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NUCLEAR REGULATORY COMMISSION REGION IV k'
611 RYAN PLAZA oRIVE. stME 1000
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,.8 ARLINGTON. TEX AS 76011
.g 1B $
MEMORANDUM FOR:
Darrell G. Eisenhut, Director, Divisio,n of Licensing, NRR FRCM:
John T. Collins, Regional Administrator
SUBJECT:
PROPOSED BOARD NOTIFICATION - COMANCHE PEAK PROTECTIVE C0ATINGS ALLEGATIONS THAT HAVE BEEN IDENTIFIED AND PREVIOUSLY FORWARDED TO TEXAS UTILITIES ELECTRIC COMPANY A total of 60 allegations related to the Comanche Peak Steam Electric Station
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protective coatings program have been identified.
These allegations have been forwarded to the licensee for their technical review, corrective actions, and preventative measures.
The licensee is in the process of completion of application of protective coatings on Unit 1.
Three inspections have been performed at Comanche Peak Steam Electric Station during 1984 to date.
These inspections have been performed by our contractor, Brookhaven National Laboratory (BNL).
The interim findings from these inspections are under review and Region IV is currently planning to request that Texas Utilities Electric Company assess and report the safety significance of these concerns.
No NRC inspection reports on protective coatings inspection results by Brookhaven National Laboratory have been written to date.
Because of the applicability of the protective coatings to the Coman~che Peak Steam Electric Station ASLB Hearing as a licensing issue and items associated with safety significance, I am recomment ing that the Board be notified i
immediately of this potential area of ccncern.
We will continue to keep you advised as to the disposition of this matter.
If additional information is required, contact D. M. Hunnicutt (728-8137) or R. L. Bangart (728-8249).
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/ %y al e gu John T. Collins
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Attachment:
Allegations cc:
G. Edison, LB1 L J- -r Ippolito, NRR
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E. Case, NRR R. DeYoung, OIE
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S. Treby, ELD S. Burwell, NRR V
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1/20/84 ALLEGATIONS CONCERNING COMANCHE PEAK PROTECTIVE C0ATINGS NOTE:
Allegations 1 through 6 are concerned with the protective coating sys-tems not being qualified, for example for environmental (irradiation) con-ditions and DBA conditions, under ANSI 101.2-1972.
(See letter to Doyle Hun-nicutt from V. Lettieri dated January 16, 1984.)
7.
NCR No. C83-01986 discusses the cracking and flaking of concrete coatings j
systems (NUTEC 11,115,1201).
The disposition sectio'n of this NCR states. " cracking of coatings is due to excessive stresses in the coating during drying and curing." The allegation is that repairing these cracks will not remedy the condition which caused the cracks.
d 8.-
Paragraph 4.1.3 of Procedure Number CCP-30, Rev.11, states: "... sh adows or ticht ra iidue of primer which may remain in the profile of t'he previously prepared substrate 'is accepta~ ble."
The allegation questions the integrity of an inorganic zinc primer which has been applied over a steel substrate with metallic zinc residue in the profile of-the steel.
The concern is that there will be coating adhesion problems, and that the zinc is isolated from the carbon steel substrate; thus the necessary calvanic action will f ail to occur.
9.
It is alleced that three coats of inorcanic zinc prir:er have been apolied at Ccmanche Peak to obtain the reouired dry film thickness.
Paragraph 3.2.4 of Instruction Number QI-QP-11.4.5, Rev. 27, states: "Only two (2) j overcoats shall be applied."
It is alleged that this system would lack chemical attraction or intercoat adhescion ~with itself.
Is this three coat primer system qualified, for example for environmental,- (irradiation) l.
conditions and DBA conditions, under ANSI N101.2-1972?
This is another i
example of the coatings systems not bein'g qualified.
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ALLEGATIONS CONCERNING COM.ANCHE PEAK PROTECTIVE C0ATINGS 1.
Paragraph 4.3.1.2 of Procedure Nu' ber CCP-40 states " Imperial coatings may m
be applied in the following sequential order: 1115/1201/11S/1201. or 11S/1201/11/1201."
Imperial letter dated May 8,1978, VBR-7697 to Mr.
