IR 05000373/1981020
| ML20010E474 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 08/18/1981 |
| From: | Hopkins J, Maura F, Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20010E466 | List: |
| References | |
| 50-373-81-20, NUDOCS 8109040163 | |
| Download: ML20010E474 (12) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-373/81-20 Docket No. 50-373 License No. CPPR-99 Licensee: Commonwealth Edison Company P.O. Box 767 Chicago, Illinois 60690 Facility Name: La Salle County Station, Unit 1 Inspection At: La Salle Site, Marseilles, Illinois Inspection Conducted: May 19-22, 29, June 2-5, 11, 12, 16, 17, 23, 24, 30 and July 1-2, 1981.
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Inspection Summary.
Inspection on May 19-22, 29, June 2-5, 11, 12, 16, 17, 23, 24, 30, and July 1-2, 1981 (Report No. 50-373/81-20)
Areas Inspected: Routine, unannounced inspection to review preoperational test procedures and results, diesel generator factory prototype testing, pre-vious open items, and the unintentional' overloading of diesel generator 2A.
The inspection involved 132 inspector-hours onsite by three NRC inspectors including 20 inspector-hours onsite during off shifts.
Results: Of the five areas inspected no items of noncompliance were identified in two areas. Within the three remaining areas five apparent items-of noncompliance were identified (failure to design systems and components in accordance with FSAR - Paragraphs 3.a.(3), (4) and 3.b.(2);
failure to have appropriate acceptance criteria and conduct proper evalu-
l ation of test results - Paragraphs 3.b.(1) and (2); failure to demonstrate I
design and performance characteristics specified in FSAR - Paragraph 3.a.(2);
failure to perform proper instrument calibration - Paragraph 5.; failure to control nonconforming parts - Paragraph 5.).
i 8109040163 810821 gDRADOCK 05000373 i
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DETAILS 1.
Persons Contacted
- J. Meley, Manager of Projects
- B. Stephenson, Project Manager
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- R. Holyoak, Station Superintendent
- R. Bishop, Assistant Superintendent
- J. Coonan, Assistant Superintendent, Maintenance
- C. Schrorder, Technical Staff Supervisor
- B. Shelton, Project Engineering Manager
- R. Kyrouac, Quality Assurance Supervisor H. Hentchel, Test Coordinator Technical Staff W. Huntington, Test Coordinator Technical Staff E. Pfister, Lead Nuclear Engineer R. Mathews, Lead Engineer 0AD The inspectors also interviewed other licensee employees including members of the technical, OAD, operations, construction, and QA staff.
- Denotes those attending the exit interview ef July 2, 1981.
- Denotes those attending the exit interview of July 2, 1981, and the telephone re-exit of July 22, 1981.
2.
Licensee Action on Previous Inspection Findings (Closed) Open Item (373/80-25-09) Possible common mode failure in diesel renerators air start system. Review of the matter by NRR determined that complete separation of air start subsystems is not required.
(0 pen) Open Item (373/80-36-03) The item involved test procedure SD-WE-101E (Sump monitoring) not specifying acceptance criteria con-sistent with the proposed technical specification limits of 25 GPM total leakage and 5 GPM unidentified leakage. The inspector inter-viewed the sump monitoring system test engineer who stated that the test procedure acceptance criteria for unidentified leakage would be 5 GPM, matching the technical specification. The engineer also described the proposed method of determining identified leakage via an in line totalizer and the drywell equipment drain sump level.
The item remains open since these criteria are not yet incorporated into the procedure.
(Closed) Open Item (373/81-07-02) The inspector completed discus-sions with the licensee and determined that procedure PT-IN-101 (primary containment instrument air) adequately tests the air dryer units for proper functioning as required by Section C.3 of Regulatory Guide 1.80.
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(0 pen) Open Item (373/81-07-03) This item dealt with how test pro-cedure PT-IN-101 (primary containment instrument air) satisfied Section C.4 of Regulatory Guide 1.80 relating to ficw and temperature of the product air.
The licensee stated that the compressor capacity check verified flow specifications but that the procedure did not yet address temperature specifications. This item remains open pending further discussion with the licensee.
