IR 05000416/1989020
| ML20248C914 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 09/26/1989 |
| From: | Adamovitz S, Decker T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20248C909 | List: |
| References | |
| 50-416-89-20, NUDOCS 8910040061 | |
| Download: ML20248C914 (12) | |
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t UNITED STATES g-
,g NUCLEAR REGULATORY COMMISSION
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REGION 11 o,g 101 MARIETTA ST., N.W.
4m, ATLANTA, GEORGIA 30323 SEP 2 6 B89 Report No.: 50-416/89-20 Licensee:
System Energy Resources, Inc.
Jackson, MS 39205 Docket No.:
50-416 License No.: NPF-29-Facility Name: Grand Gulf Inspection Conducted: August 28 - September 1, 1989 Inspector: v we4 R
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9/4[M S. S. Adamovitz p
[ fate Signed Approved by:\\ //zence4 [
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9 6/A'9 T. R. Decker, Chief Oate' Signed Radiological Effluents and Chemistry Section Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards i
SUMMARY Scope:
This routine, unannounced inspection was conducted in the areas of liquid and gaseous effluents, plant chemistry, environmental monitoring and follow-up on two employee concerns.
Results:
In the areas inspected, violations or deviations were not identified.
The licensee' had maintained an adequate program to control radioactive effluents (Paragraphs 3, 4, and 5) and had initiated several program and equipment up in a continued effort to improve chemistry control (Paragraph 7) grades
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Two employee concerns were reviewed and were not substantiated (Paragraph 8).
The concerns dealt with unreported releases and a missed chemistry surveillance.
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REPORT DETAILS 1.-
Persons Contacted Licensee Employees-G. Anderson, Environmental Coordinator
.J. Antoine, Chemical Engineer R. Buckley, Environmental Specialist G. Coker, Water Treatment Specialist D. Crawley, Radiochemist
- W. Eiff, Principle Quality Engineer G. Ellis, Manager, Security
- C. Hayes Quality Programs Supervisor
- C. Hutchinson, General Manager J. Lassiter, Chemistry / Health Physics Specialist
- F. Mangan, Director, Plant Projects and Support K..O'Neal, Chemistry Shift Supervisor
- R. Patterson, Technical Assistant, General Manager S. See, System Engineer
- G. Smith, Chemistry Superintendent
- J. Summers, Compliance Coordinator
- T. Williamson, Chemistry Supervisor
- M. Wright,. Manager, Plant Support
- J. Yelverton, Manager, Plant Operations
- G.~ Zinke, Licensing Superintendent NRC Resident Inspector
- J. Mathis
- Attended exit interview 2.
Audits (84750)
The inspector reviewed the following audit reports:
QSA-88/0034 " Implementation and Effectiveness of the Radiological Monitoring), Program - Effluent Streams and the Environment (Regulatnry Guide 4.10 " November 7, 1988.
QSA 89/0002
" Radiological Environmental Monitoring Program and Non-Radiological Environmental Protection Plan," February 16, 1989.
QSA-89/0012. " Effectiveness, Programmatic Adequacy and Implementation of Various Programs Governing the Qualification, Certification, and Training of Plant Staff, Training, Plant Modification and Construction, Nuclear Licensing and Nuclear Support Personnel," August 10, 1989.
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The audits appeared indepth with positive and negative findings documented.
Negative or deficient items were assigned numbers for tracking purposes and corrective actions were often completed during the audit.
No violations or deviations were identified.
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3.
Semiannual Radioactive Effluent Release Reports (84750)
The inspector reviewed the licensee's Semiannual Radioactive Effluent Release Reports for the last half of 1988 and the first half of 1989. The effluent release data summarized in Table A were obtained from current and previous release reports.
TABLE A EFFLUENT RELEASE SUMARY FOR GRAND GULF (First half)
Activity Released (curies)
1986 1987 1988 1989 1.
Gaseous Effluents Fission and Activation Products 1.34E+2 2.08E+2 9.44E+1 3.93E+1 Iodines and Particulate 4.85E-4 4.28E-3 4.90E-4 2.49E-4 2.
