ML20011A335
| ML20011A335 | |
| Person / Time | |
|---|---|
| Issue date: | 04/22/1981 |
| From: | Barnes I, Kelley W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20011A331 | List: |
| References | |
| REF-QA-99900049 NUDOCS 8110090326 | |
| Download: ML20011A335 (14) | |
Text
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND cNFORCEMENT REGION IV Report No. 99900049/81-01 Program No. 51300 Company:
Atwood and Morrill.Co., Inc.
285 Canal Street Salem, Massachusetts 01970 Inspection Conducted:
March 9-13, 1981 Inspector:
[
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Wm.D.Kelley;'C5ntractor}nspector-
/ Date Mechanical Engineer Reactive Inspection Section Vendor Inspecticn Branch f/22/P/
Approved by:
I. Barnes, Chief Date Reactive Inspection Section Vendor Inspection Branch Summary Inspection on March 9-13, 1931 (99900049/81-01)
Areas Inspected:
Implementation of 10 CFR Part 50, Appendix B and applicable codes and standards ir.cluding:
previously identified items; procurement source selection; ultrasonic examination; vendor audits; Alabama Power Company reported deficiency of Atwood and Morrill Co., Inc. valves at their Joseph fl. Farley Nuclear Plant; and Tennessee Valley Authority reported 10 CFR 50.55(e) deficiency or 12 inch decay heat removal swing check valve at their Bellefonte Nuclear Plant, Unit 2.
The inspection involved 30 inspection-hours on site by one NRC inspector.
Results:
In the six areas inspected, no nonconformances or unresolved items were identified.
8110090326 810423 PDR GA999 EMVATMO 99900049 PDR
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DETAILS A.
Persons Contacted Atwood and Morrill Co., Inc. (AM)
R. Brennam, Field Service Engineer B. A. Hersey, Project Manager
- M. D. Lyons, Quality Assurance Engineer
- E, H. Morency, Quality Control Supervisor
- W. Pentland - President A. G. Roussopoulos, Design Engineer
- R. St. Arnault, Quality control Engineer
- S. Shiolds, Vice President Engineering
- V. W. Toneatti, Corporate Quality Assurance Manager
- A. Webber, Product Service Manager Hartford Steam Boiler Inspection and Insurance Co. (HSB)
H. Evans - Authorized Nuclear Inspector J. Worrall - Authorized Inspector
- Denotes those persons who attended the Exit Interview (See paragraph I).
B.
General Review of Vendor's Activities 1.
The ASME resurveyed the Atwood and Morrill Co., Inc.(AM) Quality Assurance Program on April 7, 8, and 9,1980, and reissued Certifi-cates of Authorization N-1766 and N-1767, with an expiration date of May 20, 1983.
2.
The authorized inspection agen;. is the Hartford Steam Boiler Inspec-tion and Insurance Company.
The authorized nuclear inspector is a full time inspector.
3.
AM's contribution to the nuclear industry represents approximately 20 percent of its total workload.
C.
Previously Identified Items Deviation (Closed) Design and Document Control (Report 99900049/80-01, Details, paragraph C): Contrary to Criterion V of Appendix B to 10 CFR Part 50, Article NB-3111 and NCA-4134.5 of Section III to the ASME Code, and para-graph II.A.2 of AM's procedure 20-71-04, the design and stress report did not include in the calculations the forces imposed by the hydraulic operator upon the back seat and load key of the pressure seal.
The inspector reviewed the AM " Design and Stress Report for 16" - 1500#,
i Class 2, Wye Stop-Check Valve with Hydraulic Operator," Procedure No.
201-14255-09, Revision 1, and verified that the revised report had
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calculated tha forces imposed by the hydraulic operator upon the back seat and the load key of the pressure seal and the imposed stresses were less than the stresses allowed by Section III of the ASME Code.
The NRC Inspector verified that AM had revised their design check list to add the requirement of verifying the stresses in valves when they are in the closed position.
Deviation (Closed) Manufacturing Process Control - Machining (Report 99900049/80-01, Details, paragraph F.).
1.
Contrary to Article N6 2538(a) of Section III of the ASME Code the AM Quality Assurance Program did not provide a procedure for removal of unacceptable surface defects by grinding or machining which was supported by the NRC Inspecter's observation of arc-strikes and associated surface defects on the bonnet flange of a 10 inch, 300#,
Class 2, swing check-valve, S/N 16-15008.
