ML17055D281
| ML17055D281 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 10/08/1987 |
| From: | Markley M, Nimitz R, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17055D278 | List: |
| References | |
| 50-220-87-17, 50-410-87-34, NUDOCS 8710190202 | |
| Download: ML17055D281 (30) | |
See also: IR 05000220/1987017
Text
'
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report
No. 50-220/87-17
50-410/87-34
Docket No.
50-220
50-410
License
No.
~NP -54
Priority
Category
C
Licensee:
Nia ara
Mohawk Power Cor oration
300 Erie
Bou evar
West
S racuse
New Yor
13202
Facility Name:
Nine Mile Point Units
1 and
2
Inspection At: Oswe o,
Inspection
Conducted:
Au ust 24-27,
1987
Inspectors:
R. L. Nimitz, Senior
Ra
ation Specia ist
ate
N. Mar
ey,
Ra iation
Sp cia
st
a
e
Approved by:
H.
M.
an ay,
Facilities Radiation Protection Section
ate
Ins ection
Summar
Ins ection conducted
Au ust 24-27,
1987
Combined.
Re ort
o. 50-2
0 87-17;
50-410 87-34
Areas
Ins ected:'outine
unannounced
radiological controls inspection at
Units
1 an
nit 2.
Areas. reviewed were:
organization
and staffing;
training; audits;
ALARA; external
exposure control; internal
exposure control;
radwaste
and contaminated
material .control;
and start-up
surveys for Unit 2.
Results
One apparent violation was identified,(failure to adhere
to radiation
protection procedures,
section 9).
A need for improvement of housekeeping
in
Unit 2 was identified.
871019'0202
871015
ADOCK 05000220
8
Details
1.
Individuals Contacted
'Ill
N
h
k
- T. J. Perkins,
Generation
Superintendent
- T.
Roman, Station Superintendent,
Unit
1
- R.
B. Abbott, Station Superintendent,
Unit 2
- W. Hansen,
Manager - Corporate
gA
- C.
Beckham,
Manager - gA Operation
- K. Zolhtsch, Superintendent
Training
- A. Pinter, Unit 2 Licensing Engineer
- E.Leach,
Radiation Protection
Manager
- D. Barcomb; Unit 2 Radiation Protection
Supervisoi
- W. Schottens,
Assistant'upervisor,
Radiation Protection - Unit
1
- T. Egan,
Nuclear Compliance
and Verification
- R. Pasternak,
Manager,
Nuclear Consulting
NRC
- C. Marschall, Resident
Inspector
Others
- P.
D. Eddy, Public Service
Commission
- P.
D. MacEwan,
New York State Electric and
Gas
- Denotes
those individuals attending
the exit meeting.
The inspector also contacted
other individuals.
2.
Pur ose of Ins ection
The purpose of this routine,
unannounced
inspection
was to review the
following:
Unit
1 and
2
Licensee action
on previous findings
Organization
and Staffing
Training
Audits
External
Exposure Controls
Internal
Exposure, Controls
Unit 2
Radiation
Survey Measurements
3.0
Licensee Actions
on Previous
Findin
3. 1
(Open) violation (50-220/86-16-01)
Licensee did not perform surveys in accordance
with 10 CFR 20.201.
This inspection
reviewed this matter with respect
to the. corrective
actions outlined in the licensee's
May 19,
1987 letter
(NMP1L-0154).
The licensee's
response
outlined
10 corrective actions that were
taken.
Two of the
10 items
have to be verified as
implemented.
These
are
as follows:
Modification of the General
Employee Training Program to
discuss
the radiological event prompting the violation and
lessons
learned.
Improvement of management
assessment
and involvement of the
site Radiation Protection
Program through formalized training
and on-the-job evaluation of work in progress.
Inspector time limitations and licensee
cognizant
personnel
accessibility
precluded
complete
review of the remaining
two
issues.
3.2
{Closed) violation (50-220/86-16-02)
Licensee
did not adhere to radiation protection procedures.
The
licensee
implemented
the corrective actions described
in the
May 19,
1987 letter
{ NMP1L-0154)
to
NRC.
3.3
(Open) violation (50-220/86-16-03)
Licensee
did not adhere
to high radiation area surveillance
requirements
specified .in Technical Specification.
