ML17177A518
| ML17177A518 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 07/02/1992 |
| From: | Beverly Clayton NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17177A517 | List: |
| References | |
| 50-237-92-13, 50-249-92-13, NUDOCS 9207090343 | |
| Download: ML17177A518 (14) | |
Text
NOTICE OF VIOLATION Commonwealth Edison Company.
Dresden Stat i o.n
- Docket Nos. 50-237; 50-249 License Nos. DPR-19; DPR-25 As a result of an inspection conducted from April 1 through May 28, 1992~ a violation of NRC requirements was identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 19 CFR Part 2, Appendix C (1992), the violation is listed below:
C~iterion V of 10 CFR Part 50, Appendix B, require~ that activities affecting*
.. qua 1 i ty sha 11 be prescribed by documented instructions, -procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with those instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for-determining that important activities have been-satisfactorily accomplished.
~s implemented by Dresden Administrative Procedure OAP 15-06, Preparation and Control of Work Requests, Revision 2, Sections F.1.j. (1) which states i.ri part that the work packages shall be reviewed to ensure that "a developed test is*
available and is valid for this application... and F.Lj.(2) which states in.
part that the work package shall be reviewed to ensure that "verifications are crinducted in accordance with written instructions or formal procedures."
. Contrary to the above, work instructions of activities affecting.quality were not appropriate to the circumstirices or did riot include_app~opriate quantitative or qualitative acceptance criteria for determining that important
- activities have been satisfactorily accomplished as shown ~n the following examples~
- 1.
On March 23, 1992, Work Request 008dl6 re-orientated the Unit 3 Reactof Building Ventilation Excess Flow Check Valve.
The appropriate post-maintenance testing to determine that the acti~ities prescribed by the work request were s*atisfattorily accomplished was not required to.be available and included in the work package.
- 2.
On May 12, 1992, Work Request 007195 retorqued the packing on the Unit 3 10 Main Steam Isolation Valve.. The activity was not accomplished by the approved station procedure appropriate to the circumstances of adjusting packing on Main Steam Isolation Valves.
- 3.
.on December 16, 1992, 'work Request 003458 replaced the High Pressure_
Coolant Injection Booster Pump Vent Valve Assembly.
The appropriate leak check test for determining that the activities performed by the
- work request were satisfactorily accomplished was not required to be available and included in the work package.
- This is a Severity Level IV violatfon (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Convnonwea.lth Edison is hereby requ.ired to.submit a written statement or explanation* to the U.S. Nuclear Regulatory Convnission, ATTN:* Document Control Desk, Washington D.C. 20555 with a copy'to the U.S. Nuclear Regulatory Commission, Region III, 799 Roosevelt Road, Glen Ellyn, Illinois, 60137, and a copy to the NRC Resident Inspector at the Dresden Station within 30 days of the date of the letter*
transmitting this Notice of V1olation~
- This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each viQlation:
(1) the reason for the violation, or, if contested, the basis for disputing the
- vi~lation, (2) the corrective steps th*t have been taken and the results.
achieved, (3) the correctiv~ steps that will.be taken to avoid further v-i o 1 at ions, and ( 4) the date when full. compliance wi 11 be achieved.
If an
. adequate reply is not received within the time specified in this Notice, an order or a demand for information may be issued as to why the license should not be modified, suspended, or revoked, or why such ~ther action as may be proper should not be taken.
Where good cause is shown, consideration will be given to extending the response time.
Dated at Glen Ellyn, Illinois
- . this 2.....,t day of :J"t.y(J
, 1992
- ~¥-
Brent Clayton, Chief Reactor *Projects Bran~h 1
U.S. NUCLEAR REGULATORY.COMMISS~ON
.REGION I I 1*
Reports No. 50-237/92013(DRP};.50-249/92013(DRP)
Docket Nos. 50-237; 50-249 license Nos. DPR-19; DPR-2~
Licensee:
Conunonwealth Edison Company
- opus West I I I 1400 Opus Place Downers Grov~, IL 60515 F~ctlity Name:
Dresd~n Station, Units 2 ~nd*3 Inspection At: Dresden.Site, H~rris; Illinois Inspection Conducted: April 1 through May 28, 1992 Inspector: S. G. Du Pont Approved By:
{f(C ~Y4" R. C. Knop, Chief Reactor Projects Section 18 Inspection Summary Date Inspection from April 1 through May 28. 1992 (Reports No.
