IR 05000321/2021003

Integrated Inspection Report 05000321/2021003 and 05000366/2021003

ML21292A342
Person / Time
Site:	Hatch
Issue date:	10/19/2021
From:	Alan Blamey Division Reactor Projects II
To:	Gayheart C Southern Nuclear Operating Co
References
IR 2021003
Download: ML21292A342 (19)

Text

October 19, 2021

SUBJECT:

EDWIN I. HATCH NUCLEAR PLANT - INTEGRATED INSPECTION R EPORT 05000321/2021003 AND 05000366/2021003

Dear Ms. Gayheart:

On September 30, 2021, the U.S. Nuclear Regulatory Commission ( NRC) completed an inspection at Edwin I. Hatch Nuclear Plant. On October 19, 202 1, the NRC inspectors discussed the results of this inspection with Sonny Dean and ot her members of your staff. The results of this inspection are documented in the enclosed repor t.

One finding of very low safety significance (Green) is document ed 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.

If you contest the violation or the significance or severity of the violation 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 Reg ulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies t o the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Edwin I. Hatch Nuclear Plant.

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,

/RA/

Alan J. Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects

Docket Nos. 05000321 and 05000366 License Nos. DPR-57 and NPF-5

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000321 and 05000366

License Numbers: DPR-57 and NPF-5

Report Numbers: 05000321/2021003 and 05000366/2021003

Licensee: Southern Nuclear Operating Company, Inc.

Facility: Edwin I. Hatch Nuclear Plant

Location: Baxley, GA

Inspection Dates: July 01, 2021 to September 30, 2021

Inspectors: J. Hickman, Resident Inspector R. Smith, Senior Resident Inspector

Approved By: Alan J. Blamey, Chief Reactor Projects Branch 2 Division of Reactor Projects

Enclosure SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitori ng the licensees performance by conducting an integrated inspection at Edwin I. Hatch Nuclear Plant, in accordance with the Reactor Oversight Process. The Reactor Ove rsight 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.

List of Findings and Violations

Inoperability of 2D Residual Heat Removal (RHR) Pump Due to Ina dequate Maintenance Procedural Instructions for Recoupling Pump and Motor Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71152 Systems NCV 05000366/2021003-01 Open/Closed A self-revealing Green non-cited violation of Unit 2 Technical Specification (TS) 5.4.1(a) was identified for the licensees failure to incorporate adequate m aintenance procedural instructions for the recoupling of the residual heat removal (R HR) pump and motor as recommended by Regulatory Guide (RG) 1.33, section 9.a. Specif ically, procedure 52PM-E11-003-2, RHR Pump and Motor Maintenance, Version 9.4 did no t contain instructions to verify the tightness of the motor coupling nut set screws in 2D RHR pump to prevent the pump shaft downward movement within the pump, thus causing pump fail ure and pump inoperability.

Additional Tracking Items

None.

PLANT STATUS

Unit 1 began the inspection period completing a shutdown that w as started on June 30, 2021. The shutdown was performed to repair turbine temperature switches that were erroneously causing half group one signals on the A2 channel du e to instrument drift. On July 4, 2021, after repairs to the turbine temperature switches were made, the unit was restarted. The unit returned to 100 percent rated thermal powe r (RTP) on July 10, 2021. On July 15, 2021, the unit was down powered to 50 percent RTP to p erform investigation and repairs due to a condenser tube leaks resulting in an increase in reactor coolant chlorides. After repairs were made by plugging leaking condenser tubes, the unit was returned to 100 percent RTP on July 19, 2021. On August 3, 2021, the unit scrammed on low reactor water level caused by loss of normal feedwater. The loss of feedwater was caused from a loss of power to the electrical bus powering feedwater pump controls. After rep airs were made by restoring power to the electrical bus, the unit was restarted and returne d to 100 percent RTP on August 9, 2021. On September 19, 2021, the unit was down powered to 70 p ercent RTP to perform a rod pattern adjustment and turbine valve testing, and the unit retu rned to 100 percent RTP on September 21, 2021, following completion of those activities. The unit operated there for the remainder of the inspection period.