Kelly Williams, second paragraph, states: "Although the resultant systems
- 115/1201/115/1201 or #115/1201/11/1201 have not b'een qualification tes-ted, there is no reason to believe that they are not viable systems."
Thus these two systems have not been DBA qualified.
2.
Specific sequencing of coatings systems not required.
For ex-ample, NRC No. C83-01752 dated 6/23/83, Disposition section, first para-
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graph, states: " Table A2 in Appendix A of AS 31 specifies acceptable coat-ing systems, i.e., primer and final coat product identification and vendors."
It then goes on to say that full sequencing is not ident i fi ed.
"This table does not identi,fy ful.1 system sequencing or application para-meters."
Does a system's sequencing change for a' repair?
'Jhy ?
Has the repair sequence been DBA qualified?
3.
DCA, No.17,142, Rev. 2, allows Carboline 305 to be applied over another manufacturer's epoxy coating.
Has this system been DBA qualified?
4.
DCA, No.12, 374, Rev.1, allows inorganic zinc primer (Carboline CZ-11 ?)
to be top coated by Imperial 1201.
Has this system been DBA qualified?
5.
Procedure No. CCP-30A, Rev. 2, page 2 of 13, paragraph 1.3.1 allows -the application of Carboline 305 over the primer Dimetcote 6 by Ameron.
Has this system been DBA qualified?
6.
Procedure No. CCP-40, Rev. 5, page 5 of 13, paragraph 4.1.1.3 states: "Re-pair of embedded foreign objects such as nails, rebar chairs, bolts, wood, or plastic shall be repaired per the following guidelines before ap-plication of NUTECH 115 surfacer."
Have these systems been DBA qualified?
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1 Q.
Paragraph 3.2.2.3 of Instruction Nunber 01-0P-11.4-5, Rev. 27, page 8 of 27, states: " Surfaces that have been power tooled with '3M Clean-N-Strip,' 80 grit or coarser ' flapper wheels,' sanding discs, ' roto peans,'
or equivalent to provide acceptable surface profile.
It has been alleged that:
The coating system applied to surfaces prepared using the above a.
specified power tool methods are not qualified, for example for en-vironmental (irradiation) conditions and DBA conditions under ANSI N101.2-1972.
l b.
The above mentioned methods provide a smoothing or polishing action, rather than a penetrating action as obtained with sandblasting or with
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a needle gun.
The profile that is obtained using the above-mentioned methods occurs c.
in a sparse patttrn and not a densely packed pattern.
11.
It is alleged that DCA No.18, 489, Rev.1, allows a primer thickness of 0.5 mils.
If this is so, is a coating system hav.ing a primer coat of 0.5 mil thickness qualified, for example for enviromtental (irradiation) con-ditions and DBA conditions, under ANSI 101,2-1972?
12.
If maximum limits are used, paragraph 4.3.1.2 of Procedure Number CCP 40, Rev. 5., allows a 102 mil thick coating system for 115/1201/115/1201.
Is this system thickness cualified, for example for environmental (ir-radiation) conditions and DBA conditions, under ANSI 101.2-1972?
13.
It is alleged that the coatings ~ applied to areas such as the reactor core cavity will not maintain their integrity due to neutron and gamma ex-It is further alleged that water and flaked-of f paint will flow posure.
out of the reactor core cavity in the case of a LOCA.
Are the coating systems apolied to these area qualified under ANSI 101.2-19'72, esoecially for environmental and DBA conditions?
Which areas are qualified and which areas are not?
If coatings in the cavity will ccce of f with ir-radiation, will this cause a problem post-LOCA?
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14.
a.
It has been alleoed that af ter a NCR is written, anyone can sian of f on it.
b.
It has been alleged that NCRs cannot be written, and that irs must be written with "unsats."
It is alleged that NCRs must be dispositioned by an engineer, while irs can be dispositioned by anyone.
What prevents itens identified on an IR from becoming lost, the problem not being resolved, or generic items not being identified?
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15.
a.
It is alleged that Paragraph 4.4.3.0 of Procedure Number CCP-30, Rev.
11, allows CZ-11 or Carboline 191 to be applied over existing Pheno-line 305 topcoat and left intact, without sanding back to a " mottled" transition.
- I b.
It is also alleged that this paragraph allows Phenoline 305 to be ap-plied over Reactic 1201 and vice-versa.