50-231/920l~CDR~};
50-249/92013CDRPl}
Areas Inspected: Special inspection of the quality of work requests, ~dequacy
~f work instructions, and post-maintenance testing.
Results:
- One violation of 10 CFR Part 50, Appendix Jl, Criterion V, was identifiecj with.multiple examples.
The examples included wofk in~tructions fail{ng
. to require adequate post-maintenance testing.
- An unresolved item was identified pertaining t~ an apparent failure of the administrative procedure OAP 15~06 to require recording of as-found and as-left data to quantify the maintenance activity and to ensure quality of activities by restricting multiple actions within an individual step.
Poor work practices were identified pertaining.>to reliance on a multiple tiers ~eview process without re~uiring responsibility t~ quality in lower tiers.
Poor work practices were identified pertaining to the quality of.
preparation of work instructions, use of the Work Analysts'. Checklist a~~ *superv1 so_ry_ overview_ of. the. prepa:ratjon. of~ ~ork _instructions..
9207090344 920702. *,
PDR ADOCK 05000237 Q
y A concern was i dent i fi ed with the impact on management's ability to trend wor.k*requests, work planning to accurately schedule work, and for accurate ALARA trending by Dresden's practice to accomplish multiple work tasks and or work requests tn an individual work request. This practice is not governed by an administrative procedure or requirements.*
The work tasks are not required to be related other than associated with the same system.
I.
2
DETAILS Persons Contacted
- Conunonwealth Edison Companv CCECo).
- M. Pope, Quality Control Supervisor
- T. J. O'Connor, A~sistant Superintendent of ~aintenance
- E. W. Carroll, Regulatory Assurance
- B. W. Colebank, Maintenance
- K. Johnson, Instrument Maintenance Scheduler
- K. Deck, Onsite Nuclear Safety Group
- T. Kahler, Mechanical Maintenance Senior Analyst
- J. N. Kish, Onsite Nuclear Safety Group
- S. Domantas, Electrical Maintenance Analyst
- D. Saccomado, Nuclear Licensing
~J. Harrington, Nuclear Quality Programs
- Denotes those attending the exit interview conducted on May 28, 1992.
The inspectors also talked with and interviewed seve~al other licensee*
employees.
~.
Nuclear Wo~k Requests*
- a.
Scope of Inspection
- b.
During the Unit 3 startup from April l through April 15, 1992, the
- inspecto~ reviewed a sample of completed and in the process of completion work requests (NWRs).
A sample of 31 safety-related and 5 balance of plant NWRs were randomly selected.
The. inspection consisted of document reviews, post maintenance
- testing observations, and interviews with personnel.
The inspector reviewed the NWRs for adequacy of work instruction.(WI);
post-maintenance verification (PMV), and post maintenance testing_
(PMT).
The inspector also reviewed the administrative procedures controlling NWRs.
Acjministrative procedures OAP 15-01, Revisions 22 and 23, "Initiating and Processing a Work Request," and.OAP 15-06, Revisioris l and 2, "Preparation and Control of Work Requests,"
were *reviewed to verify the adequacy of the Wis, PMVs,_ and PMTs.
Work Instructions
- Dresden uses several types of Wis related to the detail and degree of complexity of the requested work.
The administrative pro:cedures define and control the different types of Wis.
A WI for a simple work request could be a statement to retorque the packing of a valve to a specified value on'the actual NWR cover 3
sheet.
For more complex tasks, a station traveler with approved handwritten instructions could exist or an existing station approved maintenance procedure would be used.
- c.
Post~Haintenance Vetiff~ation and Testin~ *.
Dresden establ ish-ed, on September 10, 1991, a detaHed guide for PHY and PMT for most of the individual components within both Units 2 and 3. The guide consists of a matrix identifying the component, type of component, required PMV/PHT and specific station approved surveillance procedures as referenced.
The matri~ was established to ensure that the required PM! for components contained in the Inservice Test, Motor Operated Valve Test, and Local Leak Rate programs was performed. *
- d.