The inspector
reviewed the corrective action described
in the licensee's
May 19,
1987 letter
(NMP1L-0154) to
NRC.
Inspector review of revised
radiation protection procedures
to address 'this violation indicated
the following:
The revised
procedures
did not adequately
describe
terms to be
indicated
on radiation work permits to implement the
surveillance
requirements
required
by technical specifications
(e.g.
What constitutes
"continuous monitoring7").
4.0
Or anization
and Staffin
The inspector
reviewed the organization
and staffing of'the Radiological
Controls
Program for Unit
1 and Unit 2.
The review was with respect to
criteria contained in Technical Specifications
and applicable licensee
procedures.
Licensee
performance
in this area
was evaluated
by:
review of applicable
documents;
observation of shift manning including backshifts;
discussions
with personnel.
Findin<is
Within the scope of the review, the following observations
were made:
The Radiological Controls organization
underwent
a major
reorganization
in late
1986.
The reorganization
resulted in the
establishment
of a separate
Radiation Protection
and Chemistry Group
versus
the previously combined Radiation Protection/Chemistry
group.
Applicable station procedures
were updated
to reflect the change
including modification of position responsibility and authorities.
However, the current Unit I and Unit 2 Technica1
Specifications
reflect the previous organizational
structure.
The licensee
has
previously submitted
a request
for
a change to the Technical
Specification.
The change
has yet to be approved.
The licensee
augmented
the Unit 2 shift Radiation Protection staff
to provide additional senior
level technicians for shift coverage
during start-up
and power ascension.
The Unit
1 facility was at power operation during the inspection.
One senior 'level
and
a junior level technician
were provided for
back shift radiological controls.
The provision of the
senior
technician
was in conformance with minimum Technical Specification
requirements.
The
ALARA coordinator
and
a Senior
ALARA Engineer recently left
licensee
employment,
The licensee has'ransferred
the site
functions (both Unit
1 and Unit 2) under the oversight of the
Respiratory Protection/Internal
Dosimetry Supervisor.
The inspector noted:
This organization
change
has not been reflected in station
procedures.
The ALARA group has lost considerable
expertise with the termination
of the two individuals.
The licensee
has yet to select
permanent
personnel
to replace
these individuals.
The positions
are currently
filled by contractors.
(Note:
This organization
change is discussed
in section 7.0 ALARA).
5.0
Audits, Survei llances,
and Performance
Monitorin
The inspector
reviewed Radiological
Controls
Program audits
and
assessments
with respect
to criteria contained in applicable Technical
Specifications
and licensee
procedures.
The following matters
were reviewed:
0
Also
performance of audits
and assessment
at required frequencies;
quality and effectiveness
of audits
and assessments;
licensee .review and closure of finding.
reviewed
was the licensee's
performance monitoring program.
Documents
Reviewed
0
0
Safety
Review and Audit Board, Audit D, Radiological Audit, dated
March 27,
1986 (Unit 1);
Safety
Review and Audit Board, Audit D, Radiological Audit dated
May I, 1987
(Unit
1 and Unit 2);
Chemistry
and Radiation Protection
Management
Audit (SY-RG-IN-86022)
dated
March 11,
1987,
performed
December
15-19,
1986 (Nine Mile
1
and 2);
Radiation Protection
Program
Audit (SY-RG-IN-87005) dated April 24,
1987, performed
March 23 to
April 3,
1987 (Nine Mile 1);
Radiation Protection
Program
Audit (SY-RG-IN-87010) dated
August 7,
1987, performed
June 29-
July 9,
1987 (Nine Mile
1 and 2);
Selected
Radiological
Controls
Program
Performance
Monitoring
Reports;
Evaluation of licensee
performance
in the area
was
based
on:
review of documents;
and
discussion with cognizant licensee
personnel.
~Findin
Within the scope of the review, the following was identified:
The quality of licensee
audits
has
improved.
In light of
Radiological
Controls
Program deficiencies identified by the
NRC and
INPO, the licensee
has initiated aggressive
audits of infield work
practices
and the adequacy
and effectiveness
of Radiological
Control
provided for these practices.
Special
emphasis
was placed
on
personnel
performance.
In addition, the licensee
has committed to
perform multiple audits of the Radiological
Controls
Program for
purposes of identifying and correcting performance
problems.