'r Are these coating systems qualified, for example for environmental and DBA conditions, under ANSI 10).2-1972?
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,16.
As a result of numerous allegations regarding improper pressure being ap-i plied to QC inspectors, NRC Office of Investigations has written violations in this area and proposed two civil penalties.
Are there 'any coating material deficiencies in the plant resulting from the improper i
pressure applied to DC inspectors (e.g., oressure not to write unsat re-I ports or NCRs, threats to lose job, use of verbal instructions to QC
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insoectors vs. written instructions, lack of supoort from OC management
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in technical disputes with construction, confusing instructions ohich do j
not support unsats, such as QI-QP-11, 4-5, Rev. 27, page 5 of 27, Note 4 and pace 19 of 27 paragraph 3.7.5.b).
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17.
It is alleged that the " air acceptability test" results are invalid be-
-cause cigarette butts are placed into the cheater valve of 'the spray gun j
prior to the test and removed after the test.
Further, it is. alleged that construction and Oc management was aware of this practice.
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2/1,6/ t ALLEGATIONS CONCERNING COMANCHE PEAK PROTECTIVE 50-445/84-03; For Allegations 1 through 17 see inspection report Note:
f 50-446/84-01, Attachment 1.
I It is alleged that QC inspecto.rs are not allowed to identify visual de-l 18.
fects such ai cracking or blistering during backfit inspections.
I It is alleged that Instruction Number QI-QP-11.4-23 and QI-QP-11.4-24 as 19.
very vague regarding the way the backfit inspections are to be conducte It is alleged that adhesion testing of the protective coatings are not 20.
The QC inspectors are instructed not to cut around performed properly.
The the adhesion test dollies when conducting adhesion tests.
instructions that come with the machine tell you to do so (and Specific tion AS-31 references these instructions).
i It is alleged that Brown & Root is doing the calibration on these adhe:
21.
testers, and they are not using a corrected value curve (which should i i
been supplied witn cach unit).
In the present nackfit program, QC inspectors are recuired to take rea
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22.
ings with adhesion testers without receiving formal training.
It is alleged that the Coatings QC Program at CPSES is inferior to tne 23.
One reason is tr same programs at other nuclear power plant projects.
standard inspection practices, used at other sites, are not used at C For example, a sample adhesion test used by a QC inspector' regularly Th another site, was not allowed at CPSES by one of the QC lead men.
the ASTM tape adhesion test.
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'24.
It is alleged that Q coatings have been placed over rusty, scaly un-prepared metal surfaces inside pipe supports made of tube steel without end-caps.
In these cases, the protective coating gets on the rusty inside of the tube.
This coating material could later. crack, scale, come off the pipe, and then travel to the sumps.
25.
It is alleged that a seal coat was accepted prior to the finished coat being applied, when in fact the seal coat should have been rejected.
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area in question is just outside the Skimmer Pump Room, in Reactor Con-tainment Building-Unit 1, on the steel liner plate.
Tne stains on the liner plate in the opinion of the inspector were not acceptable per pro-cedure and should have caused the seal coat to be rejected for finish coat application.
The QC inspector brought the condition to management's at-tantion and requested their opinion.
Management stated that the stains
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were in fact rust stains and acceptable, while the QC inspector felt it was obvious that the stains were not rust and unacceptable.
The QC in-spector stated:
"The reason I accepted this was because I feared adverse
' action would be taken against me if I rejected it."
The QC Jnspector goes on to say that this area has the finish coat on it now and none of the stains are visible.
25.
It is alleged that Design Change Authorization (DCA) documents are not controlled.
27.
It is also alleged tnat DCAs at CPSES are originated anc a. proved tar. ally by engineering.
QA/QC has no input in the review and dis Josition of DCAs.
28.
It is alieged that DCAs are used frequently and conveniently to cover up a condition for ohich a.Nonconformance Report (.1CR) shouic be written.
The alleger estimated that 40% of the DCAs are for tiCR conditions.
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29.
It is further alleged that DCAs are written to overcome a problem area which will take considerable time for repairs.
In other words, the DCAs are used to facilitate the completion of a job even though this means that accepted procedures will not be followed.
30.