Liquid Effluents Fission and Activation Products 3.01E-1 3.64E-1 3.96E-1 2.10E-1 Tritium 1.47E+1 1.83E+1 1.34E+1 7.84E0 The reports appeared to be complete and to contain the information I
specified in Regulatory Guide 1.21.
The licensee did not identify any liquid or gaseous unplanned releases for the last half of 1989 or the I
first half of 1989, and also did not identify any monitors inoperable for l
greater than 30 days.
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In examining the effluent data, the inspector noted high liquid fission and activation product activity for the third quarter of 1988.
The licensee verified that the reported number was correct and determined that the elevated activity was due primarily to Cr-51.
In general, the slow increase of liquid fission and activation products from 1986 to 1988 was attributed to plant age and not to any particular operational incidents.
No violations or deviations were identified.
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4.
EffluentMonitoringInstrumentation(84750)
The inspector, accompanied by two licensee representatives, toured selected effluent monitoring stations and verified the operability of recorders and monitor read-outs in the control room.
The inspector reviewed monitor cali% tion and functional test packages for the following monitors:
Containment Building Ventilation Gaseous Monitor, June 11, 1989 Radwaste Building Ventilation Gaseous Monitor, July 11, 1989 Turbine Building Ventilation Gaseous Monitor, September 17, 1988 Fuel Handling Area Gaseous Monitor, June 6, 1989 Offgas Post Treatment Gaseous Monitor, October 18, 1988 The examined records appeared complete and the calibrations were performed within the required time pariod.
No violations or oc.iations were identified.
5.
Liquid and Gaseous Releases (84750)
a.
The inspector observed the valve lineup, sampling, and calculations for the release of a liquid waste monitor tank. The inspector noted that an approved procedure was used and that the personnel performing the release appeared knowledgeable of the system and release requirements.
The liquid pre-release analysis was performed per procedure 06-CH-SG17-P-0041 "Radwaste Release Pre-release Analysis,"
Revision 25, July 20, 1989.
The sample was analyzed by gamma spectroscopy and isotopic concentrations were calculated by a computer program.
The inspector noted that liquid releases were allowed if the radwaste monitor was inoperable provided that two independent samples were analyzed and the that release rate calculations were independently verified by two qualified chemists.
The requirements were specified in the procedure 06-CH-SG17-V-0034 l
"Radwaste Release Inoperable Radwaste Monitor Pre-release Analysis" l
Revision 24, July 20,1989.
The inspector examined ten pre-and post-relcase packages from February 1988 to August 1989, and verified that the packages were complete per procedural requirements.
During 1989, the licensee had acquired new software for nuclide identification from gamma spectroscopy systems and had translated the original effluent sof tware to the new computer code.
The replaced effluent software had been in use since July 1989, and the inspector examined comparison nuclide and effluent packages for software verification.
The licensee also performed analyses of test cases of known standards to verify the software.
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b.
-The inspectors reviewed 33 gaseous release packages from February 1988 to August 1989 for the facility's gaseous effluent points:
Containment vent, Turbine Building vent, Fuel Handling Area, Radwaste_ Building vent, Offgas vent, and Standby Gas Treatment.
If the gaseous effluent monitors were not operable, releases were-allowed to continue provided grab samples were collected and analyzed within a specified time period.
These requirements were documented in - the procedure 06-CH-1D17-V-0032, " Inoperable Gaseous Monitor Analysis," Revision 26, July 20, 1989.
No violations or deviations were identified.
6.
. Leak Testing of High Efficiency Particulate Air (HEPA) Filters and Charcoal Absorbers In Ventilation Treatment Systems (84750)
The inspector reviewed four methyl iodide laboratory tests of charcoal samples for the Standby Gas Treatment system and the Control Room Filtration system conducted during 1988-1989.
The inspector noted that the results of three tests were within TS requirements. The charcoal bed for train A of the Control Room Filtration system initially failed the test conducted May 19, 1989.
However, the bed was replaced with new charcoal which passed the laboratory test May 26, 1989.
The "A" filter train was then leak tested May 29, 1989 with acceptable results.