Some
gA audit findings appear to be open for an extended
period of
time (e.g.
2 years).
An example
being
a finding dealing with
"establishment
of a continuous
breathing
zone sampling
program or
justify exceptions."
The finding was identified in a
1985 audit but
apparently is not scheduled
to be evaluated until the fourth quarter
of 1987.
The quality of the licensee's
surveillance
program
has
improved.
The survei llances
also focus
on personnel
performance
during
observation of infield work activities.
Follow-up of surveillance
findings was aggressive.
The licensee
audits of training and qualification of Radiological
Controls personnel
was not reviewed.
This will be reviewed in
subsequent
inspections.
Performance
Nonitorin
The licensee
has established
two major methods of Radiological
Controls
Program performance monitoring.
The first is
a monthly Performance
Nonitoring-Nanagement
Information document which includes Radiological
Controls
Program performance indicator charts.
This document is
distributed to applicable
personnel
including Senior Nanagement.
The
document tracks
among other items, total station exposure,
square
footage
of contaminated floor area, positive whole body counts
and violations.
Station goals are clearly shown
as well as performance relative to these
goals.
The second
document is
a recently established
Performance
Nonitor Report.
This document
assigns
to groups
and individuals, by name, specific
problems identified relative to group/individual performance.
Items
assigned. include radiological incident reports
and other concerns,
principally involving dosimetry.
Graphs
and charts clearly show overall
station performance
in each
area.
Group performance
in terms of number
of events is clearly shown.
Results
are reviewed for purposes
of root
cause
analyses.
However, goals for each
a'rea of performance
monitoring
has not been established.
Since this second report is relatively, new
(in- place about
3 months)
the licensee is currently reviewing its
effectiveness.
6.0
~Trainin
During
a previous inspection,
the inspector
noted that
some licensee
radiation protection personnel
and control
room operations
personnel
were
unaware of a document entitled Office Instruction for Key Control.
This
document describes
key control for access
Licensee
personnel
committed to review this matter
and initiate
corrective actions to ensure appropriate
personnel
were familiar with the
document.
0
The inspector review of this matter indicated the following:
0'
Senior Radiation Protection 'Technician,
on standby watch at
Unit 1, was unfamiliar with the document
and
had not seen or read
it;
The document
had
been
placed in required reading 'for Unit
1,
temporary technicians.
However, it was not provided
as required
reading for Unit
1 permanent radiation protection technicians;
Multiple examples of individuals not signing off "immediately
required" reading material
were identified.
Some were not signed
off- as late
as
a month following issuance.
7.0
The licensee's
ALARA program was evaluated
against criteria contained
in
the following:
Regulatory
Guide 8.8,
" Information Relevant
To Ensuring
The
Occupational
Radiation
Exposures
At Nuclear
Power Stations Will Be
As Low As Is Reasonably
Achievable
(ALARA);"
Regulatory
Guide 8. 10, "Operating Philosophy
For Maintaining
Occupational
Radiation
Exposures
As Low As Is Reasonably
Achieveable;"
Regulatory
Guide 8. 19, "Occupational
Radiation
Dose Assessment
In
Light-Water Reactor
Power Plants
Design Stage
Man-Rem Estimates."
"
Licensee
performance relative to these criteria was evaluated
by:
l
Discussions
with available
cognizant personnel;
'ours of radiologically controlled areas;
Review of station
ALARA goals;
Review of Site
ALARA Committee meeting minutes;
Review of Unit
1 ALARA Committee meeting minutes;
Review of departmental
exposure tracking;
Review of station procedures.
General
J
Inspectors
discussed
ALARA staffing, goal setting, trending
and program
changes with licensee. personnel.
~Findin
s
Within the scope of this inspection,
no violations were identified.
Inspectors identified staffing as
a potential
weakness
in the current
ALARA program.
Recently,
the
ALARA staff lost several
key personnel.
0
Goals
and goal setting methodoloay
was discussed
with licensee
personnel.
The licensee
is within the established
1987 person-rem
goal
and is
performing exposure 'tracking and tr ending.
Yionthly reports
are sent to
departmental
managers
and are dis'cussed
in Site
ALARA Committee
and
Unit
1 AL'ARA Committee meetings.
ALARA personnel
were found to be
informed on hot particle issues.