The NRC Inspector verifiec that (a) AM procedure " Performing Visual Inspection of Materials and Items," Procedure No. QC-210-4, Revision 0, had been written, approved and issued and it stated in paragraph 3.3 " Arc strikes shall be removed by grinding, and the ground area examined by liquid penetrant method."
(b) The AM Final Inspection Check List, Form QC F-100A had been revised to include a check point with QC inspector signoff for verification of visual inspection for arc strikes.
The NRC Inspector reviewed AM nonconformance report NCR 24499 and verified that the arc-strikes on the swing check valve bonnet flange had been removed and dye penetrant tested in accordance with AM procedure QC-210-4.
The NRC Inspector also verified that a training sassion (instructional seminar) was held for the QC inspectors regarding the procedures requirements regarding arc strikes and their removal.
2.
Contrary ta Article NB and NC 4231.2(e) of Section III of the ASME Code, the AM Quality Assurance Program did not provide a procedure or instruction that addresses the requirement to mark the immediate area around welded temporary attachments in a manner that the area can be identified for nondestructive examination after removal of the tem-porary attachments.
The NRC Inspector verified that:
(a) AM had revised their standard Shop Process Order, Form 103-11, requiring the areas on valve parts to which temporary hold down blocks were attached by welding to be circled with a yellow marking and the area be liquid penetrant examined after removal of the temporary hold down blocks; and (b) AM had conducted a training session (instruction seminar) for the QC inspectors regarding the Shop Process Order requirements.
D.
Alabama Power Comoany Repoated Deficiency of Atwood and Morrill Co., Inc. Valves
===1.
Background===
The Alabama Power Co. (APC) notified Region II of the Nuclear Regulatory Commission (NRC) Office of Inspection and Enforcement by letter dated December 4, 1980, that as a result of the AM recommended inspection of I
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the Main Steam Isolation Valves (MSIV), damage to the three downstream valve disc stud holes and studs was detected on the Joseph M. Farley Nuclear Plant, Unit 1.
The nuts and studs were also found to be loose on the three upstream MSIVs, but no damage to the disc stud holes or studs had occurred.
APC issued a written 10 CFR Part 21 report on December 17, 1980, which stated that a malfunction of the MSIV's could have occurred if the damaged studs and stud holes had not been detected.
2.
Objectives The objectives of this area of the inspection were to ascertain whether AM had determined the cause of the problem and whether the reported deficiencies had been evaluated, and reported in a manner con-sistent with NRC rules and regulations.
3.
Method of Accomplishment The objectives of this area sf the inspection wsre accomplished by; a.
Review of Bechtel Corporation Inquiry No. SS-1102-32, " Alabama Power Company - Joseph M. Farley Nuclear Plant - Unit No. 1 Specification for Main Steam Isolation Valves for Nuclear Service," to determine:
(1) The applicable ASME Code Section, Editions and Addenda, (2) The ASME Valve Classes and Design Temperature and Pressures, (3) The service conditions identified, and (4) Whether 10 CFR Part 21 had been imposed.
b.
Review of the following AM drawings:
(1) 21261-H, Revision 6, "32 in. - 600# W.E. Main Steam Swing Disc Trip Valve - Air Cylinder Operated, (2) 21454-H, Revision 2, "32 in. - 600# W.E. Main Steam Swing Disc Trip Valve - Air Cylinder Operated, (3) D-21941, Revision 0, " Disc Arm Assembly,"
to evaluate whether the reported deficiencies could cause malfunction of the valves.
c.
Review of AM letters of December 18 and 20,1979 and June 30, 1980 to:
5 (1) Alabama Power Co. - Joseph M. Farley Nuclear Power Plants (2)
Rochester Gas and Electric Corporation - Ginna Station Power Plant, (3) Power Authority of the State of New York - Indian Point 3 Nuclear Power Plant, (4) Consolidated Edison Company of New York - Indian Point Nuclear Power Plant, to verify that AM had evaluated the problem and notified the users (licensees) of their recommendation for inspection of the MSIV's.
d.
Review of APC's Licensee Event Report No. LER 80-073/0IT-0 dated November 11, 1980, to ascertain the deficiency reported by APC, the recommended disposition and the action required to prevent recurrence.
e.