It is alleged that on numerous occasions DCAs have been issued to dow'n-grade the surface preparation from an SP-10 to an SP-6 standard prepara-tion.
It is further alleged that DCAs are also written to downgrade Specification AS-31 requirements in containment to AS-30, which is the non-safety specification.
The downgrading of an SP-10 to an SP-6 surface preparation is an example of DCAs being written to downgrade from an AS-31 to an AS-30 requirement.
31.
It is further alleged that QC management interpreted an SP 6 on a DCA to mean "do the best you can".
For example, when difficult access areas were involved, QC management allegedly stated to the QC inspectors, if you can-not get to an area, do not worry about it.
32.
It is alleged that after a reading list was signed by QC inspectors, the document that they read was removed and replaced by a different document, yet the reading list coversheet remained the same.
33.
It is alleged that many problems at CPSES with coatings are cue to a QC Coatings lead Inspector's (Individual K) lack of experience in QC.
An example of this was when he identified the rust on an A-frame in the core area as being D-6 residue.
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I 3/li/St A'.i.EP.AilfA5 C0'CERriltG C0mCHE ICI PROTECTIE C0Ai!.%5 "7. I: 7:r allecations 1 through 33, see 1stiers dated January li and 24, 1934, and February 16, 1984, m:ent tattieri to Doyle M. h*unnicut) t 33 It is alleced that the requirenents of A.NSI/AS".E MS.2.2-1978 were not cr. fcr c:terial storage.
- 5.
It is alleged that Cc.anche ?esi has problecs te the area of woricanship, quality of work, painter qualification, and indectrination.
It is also Ells 5ed that docuaentatice require:ents wre not hairg ret, for exanple d:crantatica of painter palifications and in-process work.
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35.
It is flieged that the traceability o' coatines caterials was not always 041ntair.02.
37$ It is alleged that for the bacif!! program, areas that yere stated to hue satisfactory primer docu entation ended u; having 10 cils of pri=ar en them, wt.ich e::eeded the allowM caxim:m.
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it is als: alleged that ncne of the raps sho.ing areas of ade uata pri.ar d,: er.tatier. wire correct, for the backfit progra=. Additicnally, it is alleged that the docu:nentation for the biscifit pro;ra: was forced and fais'fied. Further: ore, it is alleged that a Q: ir.s;ector for the ni;r.:
sr.ift wrcte uo acceptable inspection rep rts for the do e area withcet ever performing the inspections.
- 35. It is alleged that high dry fils thickaesses (DFT'c) of CZ-11 are ;o.,er
'gr::ad to an acceptable PJi. -It is f arth.tr ziie;ed that this would burn-ish :. 3slis.'. the If ac, and ;:ssit4 ras. sit,in pc.or afnesion of the ::p 7
coat.
ii. It is alleced that old Pher.'elice 3v5 (between 1 and 2 years old) is being
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'O Ir.s rectier. Ru:'>er Qi-0A-ll.4-5, paragraph 3.2.2.d, rev. 27, dated 11/6/33, page 7 of 27 states: " Verify thi: the blasted er power tooled surfa:e has been brushed or vacuu:ed to the extent required for final
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e surfa:e inspection.' It is alleged this has never been perforced on j ',.
- var teol cleaned surfaces. It is further alleged that in lieu of fol-f.'.
1:xing the procedure, the surface.s are being bicwn down with cc:oressed i
air ;r wiped with a cloth rag. The concern with using coc;ressed air is l
that the surfac'e becomes conta:inated with oil and/or water. The concern i"
with a cloth rag is that the surfcce becoces conta:inated with lint.
- 41. It is alleged that when wiping a :urface icaediately prior to repairing l,,'
that surface, the paint is wiped with a foreign cleaning solution. Inis foreist. cleaning solution is alleged to be a hospital disir.fectant cen-tair.ingtwo(2)percentchlorites. The ccre_arn is that this hosoital j!
disinfettant is not alle ed by cc :edure ana could cause stress corresion 1
cracting of stainless steel.
- 42. It is alleged that duct tape has been placed over P,iW.:nd Inserts, leav-it.; a hole behir.d the duct tape. Also, femYmer was left inside :he Eichcadlasert. It is then alleged that 115 and 1201 are a; plied crea the d::t tape. The end result is what appears to be a solic wall, h:t in reality is a wall with hcles in it cc:ered with duct tape,115 and 1201.