New ALARA staff was knowledgeable of
procedural
goal setting requirements.
Licensee staff identified several
opportunities
for improvement.
These were:
a reevaluation of survey methods
and frequencies
to reduce
technician
exposure;
increased
corporate
ALARA support to assist
the
new ALARA staff;
increased
management
support to reduce worker resistance
to ALARA
exposure controls.
8.0
External
Ex osure Controls
The inspectors
reviewed selected
aspects
of the External
Exposure
Control
- Program.
The areas
reviewed
and findings follow.
8. 1
Hi
h Radiation Area Control
High Radiation Area access
control
was reviewed with respect
to
criteria contained in Technical Specifications
and applicable
licensee
procedures.
Evaluation of a licensee
performance
in this area
was based
on:
performance of independent
radiat'ion surveys during plant
tours;
independent verification of access
control to selected
high
radiation areas;
performance of independent
key audits;
discussions
with personnel.
Within the scope of this review,
no violations were identified.
Observations
during the inspection indicated the licensee
was
adequately controlling access
'I
8.2
Postin
and Labelin
The. licensee's.program
for the survey, posting,
and control of
radioactive materials
and radiological
areas
was reviewed against
the following criteria:
"Caution signs, labels, signals
and controls;"
Technical Specification
6. 12, "High Radiation Area."
Licensee
performance
in this area
was evaluated
by the following
methods:
discussion with supervisory
and technician level personnel;
inspector tours
and independent
surveys of various radiological
work areas.
~Findin
s
During the course of this review,
no violations were identified.
One item of inspector
concern
was the labeling of a mini-rad check
source.
The
2 mCi Sr-90 check source
was labeled in an
inconspicuous
manner
such that approach
and handling
may be done
without recognition of the potential
hazard.
The licensee
immediately corrected this matter.
8.3
Personnel
Dosimetr
The inspector
reviewed the personnel
dosimetry program with respect
to criteria contained in:
Personnel
Monitoring;
Personnel
Monitoring Reports;
10 CFR 20. 101, Radiation
Dose Standard for Individuals in
Restricted
Areas;
10 CFR 20. 102, Determination of prior dose;
and
applicable licensee
procedures.
The licensee's
performance
in this area
was eval'uated
by the
following methods:
discussions
with supervisory
and technician-level
personnel;
tours of radiological
areas
and observations
of work
activities.
~Findin
s
Within the scope of this review,
no violations were identified.
However, multiple examples of personnel
improperly wearing dosimetry
were identified.
When questioned
by inspectors,
some individuals
were not knowledgeable of correct use of dosimetry.
Some
individuals indicated that radiation protection personnel
had
instructed
them to wear their dosimetry that way - incorrectly.
Radiation protection technicians
accompanying
inspectors
on tours
were inattentive to improper dosimetry use.
The licensee
indicated
this matter would be reviewed.
10
8.4
Radiation Measurin
Instrument
Area and Portable)
The review was performed with respect
to criteria contained in the
following:
Final Safety Analysis Report
(FSAR), Section
11.5, "Radiation
Monitoring Systems;"
Final Safety Analysis Report
(FSAR), Chapter
14, "Initial
Tests
Program;"
Regulatory
Guide 1.68,
November
1978, "Preoperational
and
Initial Start-up Test
Program for Water Cooled
Power Reactors;"
Procedure
N2-RTP-4, "Radiation Measurement
and Shield Integrity
Checks,
NMP-2;"
Procedure
N2-SAP-100, "Start-up
and Test
Program Description
and Organization;"
Procedure
N2-SAP-101, "Preparation
and Control of Start-up
Administration Procedures;"
Procedure
Nl-FHP-25,"General
Description of Fuel
Moves;"
Procedure
Nl-FHP-27,
"Whole Core Off Load-Reload;"
Procedure
N1.-ST-W10, "Refueling Platform High Radiation Monitor
Instrument
Channel Test;"
Procedure
IE.
Gene 014,
"Kaman Instrumentation
Model
KEM-A/KEM-P Radiation Monitors, Revision 0;"
"Location and Design Criteria For Area
Radiation Monitoring Systems for Light Water Nuclear Reactors."
