IR 05000397/1988012
| ML17284A402 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 06/08/1988 |
| From: | Cicotte G, Cillis M, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17284A401 | List: |
| References | |
| 50-397-88-12, IEB-79-19, IEIN-86-023, IEIN-86-23, IEIN-87-039, IEIN-87-39, NUDOCS 8806290024 | |
| Download: ML17284A402 (20) | |
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report No. 50-397/88-12 Docket No. 50-397 License No.
NPF-21 Licensee:
Washington Public Power Supply System P.
O.
Box 968 Richland, Washington 99352 Facility Name:
Washington Nuclear Project No.
Inspection at:
WNP-2, Benton County, Washington Approved by:
Inspection Conducted:
April 25-27 and May 9-12, 1988 74~i
.
M.
Ci 1 lis, Senior Radi tion Specialist c.".4'.
R. Cicotte, Radiation Specialist Facilities Radiological Protection Section Date Signed c
Date Signed Date Signed
~Summau:
Ins ection on A ril 25-27 and Ma 9-12 1988 Re ort No. 50-397/88-12 Areas Ins ected:
Routine unannounced inspection by two regionally based inspectors of occupational exposure control during extended outages.
This included organization and management, training and qualifications, internal and external, exposure control, control of radioactive materials, contamination, surveys and monitoring, maintaining exposure ALARA, followup of open items, and a tour of the facility.
Inspection procedures 83729 and 92701 were addressed.
Results:
Of the nine areas addressed, no violations or deviations were identified.
In general, the licensee's programs were adequate.
However, more attention is needed in the:
(1) control of contractor and non Health Physics personnel and (2) control and posting of radiation'and high radiation areas (see paragraphs 10).
SHOAL 900 0 880~0'3 PDR ADDCK 0500 Q
DETAILS 1.
Persons Contacted
+G.
C. Sorensen, Regulatory Programs Manager
+C.
M. Powers, Plant Manager
" J.
W. Baker, Assistant Plant Manager M.
C. Bartlett, Plant guality Assurance Supervisor
" J.
R. Allen, Assistant Health Physics Supervisor
- +L. Bradford, Health Physics Supervisor
" D.
S.
Feldman, Plant guality Assurance/Control Manager
"+R.
C. Graybeal, Health Physics/Chemistry Manager
"+D.
E.
Larson, Radiological Programs/Instrument Calibration Manager
+J.
D. Mills, Senior Health Physicist (ALARA)
+G.
V. Oldfield, Radiological Assessment Supervisor
~ D. J. Pisarcik, Health Physicist, Support Services
"+V.
E. Shockley, Health Physics Support Supervisor
" K.
A. Smith, Radwaste Programs Leader D.
M.
Wer lau, Health Physics/Chemistry and GET Supervisor
~ D.
L. Williams, Nuclear Engineer (Bonneville Power Authority)
" Denotes those present at the exit interview held on April 27, 1988.
+Denotes those present at the exit interview held on May 12, 1988.
In addition to the individuals identified above, the inspectors met and held discussions with other members of the licensee's staff and personnel.
2.
~Fol 1owo A.
(Open) 50-397/88-01-GC:
This item refers to NRR review of the licensee's amendment 4 to the Offsite Dose Calculation Manual (ODCM)
as reported in the January to June 1986 Semi-Annual Effluent Release Report.
At the time of the inspection, the licensee had not been appr ised of NRR's concerns regarding some of the licensee's calculation methodology.
The licensee's amendment 5 to the ODCM had already been submitted.
Many of the concerns had already been addressed by amendment 5.
This matter will remain open pending an opportunity for the licensee to review NRR's concerns.
B.
(Open) IN-87-39:
This item refers to the licensee's efforts to address the issues of discrete radioactive particle control and exposures to personnel.
The licensee had implement some controls, but did not have a complete program (see paragraph 8) in place at the time of this inspection.
This matter will be examined in a subsequent inspection.
3.
Or anization and Mana ement Controls The licensee's Radiation Protection Organization and Management Controls that were implemented for the refueling outage were examined.
For the
purpose of the outage, the licensee had divided responsibilities between oversight of work conducted in the primary containment (drywell), the balance of the Reactor Building (RB), the Turbine Generator Building (TGB), and the balance of the plant (BOP).
