ML20012D756

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Insp Rept 70-0734/90-02 on 900305-09.No Violations or Deviations Noted.Major Areas Inspected:Open Items,Ie Info Notices,Mgt & Organization,Criticality Safety,Operations Review,Radiation Protection & Radwaste Mgt
ML20012D756
Person / Time
Site: 07000734
Issue date: 03/21/1990
From: Hooker C, Yuhas G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20012D752 List:
References
70-0734-90-02, 70-734-90-2, IEIN-84-60, IEIN-84-82, IEIN-90-001, IEIN-90-009, IEIN-90-1, IEIN-90-9, NUDOCS 9003280337
Download: ML20012D756 (10)


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  • U.:S. NUCLEAR REGULATORY COMMISSION REGION V Report No. 70-734/90-02 g

Docket-No.-70-734 License No. SNM-696

Priority 0-Category UHFF Safeguards Group II Licensee:-General Atomics P. 0.. Box 85608 92138 San Diego, California Facility Namai Torrey Pines Mesa and Sorrento Valley Sites Inspection at:

San Diego. California

Inspection Conducted
March:5-9, 1990

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Inspectori 634

  1. 0/90

'C. A. Hooker, Fuel Facilities Inspector Date Signed-.

Approved lby: O.M L J/stliO G. P.

ulas, Chief-Date Signed.'

Emerg Preparedness and i

Rad gical Protection Branch-

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-3 Summary:

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Areas Inspected:

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-This'was a routine unannounced inspection of licensee action on open items and IE Information Notices, management and organization, criticality safety, operations review,: radiation protection, l

radioactive waste management.and environmental protection.

The inspection also included tours of the licensee's facilities.

Inspection procedures 30703, 92701, 88005, 88015, 88020, E3822, l;

88035 and 88045 were-addressed.'

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Results:

In the areas inspected, the licensee's programs appeared adequate to

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the accomplishment of their scfety objectives.

No violations or-deviations were identified.

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9003200337 90032.1 I

PDR ADOCK 07000734 C:

PDC M

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fi DETAILS 1.

Persons Contacted Licensee R. N. Rademacher, Vice President, Human Resources K. E. Asmussen, Manager, Licensing, Safety and Nuclear Compliance L. R. Quintana, Manager, Health Physics (HP)

R. A. Rucker,. Manager, Nuclear Safety (MNS) 4 R.' Vanek, Manager, Nuclear Waste Processing Facility 1

P.. J. Niccoli, Superir,tendent, Facilities Maintenance i

J. R. Lindgren, Supervisor, Hot Cell Facility

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Consultant V.' Malakhof,. Criticality Safety Consultant I

All of the above noted individuals attended the exit interview on March 9, 1990.

In addition to the individuals noted above, the inspector met and held discussions with other members of the licensee's staff.

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Followup (92701) f a.

Licensee' Action on Open Items l

i Item 70-734/89-01-06 (Closed).

This item involved the need for the licensee to conduct an integrated drill to determine the effectiveness:of their Radiological Contingency Plan (RCP).

Based on review of licensee records and discussions with cognizant licensee representatives, the inspector noted that the licensee had conducted an integrated drill on October 25, 1989.

The drill's scenario involved an explosion at the TRIGA Fuel Fabrication Facility (TFFF)thatrecultedintwocontaminatedinjuredworkers being transported to a local hospital (Scripps Memorial) for medical treatment.

The drill also involved GA's fire department, and.the City of San Diego Paramedic Services as prearranged with the San Diego County Emergency Services.

A member of the licensee's quality assurance (QA) organization also observed and critiqued the drill.

According to the licensee', there were no significant problems identified with the exercise.

The inspector considers this item closed.

Item 70-734/87-01-07 (Closed).

This item involved an independent review of the licensee's RCP.

Based on discussions with licensec representatives regarding persons that have been involved with the RCP reviews,' subsequent revisions to the RCP, the current status of the licensee s operations, and the QA organization's involvement in the October 25, 1989, drill, the inspector considers this matter closed.

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i Item'70-734/89-01-01 (Closed).

This item involved a need for the

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licensee to ensure that comments and/or add on conditions Work Authorizations (WA) and Radiation Work Permits-(RWPs)placed on

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the. review process, were being implemented.

Based on review of selected recent WAs and RWPs, and discussions with cognizant licensee representatives, the inspector noted that comments and/or conditions were being adequately incorporated inte WAs and RWPs,

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which were rerouted for a-second review and signature prior to their final approval.