Review of APC's letter dated October 9, 1980 to AM which stated:
(1) "The AM recommended inspections of the MSIV's would be performed during the next scheduled refueling outage.
(2) They concurred with AM recommendation of replacing the 410 s/s shafts with shafts manufactured from A-564, Gr. 630 17 Cr 4 Ni steel.
(3)
. The expenditure required for extra detailed stress analysis and modifications to extend the impact life cannot be justified at this time so we will perform the inspections that will be required if the valves close under full f'ow conditions."
f.
Interviews with AM cognizant personnel to verify that they had evaluated the deficiency as not being reportable under 10 CFR Part 21 because the three accidental closures of the MSIV's were not speci-fied in the design specification; 4.
Findings a.
Within this area of the inspection, no nonconformances or unresolved items were identified.
b.
The AM swing check valves with air cylinder operators are used in the pressurized water plants as main steam isolation valves (MSIV's) and in some plants as back flow preventors in case of main steam line failure.
The air cylinder holds the valves in the open position and is spring loaded to initiate closure upon signal to close (scram) or air supply failure.
The original design specifi-cations required the valves to " retain its full integrity even after experiencing an emergency trip closing following a sudden break in the down steam piping..."
6 However, a purchase order change imposed the requirement that the valves close without disintegration with a steam flow imposed by a single guillotine pipe break.
Substantial plastic deformation of the disc diaphram was permitted with this mode of closing.
During the replacement of a shaft in the Consumers Power Company (CPC)
Palisades Nuclear Plant MSIV's by CPC personnel, with AM service personnel supervising, they discovered that the studs and stud holes holding the disc to the disc arm had sustained damage.
CPC informed AM personnel orally that the MSIV's has experienced accidental closure with full steam flow on three seperate occasioas.
AM management, engineering, quality assurance and legal counsel evaluated the NRC rules and regulations and 10 CFR Part 21 and concluded that they were not required to notify NRC.
On the advica of their legal counsel AM notified all users (licensees) of their swing-check valves subject to similar design flow conditions of their findings at CPC Palisades Nuclear Plant with their letters dated December 18 and 20, 1979 and June 30, 1980.
The users notified were:
- (1) Alabama Power Company - (APC) Joseph M. Farley Nuclear Power Plant (2) Consolidated Edison Co. of New York (CEC) Indian Point Nuclear Power Plant (3) Power Authority of the State of New York - (PASNY) Indian Point Nuclear Power Plant (4) Rochester Gas and Electric Corp. - (RGEC) Ginna Station Power Plant APC, CEC, & PASNY have responded to AM's letters in writing and orally and are kept appraised of the progress of the engineering analysis for the resolution of the problem by AM.
Only RGEC had not acknowledged AM's letters.
On December 4, 1980, APC transmitted by letter a copy of their Licensee Event Report Number LER 80-073/0IT-0.
The LER reported that APC had perform an inspection of the MSIV's in accordance with AM's recommendation and had found damaged disc arm stud holes and studs on the down stream valves and loose studs and nuts on the upstream valves.
APC stated all valves were operable; however, an engineering review conducted on November 25, 1980 concluded that if the condition had not been corrected the condition could have potentially led to a valve malfunction or failure.
APC submitted a written report to Region II of the NRC Office of Inspection and Enforcement on December 17, 1980 reporting the MSIV's stud and stud hole damage in accordance with the requirements of 10 CFR Part 21.
7 CPC issued their purchase order No. 45113-Q on November 29, 1979 which specified that AM " Restore to original purchase specification as pur-chased on CPC0 purchase order 72575-Q and/or modify to prevent failure of disc to disc arm attachment.
." Attached to the purchase order was Memorandum of Change No. 1 dated November 29, 1979 which changed the words of the purchase order from "... and/or modify to prevent failure" to "... and/or modify to increase reliability."
The memorandum of change required the following analysis to be per-formed prior to January 15, 1980:
a.
Justification that the modifications do not adversely affect the ability of the repaired MSIV's to withstand a full steam line break without failure considering the disc has already experienced three closures at full power.
b.
Comparison of observed versus expected disc deformation to assure that calculation methods used for a main steam line break are adequate.
c.