This partial decentralization of recordkeeping and Health Physics (HP) coverage appeared to provide more direct'ontrol of outage activities.
The inspectors noted that contractor HP senior and junior technicians were hired to address the scope of work to be performed.
The licensee had also assigned HP experienced personnel from the Chemistry Department to assist the plant's radiation protection group during the outage.
Contractor Health Physics Technicians (HPTs) were under the direct supervisory control of the licensee's HP staff.
The Health Physics/Chemistry Manager had adequate authority and support to ensure the plant's radiation protection and chemistry programs were effectively implemented during the outage.
No violations or deviations were identified.
Audits and A
raisal The following licensee surveillances were examined:
Surveillance Title Date Closed 2"88-068 2"88-008 2-87-266 2-87-123 2-87-107 2-87-105 2-87-104 2-87"033 2-87-032 2-87-031 Control of Contamination at Area Boundaries HP Department Training Radiological Posting Radiation Work Permit Program Contamination Control Respiratory Protection Device Control of Usage Personnel Exposure Monitoring Dosimetry Radiation Exposure Records and Reports Radiological Surveys Personnel Exposure Monitoring/Dosimetry Open Open 12-1-87 10-30-87 5-18-87 5-15-87 7-8-87 3-6-87 3-23"87 5-8-87 Personnel performing audits/surveillances met the requirements of ANSI.
N45.2.23-1978,
"gualification of guality Assurance Program Audit Personnel Audit Personnel for Nuclear Power Plants.
The periodicity
.
requirements of Regulatory Guide 1.33 were met.
The response to one of the above audits was late, and the gA department requested a response to the identified deficiencies, The response was obtained and the report closed.
guality Assurance (gA) procedure PgA-03, Revision 8, dated October 14, 1986,
"Conduct of gA Surveillances,"
does not require a response to audit findings classified as "observations."
A formal response is required for
"Deficiencies".
Approximately half the above audits were closed as action complete, without a response to observations, in accordance with that procedure.
Observations are findings that address practices for which no specific requirement/ regulation has been deemed applicabl The audit on radiological posting identified a deficiency in that personnel failed to replace postings removed for ingress/egress to controlled areas.
The inspectors made similar observations of personnel not replacing postings (see paragraph 10).
No root cause or preventive actions were observed to have been determined for observations prior to closing many surveillance reports.
The licensee's audit program appeared adequate to accomplish its safety objectives.
No violations or deviations were identified.
Trainin and ualifications Resumes for, and training provided to contractor HPTs hired for the outage were reviewed.
The inspectors observed the following training sessions:
General Employee Training (GET)
General Employee Computer-based Training (CBT)
Respiratory Protection Training (RPT)
GET and CBT was consistent with 10 CFR 19. 12.
CBT had not yet included general training on hot particle exposure control.
RPT was consistent with the requirements of 10 CFR 20. 103 and NUREG 0041,
"Manual of Respiratory Protection Against Airborne Radioactive Materials."
The licensee uses screening examinations to help assure only qualified personnel are hired, prior to conducting training for contractor HPTs.
Senior HPTs hired for the outage all appeared to meet the qualifications of ANSI/ANS 3. 1, "Selection, gualification and Training of Personnel for Nuclear Power Plants.
The licensee's GET program was undergoing re-accreditation by INPO at the time of the inspection.
Currently, all required programs are accredited.
The licensee had an open audit finding which identified that some radwaste personnel had not been trained in accordance with IE Bulletin 79-19.
The audit had just been conducted (see paragraph 4).
Planned corrective action was to conduct the appropriate training in a timely manner.
No other examples of untrained personnel were observed.
No major changes to training since the last inspection (see Inspection Report 50-397/88-04)
were observed.
The inspectors noted that the licensee was just beginning to train HPTs in discrete radioactive particle control (see paragraph 8) at the time of the inspection.
In general, the licensee's training programs that were examined appeared adequate to meet their safety objectives.
No violations or deviations were identified.
External Occu ational Ex osure Control Audit findings in this area (see paragraph 4) were addressed adequately.
Root cause analyses and corrective actions did however, identify
programmatic weakness in the areas of record keeping and compliance with HP procedures.