The inspector also reviewed the test packages and results of in-place leak tests for the following systems:
Standby Gas Treatment Train A September 20, 1988 Standby Gas Treatment Train B September 21, 1988
Control Room Filtration Train A May 29, 1989 Control Room Filtration Train B September 22, 1988 Off Gas After Filtration Train B October 13, 1988 Off Gas After Filtration Train B October 13, 1988 The results of all system tests appeared to be adequate.
No violations or deviations were identified.
7.
Plant Chemistry (84750)
a.
Protection against ingress of corrodants from plant cooling systems.
Through discussions with cognizant licensee representatives, the inspector determined that the following actions were being taken to prevent microbiological attack of cooling water pipe and heat exchangers by the plant service water.
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(1_) Main Cendenser
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The licensee was continuing to control slime and bacteria, as well as prevent the precipitation of' iron oxides, by-the addition of chemicals.
A mechanical cleaning ~ system (Amertap)-
that used recyclable sponge. balls.. to continuously clean the condenser tube inner diameters' and help: prevent fouling of the
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stainless steel tubes had been installed in 1988.
The licensee
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had experienced few. problems with' pitting in the t'ubes and the Amertap system increased the efficiency of.the condenser by.
preventing scale formation.
.(2) Standby Service Water (SSW)
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The licensee had experienced problems with microbiological 1y
' induced corrosion (MIC) in the SSW system.
The - MIC had concentrated in the areas of the A and B loop inlet piping and
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little corrosion was evident on the actual heat exchanger tubes.
Chemical cleaning of the SSW had been performed in 1987 for loop A and in 1989 for loop B.
The chemical cleaning consisted of the following basic steps:
Iron deposits were initially conditioned by the addition of a tannin solution to penetrate and loosen the corrosion products by forming an iron-tannin complex.
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Iron removal was accomplished by the addition of sulfuric acid to lower theLpH to 2.3 and by the addition of citric acid to solubilize the iron-tannin complex.
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After deposit removal, the system was thcn drained, refilled, and treated with a molybdate solution to promote passivation of the " clean" metal surface, and a biocide to reduce bacteria levels.
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During 1987, the licensee removed approximately 6000 pounds of iron oxide from loop A system piping as a result of the chemical cleaning.
During 1989, approximately 8000 pounds of iron oxides had been removed from loop B.
Flow testing of the SSW after cleaning indicated full recovery of design flow, with no
' blockage of piping or heat exchanger tubes from loosened corrosion products.
The inspector examined loop B heat exchanger flows which showed an average increase of approximately 17 percent following the cleaning.
The licensee was not planning to perform chemical cleaning of the SSW system during the next outage.
The licensee was currently evaluating mechanical, chemical, and operational changes in the SSW water treatment program to prevent MIC.
Mechanical changes included system aeration, removal of stratification in the SSW basin and possibly side-stream
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filtration.
A proposed operational change. included.
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. recirculating the water i_n the SSW basin on a more 3 frequent.
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- to-relieve stagnation or. to perform a chemical addition.
The
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the.' system.
Rather than adding chemicals in: the~ SSW basin,
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-additions would take place in-plant. and 'an injection line had
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been added to _ loop B. during the past '1989-refueling outage.. The
. installation of a chemical injection line for loop A was planned
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for the next. refueling outage during October 1990.
The licensee-had also' purchased a scale model of the SSW basin to assist in
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modeling chemical additions and ider.tifying flow patterns.
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. order to monitor system corrosion without having to open-the SSW system, the licensee was planning to place a series.of coupons l
in a sidestream off the'SSW basin.
Installation of-the coupons i
was planned for November 1989.
I (3) Turbine Building Cooling Water During 1987, the licensee began a molybdate treatment program
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for corrosion control.
Currently, the licensee was monitoring -
j pH, molybdate, ameoba, and legenella concentrations in this j
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(4) Summary i
The licensee had increased its efforts to prevent degradation of
the condenser and heat exchangers cooled by SSW and by Turbine i
Building Cooling water. A MIC task force had been formed during i
1988 to determine which pipes would require replacement.