Calculation of power operator air pressure needed to hold disc open at full power conditions.
d.
Calculate the number of trips from full power which can be with-stood by the MSIV's prior to a main steam break considering the following:
(1) Disc deformation relative to allowable deformation.
(2) Elastic energy stored in the disc arm and the ability of the studs / thread engagement to absorb this energy without loosening or deformation.
(3) Arm deformation relative to deformation which results in disc being misaligned with respect to the seat due to the removal of belleville washer function.
AM completed their analysis and submitted their report to CPC for review and acceptance.
After CPC performed their review, a meeting was held at AM Salem plant and was attended by repre-sentatives of AM, CPC, and MPR (Consultant to CPC).
It was mutually agreed at the meeting that additional analysis was required which would be performed by CPC.
CPC is in the process of performing the analysis and when it is completed and reviewed by AM its conclusions will be made available by AM to the other users (licensees) that have swing check valves subject to similar design flow conditions.
The original design of the MSIV's had the nuts restrained with a A240, type 304, locking tab that had a hex opening.
The locking
8 tab had an offset that placed the locking tab midway of the nut and was tack welded to the disc arm.
The lock tab did not provide for locking the stud and prevent it from rctating.
AM concluded that the locking tab was subject to forces and vibration that were not identified in the design specification.
To assure that the studs and nuts did not vibrate loose a repair was made at the following plants (1) APC - Joseph M. Farley Nuclear Plant (2) CEC - Indiana Point Nuclear Power Plant (3)
PASNY - Indian Point Nuclear Power Plant The repair consisted of drilling a 13/64 inch hole through the engaged nut and stud and inserting a 3/16 inch pin, then deform-ing both ends of the pin, followed by welding two square steel bars on either side of the nut to prevent rotation of both stud and nut.
Repair records would be available at each plant.
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e.
AM no longer responds to invitations to bid specifying swing-check valves for nuclear plant main steam isolation and back-flow preventor applications.
AM has developed a wye type valve that they recommended for this service.
f.
From the drawings and documents reviewed, the NRC Inspector determined that the deficiency reported by APC was a direct result of AM's notification and recommendation for inspection of the MSIV's.
The NRC Inspector also determined that AM had identified the problem at CPC and had processed and evaluated it in a manner which is consistent with NRC rules and regulations and the require-ments of 10 CFR Part 21.
All of the users (licensees) of the swing-check valve with similar main steam design flow conditions have been notified by AM.
5.
Evaluation of Reportability a.
AM stated that their management, engineering, quality assurance and legal counsel had reviewed the failure of the studs and stud holes in the disc arm of the CPC Palisades Nuclear Plant MSIV's, evaluated the NRC rules and regulations and 10 CFR Part 21 and concluded they were not required to report the failure to NRC because the damage sustained by the CPC MSIV's was caused by the cycles of closure at full power, which was not specified in the design specification.
When CPC has completed the analysis of their MSIV's, AM will review the report and evaluate the results as to its applica-bility to their swing check valves that have been installed in nuclear plant main steam lines with similar design flow condi-tions.
The users (licensees) will be notified in regard to this evaluation.
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9 E.
Tennessee Valley Authority Reported 10 CFR 50.55(e) Deficiency of 12 inch
. Decay Heat Removal, Swing-Check Valve, S/N 142-13894 Manufactured by AM.
1.
Backaround The' Tennessee Valley Authority (TVA) Bellefonte Nuclear Plant, Unit 2,
' notified Region II of the NRC Office of Inspection and Enforcement by telephone on December 12, 1980, that site craftsmen had attempted to remove a crack like indication from a 12 inch Decay Heat Removal Sw;ng Check Valve (S/N 142-13894) by gri:: ding, without obtaining prior engineering authorization.
This notification was followed by the first Interim 10 CFR 50.55(e) Report, which identified the indication as an approximately two inches long surface crack in the upper body.
The site craftsmen had ground an area approximately 2 5/8 inches by 3 5/8 inches to a depth ci approximately 1/4 inch with the indica-tion still visible.
TVA notified AM in their letter of January 12, 1981, that they were returning the 12 inch check valve to the Salem MA plant for repair.
- 2.
- Objectives The objectives of this area of the inspection were to ascertain whether AM had determined the cause of the problem, and whether the potential deficiency had been corrected, evaluated, and reported in a manner consistent with NRC rules and regulations.