3.
Review of Preoperational Test Procedures and Test Results a.
PT-DG-101A, " Diesel Generators and Auxiliaries" The inspector review test procedure PT-DG-101A, Revision 20, and the test results against the FSAR, the SER (NUREG-0519),
Regulatory Guides 1.68, 1.9 and 1.108, and IEEE-337-1972. The following problems were noted:
(1) All the diesel generator "0" tests involving Unit 2 hardware were deleted because the equipment was not available at the time the test was performed. The licensee stated all tests involving Unit 2 equipment were transferred to preoperational test PT-DG-201A, and will be completed prior to Unit I fuel loading. This is considered an Open Item (373/81-20-01) pending satisfactory completion by the licensee and review by the inspector.
(2) FSAR Section 9.5.6.1.1 states that each starting air subsystem has enough air storage capacity for a minimum of five normal cranking cycles in rapid succession without the use of the air compressor, assuming the redundant subsystem fails to operate.
It also states that the minimum receiver pressure, (defined as the start setpoint of the air compressor pressure switch) to assure a fast start with two air motors only, is approximately 220 psig and with four air motors it is approximately 140 to 155 psig.
The test procedure did not require testing to ensure the diesel could atisfy tne above commitment. This is considered to be a violation of 10 CFR 50, Appendix B, Criterion XI and the QA Manual Quality Requirement No. 11.0, and is an example of an item of noncompliance (373/81-20-02).
A review of the test results using all four starting air motor showed that diesel generator "0" could be successfully started seven times, the last one from an air receiver pressure of 145 psig.
Diesel "1A" was successfully started seventeen times, the last from an air receiver pressure of 107 psig. While it may be possible to obtain five successful starts with only 2 air motors for diesel "1A",
it is very improbable in the case of diesel
"0".
This is considered an open item (373/81-20-03) pending satisfactory resolution by the licensee and review by the inspector.
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(3) FSAR Table 14.2-34, Test Objective, Item 8, states that the preop test will demonstrate the capability of the diesel generator unit to supply emergency power within the required time and that this capability is not impaired during periodic testing of the diesels. The test procedure ignored this commitment, because the present system design does not allow the shedding of non essential loads during a LOCA signal unless the bus experiences an undervoltage
. condition. Regulatory Guide 1.108, Paragraph C.2.a.(8)
also requires such a test. Failure to modify the existing design and to perform such test is considered to be a violation of 10 CFR 50, Appendix B, Criterion III and the QA Manual Quality Requirement No. 3.0 and is an example of an item of noncompliance (373/81-20-4A).
(4) During the review of the loads being used to perform portions of the preoperational test the inspector became aware that the loads are not sequenced as listed on FSAR Table 8.3-1, " Loading of 4160 volt ESF Busses".
For example, the table states that the RHR service water pumps are energized immediately upon restoration of bus voltage, but according to the licensee they can only be applied manually by the operator as required. Discrepancies also e.tist between the delay time for sequencing of loads listed in the table and the actual delay time settings.
Failure to conform with Table 8.3-1 is considered to be a violation of 10 CFR 50, Appendix B, Criterion III and the QA Manual, Quality Requirement No. 3.0, and is an example of an item of noncompliance (373/81-20-4B).
(5) The starting air receivers low pressure alarm was set and tested at 190 psig which is below the minimum pressure re-quired to guarantee five normal starting cycles as discussed in Paragraph 3.a.(2).
This is considered to be an open item (373/81-20-05) pending the resetting of the alarm at or above the minimum pressure which satisfies Paragraph 3.a.(2).
(6) The results of the fuel consumption test for diesel "0" showed a consumption rate of 195 gal /hr. which exceeds the maximum allowed rate of 186 gal /hr. stated in the FSAR.
The licensee plans to try to reduce the consumption rate, and if that fails will increase the fuel storage tank low level alarm to guarantee a minimum of 7 days supply. This is an open item (373/81-20-06) pending licensee resolution and inspector verification.
