IR 05000483/1989001

Safety Insp Rept 50-483/89-01 on 890101-0215.Weaknesses Noted.Major Areas Inspected:Previous Insp Findings,Lers, Plant Operations,Radiological Controls,Maint Surveillance, Emergency Preparedness & Security

ML20235Z682
Person / Time
Site:	Callaway
Issue date:	03/06/1989
From:	Defayette R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20235Z679	List: IR 05000483/1989001 ML20235Z677
References
50-483-89-01, 50-483-89-1, NUDOCS 8903160102
Download: ML20235Z682 (14)

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U.S. NUCLEAR REGULATORY COMMISSION

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REGION III

Report N /89001(DRP)

Docket N License N NPF-30 Licensee: Union Electric Company Post Office Box 149 - Mail Code 400 St. Louis, M0 63166 Facility Name: Callaway Plant, Unit 1

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Inspection At: Callaway Site, Steedman, Missouri Inspection Conducted: January 1 through February 15, 1989 .

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Inspectors: B. H. Little )

C. Brown I )/

Approved By: R. W.& h .h hief DeFayette, Reactor Projects Section 3A 3/b/{f Date l

Inspection Summary i Inspection from January 1 through February 15, 1989 (Recort No. 50-483/89001(DRP)1 Areas Inspected: A routine unannounced safety inspection of previous inspection findings, licensee event reports, plant operations, radiological controls, l aredness, security, engineering and

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maintenance / surveillance, technical support, emergency prep / quality verification was performe and safety assessment Results: Ten previous inspection findings have been administrative 1y closed d (Paragraph 2.d). The cause of three licensee events identifies isolated training weaknesses (Paragraph 3.a). Operating crew demonstrates effective supervision and control of new fuel receipt and storage, normal /off normal conditions and unannounced fire drill (Paragraph 4). Effective radiological controls and practices being maintained (Paragraph 5). Engineering is actively :

involved in and responsive to potential and actual plant problems (Paragraph 9). f Quality assurance's audit of work control program implementation is considered ,

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a performance based critical self-assessment and indicates licensee's problem identification and resolution program is effective (Paragraph 10).

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l 8903160102 890306 "

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DETAILS Persons Contacted l

D. F. Schnell, Senior Vice President, Nuclear

• L. Randolph, General Manager, Nuclear Operations l J. D. Blosser, Manager, Callaway Plant  !

C. D. Naslund, Manager, Operations Support l

• J. V. Laux, Manager, Quality Assurance

• J. R. Peevy, Assistant Manager, Technical Services

• W. R. Campbell, Manager, Nuclear Engineering M. E. Taylor, Superintendent, Operations ,

D. E. Young, Superintendent, Maintenance

• W. R. Robinson, Assistant Manager, Operations and Maintenance

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R. R. Roselius, Superintendent, Health Physics T. P. Sharkey, Supervising Engineer, Site Licensing i G. J. Czeschin, Superintendent, Planning and Scheduling l

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W. H. Sheppard, Superintendent, Outages G. R. Pendegraff, Superintendent, Security L. H. Kanuckel, Supervisor, Quality Assurance Program G. A. Hughes, Supervisor, Independent Safety Engineer Group

• J. C. Gearhart, Superintendent, Operations Suppert, Quality Assurance J. J. Cassmeyer, Quality Assurance Engineer

• C. S. Petzel, Quality Assurance Engineer

• Denotes those present at one or more exit interview In addition, a number of equipment operators, reactor operators, senior reactor operators, and other members of the quality control, operations, maintenance, health physics, and engineering staffs were contacte . Followup on Previous Inspection Findings (92702) (Closed) Violation 87033-01(DRP): Failure to perform adequate preoperational test of the control room emergency ventilation system (CREVS).