Licensee
performance relative to these criteria was determined
by:
Discussions with cognizant personnel;
Review of Unit 2 power ascension
and start-up test
survei llances;
Review of Unit
1 Technical Specification surveillances;
Observation of control
room display panels,
CRT display
monitors,
and
HP hourly/daily surveillance
records.
11
Findin
s
Area Monitors
No violations were identified.
All Technical Specification
surveillance
reouirements
examined
were found to have
been
'performed
and documented.
Discussions with, personnel
regarding operation of the
DRMS indicated
a working knowledge of the system.
Findin
s
Portable
Surve
Meters)
No violations were identified.
Instruments
were found to have
current calibration stickers.
Calibration and source
check
acceptance
criteria were met on all. instruments
examined;
9.0
Internal
Ex osure Control
and Assessment
. 9.1
General
The licensee's
program for control of internal
exposure
was reviewed
against criteria contained in the following:
10 CFR 20. 103, "Exposure of Individuals to Concentrations
of
Radioactive Materials in Air in Restricted Areas;"
NUREG - 0041,
"Manual of Respiratory Protection Against
Airborne Radioactive Materials;"
Regulatory
Guide 8.9, "Acceptable
Concepts
Models, Equations,
and Assumptions for a Bioassay
Program;"
4
"Acceptable
Programs for Respiratory
Protection;"
Regulatory
Guide 8.26, "Applications of Bioassay for Fission
and Activation Products."
The licensee's
performance
was determined
by:
0
Discussions with cognizant personnel;
Review of whole body countin'g
(MBC) records;
Inspection of the
HBC facility;.
Review of radiation work permit
(RWP) records;
Review of respirator
issuance
records
and user qualifications.
12
9.2
Whole Bod
Countin
WBC)
Within the scope of the. above review,
one apparent violation failure
to follow station procedures
was identified and is described
below:
Inspectors
reviewed monthly
WBC summaries
and selected
individual
exposure history files.
Two instances
were identified (in the
same individual's exposure
history file) in which Procedure
S-RTP-10 requirements
were
apparently
not followed.
Each instance
exceeded
Table
12, column
3
Bioassay Action Point of 25
nCi, for Co-60.
A.
On March 19,
1987,
a maintenance
worker's routine whole body
count indicated
an activity of 27.94'nCi.of Co-60.
The
individual's latest
RWP entry prior to March 19,
1987 was
March 6, 1987.
B.
On March 17,
1986, the
same maintenance
worker received
a
which indicated
an activity of 27.52
nCi of Co-60.
The licensee
was unable to provide the inspectors
an evaluati'on to
show what the radioactive material
intake (i.e. MPC-hour exposure)
of this individual was.
It was not apparent
as to when the actual
intake of radioactive material
had occurred or what the individual's
actual
exposure
was.
As a result,
the inspector indicated that failure to implement
procedure
S-RTP-10 was
an apparent violation of Technical
Specification.6. 11 (50-220/87-17-01).
Inspectors
reviewed
WBC calibration records
and control charts.
Calibration,
source
checks,
and background
checks
were found to, be
performed correctly and documented
accurately.
Within the scope of the review,
one item for improvement
was
identified:
9.3
Several
sources
are
used to provide calibration checks of whole body
counter.
It was not apparent that the activity of each
source
was
traceable,
either directly or indirectly, to
a
known standard,
(e.g.
National
Bureau of Standard
Sources).
Licensee
personnel
indicated the matter will be reviewed.
This
matter will be reviewed during
a follow-up inspection.
Res irator
Protection
No violations were identified within the scope of this inspection.
Respirator
issue
records
and recent Radiation
Work Permits
were
reviewed
by the inspector.
All individuals were found to have valid
13
medical
examinations
and to have
been qualified for the use of
resp'iratory protection equipment.
'0.0
~0-
0
The inspector
reviewed start-up radiation surveys.
The review was with
respect
to criteria contained in-
N2-SUT-2-0V, "Radiation Measurements
- Open Vessel
Test
Condition;"
N2-RTP-4, "Radiation Measurement
and Shield Integrity checks-
NMP-'2."
Evaluation of licensee
performance
in the area
was based on:.
Review of test results;
Discussion with personnel;
Review of survey instrument calibration;
and
Use of personnel
dosimetry.
~Findin
s
Within the scope of the review,
no violations were identified.
Survey results
were appropriately
reviewed
and approved.
Appropriately calibrated
instruments
were in use.
