ML20148S271

Insp Rept 50-346/88-04 on 871209-880108.Violations Noted. Major Areas Inspected:Activities Re Allegation

ML20148S271
Person / Time
Site:	Davis Besse
Issue date:	01/28/1988
From:	Guldemond W, Landsman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20148S246	List: ML20148S271
References
50-346-88-04, 50-346-88-4, NUDOCS 8802020375
Download: ML20148S271 (13)

See also: IR 05000346/1988004

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U.S. NUCLEAR REGULATORY. COMMISSION

REGION III

Report No. 50-346/88004(DRP) Operating License No. NPF-3

Docket No. 50-346

Licensee: Toledo Edison Company

Edison Plaza

300 Madison Avenue

Toledo, OH 43652

Facility Name: Davis-Besse 1

Inspection At: Oak Harbor, Ohio

Inspection Conducted: December 9, 1987 through January 8, 1988

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Inspector: R.B.Landspn

Approved By: . G. u demond, Chie / .2g-gg

Reactor Projects Branch 2 Date

Inspection Sumary

Inspection from December 9, 1987 through January 8, 1988 (Report

No. 50-346/88004(DRP))

Areas Inspected: Special announced inspection of activities with regard

to an allegation.

Results: Two violations were identified (failure to follow procedures -

Paragraph 2.a (1) (a) and failure to take prompt and effective corrective

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actions after the procedural violation had been identified by the quality

organization - Paragraph 2.a (1) (c)).

8802020375 080128

gDR ADOCK 05000346

PDR

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DETAILS

1. Persons Contacted

a.. Toledo Edison Company (TED)

• L. Storz, Plant Manager

L. Ramsett, Quality Assurance Director

D. Briden, Safety Review Board Chainnan

G. Grime, Industrial Security Director

M. Schefers, Information Management Director

• G. Honma, Compliance Supervisor

R. Butler I&C Superintendent

C. Daft, Technical Planning Superintendent

S. Zunk, Nuclear Group Ombudsman

• D. Harris, Manager Quality Systems

S. Filippucci, Nuclear Security Superv hor

J. Dillich, Technical Support Manager

D. Hallenbeck, Quality Systems Specialist

M. O'Reilly, Attorney

K. Dunn, Document Control Supervisor

J. Hainline, Coordinator in Systems and Procedures

T. Davis, Coordinator in Document Control

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S. Goldstein, Systems and Procedures Manager

l M. Roder, Administrative Procedure Coordinator in Technical Support

i C. Zimmerman, Safety Review Board Clerk

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D. Levering, Systems and Procedure Supervisor

l b. USNRC

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• P. Byron, Senior Resident Inspector

! D. Kosloff, Resident Inspector

l M. Farber, Reactor Inspector

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C. Weil, Investigation and Compliance Specialist

I. Villaiva, Reactor / Nuclear Engineer

c. Other (Former TED Contract Employee)

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D. Till, Administrative Procedure Coordinator in Technical Support

• Denotes those present at the exit meeting conducted telephonically

on January 27, 1988.

2. Allegation Followup

l (Closed) RIII-87-A-0095: During the period from June 23 through

I November 10, 1987, the NRC received a number of concerns from a former

f employee at Davis-Besse. These concerns were reviewed by Region III

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both in-office and onsite with the following results:

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a. Concern No. 1

Revision 27 to site administrative procedure AD-1805, "Procedure

Preparation and Maintenance," dated May 19, 1987, was improperly

processed in that the procedure was issued without the Quality

Assurance (QA) Director's signature, contrary to the requirements of

Section 5 of Toledo Edison's Nuclear Quality Assurance Manual.

(1) Findings: In evaluating this concern, the inspector reviewed

Nuclear Group Procedure NG-AV-115, "Preparation and Control of

Nuclear Group Division and Department Procedures," Revisions 26

and 27 of site administrative procedure AD-1805, "Procedure

Preparation and Maintenance," and the administrative paperwork

associated with the review and comment on Revision 27 to

AD-1805. In addition, numerous individuals involved in

preparing, reviewing, resolving comments on, and approving

Revision 27 to AD-1805 were interviewed. Based on these

activities the following information was obtained:

(a) NG-AV-115 is one of the controlling documents which imposes

the requirements of the NRC approved Quality Assurance Program

on preparation of Nuclear Group Procedures, and changes

thereto. One of the requirements of NG-AV-115 is that

all procedures and procedure changes affecting quality be

approved by the Quality Assurance Department (QAD) prior

to issuance and iniplementation. This requirement existed

in Revision 26 to AD-1805 (a subordinate document) and was

reflected in a then information-only site document

entitled, "Test and Procedures Index" (T&PI), which

identified those procedures requiring QAD approval.