Background NRC Inspection Report No. 87033(DRP) identified deficiencies I associated with the CREVS. Preoperational Test Package No. CS-03-GK01 did not include the requirements and acceptance limits for the control room air conditioning unit equipment room (CRACUER) supply air flow as specified on Bechtel Drawing '

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No. M2H15210. In addition, the air flow to the CRACUER was neither documented nor evaluated to assure that test requirements had been satisfie Licensee's Corrective Action Taken and the Results Achieved l

• The preoperational test packages associated with both trains of the CREVS and the fuel building emergency ventilation system

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l (FBEVS) were reviewed to ensure that no'other similar omissions of verification had occurred. ' No other deficiencies were foun i A system flow balance was also performed for each train of th )

CREV The results of those flow balances did not indicate any deviations from design values which affected system operabilit ~

• Manually positioned. flow balancing dampers on the CREVS and FBEVS have been equipped with locking devices and are administratively controlled in accordance with the Callaway locked valve program. The correct balanced position'is now indicated on each manual flow balancing damper on the CREVS and the FBEV * Completion of preventive maintenance task sheets periodically verify the flow rates required for system operability of both the CREVS and FBEV * Completed a formal review of the objectives of the predictive maintenance, preventive maintenance, and surveillance testing programs for safety related systems. The licensee's review, completed in May 1988, resulted in the revision of four maintenance procedures and the issuance or revision of 36 preventive maintenance procedure Inspector's Review The inspector reviewed the licensee's response to the violation, which included a root cause evaluation and corrective action to i prevent recur.rence. The licensee has completed appropriate action for'this matte Violation 87033-01(DRP) is considered close (Closed) Violation 87033-02(DRP): Failure.to correct mispositioned damper GKD-0324 in a timely manne Background On August 14, 1987, while performing control room emergency ventilation system (CREVS) flow measurements, utility personnel found damper GKD-0324 in a nearly closed position. This resulted in a flow of 160 cfm to the control room air conditioning unit equiprent room (CRACUER). Although the system engineer was aware that the design air flow, as specified on Bechtel Drawing No. M2H15210, was 350 cfm, the damper was left in the as-found position. Plant engineering issued a Request for Resolution of this matter on August 19, 1987; however, the damper was not correctly positioned until October 8, 1987. The licensee's evaluation of this matter attributed the cause to utility personnels' failure to document the discovered condition on the appropriate corrective action document (incident report).

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l Licensee's Corrective Action ]

• Management has counseled the engineering personnel involved l with the determination of system operability on their failure

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'l to initiate'an appropriate corrective action document (incident report) to address the discovered conditio * Involved personnel have been' counseled on the importance j of resolution of significant deviations from safety'related parameter Additional guidance was issued to engineering personnel to clarify'the conditions which require the initiation of an incident repor * Systems Engineering Department Policy / Practices.No. 13, issued !

October 26, 1987 provides management definition and guidelines j relating to the generation of incident report i Inspector's Review

.The inspector interviewed members of the utility's Nuclear Engineering Department and reviewed management's guidelines for generation of incident. reports. The guidelines were clearly defined and communicate A sampling of incident reports indicates that engineering maintains a low reporting threshold and is responsive to incidents and requests for resolution initiated by other work group j Violation 87033-02(DRP) is considered close (Closed) Unresolved Item 87023-05: Fire protection acceptability of a modification to add reflash capability to' area monitor system :

annunciator !

Background i

NRC Inspection Report No. 50-483/87023(DRSS) documents the inspection l and close out of Licensee Event Report No. 87013 " Inoperable Control ,

Room Emergency Ventilation System (CREVS)." The inoperability of the I CREVS occurred when electrical penetrations were breached during work

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associated with a Callaway Plant Modification (CMP No. 85-0178). The modification was made to provide reflash capability.to the area monitor system annunciator The inspection focused on the CREVS operability aspects of breaching the control room pressure boundary.

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The fire protection acceptability of the modification was not i l reviewed, and was identified as an " Unresolved Item" pending furthe NRC review.

l Inspector's Review I l The inspector reviewed CMP No. 85-0178 and associated quality records including the fire protection review certification, fire barrier

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The fire protection review certification'is provided'in Attachment "A" of CMP.No. 85-0178.- The engineering review documents that the resulting changes did.not constitute a modification of features of the approved program and did not decrease the level of fir protection in the plant.'