No major changes to the licensee's dosimetry program had been made since the last inspection.
Planning and preparation for the'utage were adequate.
Representative personnel radiation exposure records, reports, and approvals to exceed licensee administrative limits were reviewed.
No instances of doses in excess of administrative limits without approval were observed.
No personnel had been approved to exceed the whole body dose limit of 10 CFR 20. 101(a) without a current form NRC-4 or its equivalent on file.
The licensee's Radiation Exposure Card (REC) system is reviewed daily.
Individuals sign on Radiation Work Permits (RMP) and indicate RMP numbers, date/time, and dose received on the REC each time they enter/exit.
This assures that individuals are provided with a report of their cumulative and available radiation dose each time they enter the radiologically controlled area (RCA).
The licensee's dosimetry program is in the process of being recertified by NVLAP.
The licensee's thermoluminescent dosimetry (TLD) processing system provides a backup TLD crystal for each TLD exposure.
Gamma, neutron and beta exposures and anomalous readings were reviewed and analyses by the licensee appeared adequate.
The licensee issues a
special whole body TLD with extremity dosimetry to differentiate whole body dose, for specific tasks, from the periodic TLD reading.
Radiation exposure records were being maintained in accordance with Regulatory Guide 8.7, "Occupational Radiation Exposure Records Systems."
The licensee's staff stated that no overexposures of individuals, reportable in accordance with 10 CFR 20.403 and 20.405, had occurred in 1988.
The licensee was observed to be in compliance with 10 CFR 20. 104.
Administrative controls on personnel access, dose control, and use of RWPs appeared adequate, and had not changed since the last inspection (see Inspection Report 50-397/88-04).
The licensee seemed to be maintaining their previous level of performance in this area and their controls appeared adequate to accomplish its safety objectives.
No violations or deviations were identified.
Internal Ex osure Control and Assessment No recent audits of internal exposure assessment had been performed at the time of the inspection.
An audit of respiratory protection equipment use had identified no deficiencies and other findings were primarily administrative in nature (see paragraph 4) ~
The audit was closed in a timely manne No major changes to respiratory protection or internal exposure control had been made since the last inspection.
The licensee depends on the extensive use of contamination enclosures and temporary ventilation units to reduce the size of areas requiring respirator use.
Other preparation for the outage consisted primarily of plans to aggressively decontaminate work areas to prevent contamination spread.
These measures were observed to be effective.
One concern the inspectors had was related to the reuse of face/eye/head protection in contaminated areas.
Numerous faceshields, welders'asks, and hard hats were observed to have been left in contaminated work areas.
Yellow hard hats are designated by the licensee to be used, placed in receptacles for used hats, wiped down, and placed in receptacles for re-use.
Personnel were observed to not be following this policy, by leaving hats in re-use bins, or using hats from the used bin or from the work location.
The licensee stated that no specific program similar to the hard hats was in place for other equipment such as face shields or welders masks.
The inspectors discussed the high potential for facial contamination or inhalation of particles adhering to contaminated face protective devices (hard hats, face shields, welders masks) with the licensee at the exit interview.
An examination of individual dose records and personnel contamination reports revealed numerous minor facial contaminations.
All those reviewed (approximately 25 reports)
revealed that the appropriate dose evaluations or bioassay results were included in the record.
The licensee stated at the exit interview that they would review their policies,to reduce the potential for uptake of radioactive material from the use of face shields/welders masks.
Whole body counting results for several individuals with facial contamination were reviewed.
No exposures to airborne radioactivity in excess, of the limits of 10 CFR 20. 103 were observed.
Respiratory protective equipment was adequate for the outage.
The licensee makes extensive use of airline respirators in order to provide greater worker comfort and more protection when the potential for large multiples of the MPC exists.
The licensee seemed to be maintaining their previous level of performance in this area and their program appeared adequate to accomplish its safety objectives.
No violations or deviations were identified.
Control of Radioactive Materials and Contamination Surve s
and
~Monitor in With the exception of correlation of similar findings in different areas, as discussed in paragraph 4,
no concerns were identified by review of the audits.
No major changes had been made since the last inspection.
I
, 6 The licensee had sufficient equipment to perform surveys and monitoring.
One contamination monitor (frisker), and two continuous air monitors (CAMs), available for use, were observed to have not been source-checked as required by the licensee's procedures.