Unit 2 began the inspection period at 100 percent RTP. On Sept ember 11, 2021, the unit was down powered to 70 percent RTP to perform a rod pattern adjustm ent and turbine valve testing, and the unit was returned to 100 percent RTP the same day. The unit operated there for the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of th e inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise note d. Currently approved IPs with their attached revision histories are located on the public web site 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 inspe ction activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Wa ter Reactor Inspection Program - Operations Phase. The inspectors reviewed selected p rocedures and records, observed activities, and interviewed personnel to assess licens ee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

Starting on March 20, 2020, in response to the National Emergen cy declared by the President of the United States on the public health risks of the coronavi rus (COVID-19), resident and regional inspectors were directed to begin telework and to remo tely access licensee information using available technology. During this time, the resident ins pectors performed periodic site visits each week, increasing the amount of time on-site as loca l COVID-19 conditions permitted.

As part of their on-site activities, resident inspectors conduc ted plant status activities as described in IMC 2515, Appendix D; conducted routine reviews us ing IP 71152, Problem Identification and Resolution, observed risk significant activ ities; and completed on-site portions of IPs. In addition, resident and regional baseline inspection s were evaluated to determine if all or a portion of the objectives and requirements stated in the I P could be performed remotely. If the inspections could be performed remotely, they were conducte d per the applicable IP. In some cases, portions of an IP were completed remotely and on-si te. The inspections documented below met the objectives and requirements for comple tion of the IP.

REACTOR SAFETY

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (4 Samples)

The inspectors evaluated system configurations during partial w alkdowns of the following systems/trains:

(1) Alignment of the Unit 2 residual heat removal (RHR) system following a pump operability test the previous day, using 34SO-E11-010-2, on Ju ly 21, 2021.

(2) Alignment of the Unit 1 plant service water (PSW) system fo llowing 1B PSW pump motor replacement, using 34SO-P41-001-1, on July 30, 2021.

(3) Alignment of the Unit 1 core spray (CS) system, 'A' Loop, d uring CS loop 'B' valve operability test, using 34SO-E21-001-1, on August 17, 2021.

(4) Alignment of the Unit 1 CS system, 'A' Loop, during loop 'B ' pump operability test, using 34SO-E21-001-1, on August 18, 2021.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 Samples)

The inspectors evaluated the implementation of the fire protect ion 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) Unit 1 standby gas treatment system room on July 14, 2021.

(2) Unit 2 reactor core isolation cooling system room on July 1 5, 2021.

(3) Unit 2 reactor building 158'/164' elevation on July 20, 202 1.

(4) Unit 1 and 2 intake structure on July 28, 2021.

(5) Unit 1 and 2 emergency diesel generator (EDG) building on A ugust 19, 2021.

(6) Unit 1 and 2 control building 112' elevation, on August 20, 2021.

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)

The inspectors evaluated internal flooding mitigation protectio ns in the:

(1) * Unit 1 reactor building northwest control rod drive (CRD) comp artment

• Unit 1 reactor building northeast residual heat removal (RHR) and core spray (CS) compartment

• Unit 1 reactor building southeast RHR and CS compartment

• Unit 1 reactor core isolation cooling (RCIC) southwest compart ment

• Unit 1 high pressure core cooling (HPCI) compartment

71111.11Q - Licensed Operator Requalification Program and Licen sed 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 per formance in the control room during a plant startup, following the forced maintenance o utage on July 6, 2021. The inspectors observed non-critical heat-up due to a po sitive moderator coefficient, rod pull to criticality and to the point of adding heat, and observed the operating crew establish a controlled heat-up rate within techn ical specification limits.

Licensed Operator Requalification Training/Examinations (IP Sec tion 03.02) (1 Sample)

(1) The inspectors observed and evaluated "License Operator Jus t in Time Training" (JITT) H-LOCT 21-026 "U1 MOC Startup," for one team during simu lator training on July 1, 2021.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

The inspectors evaluated the effectiveness of maintenance to en sure the following structures, systems, and components (SSCs) remain capable of pe rforming their intended function:

(1) Review of the Unit 1 high pressure coolant injection (HPCI) system following failures of various HPCI components, on September 24, 2021.

71111.13 - Maintenance Risk Assessments and Emergent Work Contr ol

Risk Assessment and Management Sample (IP Section 03.01) (5 Sam ples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure config uration changes and appropriate work controls were addressed:

(1) Unit 1 elevated risk due to the trip of the 1B PSW pump, fr om July 19 to July 30, 2021.

(2) Unit 1 elevated risk following reactor trip and being in sh utdown cooling, 31GO-OPS-024-0, Outage Safety Assessment dated August 4, 2021.

(3) Unit 1 elevated risk due to unplanned inoperability of the 1C PSW pump, from August 26 to September 16, 2021.