Findings Associ~ted with Violation of.Requirements The inspector identified discrepancies in three of the selected safety-related and two of the selected.balance of plant. NWRs.
The discrepancies identified in the safety-related NWRs are violations tif quality requirements of 10 CFR 50, Appendix B, Criterion V, which requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be.
accomplished in accordance with these instruction, proced~res, or.
drawing~. Instructions, pr~cedures, or drawings shall incl~de appropriate quantitative or 4ualitative acceptance criteria for determining that important activities have been satisfactorily accomplished (50-237 /9201.3-01 (DRP); 50-237 /92013...,01 (DRP.>).
The following are ihe details of the inspector's findings:
NWR 008016*
. The NWR was implemented to re-orient~te the reactor building
. ventilation excess fl ow check va 1 ve which was discovered to be installed in the reverse direction.
The work instructions were contained on*the NWR cover sheet.
- The instructions were appropriate to the task since the check valve was to be removed, turned to the proper orientation and installed; The review of the PMV and PMT requirements revealed the following violation of 10 CFR 50,* ~ppendix B, Criterion V:
The Post-Maintenance Verification and Testing Matrix issued on September 10, 1991, contained requirements
. for stroke.exercise (timing), position indication testing, and a fail safe test. The Work Analysts' checklist,Section VII, Post-Maintenance Testing, 4
Step b., "The PMV /PMT da'ta base has been referenced and all verification/tests have been specified on the PMV/PMT Record Sheet," was noted by the Work Analysts as being tompleted.
However, during the review of *the completed NWR by the operating department Shift Engfoeer, it was discovered.that the stroke exercise and the position indication tests we~e not incl~ded on**
the PMV/PMT Record Sheet. The Shift Engineer* *
- corrected the record sheet and the omitted tests were subsequently performed.
During discussions of this occurrence.with the licensee staff, it was noted that their "multiple tier review of wo,rk is important to the succes$ful operation of the PMT program." Although the i~spector agrees that multiple tier review is impo~tant to quality, it should be noted that only the leist tier of review was successful.
NWR'POZ195 The NWR ~as implemented to repair a packing leak on the main steam isolation val~e, 3-203~10.
The work instructidns was contained on the NWR cover sheet.
The instructions stated "retorque packing to 47-50 ft. lbs.
Cycle valve and retorque until nti nut movement is f~lt."
- The inspector found tha.t containing the work instructions on the NWR was not in accordance with the.station Administrative Procedure, OAP 15-06, "Preparation and
- .Control of Work Requests."
OAP 15-06, Step F.1.m, states that if the NWR was determined to be."Routine Maintenance" and noted on the NWR; then the work instructions can be
~
written on the NWR.
This NWR was not determined and noted as "Routine Maintenance." Also, OAP 15-06, Step F.l.n,
- st~tes, in part, that the work package, such as a traveler~
should be consistent ~ith the complexity of work and previous maintenance using various documents*.
- These documents included approved Dresden station procedures.
An approved maintenance procedure, DMP 40-40, existed for repacking of v~lves, including the Main Steam Isolation Valve.
The station procedure was not used and is considered to be in violation of 10 CFR 50, A~pendix B, Criterion V.
NWR 003458 The NWR was implemented to repair the High Pressure Coolant Injection (HPCI) Booster Pump Vent Valv~~ The work task.
- involved replacing the vent valve assembly with a newly fabricated assembly which contained three valves and
. associated piping and connections.*. Twenty-two welds were required during the fabrication~
- 5 -
The inspector reviewed the PMT and found that leak check testing of the welds wa~ not prescribed. The inspector discussed the discrepancy with the operating staff. The operating staff agreed and scheduled the appropriate leak check testing. Discussions with the maintenance staff.
revealed that leak check testing wa~ not included in the work package because the replaced valve was less than one inch in size. This exempted the valve from the American Society of Mechanical Engineers (ASHE),Section XI, nRepair
- and Replacement Requirements." The licensee co~sidered the leak check testing performed by the operating staff as being above the minimum testing requirements.
The. HPCI booster pump vent valve assembly is considered to be a support system to the safety-related HPCI system.. J.n addition~ th~ fabrication of the.vent valve assembly was.