These instruments were checked satisfactorily when brought to the attention of the licensee.
Personnel contamination monitoring practices and equipment frisking habits were observed.
Personnel skin contamination reports contained sufficient data for assessment of personnel exposure.
Instrument operation was discussed with several HP technicians.
The only concern identified by the inspectors was a lack of familiarity by HPTs with the ion chamber instrument modified by the licensee for pore efficient beta radiation detection.
The modifications were consistent with industry standards for enhanced beta detection.
The licensee's program for control of contamination, at the time of the inspection, did not include proceduralized controls for work involving exposure to discrete radioactive particles.
Many of the measures were in place, but the licensee's procedure, scheduled for implementation as procedure 11.2.7.4,
"Discrete Radioactive Particle Control", had not been signed for approval by May 11, 1988.
The procedure was awaiting final approval after the Procedure Oversight Committee (POC) completed their review on April 27, 1988.
The licensee had received Information Notices (IN) 86-23"and 87-39, both related to control of particles.
The licensee stated that the reason for not fully implementing the program was that they wanted to thoroughly address all aspects, in order to avoid too hasty a decision on how to implement the controls.
The inspectors expressed the concern that if controls and monitoring were not performed, hot particle exposures would remain undetected, in a meeting with licensee HP management on May ll, 1988.
On May 16, 1988, NRC Region V
received Revision.0 to 11.2.7.4, dated May 11, 1988.
Observations of surveys being performed by HPTs disclosed no problems.
The only poor practice observed in the area of contamination control appeared when grinding was being performed in the east valve gallery on the 467'levation of the Radwaste building, Grinding material was spewing out of a tent into the uncontaminated area due to improper tent construction.
When brought to his attention, an HPT assigned to cover the work corrected the problem by redirecting the workers'fforts, repairing the tent and performing a survey.
P The licensee recently obtained a monitor for:detection of low levels of radioactivity in bags of potentially contaminated waste.
The licensee expects to significantly reduce the volume of compacted waste by use of a new bag monitor which will be used to monitor clean uncontaminated materials for unrestricted disposal.
The licensee appeared to be maintaining their previous level of performance in this area and their program appeared adequate to accomplish their safety objectives.
No violations or deviations were identified.
Maintainin Occu ational Ex osures ALARA
No recent audits of the ALARA program had been conducted and no major changes had been made to the ALARA program since the last inspection.
The following licensee records/documents were reviewed:
40 completed ALARA Program Review Records (APRRs)
27 active Radiation Work Permits (RWPs)
Workers with whom ALARA principles were discussed appeared to understand the purpose of the program.
The licensee has a program for soliciting ALARA suggestions from workers, though this appears to be under-utilized.
All major work was being reviewed by the licensee's ALARA group, and reviews appeared appropriate to the tasks.
The ALARA'oordinator stated that many of the ALARA reviews were delayed until the start of the outage, since the work requests were not submitted for review in a timely manner prior to the commencement of work, and consequently many reviews were performed "at the last minute."
The licensee's ALARA goals.and objectives for the outage appear reasonable and are being tracked by the ALARA Supervisor.
ALARA goals for total dose expenditure and planning were consistent with scheduled work.
The licensee used mockup training effectively for work with a high potential for large exposures.
The licensee seemed to be maintaining their previous level of performance in this area and their program appeared fully capable of accomplishing its safety objectives.
No violations or deviations were identified.
The inspectors conducted several tours of radiologically controlled areas in the reactor building, drywell, radwaste building, turbine building, and the laundry facility.
Independent radiation surveys were conducted using an ion chamber survey instrument model R0-2, Serial Number 015843 that was due for calibration on July 13, 1988.
The inspectors observed that in the following controlled areas a portion of the radiological postings had been removed, presumably for ingress/egress, without having been replaced in their proper position:
a.
Control Rod Drive Mechanism (CROM) maintenance
.area 501'B contaminated area, radiation area, sign down to one side.
Residual Heat Removal (RHR)'B'eat exchanger room 548'B contaminated area, high radiation area, sign obscured by open door.
In this instance, workers in the area were appropriately monitored and were aware of the radiological status of the roo C.