(4) Unit 1 elevated risk due to unplanned inoperability of the HPCI system due to HPCI discharge valve failing to open, from September 8 to September 10, 2021.

(5) Unit 1 elevated risk due to limited condition of operation (LCO) extension for the 1C PSW pump, from 30 days to 45 days, September 21 to September 28, 2021.

71111.15 - Operability Determinations and Functionality Assessm ents

Operability Determination or Functionality Assessment (IP Secti on 03.01) (7 Samples)

The inspectors evaluated the licensee's justifications and acti ons associated with the following operability determinations and functionality assessme nts:

(1) Condition Report (CR) 10810391, Unit 1 "B" Recirculation Di scharge Valve did not close on demand on July 3, 2021.

(2) CR 10812018, Unit 2 "A" Emergency Diesel Generator (EDG) Fu el Oil Transfer Pump seal leak of 0.5 to 1.0 GPM on July 12, 2021.

(3) CR 10813948, Unit 1 "B" plant service water (PSW) pump trip on July 19, 2021.

(4) CR 10817764, Unit 1 high pressure coolant injection (HPCI) main pump mechanical seal leak, inboard seal on August 3, 2021.

(5) CR 10822020, Unit 1 "B" HPCI pump room cooler leak on Augus t 25, 2021.

(6) CR 10823851, Unit 1 "C" PSW pump foreign material analysis, effects on 1A and 1B PSW pumps on September 2, 2021.

(7) CR 10827289, Unit 2 "A" EDG battery with cell 27 jar cracke d through the side wall on September 15, 2021.

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Sect ion 03.01 and/or 03.02) (2 Samples)

The inspectors evaluated the following temporary or permanent m odifications:

(1) Temporary modification to bypass air around solenoid valves 1N11-F036A and 1N11-F036B, as their failure would result in the loss of the steam j et air ejector on Unit 1 and result in a subsequent greater than 20 percent down power.

(2) Permanent modification to the upper and lower seismic restr aints on 1C PSW pump due to excessive contact with the pump column preventing proper alignment of the pump.

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)

The inspectors evaluated the following post-maintenance test ac tivities to verify system operability and functionality:

(1) NMP-ES-017-020, "MOV Electrical Checkout and Adjustments fo r SMB/SB Actuators," Version 6.5, and 34SV-B31-001-1, "Recirculation Sys tem Valve Operability," Version 7.10, following motor replacement of the 1B recirculation discharge motor operated valve on July 4, 2021.

(2) 34SV-R43-002-1, "Diesel Generator 1B Monthly Test," Version 24.6, following the troubleshooting and replacement of the fuel oil filter differen tial pressure gage on July 14, 2021.

(3) 34SV-P41-001-1, "Plant Service Water Pump Operability," Ver sion 15.2, following the replacement of 1B plant service water pump motor on July 30, 20 21.

(4) 34SV-B31-001-1, "Recirculation System Valve Operability," V ersion 7.11, after replacement of fuse clips in the valve breaker for 1B31-F031B d ischarge valve for 'B'

recirculation loop, on August 5, 2021.

(5) SNC1171149, Functional test of auto transfer time delay rel ay for turbine building switchgear 1R23S021, following relay replacement on August 6, 2 021.

(6) 34SV-P41-001-1, "Plant Service Water (PSW) Pump Operability," Version 15.2, following the replacement of 1C PSW pump on September 28, 2021.

71111.20 - Refueling and Other Outage Activities

Refueling/Other Outage Sample (IP Section 03.01) (2 Samples)

(1) The inspectors evaluated forced outage activities on Unit 1, due to turbine building temperatures switches causing half group I signals on the A2 ch annel, from June 30, 2021 to July 6, 2021.

(2) The inspectors evaluated forced outage activities on Unit 1, caused by a reactor scram resulting from a loss of normal feed water, from August 3 to August 8, 2021.

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01) (1 Sample)

(1) 34SV-R43-012-2, "Diesel Generator 1B 24 Month Operability T est," Version 8.1, on August 11, 2021.

Inservice Testing (IP Section 03.01) (1 Sample)

(1) 34SV-E11-001-1, "Residual Heat Removal Pump Operability IST," Version 30.1, on July 15, 2021.

71114.06 - Drill Evaluation

Drill/Training Evolution Observation (IP Section 03.02) (1 Samp le)

The inspectors evaluated:

(1) Licensed reactor operators respond to a Reactor Scram with Anticipated Transient Without a Scram (ATWS) in the simulator and observed the crew make an emergency declaration and notification. This represented a dril l and exercise performance opportunity on July 6, 2021.