- considered and. noted as safety-related work.
- The leak check.*
test is considered to be the minimum appropriate testing for*
- the circumstances of post-maintenance testing of fabricated welds on a safety-related system.
The omission of the leak check testing of the welds on the HPCI booster pump vent system is a violation of 10 CFR 50, Appendix 8, Criteribn V.
These e~amples of violations of 10 CFR 50, Appendix 8, Criteririn
.V, are of concern because of 'D~esden's recent efforts to impr~v~
the quality of work instructions and to ensure that required post~
maintenance testing are performed.
- e.
Unresolved Inspection Item Outing the review of work packages, the inspector identified
- several work requests that did not appear to be of a quality as described in 10 CFR 50, Appendix 8.
Examples included the-failure to record as-found and as-left data to qualify the maintenance
~ctivities, to require acceptance or rejection criteria. to ensure tjuality and work instructions containing multiple action~ within.
individual inst~~ction steps. Instruction steps containi~g
- multiple actions may prevent assurance of the quality of maintenance by creating opportunities to fail. to assemble components in the required order or omit critical alignment requirements, all of which can affect the quality of the maintenance activities.
- This is also of concern b~cause of
.Dresden's recent efforts to improve the quality of work request instructions.
Administrative procedure OAP 15-06 appears to be insufficient in requiring quality of maintenance activities.
OAP 115-06 does not require recording of as-found or as-left data in work instructions, that clear acceptance or rejection criteria is prescribed by the work instructions, or restrict the use of
. multiple actions within individual steps in the work instructions.
Ih spetific cases; such as~maintenance activities involving 6
modifications, acceptance criteria are required fn the work instructions. However, this is not required by the procedure for other applications.
Dresden, as part of their recent efforts to improve work package
- qu~lity, did develop a guide to assist in preparing work instructions. However, this guide is not required to be adhered to and the inspector found it riot to be effective in ensuring quality. The licensee developed a detailed Work Analyst's Work Package Preparat i 9n Checklist and a p'ost-ma i ntenance verification/test matrix.
Both the checklist and matrix addressed all of the identified violations of 10 CFR 50, Appendix 8, but was inappropriately used in all cases.
The checklist inquires on whether work.instruction steps contained only one action requirement and that the work instructions and post-maintenance
- testirig contain clearly stated accept~nce/rejection criteria.
- In
~ll cases, the inspector verified that th~ checklist was inappropriately used by the Work Analyst. This is indicative of both the training received by the Work Analyst and the supervisory overview of the work package preparation.
The apparent inad~quacies of administrative procedure OAP 15-06 are considered to be an unresolved inspection item (50-237/92013~
02(DRP);50-249/92013-02(DRP)) bec~use the inspection* did not determine, du~ to inadequate information and inspection duration, that the procedure did or did not satisfy the requirements of 10 CFR 50, Appendix B.
The following are examples of the unresolved inspection item:
NWR 006941.
The NWR was implemented to remove corrosion developing on the Unit 2 24/48 volt battery. The request was to clean cell posts and connections as required.
. The work instructitin was cont*ined on the NWR cover sheet as
- "request permission from operating to clean the cell connections.
Do not disconnect any connections.
Using a clean wire brush, clean the corrosion from the affected connections and with a clean cloth, clean the corrosion from the top of battery cells. Apply No-Oxide, Store No.
777.f60, to the connections. See the PMV/PMT form*
attached."
. The PMV/PMT for the NWR was app~op~iate.
- The review of the Dresden Work Analyst's Package Preparation Checkli~t (WA checklist) identified that the work instructiori contained clearly stated acceptance/rejection 7
criteria. However, as stated above, the work instructions did not contain either acceptance or rejection criteria.
NWR 0090405 The NWR was implemented to replace the High Pressure Coolant.
Injection Punip Discharge Valve worm gear in the motor operator (MOY).
- An approved work instruction contained within a station traveler prescribed the detailed steps for r~moving and repl aciilg the MOY worm gear.
The PMY/PMTs wefe approp~iate and accomplished.
The detailed review of the work instructions identified that several steps contained multiple ~ctions.