This item is considered closed.

Items 70-734/89-01-02, 03 and 04 (Closed).

These items respectively, involved the need for (1) management oversight of calibration and associated calculations for air sample flow meter calibrations, (2) maintaining _ records to identify locations where gas. flow meters had been used when their calibration acceptance criteria was not met, and (3) maintaining documentation to support the licensee's calibration frequenc{' Gas Meter Calibration-of gas flow meters.

Based on'a review of revised procedure EMP-4, Procedure", dated August 18, 1989, selected flow meter calibration-records, a letter from the manufacturer of the gas flow meters regarding calibration frequency, and discussions with persons involved with gas meter calibrations, the inspector determined that the licensee had taken adequate action regarding these items.

The inspector had no further questions and considered each of these-items closed.

Item 70-734/89-01-05 (Closed).

This item involved a need for the licensee to ensure that updated NRC Form-4s adequately reflected-each individual's total accumulated radiation exposure.

Based on review of selected Form-4s, the inspector noted that personnel exposures documented on these forms appeared to be consistent with the individual's exposure history.

The inspector also noted that the licensee was in the process of auditing each individual's personne1' exposure file to ensure that their Form-4s adequately reflected their exposure history.

The inspector considered this matter closed.

Item 70-734/89-04-01 (Closed).-

This item involved a need to upgrade the posting of criticality control limits on storage carts in the TFFF, consistent with the controls' imposed by the WA.

During a tour of the TFFF, the' inspector observed that the licensee had attached new signs on each side of the-storage carts that delineated their L

criticality limits consistent with the controls specified in the WA.

The inspector considers this matter closed.

1 Item 70-734/89-04-02 (Closed).

This item involved an inconsistency between licensee procedures and field tests performed on criticality alarm systems.

Based on a review of revisions being made in calibration procedures, completed field test records and discussions with facilities maintenance, personnel, the inspectur determined that the licensee was taking appropriate action to correct the inconsistencies.

The inspector considers this matter closed.

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Item 70-734/89-04-03 (Closed).

This item involved early evaluation of. routine air samples.

The licensee had changed from evaluating routinely collected air samples within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, as im) lied by the license, to about 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after collection.

During t11s inspection the inspector noted that the licensee had reinstituted evaluating, routine air samples within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after collection.

The inspector considers this matter closed.

b.

IE Information Notices The inspector verified that the licensee had received, reviewed and taken action or were taking action on IE.Information Notices Nos.

84-60, 84-82, 90-01 and 90-09.

3.

Management and Organization (88005)

This area was reviewed to determine the licensee's compliance with the requirements of the License Conditions, and licensee procedures.

Responsibilities and qualification requirements for management personnel and organizational groups are defined in Part.II, Section 3 of the License.

Education and experience of named key personnel are presented i

in Section 1 of the Safety Demonstration.

Based on discussions with

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cognizant licensee representatives and review of licensee organizational charts, the inspector observed that the licensee's management positions and organizational structure were consistent with the license.

The inspector noted that the position of MNS had recently been assumed by a new qualified individual, due to the retirement of the previous MNS.

The new MNS had also been the person performing the independent reviews of nuclear safety analysis (NSA).

T1e retired MNS was being retained as a.

consultant to provide-assistance for various programs such as Modular High Temperature Gas-Cooled Reactor (MTGR) fuel development.

With the retirement of the previous MNS, the licensee was left with two permanent staff members qualified.to perform nuclear safety evaluations.

The inspector also noted that the HP department had recently hired a contract HP technician (HPT), and were planning to hire an additional three HPTs and a degreed HP supervisor-to augment-their current staff for the proposed decommissioning of Building 37.

The licensee's Criticality and Radiation Safety Committee's (CRSC) annual audits of the various safety related programs conducted December 16, 1988, through May 10, 1989 and annual report dated July 11, 1989, were reviewed.

TheAuditfindIngs:appearedtobeadministrativein nature and did not represent any significant impact on safety.

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discussions with cognizant licensee representatives and review of selected responses to the audits, the inspector determined that actions taken appeared appropriate.

The inspector also observed that the annual CRSC audit of the HP program was in progress during this inspection.

QA Audit Report, No. 90002, " Audit of Health Physics Services", dated February 19, 1990, was also reviewed.

The audit was conducted during January 15-February 8,1990.

The audit t.nvered a review of HP i

procedures, selected HP records, and calibration of radiation detection equipment.

No deficiencies were identified.