Main steam line tunnel 501'B contaminated area, radiation area, sign hooked on one side such that although present, it could not be read without turning it around.
d.
CRD accumulator area 522'B radiation area posting/rope dropped on one side by worker, who left for 10 minutes and replaced the sign upon returning after he saw the inspector.
The licensee, when informed of the above by the inspectors, restored the postings.
The inspectors observed the following practices that were inconsistent with the licensee's procedures:
A large percentage of workers wore protective clothing hoods, prescribed by their respective radiation work permits (RWP), tied back such that the sides of the head and neck were uncovered.
HPTs (12 Senior and 6 Junior HP Technicians) with whom this matter was discussed stated various reasons why this practice was acceptable, unacceptable, or why they did not view the practice as within their purview.
This practice was observed in areas with contamination levels as determined by licensee surveys ranging from 1000 to 100,000 dpm/100 cm~.
When this was discussed with the licensee, the Health Physics/Chemistry Manager immediately addressed proper protective clothing use with workers.
The Health Physics Supervisor stated that they were attempting to determine how the practice was initiated.
At 6:00 A.M. on May 10, 1988, a survey by the inspectors revealed that the RHR pump 2C room on the 422'levation of the RB exhibited radiation dose rates in a major portion of the room of 3 to 12 mr/hr, outside the boundries a small area posted as a radiation area surrounding a pipe later identified by the licensee as a floor drain line from the 606'levation of the RB.
'
boundary verification survey had been performed by the licensee at 8:45 p.m.
on May 9, 1988.
The last specific survey of the posted area was conducted May 5,
1988 at 1:30 p.m., indicating 8 mr/hr inside the boundary.
The licensee's procedure, 11.2.7. 1 revision 4, "Area Posting" requires that areas 2.5 mrem/hr or higher be posted and barricaded.
Two electricians entering the room while the inspectors were present were unaware that work they were scheduled to perform was in a radiation area outside the roped area.
When the situation was brought to the attention of the HP Supervisor, he stated that a change in radiological conditions probably resulted from drainage of liquids through the floor drain line in conjunction with local leak rate testing (LLRT) of various contaminated systems.
The inspectors expressed concern that evolutions resulting in deterioration of radiological conditions could occur without the knowledge of health physics, or that health physics personnel may not recognize probable impact of evolutions involving movement of materials or liquid.
The licensee's radiation protection staff took immediate action to resurvey and repost the ar e Technical Specification 6. 12.2 states, in part:
"...For individual areas accessible to personnel with radiation levels such that a major portion of the body could receive in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> a dose in excess of 1000 mrems that are located within large areas, such as the containment, where no enclosure exists for purposes of locking, and no enclosure can be reasonably constructed around the individual areas, then that area shall be barricaded, conspicuously posted, and a flashing light shall be activated as a warning device...."
At approximately 8:40 a.m.
on May 10, 1988, during a tour of the
, primary containment (drywell), a light which had been placed near a
highly radioactive RWCU drain line was observed to not be flashing.
Dose rates obtained previously by the licensee indicated 5 R/hr at 18" from the shielded line.
Upon exiting the drywell at approximately 9:30 a.m.,
the inspectors noted that the HP log for the drywell control point indicated that all such lights had been working at 6:40 a.m.
and at 8:30 a.m.
No previous entries to the effect -.that areas of greater than 1000 mr/hr were denoted by flashing yellow lights were contained in the log.
The licensee later that morning stated that although no specific instructions or program had been implemented to ensure continued operability of the flashing yellow lights, each shift had been instructed henceforth to check and record in the. log that such had been done.
Pursuant to 10 CFR 2, Appendix C, Part V, Subpart A.
Notice of Violation, licensees are not ordinarily cited for violations resulting from matters not within their control, such as equipment failures that were not avoidable by reasonable licensee quality assurance measures or management controls.
As the licensee had initiated periodic examinations of the lights at approximately the time the failure was noted, to assure the continued warning function, this was determined to be a reasonable measure.
The licensee's staff informed the inspector that appropriate radiation protection procedures would be revised to require that shiftly operability checks be performed.
An area posted "Caution," "Radiation Area," "up to 15 mr/hr,"
"Pass-Thru Area," in the radwaste building, 437'evel, was surveyed.