One example of multiple actions is Step No. 8 of the ~ork instructions, which stated, "remo~e the nut holdihg the spring pac.k assembly together by removi ilg the set screw.in.
the nut. If the nut fs a regular* lock nut the nut will not have a set screw in the nut.
Remove the spring from the carttidge stem keeping th~ springs in the original orientation." In this case~ the step contained two actions, removing the set screw and the spring, one caution, maintaining the original orientation; ~nd one note that ~
lock nut will not have a set screw.
Another example is Step No. 11, which stated, "repla~e the worm and the bearing assembly from the bearing cap~ Remove the~set screw out of the bearing locknut.
Then remove the locknut and the beari~g." A third example is Step No. 13, "thread the cartridge stem into the bearing tap.
Install the set screw into the threaded area of the bearing cap to
. cartridge ste~. Then install. the spring washers to the correct orientation. Tighten the nut to the recorded MIC reading." This step clearly contains three actions, threading the cartridge stem, installing the set screw and installing the spring washers.
The last action, installing the spring washer; was selected as a quality control (QC) hold point and observed by a QC inspector.
The last example is Step No. 15, which stated, "Install new 0-rings and gaskets on the spring pack cover. *Install the cover being careful not to pull the declutch ~haft out.
Inst~ll the _
bolt~ and tighten the bolts." Thii example, in ~dditiori to multiple actions, install the 0-rings and gaskets and the cdver and bolts, contains a caution pertaining to the possibility of pulling the declutch shaft out of pbsition.
8
The work analyst uses the WA checklist to prepare the work instructions. The WA checklist,Section V, "Prepare Work Instructions," ~sks whether *each step contains ~nly one
- action requirement." The work analyst failed to recognize
. that the prepared WI steps contained more than one action requirement and denoted on the checklist that the work instructions did not contain multiple actions.
Additionally, the Dresden Station Procedure Writer's Guide (Writers Guide) instructs that warning, caution, and note
- statements should not contain action steps.* It should be not.ed that. the Writer's Guide was not intended for preparing work instructions and is not required to b~ used by work analysts.
The referencing of the Writer'.s Guide in this example was to demonstrate that information in preparing adequate instructions f<>r activities affecting quality was available..
- NWR D03420
- The NWR was iniiiated to disas~emble and inspect the HPCI turning gear. *The NWR also directed adjusting the clash gear as necessary.to ensure that the HPCI turning gear maintains engaged.
The inspector reviewed the work instructions contained with the work package and found that the initructions *cQntained multiple action requirements similar to those associated with NWR D090405~. An example is Step No. 10, which stated, "with bearing housing uppet cover removed, inspect front and back bearing ho~sing oil deflectors. With feeler gaugesi '
check for co~rect clearance-between shaft. A clearance of
.. 0.005 to 0.. 007 foches should.be maintained. Adjust deflectors if required. Clean out oil drain hole in bottom of front and back deflectors and en 1 arge drain hole per factory representative recommendation.*" This step contained tw6 action requirements.
The first pert~ined to ~easuring and adjusting the deflectors. The-second pertained to enlarging the d~ain hole.
Additionally, the work instructions did not require recording of the as-found and as-left measurements of the
- clearance between the shaft arid oil deflectors was not required to be recorded.
NWR D03240 The balance of plant NWR was implemented to in~estigate and
- repair a sticking agastat on the Unit 3 Main Generator Variac.
In accordance with Dresden's administrative procedures, the NWR was classif~ed as reliability related.
9
The approved work instructions were contained in the work package.* The inspector reviewed the detailed work instructions and found that several steps contained cautions and n~tes within the action requirements. Step No. 11, nonce the motor is operating proper.ly, operate electrically and *using an ohmmeter, check that all of the contacts that are not SPARES exhibit one ohm or less resiStance when **
closed and infiriite resist~nce when ~pen. :It might be necessary to stop the motor when the contacts operate to achieve an accurate reading," is an ex-ample of a note being included with the action requirement.
Step No. 13, "if any limit switchei are replaced, since th~re are.three limit switches_gang mo.unted, all three.limit switches will be disrupted.. Consequently, electrically recheck all three limit switches," is another example of combining a note with *
- an action requirement. Step Nos. 7.A and 7.8-contained cautions ~ith the action requirement; Step No. 7.A st~ted,
- nt.o run the motor in the RAISE FIELD mode, apply 125V d.c.