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l Criticality audits are discussed in Section 4 below.

Selected old, new and revised licensee procedures and WAs were reviewed.

The inspector noted from these samples, that the licensee's procedures included the appropriate reviews and approvals consistent with the requirements specified in Part II, Section 3 of the License.

i The licensee appeared to be maintaining their previous level of i

performance in this area.

Their program appeared adequate to the y

accomplishment of its safety objectives.

No violations or deviations i

were identified.

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Criticality Safety (88015)

The inspector reviewed the licensee's program for compliance with the l

requirements of 10 CFR Part 70, License Conditions, licensee procedures, i

and recommendations outlined in various industry standards.

The

_j inspection included a review of selected procedures, WAs, records, and interviews with personnel and facility tours.

l There had been no operations that required a NSA since the last inspection in this area (Report No. 70-734/89-04).

Monthly Nuclear Safety reports and quarterly (required annually) inspections of areas -

containing more than 500 grams of fissile material from July 1989 through December 1989 were reviewed.

The primary area for inspection is the shipping vault in building 41 and the TFFF.

The inspector noted that the inspections appeared adequate in depth and scope for current. activities.

Inspection findings appeared to be administrative in nature and did not represent any significant safety problems with the licensee's criticality safety program.

Actions to correct inspection findings were. evident.

The inspector toured selected facilities to observe current operations and criticality controls.

Inspection Report No. 70-734/89-04 documented that chopped chips of lathe turnings from fuel castings in the TFFF were collected and stored in open 5 gallon cans.

Since the chopped chips only occupied a small volume of the 5 gallon containers, the inspector-encouraged the licensee to consider the use of lidded 1 gallon containers for storing the chopped fuel chips to increase the sefsty margin for potential overbatching and inadvertent water-intrusion.

During this inspection (70-734/90-02), the inspector observed that~the TFFF was storing chopped fuel chips-in lidded 1 gallon cans.

The inspector observed no problems with posting of criticality control limits or poor criticality safety practices in the areas toured.

Criticality monitoring systems (CMSs) were noted to be functional in the areas where they were required.

The inspector observed that the licensee had completed the installation of a new upgraded CMS in the TFFF.

The control panel for the old CMS was previously located in a locked storage room at the entry to-the facility.

During the previous inspection, the inspector discussed the limitations of the location of this unit.

During this inspection, the inspector observed that the control panel for the new CMS was visibly located near the inner door entrance to the facility.

Required-annual calibrations and monthly field tests of the CMSs were

p 5-e noted to have been conducted at a frequency more conservative than required for the more active areas.

The licensee's performance in this area appeared fully satisfactory.

Their program appeared adequate to the accomplishment of its safety objectives.

The licensee also demonstrated good response to NRC in tiatives, which was also demonstrated in Section 5 below.

No violations or deviations were identified.

5.

Operations Review This area was reviewed to determine if operations were being conducted in accordance with the requirements of the-license, licensee procedures, and recommendations outlined in various industry standards.

The inspection

'of-this area was primarily based on observations made during facility tours, and the closure of open items involved with= operational activities in Section 1, above.

The licensee was noted to be in the process of contractino the Pechtel Corporation for Decontamination / Decommissioning (D&D) of-the High

' Temperature Gas Cooled Reactor (HTGR) fuel manufacturing facility in Building No. 37 (SVA).

The licensee expected to have their

. Decommissioning Plan submitted to the NRC for review by April 1, 1990.

The licensee was also making plans to ship the radioactive waste L

generated from the D&D activities to the Department of Energy for disposal at the Nevada Test Site.

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L The. inspector observed that the licensee had recently moved the special nuclear material Quality Control Lab (QC) from.the SVA Building to L

-Building No. 39 (SVB).

The inspector observed that the new QC Lab was adequately equipped with filtered exhaust hoods for handling radioactive L

materials, and air sampling stations appeared appeared to be appropriately located.

A new WA was also posted in the Lab.

The licensee was also in the process of relocating equipment from SVA to SVB that could be used for the proposed MTGR fuel pilot plant.

The TFFF continues'to manufacture replacement fuel elements with equal to or less than 20 % U-235 on a reduced scale.

The inspector checked the q

operation of the ventilation system.

During the previous inspection of

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l-l this area, the inspector discussed, with the licensee, the value of installin facility'g an alarm on the TFFF's exhaust ventilation system to warn the s staff in the event of system failure.

During this inspection, L

the inspector observed that the licensee had installed an audible and visual alarm system'on the exhaust ventilation.