- 42. I: is alleged that zinc prizer was nst sufficiently cured hafcre a ::p c:ct was applied. It is also alleged that the procedures v.re not fsi-1:ved to de:arsine if the zinc priner was prc:arly cured.
G.
It is alleced that the " nickel' test was not perfor::ed prcperly due to instru:ti:ns received fror. QC supervisors. 'It is alleged that Q: 5 per-visors instructed QC inspectors to lay the niclei fla; on the surface of the coatir.g; then to lightly ret the nickel, as lightly as the inspe:tcr c:n:ld, across the coating, to keep just encugh pressere on the nickei so
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h 15 allt;tf tha' rep!!rs of defects have been at:c.,plisnec witt, n
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inspe:tict. of these defects. For emple, a repair is cade, so:
I 20n! com-S es along and walks in that reMir, yoo have acccc:e:r that area as satis
' fact.y with footprints, contarafr.atien, sand, etc., and it is never re inspected.
It is further alleged that this repair is not given a final r
j inspe:tica of the type that would have been perfomed had it been a re-
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5tlar p.o'u tion type job.
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t 45.
It is allese:! that during tooke gauge tests, it was observed that tvsth'-
9 was seen on steel substrate, a4 grease, grir.a, filth, and other con-ta=inar.ts on concrete substrate.
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i 47.
It is a'.leied that for an installation hancer for the stear, canerators, t,*
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in violation of a written instructisn, W inspectors wre instructed to f perfs.: approximately 25 e1cce.ar adhesion tests.
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f It is alleged that coatings have been appifed our seismic joints. These joints are filled with foa: and wre n:>t to be rcate<i i
I 45.
It is allege:! that overspray into aran that has previously been inspitted has been allcwed and is cma.,c;lete.
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E U al,ie;ef that coatings hare-been 4pplied without the terefit of
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h is alle;e' that Fhenolice 305 was thinned to a 50/50 cir with thinner.
t This 50/50 aix, sen dried, beca::a as b.ittle as glass.
The 7henolina j
205 he:ne s: trittle that it was not pessible to c,ttin a t::ke gauge
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.etding. It lost its ispact resistance and abrasion resistante.
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i uege: that cca:ings have been placed c.er raw con: rete tha: ha:
nc se.-fa:e pre:aration.
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- 51. P is alleged that C inspect er infn
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- 54. It is allaged that during the cackfit Fregram, only the first u E
.,gW.g ft:::t; reading was recorded, even.lf the follodng readin s
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n:gner or.
icwer, ceaning further cut of the acceptable range It is f::rd.er allegid that the trend analysis sas a6ersely affec ir.:1::ii::; the actual readings. '
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55 I: is alleged that areas identified duricg the Eacifit Prog f.-
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- :tside of the a:ceptable range (c.r applied coatings were no 4
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55.
h It is all ge:! that original docx.entatica related to the Baci t%
was destr:yed by ? c:nage:ent.
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i 57 It is alleged tha: in Unit.'2, elevation 850, the roos directly of
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elevnce had an area ccated th'at ves esvered with filth, w
- oba::o juice, and cther unsuitabte caterial.
53, 0 Inspe::cr procedures su'ch as QI-QP-11.4-1 state:
Ix defined as the minicus light presced by a (2) cell battery It is alleged that the mini =um is terr, light, it is alleged that E ins:e:::rs were to perfom their inspectior.s it arc's length, a liget was bricht, that wasn't the sir.iaers.
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Rather, it was the cari:a and they sh:;16 obtain a Water flashlight..
55.
It is aMe;ed that a 0: :nspector accep:ec substandard c:a in liner plate, below end above the pelar crane rail at 4:icath
- 50. It is allegst that C Ins;ectors nore seie:tively 3ent to va.-icus
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inssetti:as so that the coatings woulc psss inspectier..
Forexd:ple, p.:::::icn calls for W Inspectic...
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t:it they are no ready. F.e returns tc the E office. C: the wa Vher the inspector arrives, he is
!3' Casts a se: nd i::soector proceding to the 'eres te was just t ld o
was not i