- across the wires that terminate to re~istrirs G2R and GlR.
Caution, wire from resistor G3R will become ene~gized." In addition to containing cautions with action requirement~, it i~ inappropriate to cautipn the work instruction.user after the action. Appropriate use of cautions, as.noted by the.
D~esden Station Procedure Writer'~ Guide, is to state the
_caution separate of and before the action requiremenL Additionally, the inspector found that Step No. 10, "~emove and check the motor :brushes,. replace if necessary, if the
- same br1.i'shes are re-installed, re-install them in the same brush holder from which they were removed and at the same curvature," did not contain acceptance or rejection criteria
-for inspecting the brushes *or require recording the as-found and as-left measurements of the brush curvatures.
Due to the lack of as-found and as-left data associated with the NWR, the various measurements were required to be
- reperformed to maintain a quality machinery history.
.NWR P08197 The balance of plant NWR was implemented to adjust the Unit 3 Main Generator Excitor Field Variac because of excessively slow motion of the variac in both raise and lower directions.
The inspector reviewed the PMV and PMT identified in the work package.
The originally stat~d probiem was that the variac moved slriwly at about 1/8 inch per minute wi.th about five minutes for full travel.* The post-maintenance verification was prescribed to verify that the variac moved smoothly in both directions for complete travel. This was not an appropriate verification that the problem of the
.:.. _~.__ _.
~-. -* - ~-- - - -.. -- - -
10
variac moving slowly was corrected. Additionally, neither the PMV or PMT contained acceptance or rejection criteria associated with the variac travel speed.
The inspector reviewed the WA checklist and discovered that the Work Analyst inappropriately noted that ~cceptance and rejeCtion criteria was stated for. the PMT.
- f.
Work Practices The inspector also observed several work practices that are of concern, in addition to the inappropriate use and s~pervision of the work package preparation.
NWRs 008016 and 003458 contained examples of PMTs not being included with the issued work packages.
In the case -0f NWR 008016, the licensee operating staff identified the missing MPTs.
The inspector identified the lack of leak check testing on the safety-related support system associated with NWR 003458.
During discussions with the maintenance staff, it was apparent that reliance on the multiple tier review process is important to the success of Oresden's work package.
However, it is also apparent that accountability is not required in the lower tiers, as
.e.videnced by the many examples of inappropriate use of the.WA checklist and PMV/PMT matrix and the ineffective supervision of the work package preparation process.
Another work practice of concern was revealed during the ~eview of NWR 003420.
The NWR was initiated to resolve the High Pressure Coolant Injection (HPCI) turning gear disengaging p~oblem. The licensee included, in.the work instruction, two additional tasks to resolve another identified problem on the HPCI system-that.was
. not related to the turning gear engaging problem; The first was to change the ~learance of the HPCI turbine/pump shaft oil deflectors. The other was to enlarge the oil drain line from the
- oil deflectors. These efforts were intended to reduce the amount of shaft oil leakage.
The insp~ctor recognized the administrative benefits to combining work r~quests. However, the inspector questions the licensee management's ability to evaluate and trend the backlog of work requests. The licensee stated that combined work requests were trended separately. The inspector also questions the ability of work planning to accurately schedule work during short forced outages since hours to complete the work_
request are not separated for the individual tasks.. Additionally, the inspector questioned the licensee's ability to accurately assess the radiation dose acquired for -the individual tasks for
- ALARA.planning.
The licensee beHeved that their radiation work permit process accurately captured the acquired dose for each of the individual tasks.
One violation and one unresolved item both with multiple examples were identified.
11
- 3.
Unresolved Items Unresolved items are niatters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations.
An unresolved item disclOsed during the inspection is*
discussed tn Paragraph _2.e.
- 4.
Exit Interview C30703l The inspector met with the licensee representatives denoted in Paragraph 1 during the ~nspection period and at the conclusion of the inspection on May 28, 1992.
The inspectors summarized the scope and results of the inspection and discussed the likely content of this inspection _report.
The licensee acknowledged the information and did not indica.tethat any of the information disclose~ during the inspection could be considered proprietary in nature.
12