3.
Method of Acr.omplishment The objectives of this area of the inspection were accomplished by:
l a.
Review of TVA Over, Short, Substitution, and Damaged Report Number 178175 dated December 30, 1980 to verify that AM had been ordered to repair the 12 inch swing-check valve.
b.
Visual inspection of 12 inch swing check valve S/N 142-13894 to verify that repairs were complete.
c.
Review of AM Non-Destructive Examination Report - Liquid Penetrant, dated February 12, 1981 to verify that there was no rejectable indication after completion of the repair, and minimum wall thickness had been verified.
d.
Review of AM Test Report, dated March 6, 1981 to verify that the hydrostatic test and seat leakage (water and air) test had been performed and the 12 inch check-valve was acceptable.
e.
Review of the radiography shooting sketch and evaluation sheets, dated July 20, 1978, and the radiographs of the crotch area which contained the indications, to ascertain that the technique and radiographs met ASME Code requirements.
O 10 f.
Review of AM Nonconformance Report No. 24890 and Shop Process Order to verify repairs were performed in accordance with the ASME accepted QA program.
g.
Review of AM Engineering Evaluation of Repairs to verify that it did not invalidate the Certified Stress Report.
h.
Review of AM Dye Penetrant Inspection Report for 100% PT Post Final Machining, dated September 5, 1978.
i.
Review of PRL Industries Certification of LP Inspection, dated July 24-25, 1978.
j.
Interviews with cognizant personnel to verify that they had evaluated the deficiency as not being reportable under 10 CFR Part 21.
4.
Findings a.
Within this area of the inspection, no nonconformances or unresolved items were identified.
b.
The body of the 12 inch 1500#, SA351 Grade CF8M, Class 1 swing-check valve, S/N 142-13894, had been 100 percent dye penetrant and radiographically examined prior to assembly and hydrostatic test and found acceptable.
TVA's representative witnessed the final hydrostatic shell and seat leakage tests for the assembled valve and signed the AM Test Report on September 26, 1978, with no leakage reported for the hydrostatic shell test.
There was no evidence of an indication in the valve body in the test reports.
TVA returned the valve to AM for repair with their Over, Short, Sub-stitution and Damaged Report Number 178175, after site craftsmen had found a crack like indication in the body and had attempted to remove it by grinding.
When the valve was received at AM Salem plant the indication was not observable during visual inspection, but was detectable using the original approved liquid penetrant procedure.
AM issued a nonconformance report (No. 24890) and Shop Process Order for the repair, which consisted cf:
(1) removing the indication by grinding the 2 5/8 inch by 3 5/8 inch area approximately 1/16 deeper and blending into the adjacent area; (2) liquid penetrant examination of the entire affecte.d (ground) area; (3) verification of adequacy of wall thickness in the affected area; (4) performing an engineering evaluation of the effect of the repair on the stress report; and (5) performance of hydrostatic shell and seat leakage tests:
All repair work, testing and evalu-ation have been completed and documented, and the valve is now packaged for shipment on receipt of TVA's review and approval of the documentation.
11 5.
Evaluation of Reportability AM stated that its evaluation and tests demonstrated that the function, operability and integrity of the valve was not affected by the repair, and, the deficiency did not pose a threat to safety and was therefore not reportable by AM under 10 CFR Part 21.
The NRC inspector determined from the drawings and documents reviewed, that the reported deficiency had been processed and evaluated in a manner that was consistent with the requirements j
of 10 CFR Part 21.
Also, the drawings and documents reviewed provided reasonable assurance that the reported deficiency had been repaired and safety and health of the public was not in jeopardy.
F.
Procurement Source Selection 1.
Objectives The objectives of this area cf the inspection were to verify procedures had been prepared and approved by AM to prescribe a system for procure-ment source selection, bid evaluation and contract award in accordance with NRC rules and regulations and the ASME accepted Quality Assurance Program.
2.
Method of Accomplishment The objectives of this area of the inspection were accomplished by:
a.
Review of the ASME accepted Quality Assurance Manual Issue 5, I
(1) Section 4, " Procurement Document Control,"
(2) Section 7, " Control of Purchased Materials, Items and Services," and (3)
Section 18, " Audits,"
to verify that the vendor had established procedures for procure-ment source selection, bid evaluation, and award of contract.
b.