(7) Lae to the construction status of Unit 2 the margin load test for diesel generator 2A may not be p(cformed prior to Unit 1 fuel load. The inspector requested that the licensee tabulate all Unit 2 loads required for Unit 1 operation to justify not performing a ' margin load test on diesel 2A prior to Unit 1 fuel loading. This is an open item (373/81-20-07) pending
review of the justification to be prepared by the licensee.
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(8) The licensee does not have a program to perform periodic testing, and adjust the frequency of testing, based on de-monstrated performance (valid starts and failures) follow-ing the successful completion of the 23 consecutive valid tests.
Lack of such a program makes the 23 consecutive successful start reliability demonstration worthless, since subsequent failures would not be counted. The licensee objects to counting any start attempts prior to the issuance of the operating license. The licensee feels such a requirement is a disincentive to the performance of surveillance testing during the period between the completion of the 23 starts test and the issuance of the license. This is considered to be an unresolved item (373/81-20-08) pending the receipt of additional guidance from IE:HQ.
(9) Due to a time delay caused by an over-under voltage relay-it is presently impossible to be able to energize the ESF busses within 10 seconds as stated in FSAR in Table 6.3.3,
" Operational sequence of ECCS for Design-Basis Accident."
The licensee is investigating the problem and plans to take the necessary corrective action. This is an open item (373/81-20-09) pending satisfactory resolution by the licensee.
(10) The licensee does not have the capability to trip the diesel generator in the event of a LOCA with off site power available. As a result, the diesel operates at full speed-no load for as long as a LOCA signal exists. This problem has already been identified to the licensee as open item number 373/80-05-06. The licensee plans to correct the problem by every four hours synchronizing the diesel generators with the grid and fully loading the units for 15 minutes.
The inspector stated that present plans to synchronize the diesel generators with offsite power whenever a LOCA signal is present is a violation of General Design Criteria No. 17.
This item remains open.
(11) Several diesel generator start failures were experienced caused by open or missing blocking diodes in the tachometer relay circuits. During discussion of the problem the licensee stated periodic verification of the integrity of all required diodes was being considered to assure the operability of the start and breaker closure permissive circuits. This is an open item (373/81-20-10) pending-satisfactory resolution by the licensee.
(12) Problems with the " aging" of the crankcase pressure switch l
were experienced. The licensee stated replacement of the
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pressure switches every 2 years is planned. This is an open item (373/81-20-11) pending licensee incorporation of l
this item in the preventative maintenance program.
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(13) The deficiencies which remain unresolved must be reviewed by QA prior to system release for operation. At that time all items which must be corrected prior to fuel loading will be identified. This is an open item (373/81-20-12) pending in-spector review of the corrective action taken by the licensee prior to fuel loading.
b.
PT-D0-101 and PT-D0-201, " Diesel Fuel Oil" The inspector reviewed the test procedure and the test results approved by the Station Nuclear Engineering Department (SNED)
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against the FSAR, the SER (NUREG-0519) and Regulatory Guide 1.68.
f The following problems were noted:
(1) The acceptance criteria for the low level alarms of the fuel oil storage tanks permits the amount of stored fuel to fall below the minimum requirement specified in the FSAR. For diesel generators IA (tank 1D001T), 0 (OD001T),
and 2A (2D001T',, SNED approved an acceptance criteria of 6.4 1 0.1 psi on June 1980 for retest D0-1.
Using the design specific gravity of 0.86 for the fuel the accept-ance criteria is equivalent to 206.3 3.2 inches. The inspector reviewed the as-built drawings with the licensee and determined that:
(a) the fuel level is measured by a bubbler level instrument with a sensing line which terminates 2 inches above the storage tank bottom.
(b) the tank connection to the fuel transfer pump is a 2 inch pipe with its center line 12 inches above the tank bottom-(c) as a result the first 11 inches of indicated fuel are i
not available.
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(d) using the licensee's value of 158 gal /in., the amount of fuel available for use at the acceptance criteria set point of 6.4 psi is 30,857 gallon. The 0.1 psi tolerance
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This is contrary to Section 9.5.4.1.1.e of the FSAR which
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states that, " Storage Tank low level alarms are set such l
that the minimum 7-day supply is available at alarm I
actuation." The 7-day supply for a maximum consumption
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rate of 186 gal /hr. is equivalent to 31,250 gallon.