AD-1805 was identified on the T&PI as requiring QA

approval.

l The NRC does not specifically require this degree of in-line

Quality Assurance Department (QAD) involvement in procedure

preparation and change as part of the Quality Assurance

regulations contained in 10 CFR 50, Appendix B; however,

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10 CFR 50 Appendix 8, Criterion V, does require that

l activities affecting quality be conducted in accordance

l with approved procedures. Thus, the procedure approval

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requirements contained in both NG-AV-115 and AD-1805,

l Revision 26 represent a conservative application of NRC

l requirements. This degree of conservatism in procedural

L control is not uncommon in the nuclear industry.

l Revision 27 to AD-1805 was originated by the Technical

Support Department. One of the changes proposed by

Revision 27 was the deletion of QAD in-line approval of

procedures and procedure changes. During the Revision 27

i review process, which, in accordance with NG-AV-115,

l Revision 26 to AD 1805, and the T&PI, required QAD

approval, QAD identified this change as unacceptable.

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Ensuing attempts by both the Production and Quality

departments at resolving QAD's corrments were unsuccessful,

and, on April 27, 1987, the draft Revision 27 was

submitted to the site Safety Review Board (SRB) for

resolution.

The SRB met on May 8, 1987, and, as indicated in the

Procedure Development Form (PDF) for Revision 27, determined

that NG-AV-115 would have to be revised to reflect the

reduced level of QAD involvement in procedures and procedure

changes before Revision 27 to AD-1805 could be approved and

issued. The PDF was not signed by the QAD Director at this

time because the requisite changes had not been made to

NG-AV-115. The draft Revision 27 with SRB comments and the

PDF without the QAD Director's signature were returned to the

site Technical Support Group for continuing coordination of

the revision process. On May 13, 1987, the Technical Support

Manager signed the Revision 27 cover sheet indicating that

the revision was ready for issuance. The Plant Manager also

signed the cover sheet on May 13, approving its issuance and

implementation. This signature process was reperformed on

May 19, 1987. The second signatures by the Plant and Technical

Support Managers were not required, and their purpose could

not be determined. At the time of both signings, NG-AV-115

still required QAD approval of the revision. This approval

had not been obtained as indicated by the lack of the QAD

Director's approval signature. The failure to obtain required

QAD Director approval prior to issuance of Revision 27 to

AD-1805 was a violation of existing controlling procedures

and was contrary to 10 CFR 50, Appendix B, Criterion V

(346/87004-01(DRP)).

(b) During the interviews conducted regarding the circumstances

surrounding the inappropriate approval and issuance of

Revision 27 to AD-1805, the following pertinent information

was identified:

1. The Technical Support Manager signed the cover sheet

on May 13, 1987, based on verbal confirmation that all

comments had been resolved,

ii. The Plant Manager signed the cover sheet on May 13,

1987, believing that the SRB had resolved QAD comments.

He further stated that at the time he signed the cover

sheet, he was unaware that a prerequisite revision to

NG-AV-115 was required.

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iii. On May 13, 1987, during the administrative processes

supporting implementation of Revision 27 to AD-1805,

including updating the T&PI, the fact that QAD had not

approved the revision was brought to the attention of

the Document Control (DC) Group, which was responsible

for further processing and distribution, and the

Systems and Procedures (S&P) Group, responsible for

updating the T&PI. DC returned the procedure to

Technical Support for resolution of this discrepancy

prior to distribution.

iv. On May 14, 1987, an S&P Group supervisor signed the

PDF with the notation to proceed with processing

without QA concurrence,

v. Technical Support determined that QAD was not prepared

to accept the necessary changes to NG-AV-115 to support

implemeritation of Revision 27 to AD 1805.

Based on the results of interviews as discussed above, the

lack of QA approval had been identified to at least three

organizations assigned key functions in the procedure

implementation process. Notwithstanding, Revision 27 to

AD-1805 was issued on May 19, 1987.

(c) On May 19, 1987, QAD discovered that Revision 27 to AD-1805

was issued without its approval. Further attempts to resolve

the concerns with Technical Support failed and, on June 26,

1987, QAD issued Potential Condition Adverse to Quality

Report (PCAQR) 87-0322. This PCAQR was still open at the

time of the inspection. A memorandum proposing escalation

to a Management Corrective Action was prepared by the

Director, QAD, on August 6,1987. The purpose of this

memorandum was to bring this issue to the attention of the

Nuclear Group Vice President for resolution. This memorandum

was not issued. The failure to take prompt and effective

corrective action for the identified violation is a violation

of 10 CFR 50, Appendix B, Criterion XVI (50-346/87-004-02(DRP)).