Fire barrier integrity records (FBIRs) were established'for the breached electrical penetration seals associated with the modification. The FBIRs specified that hourly fire watch patrols be performe A sample review of fire watch tracking forms (June 11 through-July 10, 1987 - the period of breached electrical penetration seals)'showed that the specified hourly fire watch patrols were performe The inspector determined that the licensee provided appropriate fire protection response regarding the modificatio Unresolved item 87023-05(DRSS) is considered close The items identified below have been closed during this inspection period based on a directive by the Division Director, Division of Reactor Safety,. Region III. Our decision to close these items is based on the. length of time the item has been in existence and the recognition of limited safety significanc LClosed) Violation 87008-02(DRS): Second verification failed to Tdentify incorrectly positioned vent valve, i (Closed) Open Item 87012-01(DRS): Adabase system including QA list l review upon completio (Closed)'Open Item 87012-02(DRS): 0QAM to subtier document revision l control is incomplet (Closed) Unresolved Item 87012-03(DRS): Training / Qualifications adequacy remains unaudited for er.gineers.

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(Closed) Open Item 87015-01(DRS): Review of super heat on EQ component (Closed) 0)en Item 87015-04(DRS): EQ file on Struthers Dunn-relays to 3e clarifie \

(Closed) Open Item 87018-4A(DRS): Fire damper procedure revision I is needed to determine proper position of the damper "S" hoo J (Closed) Open Item 87018-4B(DRS): Licensee evaluation for the need to perform fire damper drop tes I

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(Closed) Open Item 87019-01(DRS): Control of E0P basis documentation, j (Closed) Open Item 87024-01(DRS): Delta flux summer gein comparison l)

in procedures; ISL-BB-0020411, 421, 431, and 44 I No violations or deviations were identifie . InspectionofLicenseeEventReports(92700]

Through direct observations, discussions with licensee personnel, and a {

review of records, the following licensee event reports were reviewed to determine that deportability requirements were fulfilled, that immediate corrective action was accomplished, and that corrective action to prevent recurrence was accomplished in accordance with Technical Specifications I (T/Ss). The LERs listed below are considered close The licensee event reports (LERs) identified below describe events that occurred between April and November, 1988 which resulted in reactor trips and/or safety system challenge * (Closed) LER 88-005-00: Engineered safety features (ESF)

actuation on high steam generator level (S/G) and a reactor trip on low S/G level due to improper feedwater contro * (Closed) LER 88-010-00: Reactor trip due to personnel error !

and ESF sctuation due to valve leakag * (Closed) LER 83-015-00: Two ESF actuation events due to ring i bus breaker trip upon loss of safeguards Bus NB01 and due to high spike on radiation monitor GK-RE-0 Inspector's Review The inspector determined; that the events were appropriately documented and reported. The events were included in the licensee's event reduction program for cause determination, evaluation and correction. The licensee's evaluation of the events identified hardware and procedural deficiencies, as well as training weaknesse The training weaknesses identified below contributed or caused avoidable reactor trips or challenges to safety system * The licensed operator's use of steam flow and feed flow indications to anticipate plant response led to an erroneous decision as to the cause of the level increase and the actions necessary to correct it. Inaccuracies exist in stream flow / feed flow indications at low power level Recognition of these inaccuracies had not been stressed to operators. (LER 88-005)

• A non-licensed equipment operator (E0) did not understand the function of the potential transformer (PT) fuses relative to the PB03 bu The E0 mistakenly thought the PT fuses only affected the spare breaker located immediately below. Because

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the spare breaker was de-energized, the E0 assumed the PT fuses were de-energized as well. (LER 88-010)

• The ECF actuations' described in this event resulted from inefi c tive training of the assistant equipment operator (AE0) that racked in the 15KV feeder breakers. The AE0 did not recall the need to disengage the rail latch mechanism from the test position to enable racking screw operatio (LER 88-015)

The training weaknesses involved different activities and personnel and do not appear to represent generic training deficiencies. The licensee has provided specific training in areas identified and has included the events in the " lessons learned" phase of operator qualification and requalification training progra LERs88-005, 88-010 and 88-015 are considered close (Closed) LER 88-011-00 and Supplement 01: Engineered safety features (ESF) actuation as a result of a relay driver card failur Background On September 22, 1988, at 0726 CDT a relay driver card in the load  !

shedder and emergency load sequencer (LSELS) failed resulting in a turbine driven auxiliary feedwater pump (TDAFP) actuation. Licensed operators secured the T0AFP after verifying normal steam generator water levels and feedwater system operation. The defective card was replaced and proper operation was verified. The TDAFP actuation feature was restored at 1427 CO Inspector's Review The inspector reviewed the details of the event, including the associated incident report number 88-198 and work request No. WR-443147, and interviewed control room supervision in the ,

control room at the time of the event. The inspection showed  !