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far, the licensee _ had not-experienced problems with clam
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infestations in the heat exchangers or system piping.
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b.
Water Makeup System
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A second pathway for ingress of contaminants into the reactor coolant
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was through makeup of condensate /feedwater.
The licensee had experienced problems with the facility's original water treatment plant due to corrosion of drain lines associated with the l
_ regeneration. of ion exchange demineralizers.
During 1987, the (
facility had opted to use temporary vendor-supplied systems to produce makeup water in the range of 0.065 umho/cm conductivity, l
100-200 ppb total organic carbon (TOC), and 50 ppb silica.
Biocides were also added to reduce biological fouling in the Servu.e Water System and to eliminate scale formation in the Chulating Water System.
The biocides, fed upstream of the Makeup Water Treatment System intake, were determined to be non-ion exchangeable and.
elevated the TOC of the makeup water.
The plant then opted to feed biocides on a six hours on/six hours off basis and to produce makeup water only when the biocide was not being fed. This program improved TOC levels in the makeup water but led to an increased fouling rate
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of the plant's heat exchangers.
The licensee evaluated several options to improve makeup water chemistry, and during April 1988, a vendor supplied triple membrane demineralized system was installed.
Water treatment from this system consisted of five separate stages.
The first stage of initial retreatment consisted of multimedia and charcoal filtration.
Ultra filtration was the second stage followed by electrodialysis reversal which served as the primary demineralized.
The third stage consisted of a' reverse osmosis (RO)
unit with a thin film composite membrane.
The R0 unit removed approximately 97 percent of the remaining minerals 85 percent of the TOC, and 94 percent of the total dissolved solids.
The water was then passed through the fourth stage, an ion exchanger deminaralizer, and the final stage, ultraviolet sterilization for TOC removal. The system consistently produced makeup water at the rate of 50 gallons per minute and water quality of 0.056 umho/cm conductivity and 3 ppb TOC.
In the one and a half years that the treatment system has been used, the plant has experienced no down time.
c.
Laboratory Facilities and Instrumentation The licensee was planning a renovation of both the clean and hot laboratories during 1989.
The laboratory areas were to be expanded by taking over part of the facility's original water treatment plant.
This expansion would double the available laboratory space.
During the past refueling outage (April 17 - May 5,1989), inline analog conductivity and dissolved oxygen monitors for the reactor water, condensate, and radwaste systems were replaced with digital monitors.
For the next refueling outage, the licensee planned to replace the inline pH meter for the condensate system and to insert an inline pH meter for the reactor water.
An inline ion chromatograph for the condensate and final feedwater systems had been inservice since May 1989.
The ion chromatograph's lower limit of detection for anions was determined to be 0.5 parts per trillion.
d.
Review of Reactor Coelant Chemistry Controls The inspector reviewed summary 1988 and 1989 chemistry data for the reactor coolant.
Typical values for chloride, sulfate, and silica concentrations were less than 1 ppb, 4 ppb, and 180 ppb respectively.
Conductivity values averaged 0.176 umho/cm for the past fuel cycle and currently ranged from 0.14 to 0.15 umho/cm.
Typical dose equivalent iodine values for 1988 and 1989 ranged from E-5 uCi/gm to E-4 uCi/gm.
From the data reviewed, the inspector determined that the licensee had maintained chemistry parameters within technical specification (TS) requirements for plant operational conditions.
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Conclusions The inspector verified that the chemistry control requirements of TS 3/a.4.4 had been met since the last inspection. The licensee was
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continuing to take positive actions to implement chemistry criteria recommended by the Steam Generators Owner's Group and the Electric Power Research Institute.
Thus far, the plant had not detected intergranular. stress corrosion cracking (IGSSC) in the recirculating water systems. The licensee was. knowledgeable of the problem and was utilizing the 1ctest techniques of non-destructive examination to test for IGSCC.
No violations or deviations were identified.
8.
LnployeeConcerns(99014)
a.
Statement of concern:
During December 1987 on the midnight shift a water chemistry surveillance was missed.
A TS required sampling on four hour intervals and the workers were instructed to perform the surveillance at 3.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> intervals in order to preclude the possibility of missing the four hour TS limit.