There had been no activities involved with NRC licensed material-in the Hot Cell Facility since the last inspection of this area.

The inspector noted that the ventilation system, and air monitoring and radiation monitoring equipment were being maintained fully operational.

In the areas toured, the inspector observed that (1) the exhaust ventilation systems appeared to be fully functional, (2) pressure drops across the main filters were within the limits specified in the license, l

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.y (3) current air flow measurements were posted on exhaust hoods, and (4)

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housekeeping appeared adequate, a

The licensee's program appeared adequate to the accomplishment of its safetyobjectives.

No violations or deviations were identified.

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Radiation Protection (83822)

N The inspector examined the licensee's program for compliance with the requirements of 10 CFR Parts 19 and 20, License Conditions, licensee procedures and recommendations outlined'in various industry standards, a.

External Exposure Control Personnel monitoring was primarily) based on cuarterly exchanged thermoluminescent dosimeters (TLDs processec by a contract vendor.

Vendor. reports for TLDs processed in 1989 were reviewed.

Radiation exposures appeared to be minimal and have' decreased with the gradual reduction in licensed activities.

The inspector verified that form NRC-5 or equivalent for each individual were maintained in accordance with NRC recuirements.

The inspector noted that no individual had exceedec the limits specified in 10 CFR 20.101(a).

Letters documenting exposures pursuant to 10 CFR 19.13 had been expeditiously prepared and sent to individuals that had terminated, b.

Internal Exposure Control Afr sample data for the TFFF, and SVA and SVB buildings from January 1, 1989 through February 26, 1990, were reviewed.

There were no indications of workers being exposed to intakes of radioactive neaterial which would exceed the 40- MPC-hour control measure requiring an evaluation pursuant to 10 CFR20.103(b)(2).

Data from routine air samples indicated that average air concentrations were 1.0E-13 microcuries/ milliliter (uci/ml) or less.

The maximum air concentration noted was 1.39E-11 uCi/ml.

The air sample data indicated that workers exposure from airborne activity was being maintained ALARA.

The inspector also noted that the licensee conducted annual reviews of air sample locations.

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During facility tours the inspector observed that air sampling L

stations appeared be sufficient in number, and reasonably L

representative of the work area being sampled.

Engineering controls l

to contain loose radioactive material were evident.

Supplied air hoods are used by workers when there is a task that has the o

potential for creating high airborne radioactive material.

All individuals that may be required to wear air hoods were noted to l

have been medically qualified and had received training in L

respiratory protection.

Although the licensee does not use air L

purifying respirators in their program, the inspector was informed that a program to institute such use for the proposed D&D of the HTGR fuel fabrication facility was being considered.

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The primary activities at GA involve the use of the use of l-uranium-zirconium alloy for the fabrication of TRIGA fuel, and the l:

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use:of uranium oxide when the HTGR fuel fabrication facility was in operation.

The licensee's uranium bioassay program has been primarily based on nontransportable enriched uranium (greater than 5.0 percent U-235) compounds, with nominal enrichments of 20 and 93

-percent U-235.

Bioassay sampling consisted of semiannual invivo lung counts, performed by an outside vendor using a mobile unit with a minimum detection level (MDL) for U-235 that ranged from 30 to 60 micrograms (u ).

Urine sample measurements were also performed semiannually y-an outside vendor using the-radiometric method with a MDL of abou 0.9 picocuries uranium per liter.

Invivo-lung counts and urinalysis results for 1988 and 1989 were reviewed.

The inspector noted that one individual had a lung count that sibhtly exceeded the licensee's investigation level of 100 ug U-235.

The licensee investigation concluded that the U-235 results may have been the interference from a slight amount thorium detected, since this' individual's had only worked with thorium during the time

. period involved and previous and post bioassay measurements had not detected any U-235.

The inspector's review of the bioassay data for this individual identified no problems with the. licensee's conclusion. -Based on independent calculations by the inspector, it appeared that no bioassay measurement indicated any individual had exceeded the 40-hour control measure specified in 10 CFR 20.103(b)(2) to warrant further licensee investigation.

c.

Control of Radioactive Materials and Contamination, Surveys, and Monitoring n

During facility tours, the inspector observed that adequate l

operating personnel survey instruments were conveniently loce.ted at l-exits from contaminated areas.

Workers were observed to be dressed l

in protective clothing as specified on WAs or RWFs.