The licensee
was
taking special
precautions
regarding monitoring of personnel
exposure
to neutrons.
The licensee's
personnel
neutron monitoring
methods
were consistant with Regulatory
Guide 8. 14.;" Personnel
Neutron Dosimeters."
11.0 Radioactive
and Contaminated
Material Control
- The inspector toured the controlled areas
and reviewed licensee control
of radioactive
and contaminated material.
Personnel
frisking practices
and housekeeping
was also reviewed.
The review of the area
was with respect
to applicable regulatory
requirements
and licensee
procedures.
Evaluation of licensee
performance
was based
on observations
during plant
tours,
independent
radiation surveys
performed
by the inspector,
and
discussion with cognizant personnel.
~ indi ncis
Within the, scope of the review,
no violation was identified:
Within the scope of this review, the following items needing licensee's
attention
were identified:
14
All whole body portal type frisking booths at the main egress
points
from Unit
1 and Unit 2 Radiological Controlled Area were out of
service.
The licensee
was utilizing hand held friskers.
Some personnel
were observed
performing improper frisking with hand
held friskers.
The licensee's
hot particle survey
and control program
has not been
fully established.
Procedures
addressing
this area
have yet to be
established.
Housekeeping
in the lower elevations of Unit 2 reactor building was
considered
poor.
Protective clothing was scattered
around, cotton
gloves were found stuffed in instrument racks,
and balls of tape
'ere
found in corners.
In addition, liquids were found running out
of posted
contaminated
areas
into non-contaminated
areas.
Licensee
personnel
indicated these
areas
would be reviewed
and
appropriate
action taken.
12.0 Evaluation of Off-scale Dosimeter Results
12.1 General
During installation of neutron source
pin holders in the Unit 2
Reactor Vessel,
on November 1, 1986, licensee
divers experienced
the
following dosimetry anomolies:
1.
The self reading pocket dosimeters
(SRD) worn on the chest
and
left arm of Diver
1 were found off-scale.
In 'addition, Diver
1
sustained
an unanticipat'ed
neutron
dose of 330 mrem to his
chest;
Diver 2 sustained
an unanticipated
380
mR exposure
to the
worn on his chest.
In addition, Diver 2 sustained
an
unanticipated
neutron
dose of 80 mrem to the chest;
Diver 3 sustained
an off-scale reading for the
SRD worn on his
right arm.
In addition, Divei
3 sustained
an unanticipated
neutron
dose of 20 mrem to his right arm.
Since pre-dive surveys
indicated
no significant neutron
or
gamma
dose would be received
by the divers, the licensee initiated an
investigation of the cause of the anomolies.
12.2 Licensee
Evaluation
and Conclusion
The licensee,'s
evaluation
and conclusions
were as follows:
The off-scale
SRDs were determined to have
been wet, resulting
in their discharging.
Water was visible in their plastic
holder.
15
The 'dosimeter that read
380 mrem was determined to be
malfunctioning.
Dropping the dosimeter resulted
in it
discharging to 380 mrem.
All film badge results
were reported
as minimal verifying that
no
gamma exposure
was received
by SRDs.
Neutron badge results
were re-checked
and verified correct.
The licensee
contracted with Gilbert Services
to perform dose
rate calculations at various distances
from the neutron
sources.
The calculations
confirmed the pre-dive neutron
survey results (i.e. minimal dose. rates).
A special instruction was wriften to perform underwater
gamma
surveys of the sources
using
a special
underwater
gamma probe.
Dose rates
were confirmed to be the
same
as pre-dive surveys
={i.e. minimal exposure rate).
A lucite phantom with similar dosimetry
was lowered next to the
source
holder locations.
Dosimetry results indicated minimal
exposues.
The licensee
was unable to establish
a circumstance
or dose
rates
which could have caused
the
anoma'1ous
neutron results,
The licensee
conservatively
assigned
the neutron whole body
dose results
to the divers.
12.3
NRC Review
The licensee's
evaluation
was considered
reasonable
and
comprehensive.
No violation was identified.
13.II ~Ei
The inspector
met with -licensee
personnel
denoted in Section
1 at the
conclusion of the inspection.
The inspector discussed
the purpose,
scope
and findings of the inspection.
No written material
was provided to the
licensee.
~
'