The surveillance was performed within the original time limit but the sample was invalid since it was collected from a point of no flow.
A subsequent sampling was performed at a
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valid sample point but, by that time, the four hour time limit had been exceeded.
Inspection of concern:
The inspector determined that the plant was in a refueling outage from October 1987 to January 1988 which would include the time period of the allegation.
During November and December 1987, the plant was in either Mode 4 (cold shutdown) or 5 (refueling).
TS 4.4.4.c required that the conductivity of the reactor coolant be recorded continuously or, if the continuous recording conductivity monitor was inoperable, an inline conductivity measurement was required to be made at least once per four hours in operational conditions 1, 2, and 3, and at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at all other times.
Since the plant was in Mode 4 or 5 during this time period, 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, not four i
l hour sampling, would have been required. The plant did enter station
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initiated limiting conditions for operation (LCO) during November and December 1987 due to inoperable inline conductivity meters.
The inspector reviewed LCOs 87-1203, 87-1470 and 87-1512 which required 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> sampling. The inspector also examined November-December 1987 entries in a Chemistry log book which was an informal record of chemistry activities.
The cloth bound notebook listed the LCOs and the required 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> sampling. Additionally, the inspector examined the LC0 forms which documented the surveillance requirements and sampling dates.
On November 26, 1987, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> sampling requirement was exceeded by one hour and 10 minutes.
The inspector examined the incident report IR 87-11-19 which documented the missed surveillance. On this date, Chemistry personnel were performing 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> conductivity L______________-
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readings asL required' by LCO 87-1203 and the next sample was due
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. November 26, 1989.01:30a.m._
The plant had two ' sampling points for reactor water; the residual. heat removal (RHR)_ loop A or the reactor-recirculation pump' -(RRP)'.
Chemistry personnel had ' checked ^ the Chemistry night orders and current data sheets to' determine a valid'
sampling point.
The information from the two reports. conflicted and y
. the chemist chose RHR-A as required by the. night orders issued -
November 23, 1987.. Samp. ling was performed at 1:10 a.m. but the chemist noted abnormal. readings,for conductivity. After checking the sampling equipment, Chemistry contacted Operations:for assistance.
~ valves to RHR-A-were/not open and Operations : deMrmined ' that the
'that the sampiv had been collected'from aLpoint of no flow..A sample was then collected'from RRP at 02:40 a.m.
By this time, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> sampling had been exceeded.
However, the licensee's review of the
,u incident concluded that the sampling and analysis was being performed under TS surveillance requirement 4.4.4 and was completed within the allowable extension of 25 percent of the. surveillance. interval by TS 4.0.2 The licensee's corrective actions to prevent recurrence included counseling Chemistry personnel to verify valve lineups prior to sampling and revising of selected Chemistry surveillance procedures to include verification and sign-off for' sample path lineups.
During the - current inspection, the RII inspector and resident-inspector contacted the NRR project manager for Grand Gulf.
The project manager verified that the 25 percent extension of the surveillance interval was applicable to this situation.
Conclusion:
Ouring 1987, a.24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> sampling surveillance was exceeded by one-hour and 10 minutes.
However, since the 25 percent extension of the
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surveillance interval was applicable, the water chemistry surveillance was not missed. This concern was not substantiated.
b.
Statement of concern:
There were two unreported releases.
Inspection of concern:
Since this concern was general and did not provide details of specific incidents, the inspector reviewed the licensee's program for quantifying and documenting radioacthe releases.
The procedure 01-S-08-11, _ " Radioactive Discharge Controls,"
Revision 10, February 23, 1989, established the responsibilities and requirements for completing pre-release and post-release discharge permits, and established that the Shift Superintendent was responsible for all releases during his shift. Pre-release and post-release calculations for liquid radwaste release were described in the procedures 06-CH-SG17-P-0041'
"Radwaste Release Pre-release Analysis,"
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Revision 25, July 20, 1989, and 06-CH-SG17-0-0043, "Radwaste Release Post-Release Calculation," Revision 25, February 21, 1989.
The licensee also maintained a procedure for liquid releases from the SSW.