RWPs provided adequate worker instructions. Safety evaluations were also performed s

I on each RWP to ensure that the conditions of the'RWP were being complied with. ~The inspector noted that radioactive materials and l

radiation areas were posted in accordance with the requirements l

delineated in'10 CFR Part 20.

1 Based on review of survey records, the inspector noted that the licensee' radiation and contamination survey program appeered to be

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consistent with Section 4.0 Part II of the License and trce p

requirements of specified in 10 CFR 20.201.

The Licensee's annual CRSC meeting to review GA's ALARA program was conducted on August 9, 1989.

The inspector noted that the ALARA review adequately addressed efforts and radiological conditions for exposure reduction, and presented summaries personnel exposures.

The licensee's performaru in this area appeared adequate.

Their programsseemedcapableofmeetingtheirsafetyobjectives.

No violations or deviations were identified.

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Radioactive Waste Management (88'10)

The inspector reviewed the licensee's program for. compliance with 10 CFR Part 20,: license requirements and rcrommendations outlined in various industry standards.

There have been no significant changes in the license's program since the last inspection of this area. The-inspector noted that high activit levelradioactiveliquidwastewassolidified,andlowactivitylevel" i

-liquids wer? filtered, sampled and analyzed prior to being released in batches to the regional-sewer system.

Review of radioactive liquid i

discharges from January 1,1989, through March 6,1990, indicated that all releases were within the requiremefs specified in 10 CFR 20.303.

The review of gaseous effluent samplin'g data from January 1,1989, through January 1, 1990 indicated that releases of radioactive materials were well below the limits specified in 10 CFR-Part 20, Appendix B,. Table II.

The licensee's procedures for assuring the quality of counting equipment 1

data were examined for 1989.

The records were noted to include routine testing for performance, reproducibility, resolution, and efficienty for-counting equipment.

Records of routine counting equipment testing were examined and considered satisfactory.

The records documented the equipment was bein0 operated within the specifications stated in the licensee's procedures.

The lower limit of detection of samples being counted appeared to be well below the concentration limits specified in 10 CFR Part 20, Appendix B, Tables I and II.

The licensee's semiannual effluent reports for the periods of January 1 through June 30, 1989, dated July 17, 1989, and July 1 through December 31, 1989, dated February 28, 1990, were reviewed.

These reports were submitted in accordance with 10 CFR 70.59 and provided a summary of the radioactive gaseous and licuid effluents released from the facility. The inspector noted that the acditional backup data supplied with the July 1 through December 31,-1989, report indicated a major improvement compared to previous = reports.

Previous reports provided limited data for adequate-peer review.

The 1"spector encouraged =the licensee to consider using the format contai a

" Appendix B of Regulatory Guide 4.16, " Monitoring and Reportira Rao M

vity in Releases of Radioactive Materials in Liquid and Gaseous eff k ats from Nuclear Fuel Processing and Fabrication Plants and Uranium Hexafluoride Production Plants", dated December 1985.

The effluent releases were noted-to be less than the limits specified in 10 CFR Part 20, Appendix B, Table II.

No errors or anomalies were identified.

The licensee's program appeared adequate to the accomplishment of its safety objectives. No violations or deviations were identified.

8.

Environmental Protection (88045)

The inspector reviewed the licensee's program for compliance with 10 CFR Part 20, license requirements and recommendations outlined in various industry standards.

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The inspector noted that the licensee's procedures were consistent with-the requirements delineated in Part II Section 6 of the license for (1) therequiredtypeofsamplestobecollected(e.f2} air, water,. sewage, soil vegetation and external gamma radiation),

the minimum detection sensItivityre sites, and (4) quired for sample analysis, (3) the number of sampling the non-radiological monitoring program.

In addition to the observations made in the above-Section, tie inspector reviewed the environmental-data and ch ram as-submittedinthelIcensee'anesmadeinthelicensee'sprofedNovember s icense renewal application da 1989.

The inspector noted that the data indicated that releases of cc radioactive materials to unrestricted-areas were well below the regulatory limits.

Changes in sampling locations were consistent with the reduction of the licensee's site houndary, and appeared to be representative for monitoring releases to unrestricted areas.

The licensee's performance in this area appeared fully satisfactory.

l Their program appeared capable of meeting its safety objectives.

No violations or deviations were identified.

9.

Exit Interview The inspector met with the licensee representatives, denoted in Section 1

1}ndingsoftheinspectionweresummarized.at the conclusion of the inspection'o The-scope and' f

The licensee was informed that no violations or des:htions were identified.-

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