Review of the following procedures:
(1) QC-214-1, Revision 0, " Approved Vendor List,"
(2) QC-218-1, Revision 0, " Procedure for Vendor Audits" (3) QC-218-3, Revision 0, " Vendor Quality Assurance Program Survey;"
(4) QC-218-4, Revision 0, " Source, Inspection;"
12 to verify that procurement source selection, bid evaluation and contract award procedures were prepared by the designated authority, approved by management, and reviewed by QA.
c.
Review of the Quality Assurance Manual Sections and procedures listed above, to verifiy that they provided for integrated action and evaluation of supplier's history.
d.
Review of the Quality Assurance Manual Sections and procedure listed above to verify that they provided for:
(1) Measures to assure the supplier's bid conforms to the procurement document.
(2) Bid evalustions were made by a designated individual.
(3) Resolution of unacceptable conditions.
3.
Findings
' a.
Within this area of the inspection, no nonconformances v unre-solved items were identified.
b.
The inspector verified that procedures had been orepared and approved by AM to prescribe a system for procurement source selection, bid evaluation and contract award in accor-dance with NRC rules and regulations and the ASME accepted Quality Assurance Program.
G.
Ultrasonic Examination The inspector ascertained that AM does not perform ultrasonic examination in the Salem plant.
All valve material, that either the ASME Code or the customer design specification requires to be ultrasonically examined, is procured from an outside vendor that has been surveyed, qualified, and placed on the Approved Vendors List in accordance with the requirements of the ASME accepted Quality Assurance Program.
H.
Vendor Audits 1.
Objectives The objectives of this area of the inspection were to verify that:
1.
Procedures had been prepared and approved by AM that prescribed a system for auditing vendors, which is consistent with NRC rules and regulations and the commitments of the ASME accepted Quality Assurance Program.
b.
The AM audit procedures were being properly and effectively i
implemented.
13 2.
Method of Accomplishment The objectives of this area of the inspection were accomplished by:
a.
Raview of the ASME accepted Quality Assurance Manual Issue No. 5, (1) Section 7, " Control of Purchased Materials, Items and Services," and (2) Section 18, " Audits,"
to verify that procedures had been established to prescribe a system for auditing, which is consistent with NRC rules and regulations.
b.
Review of the following procedures:
(1) QC-218-1, Rev. O, " Procedure for Vendor Audits" (2) QC-218-2, Rev. 1, " Quality Assurance Auditor Training," and (3) QC-218-3, Rev. O, " Vendor Quality Assurance Program Surveys,"
to verify that they had been prepared by the designated authority, approved by management, and reviewed by QA.
c.
Review of the Quality Assurance Manual Sections and proceJures listed above to verify that they identify the organizations responsible for auditing and their responsibilities; establish audit personnel qualifications and training, and that the audits are performed by qualified personnel.
Also, to verify that the essential elements of the audit system are established.
d.
Review of vendor audit schedules to assure that the audits of the vendor's quality activities during design, procurement and manufacture are planned, documented, and conducted in the pre-scribed manner, and assure coserage of all aspects of the QA program.
e.
Review of vendor audit reports to verify that they include pro-visions for written plans, team selection, team orientation, audit notifications, pre-audit conferences, audit performances, and post-audit conferences.
f.
Review of vendor audit reports to verify that they are properly distributed to management and the audited vendor organization; and that follow-up audits to verify corrective action is required.
14 g.
Review of six selective AM audit reports to verify the appli-cable procedures were available to the audit team personnel, and that the audit procedures were properly and effectively implemented.
3.
Findings a.
Within this area of the inspection no nonconformances or unresolved items were identified.
b.
The inspector verified that:
(1) Procedures had been prepared and approved by AM, which prescribed a system for auditing vendors that is consistent with NRC rules and regulations and tse commitments of the ASME accepted Quality Assurance Program.
(2) The vendor audit procedures were being properly and effectively implemented by AM.
I.
Exit Interview At the conclusion of the inspection on March 13, 1981, the inspector met with the company's management, identified in paragraph A., for the purpose of informing them as to the results of the inspection.
During this meeting management was informed no nonconformances or unresolved items were identified.
The company's management acknowledged the inspector's statement. and had no additional comments.
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