Process and effluent monitor calibrations were described in the facility's surveillance procedures, and the conditions to allow releases with inoperable monitors were also described in separate procedures.
The administrative procedure 01-S-06-5 " Incident Reports / Reportable Events," Revision 18, January 3,1989 documented the methods for documenting, investigating and reporting abnormal events at the plant.
As indicated in Paragraph 5.a, the inspector observed the valve lineup, sampling and calculations for the release of a liquid waste monitor: tank.
The sample was analyzed by gamma spectroscopy, and isotopic concentrations and dose commitments were calculated by a computer program.
The inspector examined ten pre-and post-release packages for liquid releases from February 1988 to August 1989 and verified tFrt the packages were complete per procedural requirements.
The inspector also examined 33 gaseous release packages from February 1988 to August 1989, and determined that the packages were complete.
Additionally, six effluent monitor calibrations and functional test packages were reviewed.
The licensee maintained a computer base of incident report (IR)
summaries.
A file sort was requested bcsed upon abnormal discharges or releases, and 14 IR summaries from 1982 to 1988 were reviewed.
The reports indicated that the licensee had a procedure in place to document and report any unusual releases.
The inspector further determined that the Chemistry department was responsible for sampling and analysis of effluent streams but Operations personnel performed valve lineups for releases.
Also sampling, analysis, calculations and approval for releases were not performed by a single individual within the Chemistry department.
Conclusion:
The licensee maintained a program to adequately monitor, control, and reccrd releases.
An unreported release would require the coordination of several people and two groups - Chemistry and Operations.
Since the employee concern was general and did not supply any specific details, further inspection is not warranted.
This concern was not substantiated.
No violations or deviations were identified.
9.
Environmental Monitoring (84750)
The inspector reviewed the licensee's Environmental Report for 1988.
In general, 1988 results showed no significant changes as compared to previous data. Tritium detected in surface water samples iri the Discharge
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Basin showed a slight' decresse during.1988.
The average conc'entration
- detected in 1988.was 798 pC1/1 as compared to 902 pCi/1 in 1987. Tritium
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was not detected in the' upstream and downstream Mississippi River samples -
and gamma emmitters were not detected in any surface waters. Mean values for radionur.lide concentrations. in barge slip sediment appeared to decrease during 1988.
However, due.to inherent sampling difficulties for sediment, the licensee did not' identify a decreasing trend.
In reviewing; the data, the inspector noted Mn-54' activity of 11240 pCi/kg for a 1987 seciment sample.
This concentration was at least 2.5 times greater than any other -reported values.
The inspector discussed this value with
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environmental personnel who indicated that'the high value had been noted'
and that the sample had been transferred to a ' clean container-and recounted to ' confirm the results.
Thermoluminescent dosimetry (TLD)
results.for 1988-ranged from.16.7 to 22.9 mR/ quarter.
Quarterly results for direct radiation doses to the public were less:than one mrem with a total 1988 annual dose of'1.1 mrem as compared to 0.8 mrem in 1987.
The licensee was considering moving a surface water sampling point from midstream to near shoreline.
Environmental personnel indicated that
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thermal studies identifying currents within the river supported this move, and a comparison study of midstream versus shoreline analytical results was to be conducted to determine any differences in mixing.
No' violations or deviations were identified.
10.
Exit Interview The inspection scope and results were summarized on September 1.- 1989, with those persons indicated in Paragraph 1.
The inspector described the areas ' inspected and discussed in _ detail the inspection results listed below.
Proprietary information is not contained in this' report.
Dissenting comments were not received from the licensee.
The licensee had maintained an adequate program to control effluents (Paragraphs 3, 4, and 5) and plant chemistry (paragraph 7).
The licensee's continued actions to improve chemistry control included:
New water makeup system (Paragraph 7.b)
Planned expansion of the chemistry laboratories (graph 7.c) Paragraph 7 Installation of an inline ion chromatograph (Para
Planned improvements in water treatment of the SSW system to control MICproblems(Paragraph 7.a)
Two employee concerns were reviewed and were not substantiated (Paragraph 8).
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