that the engineered safety feature functioned as designed and that approp'riate corrective action was taken. LER 88-011 " Description of Event states "the TDAFP and the 'A' train of the ESF system were declared inoperable," whereas, the card failure only effected the TDAFP actuation featur The licensee issued Supplement 1 to I correct the description of the even LER 88-011-00 and Supplement 01 are considered close No violations or deviations were identifie . Plant Operations (71707) (71710) (64704) Operational Safety Verification Inspections were routinely perfornied to ensure that the licensee conducts activities at the facility safely and in conformance

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with regulatory requirements. The inspections focused on the implementation and overall effectiveness of the' licensee's' control  ;

of operating activities, and on the performance of' licensed and non-licensed operators and shift technical advisors. The inspections included direct iservation of activities, tours of the facility, interviews and e issions with licensee personnel, independent verification of w.aty system status and limiting conditions;of operation (LCO),.and reviews of facility procedures, records, and i reports. The following items were considered during these j inspections: i l

• Adequacy of plant' staffing and supervisio * Control room professionalism, including procedure adherence, operator attentiveness, and response to alarms, events, and off-normal-condition * Operability of selected safety-related systems, including attendant alarms, instrumentation, and control * Maintenance of quality records and report The inspectors observed that control room supervisors, shift technical advisors, and operators were attentive to plant conditions, performed'

frequent panel walkdowns and were responsive to off-normal' alarms and conditions. Shift turnovers were performed.In a disciplined manner, including; log reviews, joint panel walkdowns, annunciator checks and crew briefings. Status boards were current, reflecting on going surveillance activities and associated LCO action time restraint The inspectors performed a sample inspection of the licensee's activities associated with the receipt, handling, and storage of new fuel assemblies. Appropriate procedures were on station and adhered to throughout the fuel handling process, including pre-fuel movement surveillance, fuel assembly inspections and double verification of fuel storage location The inspector observed the control room operators' response to a complete loss of general service water (GSW) resulting from a GSW

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pump trip and lockout. The operators responded promptly to the incident. Within 15 seconds of the alarm, operators had evaluated the problem and had started both essential service water (ESW) pump l The ESW system was aligned to backfeed the general. service water system pending resolution of the GSW pump problem.

l The inspector noted that the prompt action resulted in maintaining normal component operating temperatures, however, a procedure did not exist for the action take The event, including the lack of a procedure, was discussed with the licensee. The licensee's evaluation determined that the operator action was satisfactor The action taken is being included in the alarm response procedure _ __-_____ __ -

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. . Off-shift Inspection of Control Rooms The inspectors performed routine inspections of the control room during off-shift and weekend periods; these included. inspections between the hours of 10:00 p.m. and 5:00 a.m. The inspections were conducted to assess overall crew performance and, specifically, control room operator attentiveness during night shift The inspectors determined that both licensed and non-licensed operators were attentive to their duties, and that the administrative controls relating to the conduct of operation were being adhered t Plant Material Conditions / Housekeeping The inspectors performed routine plant tours to assess material conditions within the plant, ongoing quality activities and i plantwide housekeeping. The inspectors also accompanied the i licensee's management on monthly plant tour Fire Protection / Prevention Program The inspector observed the back-shift operating crew's response to an unannounced fire drill conducted on February 14, 1989. The l inspector was in the control room at the onset of the drill and

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observed the crew's response in the control room and the fire brigade's response in the plan The fire brigade team members appeared well trained and responded  !

to the scene with appropriated equipment. The team leader provided I effective direction and coordination. The team leader and two fire team members were prompt in reaching the fire equipment staging area. Two fire team members, working in the respirator cleaning trailer, did not hear the fire alarm or the announcement over the gaitronics communication system which resulted in a delay of about seven minutes in their respons Minor deficiencies were identified and included in the licensee's post arill critiqu In addition, incident report No.89-031 was initiated to evaluate the gaitronics problem. The licensee's initial review found that the gaitronics' speaker volume was turned dow Action was initiated to alert personnel of the problem and of potential consequences. The incident is being further evaluated l for action to prevent recurrenc '

No violations or deviations were identifie l 5. Radiological Controls (71709)

The licensee's radiological controls and practices were routinely observed by the inspectors during plant tours and during the inspection of selected work activities. The inspection included direct observations of health physics (HP) activities relating to radiological surveys and monitoring, maintenance of radiological control signs and barriers, contamination,

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and radioactive waste controls. The inspection also included a routine review of the licensee's radiological and water chemistry control records and report I Overall radiological controls, practices and plant conditions were I good. The health physics (HP) staff maintained effective access control and were knowledgeable of ongoing work, radiological conditions and protective requirements within the radiological controlled areas (RCA).