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submitt als listed below:

MS06: Emergency AC Power Systems (IP Section 02.05) (2 Samples)

(1) Unit 1 (July 1, 2020-June 30, 2021)

(2) Unit 2 (July 1, 2020-June 30, 2021)

MS07: High Pressure Injection Systems (IP Section 02.06) (2 Sam ples)

(1) Unit 1 (July 1, 2020-June 30, 2021)

(2) Unit 2 (July 1, 2020-June 30, 2021)

MS08: Heat Removal Systems (IP Section 02.07) (2 Samples)

(1) Unit 1 (July 1, 2020-June 30, 2021)

(2) Unit 2 (July 1, 2020-June 30, 2021)

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (IP Section 02.03) (2 Sampl es)

The inspectors reviewed the licensees implementation of its co rrective action program related to the following issues:

(1) The 1D residual heat removal service water pump (RHRSW) fai lure caused by the pump shaft seizing to the mechanical seal box in the discharge head.

(2) Inoperability of 2D residual heat removal (RHR) pump due to inadequate maintenance procedural instructions for recoupling pump and mot or.

71153 - Follow Up of Events and Notices of Enforcement Discreti on

Event Followup (IP Section 03.01) (2 Samples)

(1) The inspectors evaluated the Unit 1 reactor scram caused by loss of normal reactor feed water and licensees response on August 3, 2021.

(2) The inspectors evaluated the unplanned inoperability of the 1C PSW pump caused by the shaft shearing, on August 26, 2021.

INSPECTION RESULTS

Inoperability of 2D Residual Heat Removal (RHR) Pump Due to Ina dequate Maintenance Procedural Instructions for Recoupling Pump and Motor Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green None (NPP) 71152 Systems NCV 05000366/2021003-01 Open/Closed A self-revealing Green non-cited violation of Unit 2 Technical Specification (TS) 5.4.1(a) was identified for the licensees failure to incorporate adequate m aintenance procedural instructions for the recoupling of the residual heat removal (R HR) pump and motor as recommended by Regulatory Guide (RG) 1.33, section 9.a. Specif ically, procedure 52PM-E11-003-2, RHR Pump and Motor Maintenance, Version 9.4 did no t contain instructions to verify the tightness of the motor coupling nut set screws in 2D RHR pump to prevent the pump shaft downward movement within the pump, thus causing pump failure and pump inoperability.

Description: On April 16, 2021, the 2D RHR Pump was operating in torus cooling mode and after approximately 10 minutes of pump operation, an overcurren t annunciator OVLD/Lockout Relay trip was received. The annunciator response procedure wa s entered, the 2D RHR pump was manually secured, and TS LCO 3.5.1 A(1) was subsequent ly entered. After initial troubleshooting, another pump run was attempted that resulted i n an automatic pump trip.

Following the second attempted pump run, the 2D RHR pump was di sassembled, and the

first stage impeller was found bound to the suction head wear r ing. During the pump repair, the mechanics working on the mechanical seal observed that the motor coupling nut set screws were loose. The design/intent of the set screws is to h old the motor coupling nut stationary. Due to these set screws being loose during each pu mp start, the combination of shaft loading/unloading on the nut caused significant torque le ading to the coupling nut loosening. During the nut loosening process from each start, t he pump shaft moved downward within the pump. This caused the first stage impeller to come in contact (rub) with the suction head wear ring and resulted in it grinding/cutting into the wear ring. The binding together of the impeller and wear ring caused the overcurrent i n the motor that resulted in the overcurrent annunciator OVLD/Lockout Relay trip seen in the con trol room.

The motor for 2D RHR pump was replaced on March 4, 2019. At th e time, the motor coupling was disconnected, and the licensee failed to ensure the set scr ews were tightened down as required. The cause of the improper maintenance was inadequate procedural guidance for the process of tightening the motor half coupling nut set screw s. During the creation of the maintenance procedure 52PM-E11-003-2 in 1991, information from the vendor manual pertaining to a referenced General Electric (GE) Service Inform ation Letter (SIL) #417, was not transferred from the RHR Pump maintenance vendor manual to the new pump maintenance procedure. GE SIL #417 was provided to Plant Hatch on January 14, 1985. The SIL was a warning to affected utilities that the mot or half coupling nut could loosen and lead to pump failure if the set screws were not installed a nd tightened properly. The licensee responded to GE SIL #417 by revising the vendor manual SX27070 with an As Built Notice (ABN), however failed to transfer this information over to their revised procedure in 1991.