For diesel generator 1B (storage tank 1 D002T) the SNED approved acceptance criteria was 6.65
.1 psi or 214.4 3.2 inches.
The inspector reviewed the as-built drawings with the licensee and determined that:
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(a)
the fuel level is measured by a bubbler level instrument with a sensing line which terminated 2 inches above the tank bottom.
(b)
the tank connection to the fuel transfer pump terminates vertically 4 inches above the tank bottom.
(c) as a result the first 2 inches of indicated fuel are not available.
(d) using the licensee's value of 141 gal /in., the amount of fuel available for use at the acceptance criteria set :aint of 6.65 psi is 29,948 gallon. The 0.1 psi tolerance allows the alarm to range from 29,497 to 30,399 gallon. Based on the FSAR requirement of a 7-day supply minimum, the low level alarm must be set 29,750 gallon.
The approval of an acceptance criteria and of test results which allow the amount of fuel in the storage tanks to fall below FSAR requirements is considered to be a violation of 10 CFR 50, Appendix B, Criterions V and XI and the QA Manual Quality Requirement 11.0 and is an example of an item of ncn-compliance (373/81-20-13Al.
(2) The acceptance criteria, and approved test results for the diesel fire pump day tank low level alarm and the high level auto trip of the transfer pump do not meet the mintaus feel requirements stated in the FSAR. The low level alarm.is set at the equivalence of 70 gallon and the high level auto trip at 450 gallons.
In the safety evaluation of the diesel generator's fuel storage tank capacities, Section 9.5.4.3 of the FSAR states that, "Each 750 gallon diesel fire pump day tank contains sufficient fuel for approximately 35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br /> of operation of associated diesel fire pump.
Since 35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br /> is considered sufficient time to extinguish probable fires at the station, it is not necessary to include consumption of the diesel fire pump in determining the minimum 7-day storage capacity."
The approval of an acceptance criteria and of test results which allow the amount of stored fuel in the diesel fire pumps day tanks to fall below the minimum requirements specified in the FSAR is con-sidered to be a violation of 10 CFR 50, Appendix B, Criterions V and XI, and the QA Manual, Quality Requirement No. 11.0 and is an example of an item of noncompliance (373/81-20-13B).
In discussions with the licensee the inspector determined that:
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(a) the fuel consumption of the diesel fire pumps has not been measured.
(b) two different fuel consumption values exist: 0.677 gpm per PT-D0-101, and 17.7 gph based on a licensee conversation with the engine manufacturer.
(c) based on the 0.677 gpm of PT-D0-101 the required low level alarm set point is 1422 gallon, while based on the 17.7 gph value it would be 620 gallon.
(d) the licensee stated that he thought the diesel fire pump requirement should be 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and not 35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br />.
Even using 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> at 17.7 gph, or 142 gallons, the low level alarm acceptance criteria is inadequate.
(e) the capacity of each fire diesel pump day tank is 550 gallon not 750 gallon a' stated in the FSAR.
Design and installation of fire diesel pump day tanks smaller than called for in the FSAR is considered to be a violation of 10 CFR 50, Appendix B, Criterion III and the QA Manual, Quality Requirement No. 3.0 and is an example of an item of noncompliance (373/81-20-4C).
(3) The deficiencies which remain unresolved must be reviewed by QA prior to system release for operation. At that time all items which must be corrected prior to fuel loading will be identified. This is an open item (373/81-20-14)
pending inspector review of the corrective actions taken by the licensee prior to fuel loading.
4.
Diesel Generator Prototype Tests Review The inspector reviewed the results of the factory prototype testing performed on diesel generator "0" (Serial No. 76 C1-111). The tests consisted of six starting tests, a sequential loading test, a 300 stort qualification test, a full load test, a 110% overload test, and a voltage stability and transient response test. The last three tests were also performed on diesel generators "1A" and "2A" (Serial Nos. 75Cl-1096 and 76 C1-1012 respectively). The inspector determined that the test results satisfied regulatory requirements except as noted below:
a.