Good radiological control practices were observed during new fuel handling and storage activities in the fuel building. The work in and around the spend fuel pool was closely monitored by HP staff. Special surveys were performed to determine hot particle presence. None were foun The licensee continues to focus personnel's attention / awareness in the areas of hot particle and ALARA considerations. This is evident in work planning for the forthcoming refueling outage, outage module training, and through information on industry events discussed in the utility's weekly newsletter. Callaway plant personnel received 26.5 yearly man-rem exposure in 1988. Based on the review of industry data, the licensee determined that Callaway had the lowest man-rem exposure on record for U.S. plants with greater than 1000 MWe unit No violations or deviations were identifie . Maintenance / Surveillance (62703) (61726)

Selected portions of the plant surveillance, test and maintenance activities on safety-related systems and components were observed or reviewed to ascertain that the activities were performed in accordance with approved procedures, regulatory guides, industry codes and standards, and the Technical Specifications. The following items were considered during these inspections: the limiting conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved proceoures and were inspected as applicable; functional testing and/or calibration was performed prior to returning the components or systems to service; parts and materials that were used were properly certified; and appropriate fire prevention, radiological, and housekeeping conditions were maintained, Maintenance The reviewed maintenance activities included:

Work Request N Activity WR-113550 Install temporary Modification 89-M-003 (cask weeping experiment).

WR-121777 Weld repair of electrical Breake: NB02-07 trip latch roller sto . _ _

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Work' Request N Activity .j LWR-44824 Trouble shoot radiation Monitor GTR2 (containment purge exhaust).

. WR-119627 Repair oil level-sight glass leak (auxiliary turbine driven.feedwater pump).

WR-448719 Weld hinges for' maintenance access to'

outside missile barrier ('B diesel generator room).

Multiple Requests 'A' emergency diesel routine surveillance, preventive and corrective maintenanc P-448505 Main generator hydrogen usage tes W-119150 Repack outboard glands on 'A' motor drlven auxiliary feedwater pum Surveillance The reviewed surveillance included:

Procedure N Activity OSP-SA-0007B Train 'B' auxiliary feedwater actuation system - slave relay tes OSP-NE-00002 'A' emergency diesel - 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> verification ru 'B' emergency diesel - one hour load test (post maintenance).

OSP-FC-V0001 Auxiliary feedwater pump turbine valve operability.-

ISF-AB-0P514 Steam generator 'A' pressure - functiona ISF-AB-0P534 Steam generator 'C'l pressure - functiona ISF-AE-OL528 Steam generator 'B' narrow range level  ;

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protection - functiona MSE-NK-QB001 125 volt battery - weekly surveillanc '

ISF-BB-0P458 Pressurize" pressure protection -

functiona j ISL-GS-00ALB Containment hydrogen analyzer Train 'A'.

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Procedure N Activity ISL-GS-00 CIA Containment hydrogen recombiner Loop 'A'.

ISL-GG-00R28 Fuel building vent radiation detector -

loo ISL-NF-NB01B Load shedding and emergency load sequencin ETP-AE-ST002 Engineering test to evaluate feedwater venturi performance with pH change ESP-ZZ-00018 Incore versus indicated axial flux difference compariso ESP-ZZ-00027 Loop 2 delta temperature measuremen No violations or deviations were identifie . Emergency Preparedness (82301)

An inspection of emergency preparedness activities was performed to assess the licensee's implementation of the emergency plan and implementing procedures. The inspection included monthly observation of emergency facilities and equipment, interviews with licensee staff, and a review of selected emergency implementing procedure No violations or deviations were identifie . Security (71881)

The licensee's security activities were observed by the inspectors during routine facility tours and during the inspectors' site arrivals and departure Observations included the security personnel's performance associated with access control, security checks, and surveillance activities, and focused on the adequacy of security staffing, the security re ponse (compensatory measures), and the security staff's attentiveness and thoroughnes No violations or deviations were identifie . Engineering and Technical Support (37701)