Corrective Actions: The licensee entered this pump failure eve nt into their corrective action program. The licensee repaired 2D RHR pump by properly reinstal ling/tightening the motor coupling set screws and by replacing the pump rotating assembly /suction head. Additionally, the licensee verified the clearance between the mechanical seal gland plate and collar on all remaining Ingersoll Rand Pumps met requirements and no movement of the coupling nuts had occurred to other similar pumps. The licensee also revised their procedure 52PM-E11-003-2, incorporating instructions to apply thread-locker to coupling nut set screws and to ensure they were properly tightened to reduce the likelihood of this type of event occurring again.

Corrective Action References: Condition reports (CRs) 10791097 and 10801317; technical evaluations (TE) 1090830, 1090831, 1090832, 1090833, 1090834 an d 1090835 corrective action report (CAR) 279192.

Performance Assessment:

Performance Deficiency: The failure to provide appropriate pro cedures, instructions, or drawings for maintenance that could affect the performance of s afety-related equipment per TS 5.4.1 and Regulatory Guide 1.33 was a performance deficiency. Specifically, there were no instructions or drawings to verify the tightness of the moto r coupling nut set screws to prevent shaft downward movement within the pump.

Screening: The inspectors determined the performance deficienc y was more than minor because it was associated with the Equipment Performance attrib ute of the Mitigating Systems cornerstone and adversely affected the cornerstone obje ctive to ensure the availability, reliability, and capability of systems that respo nd to initiating events to prevent undesirable consequences. Specifically, the 2D RHR pump failed due to incorrect

maintenance by the licensee when they failed to tighten the mot or half coupling nut with set screws, resulting in an out of service time for the pump greate r than its normal TS outage limit.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The affected cornerstone was Mitigating Systems, as determined by Inspection Manual Chap ter (IMC) 0609, Attachment 4, Initial Characterization of Findings. Utilizin g IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, the performance deficiency required a detailed risk evaluation because the degraded condit ion represented a loss of the PRA function of one train of a multi-train TS system for greate r than its TS allowed outage time.

A regional Senior Reactor Analyst (SRA) conducted a detailed ri sk evaluation using the guidance in IMC 0609 Appendix A and the Risk Assessment Standar dization Project (RASP)

Handbook. The SRA modelled the condition using the Hatch Unit 1 &2 SPAR model version 8.58 dated February 28, 2017, and SAPHIRE 8 Version 8.2.3. The exposure period was divided into two periods. First, the 10-day period from the las t run of the 2D RHR pump on April 13, 2021 until April 22, 2021, when the one-time emergenc y TS amendment was approved and the second from April 22, 2021, until the 2D RHR p ump was declared operable on April 29, 2021. During the second period, the compensatory a ctions required by the emergency TS were credited. The issue was modelled as a failure to start of the 2D RHR pump, due to the failure mechanism failure to run was not consi dered. The dominant accident sequences included several fire scenarios and a loss of condens er heat sink event with a failure of RHR, late injection and containment venting function s. For the first 10-day period, risk was determined to be 5.042E-7 core damage events per year. For the final seven-day period, the risk was 4.482E-8 core damage events per year. Thus, total risk for the exposure period was 5.49E-7 core damage events per year, which makes thi s a finding of very low safety significance (Green).

Cross-Cutting Aspect: Not Present Performance. No cross-cuttin g aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance.

Enforcement:

Violation: Hatch Unit 2 Technical Specification 5.4.1.(a) Pro cedures, states, in part, that written procedures shall be implemented covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, February 1978. Regul atory Guide 1.33, Quality Assurance Program Requirements (Operation), Appendix A, Paragr aph 9.a, Procedures for Performing Maintenance, requires that maintenance that can af fect the performance of safety-related equipment should be properly pre-planned and per formed in accordance with written procedures, documented instructions, or drawings approp riate to the circumstances.

Contrary to the above, on March 4, 2019, maintenance procedure 52PM-E11-003-2 did not provide procedures, instructions, or drawings regarding 2D RHR pump motor replacement that were appropriate to the circumstances. Specifically, ther e were no instructions or drawings to verify the tightness of the motor coupling nut set screws to prevent shaft downward movement within the pump.

Enforcement Action: This violation is being treated as a non-c ited violation, consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On October 19, 2021, the inspectors presented the integrated i nspection results to Sonny Dean and other members of the licensee staff.

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