The 300 start qualification test consists of 270 starts from design cold ambient or standby temperature conditions, and 30 starts from hot equilibrium temperature conditions. The diesel generator shall start and be ready to accept load within a specified time interval, be loaded to 50% load, and operated long enough to attain em '.iibrium temperature. Equilibrium temperature for 50% load is approximately 165F. The factory test procedure defines standby temperature conditions for the-8-
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270 starts as 135 i 10F, and defines a hot start as a start following five minutes from the previous run. The review showed that of the 30 hot starts, 9 were performed at temperatures of less than 165 i 10F (ranging from 139F to 153F) and on one start' the recorder being used to determine the time from start signal until rated speed and voltage were reached was left on slow speed invalidating the measurement.
To supplement the hot starts of the 300 start qualification test the inspector reviewed the results of the 23 consecutive valid starts performed at the site and determined that over 10 satisfactory starts were done from a temperature of 165 10F.
b.
During the qualification runs the air start motors were refurbished every 50 starts. The inspector informed the licensee that the pre-ventive maintenance program must call for the refurbishing of the 4 start motors on each diesel no later than every 50 starts. The licensee plans to incorporate this requirement in their maintenance program. This is considered an open item (373/81-20-15) pending inspector verification that the license has taken the required action. The inspector also stated that, in line with the above requirement, he would expect that prior to Unit 1 fuel loading, the in service air start motors for diesel generators 1A, 2A, 0, and IB will be replaced to ensure the fuel cycle starts with air motors which have a low number of start cycles. This is an open
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item (373/81-20-16) pending inspector verification of the licensee's action.
c.
The motor starting test is designed to demonstrate the diesel generator's capability to accelerate and carry the design loads, in the desired sequence, within the voltage and frequency limits of Regulatory Guide 1.9.
The factory test consisted of loading the diesel generator with an unloaded 1500 H.P. motor, followed by selective resistance banks simulating the pump loads, and finally an 800 HP motor five seconds after the initial 1500 HP motor breaker closing. The test results report gave no data to demonstrate that the loading sequence and resistance load values used during the test actually simulated the loading of the LPCS and RHR pumps.
In addition, the recorder trace indicated that the initial voltage drop may have ex<eeo.d the limits stated in Regulatory Guide 1.9.
This test will be v.peated during the performance of preoperational
.si g the actual plant loads which we plan to witness.
test PT-AP-1
This is.on s i,
.-d a, open item (3 73/81-20-17) pending the satis-factory complet
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5.
Diesel Generator 2A Overloading During preoperational testing of the 2A diesel generator, the licensee noted that some of the engine readings were different than what he had experienced during testing of the other diesels, and~ appeared to indicate an overloading of the unit. The local and remote megawatt meters were recalibrated on May 20, 1981 and f"ind to be reading low by a factor of 1.21.
As a result _the licensee recalculated the power levels at which testing had been performed with the following results:
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a.
two 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> runs at between 3200 to 3270 kw (125% of rated)
b.
two 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> runs and two I hour runs at between 2930 to 3025 kw (115% of rated)
c.
thirteen I hour runs at between 2900 to 2940 kw (112% of rated)
d.
several runs accumulating approximately 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> between 2540 to 2720 kw (95-105% of rated).
On May 21, 1981 a representative of Steward and Stevenson Services inspected the diesel power units thru the air box and determined that the engine had not suffered any visible damage. He requested a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run at full load to measure present oil consumption. The measured oil consumption rate was 0.24 gal /hr. which is lower than the consumption rate of the "0" and "1A" diesels, and within the expected range. The licensee also analyzed a sample of lube oil with satisfactory results.
No water was detected in the oil.
But the inspector was informed that on April 9, 1981 water had been found on the lube oil. An inspection determined that power unit #1 had a cracked cylinder liner. The liner was replaced during April 1981. According to the licensee approximately half of the overloaded runs were conducted prior to April 9, 1981.