Accessible whole body dose rates in the area, next to a protective clothing dressout area located adjacent to Equipment Drain Retention Tank (EDRT-5), ranged from 5 to 60 mr/hr, with contact readings on EDRT-5 of 200 mr/hr.
An area by a floor drain tank (FDR-9) and off-gas monitoring equipment was located nearby, with whole body dose rates less than 1 mr/hr.
When the dressout area was discussed with the licensee, they stated that it was placed where it was due to fire protection considerations, and that the dose rates had changed due to filling of EDRT-5.
The licensee immediately performed a survey and corrected the posted dose rates and relocated the dr essout area.
At approximately 7:30 a.m.
on May 12, 1988, the senior resident inspector (SRI) informed the inspectors that the radiologically
controlled area (RCA) boundary had been modified for work in the Diesel Generator (DG) building.
He stated that the RCA boundary had been moved from the outer to the inner door, and that he had observed a previous occurrence for which no survey was available to demonstrate that the area could be released for unrestricted use.
This was discussed with the HP Supervisor, who stated that the boundary was not modified at that time, and that security personnel would call HP when they were ready to open the door and move the boundary.
The manner in which the licensee s facility was arranged was such that personnel would have to sign on a routine RWP to enter the DG building, and exit back to the main corridor, leaving the RCA via the portal monitors and frisking stations, thus assuring appropriate monitoring.
At approximately 8:00 a.m.
on May 12, 1988, the inspectors observed that the RCA 'boundary at the DG ¹1 room had been removed.
Discussions with security personnel, workers in the room, and HP personnel revealed the following:
a
~
RCA boundary signs read as follows:
"RADIOLOGICALLYCONTROLLED AREA BOUNDARY"
"No uncontrolled entrance [exitj at this point"
"Health Physics must be present prior to opening" b.
Work being conducted in the DG ¹1 room had been going on for several days.
The practice had been to survey the room, block access and place boundary signs at the inner door, remove the postings at the outer door, and allow non-RWP work to proceed from outside the building.
At completion of a day's work, the postings would be restored and access allowed normally from the inside of the RCA.
C.
Health physics personnel were not aware that work had resumed, and thus no survey had been performed and HP personnel were not present.
Security personnel, who had to open the outer door as a vital area boundary, did not specifically recall having informed HP personnel of the change in access.
d.
The RCA boundary had been restored at completion of daily work on May ll, 1988, and access from within the RCA restored.
At 5:56 a.m.
on May 12, 1988, Security personnel opened the outer RCA boundary door and locked the inner door of the DG¹l room.
Between 5:56 a.m.
and 8:02 a.m.,
33 persons entered the room for maintenance on DG¹1.
e.
The boundary signs at the outer door had been removed or covered.
Temporary RCA boundary postings were available, but had not been placed in position.
At approximately 8: 15 a.m.,
when informed of the status of the room, HP personnel suspended access to the room, monitored all personnel who had been inside, and performed a survey of the
room to resume access for maintenance.
No contamination was found.
The temporary postings were then positioned.
The inspectors discussed the potential for degradation of radiological conditions without the knowledge of HP personnel with the Health Physics/Chemistry Manager.
He stated that a method of assuring that HP is informed of such changes would be developed.
Licensee procedures address conduct of personnel in radiologically controlled areas, and the necessity of adherence to HP instructions and postings is emphasized in general employee training.
Several HP technicians stated it was not their responsibility, and they would not exercise initiative, to suggest changes in practice to workers, unless clear violations of HP procedures were involved.
The inspectors discussed the potential impact of less than voluntary compliance by other departments with the Health Physics/Chemistry Manager and at the exit interview.
The licensee's performance in this area appeared to be weak and seemed marginally capable of meeting its safety objectives.
The inspectors emphasized the importance for increasing the overview of work activities through increased audits/surveillances and HP tours as a means for improving their performance in this area.
No violations or deviations were identified.
ll.
Exit Interview The inspectors met with those individuals denoted in paragraph 1 on April 27, 1988 and May 12, 1988, at the conclusion of the inspection.
The scope and findings of the inspection were summarized.
The licensee acknowledged the inspectors'oncerns and stated that corrective action to address the inspectors'oncerns noted in paragraphs 7 and 10 would be conducted.