An inspection of engineering and technical support activities was performed to assess the adequacy of support functions associated with operations, i maintenance / modifications, surveillance and testing activities. The i inspection focused on routine engineering involvement in plant operations and response to olant problem The inspection included direct l observation of engineering support activities and discussions with  !

engineering, operations, quality control and maintenance personnel, i

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An inspection in this area was performed to dete'rmine the licensee's knowledge of and response to a potentia 1' generic problem associated with General Electric Magne-Blast 4160 volt circuit breakers. The problem involved cracked welds on latch roller link striker plates identified at the Wolf Creek (WC) nuclear plant. WC reported the deficienr.y in a Part 21 report (ET-88-0177) dated November 18,.198 The. inspector was first advised of the problem by the NRC Senior Resident Inspector at Wolf Cree The inspector met with members of the licensee's system engineering group !

to discuss problem applicability to Callaway. The inspector determined that the licensee was advised of the problem through discussions with WC, and had initiated action to obtain an engineering evaluation in this matte The licensee's immediate action included:

• Issued incident report No.88-230, November 3, 1988, to obtain engineering evaluation of applicabilit I e Performed a work history review to determine breaker failure !

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• Issued a temporary change notice (TCN) No.88-726 to maintenance !

procedure No. MPE-ZZ-QS005 to specifically inspect for cracked welds during scheduled preventive maintenance (PM) inspection The work history review identified a similar breaker deficiency (striker plate broken off) on March 27, 1984, which was rewelded. No failures were found subsequent to initial plant operation On January 11, 1989, while performing a PM inspection of breaker No. NB02-07 a hairline crack, approximately 3/8 of an inch in length, was found in the weld which attaches the striker plate to the breaker ,

. frame. The licensee documented the deficiency on a nonconforming i materiai report No. 89-I00015 and on IR No.89-007 to obtain further !

engineering evaluation. The defective weld has been repaire The inspector determined that the licensee has taken appropriate action l in this matter, and indicates active involvement and responsiveness by plcnt engineering relative to potential and actual plant problem No violations or deviations were identifie . Safety Assessment / Quality Verification (35701) (35502)

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An inspection of the licensee's quality programs was performed to L assess the impicmentation and effectiveness of programs associated with I management control, verification, and oversight activities. The inspectors considered areas indicative of overall management involvement in quality matters, self improvement programs, response to regulatory and industry initiatives, the frequency of management plant tours and control room observations, and management personnel's attendance at technical and planning / scheduling meetings. The inspectors attended On-site Review

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Committee meetings and incident / event critiques and reviewed related documents, focusing on the licensee's root cause determinations and corrective actions. The inspection also included a review of quality records and selected quality assurance audit and surveillance activitie An inspection was performed to evaluate the effectiveness of the licensee's quality assurance (QA) program relating to problem identification and resolution. The inspection included the review of QA Audit Report No. AP88-017, the associated Request for Corrective Action (RCA) reports and response to the RCA items. The licensee's QA Department Semiannual Report (July through December 1988) was also reviewed to determine if problems identified are included in the licensee's trend analysis progra :

Inspection Findings The QA audit assessed the effectiveness of operations and maintenance work control programs. The audit included QA field observation of the performance of 47 work activities and 33 worker protection assurance (WPA) tagouts. QA observations included a mixture of safety related and balance of plant related work activitie The audit was comprehensive in scope, focused on field performance and provided a critical self-assessment of work control program ,

implementation. The audit report identified program strengths,

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improvement recommendations and problem area The inspection showed that problems identified were appropriately documented on RCAs and communicated to responsible line managemen QA received line management response for all RCAs which included; evaluation of cause, corrective action and action to prevent recurrenc QA assessment and trending of RCAs was included in QA's semiannual report to licensee managemen The inspectors determined that the licensee has implemented an effective problem identification and resolution progra No violations or deviations were identifie . Exit Meetino (30703)

The inspectors met with licensee representatives (denoted under Persons Contacted) at intervals auring the inspection period. The inspectors summarized the scope and findings of the inspection. The licensee representatives acknowledged the findings as reported herein. The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not identify any such documents / processes as proprietar ,

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