Based on discussions with EMD personnel, it is possible that the cylinder liner cracking was the result of the overloading which occurred prior to April 9, 1981.
A review of the event determined that the local wattmeter was initially calibrated by Operational Analysis Department (OAD) personnel on March 26, 1979. Sometime in 1980 the local meter was damaged and was replaced with a meter having different calibration units until a new meter could be obtained. A Nonconformance Report (NRC) was not written to prevent the inadvertent use of the installed temporary wattmeter. At the time of equipment turnover for preoperational testing, Station Construction and Site QA failed to identify the temporary wattmeter in a Deficiency Report as required by LSU 100-2.
Failure to generate an NCR at the time of installation or to identify in a deficiency report at the time of turnover for preoperational testing is considered to be a violation of 10 CFR Part 50, Appendix B, Criterion XV and QA Manual Quality Requirement No. 15.0 and is con-sidered to be an item of noncompliance (373/81-20-18).
Prior to preoperational testing of the diesel generator on March 1981 the Test Engineer requested a recalibration of both wattmeters because their original calibration exceeded one year. A Temporary Turnover Agreement returned the instrument to OAD on March 12, 1981.
The following day the OAD Engineer signed off the Temporary Turnover Agreement signifying that the calibration had been satisfactorily completed. However no calibration data records exist to indicate what were the "as found" and "as left" readings, and how the cali-bration was performed to produce satisfactory results. The Test Engineer accepted a verbal assurance from OAD that the wattmeter had been properly calibrated, but failed to ensure that the required
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calibration data was available as required by LSU 300-4, Revision 3.
Failure to perform a proper calibration and to record the results obtained and failure by the Test Engineer to verify the availability of the calibration data are a violation of 10 CFR 50, Appendix B, Criterion XII and the QA Manual Quality Requirement No. 12-0 and
is considered to be an item of noncompliance (373/81-20-19).
6.
Preoperational Test Procedure Verification The inspector verified that the following preoperational test pro-cedures appear to meet the requirements of Section 14 of the FSAR and were reviewed and approved by licensee management in accordance with the requirements of Regulatory Guide 1.68 and the licensee's QA Manual.
a. PT-FC-101, Fuel Pool Cooling b. PT-FR-101, Fuel Handling Equipment c. PT-NR-101A, Source Range d. PT-NR-101B, Intermediate Range e. PT-NR-101C, LPRM, APRM and RBM f. PT-NR-102, Traversing in Core Probe g. PT-SI-101, Seismic Instrumentation h. PT-VY-101, CSCS Equipment Cooling Water i. PT-0G-101, Off Gas j. PT-VY-102, CSCS Equipment Ventilation k. SD-WR-101, RBCCW l. SD-WS-101, Service Water m. SD-RT-101, Reactor Cleanup n. SD-CD-101, Condensate and Condensate Booster o. SD-CD-102, Condensate and Auxiliary Equipment p. SD-CW-101, Circulating Water and Auxiliary Equipment q. SD-CY-101, Cycled Condensate Supply r. SD-HD-101A, Heater Drain s. SD-HD-101B, Moisture Separators and Reheaters t. SD-FW-101, Reactor Feedwater u. SD-FW-102, Feedwater Control v. SD-CX-102, Rodworth Minimizer w. SD-CX-101, Process Computer 7.
Startup Procedure Review The inspector conducted an initial review of startup test procedure STP-3, " Fuel Loading" with the licensee. Final review of inspector comments will be performed during a future inspection.
8.
Unresolved Items Unresolved Items are matters about which more information is required in order to ascertain whether they are acceptable items, Items of Noncompliance, or Deviations. An Unresolved Item disclosed during the inspection is discussed in Paragraph 3.a.(8).
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9.
Exit Interview
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The inspector met with licensee representatives (denoted in Paragraph 1)
on July 2, 1981. The inspector summarized the scope and findings of the inspection. A telephone conversation regarding the inspection findings was conducted on July 22, 1981.
The licensee acknowledged the statements by the inspector with respect to the items of noncompliance (Paragraphs 3.a. (2), (3), (4); 3.b. (1),
(2), and (5).
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