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Racks SWP 80-580, Boron Verification of Spent Fuel Racks, dated
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9/18/80
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Inspection Scope Using the procedures and documents listed above, the inspector per-
formed a sampling review of documentation adequacy and work performance.
Receipt inspection on rack NES-2 was observed.
The inspector noted that a sampling verification of the internal composition of the racks was not planned.
The licensee :tated that such a verification would be performed and the inspector reviewed results of this verification for racks NES-1 and 2.
During installation the inspector verified work procedures provided adequate instructions for the following:
Qualified and Controlled Field welding and NDE procedures and
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personnel Control of rigging and handling to prevent damage to new racks
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and existing structures Proper location
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Dimensional checks for levelness, alignment, clearances Final clearance check using dummy fuel element (drag test)
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The inspector visually examined the new spent fuel storage racks on a sampling basis to verify requirements were met in the following a reas.
Cleanliness
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Configuration of the racks relative to the assembly drawings
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Obvious defects such as cracks, dents and missing parts
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Identification
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The following items were observed during installation.
Proper location and orientation
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No apparent damage to the racks or pool during installation
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Ongoing work being performed in accordance with approved
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procedures Adequate QC inspection coverage
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c.
Findings Following completion of alignment of the free standing racks
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in the pool and during the leveling checks the inspector observed work in progress and made independent measurements of spacing dimensions. The licensing documents stated that the racks would be spaced a minimum of one inch from the pool walls and two inches from each other.
The inspector measured a minimum spacing of 113/16 inches between racks 1 and 2 and 15/8" between racks 2 and 3.
In addition, racks 4 and 5 could not be completely installed because a wheel had broken on the handling rig.
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licensee had measured the spacing at d;screte points between the racks.
Upon notification by the inspector, the licensee remea-sured the racks and concurred with the inspector's findings.
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licensee also discovered that the drawing being used for installa-
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ton verification NES Drawing 80E2754, Fuel Storage Rack Installa-tion in Pool, was the wrong revision (Revision 2 effective Revi-sion 1 in use). The location of a banding strap was changed in Revision 2 and this was one location where the racks were less than two inches apart.
The licensee reviewed the effect of the closer spacing and decided that the racks would be reinstalled with the specified spacing.
In the interim, the licensee stated that the racks would not be used to store fuel.
Failure to install the Spent Fuel Racks within the dimensions specified in the license application and drawings is an item of noncompli-ance(317/80-15-04).
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During a Quality Assurance Audit of a vendor (Metal Products) an
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auditor examined welds in an assembly being scrapped for other reasons. As a result of this audit the licensee informed the SRI on September 26, 1980 that the spent fuel racks were discovered to have lack of fusion in particular spot welds.
The area involved was in vertical rows which hold poison material in a wafer manner between stainless steel (304L) sheets around the outside of 2x2 sub-assemblies.
Four rows are present on a side, and only one row was apparently defective.
This row contains a double layer of stainless steel on the inside sheet.
Of the 66 welds examined 5 were good.
All these were repair welds due to burn holes in the original weld.
The designer (NES is evaluat-ing the structural integrity of the racks assuming only 3 vertical rows of welds in the sub-assemblies.
The licensee stated that a Part 21 report will be made if a substantial safety hazard is found to exist.
This item (317/80-15-05) will be followed by the NRC.
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11.
Review of Licensee Event Reports (LER's)
The inspector reviewed LER's submitted to the NRC:RI office to verify that the details of the events were clearly reportad, including the accuracy of the description of cause and adequacy of corrective action.
The inspector determined whether further information was required from the licensee, whether generic implications were indicated, and whether the event war-ranted onsite followup.
The following LER's were reviewed:
LER (Unit No.)
Dated Subject 80-022/01X(1)
9/22/80 Safety Analysis for Boron Dilution Incident During Hot Leg Drain.
Revision 1 changes new minimum shutdown margin to 1.5% reflecting results of current safety analysis
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i 80-039/03L(2)
9/29/80 Channel C High Pressurizer Pressure Trip Setpoint zero shifted high
- 80-046/03L(1)
9/16/80 Containment Radiation Monitoring System Out of Service for 15 Minutes 80-045/03L(1)
9/20/80 Plant Computer Out of Service
- 80-044/03L(1)
8/20/80 Containment Sump RCS Leakage Detection System Out of Service
- Denotes reports selected for onsite followup.
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LER (Unit No.)
Dated Subject 80-042/03L(1)
9/06/80 ESFAS Channel ZE Deenergized for Correc-tive Maintenance
- 80-041/01T(1)
8/13/80 Service Water System Degraded Due to Air Ingress
- 80-037/03L(2)
9/26/80 Containment Sump RCS Leakage Detection System Out of Service b.
For the LER's selected for onsite review (denoted by asterisks above),
the inspector verified that appropriate corrective action was taken or responsibility assigned and that continued operation of the facility was conducted in accordance with Technical Specifications and did not constitute an unreviewed safety question as defined in 10 CFR 50.59.
Report accuracy, compliance with current reporting requirements and applicability to other site systems and components were also reviewed.
No unacceptable conditions were identified.
12.
Review of Periodic and Special Reports Upon receipt, periodic and special reports submitted by the licensee pur-suant to Technical Specification 6.9.1 and 6.9.2 were reviewed by the inspector.
This review included the following considerations: The report includes the infonnation required to be reported by NRC requirements; test results and/or supporting information are consistent with design predic-tions and performance specifications; planned corrective action is adequate for resolution of identified problems; determination whether any information in the report should be c.lassified as an abnornal occurrence; and the validity of reported informatiori. Within the scope of the above, the following periodic reports were reviewed by the inspector:
August,1980 Operations Status Reports for Calvert Cliffs No.1 Unit
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and Calvert Cliffs No. 2 Unit, dated September 15, 1980.
13.
Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable, items of noncompliance or deviations.
Unresolved items addressed during this inspection are discussed in Para-graph 5 of this report.
14.
Exit Interview Meetings were held with senior facility management periodically during the course of this inspection to discuss the inspection scope and findings.
A summary of inspection findings was also provided to the licensee at the conclusion of the report period.
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