(d) QAD indicated during interviews that it is currently

reviewing all procedures and changes issued under

Revision 27 to AD-1805 to ensure that ouality requirements

were not deleted fro.n site procedures. To date, no safety

issues have been identified.

(2) Conclusions: Based on the above information, the following

conclusions were reached:

(a) The changes made to AD-1805 by Revision 27 reduced

the level of QAD involvement in the procedure control

process.

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(b) Revision 27 to AD-1805 was implemented in violation of

Nuclear Quality Assurance Manual (NQAM) requirements.

This failure to adhere to the NQAM is a violation of NRC

requirements.

(c) The issuance of Revision 27 to AD-1805 in violation of

NQAM requirements represents a deficiency in quality

programs at Davis Besse'in that the discrepancy leading to

the violation was identified in accordance with approved

practices prior to issuance and appropriate actions to

establish compliance were not taken.

(d) Senior licensee management failed to take action to resolve

a significant policy issue difference between the production

organizatica and the independent quality organization,

despite the fact that the issue had been identified to at

least three cognizant organizations. This represents a

violation of NRC corrective action requirements and, more

importantly, points to a weakness in management performance,

b. Concern No. 2

Documentation of S&P supervisory direction to process Revision 27 to

AD-1805 without qAD approval was taken from the alleger by site

se',urity when the alleger was escorted from the site.

(1) Findings: The alleger was escorted from the site on May 16,

1987, and the subject document was taken by security. During

this inspection, a copy of this document was provided by the

Davis Besse Ombudsman to the inspector. It is conmon practice

for licensee organizations to recover licensee documents from

individuals removed from the site. NRC regulations do not

prohibit this.

(2) Conclusions: The concern was substantiated; however, there was

no regulatory issue involved. The alleger's implication of

attempted coverup was not substantiated, as the subject document

was readily produced by the licensee,

c. Concern No. 3

Starting January 15, 1987, new revisions to procedures were not

entered on the T&PI as required.

(1) Findings: As noted above, the T&PI was an information-only

document and not subject to Quality Assurance Program controls.

l Notwithstanding, the inspection disclosed that during this time

l period, the responsibility for the T&PI was transferred from the

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SRB Clerk to DC and then to S&P, new computer systems were

installed to track the T&PI, and DC was issuing new procedure

manual indexes for site manuals. These changes were not

proceduralized until Revision 27 to AD-1805 was issued, with

the result that lines of responsibility were not clearly defined,

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Some omissions to the T&PI did occur; however, a licensee audit

in-March-April 1987 identified these, and necessary corrections

were made.

(2) Conclusions: .The inspection substantiated that omis; ions

occurred in the T&PI; however, interviews indicated that the

problem had been identified by the licensee prior to the

alleger's employment and that necessary corrective actions were

in progress. Additionally, this issue is not a regulatory

concern,

d. Concern No. 4 ,

Inaccurate information was provided by S&P to management for reports

on the status of assigned tasks.

(1) Findings: Personnel interviewed denied that this occurred.

No written evidence could be found con.erning this issue.

(2) Conclusions: This concern could not be substantiated. The

alleged inaccurate information does not address regulatory or

safety issues. Additionally, the alleger stated he was not aware

of any problems with either associated records or records

alterations.

e. Concern No. 5

An S&P supervisor directed the S&P staff to delay updating the

computer data base used to track the procedure numbering system. The

alleger was discouraged from bringing concerns to S&P and other

management, and, when the alleger did discuss the situation with an

S&P manager, was "chewed out."

(1) Findings: During the time frame in question, in an effort

at more clearly establishing lines of responsibility, site

management assigned S&P to issue, track, and revise indexes of

procedure numbers. The responsibility for issuing naw procedure

indexes was later returned to DC. During this period an S&P

supervisor purportedly was heard to comment that "if S&P doesn't

do a good job on issuing procedure indexes, maybe DC will take

the responsibility back". The supervisor denied having made this

statement when confronted with it but did attribute the comment

to the S&P Manager. Based on interviews with the alleger and

several co-workers, the computer data base was updated regularly

in spite of the perceived direction to the contrary from

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management.

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Interviews with S&P supervisors and managers ano the alleger

disclosed that S&P management did approach the alleger to

discuss this issue after he brought it to the attention of his

! supervisor.

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(2) Conclusions: The concern that S&P management made statements

that the S&P staff could interpret as direction to delay computer

data base updates was substantiated. Notwithstanding, S&P did

maintain the data base. In addition, S&P management made itself

available to the alleger to discuss his concerns. Thus, the

second portion of this concern was not substantiated.

f. Concern No. 6

The rules * a not adhered to as illustrated by the following

examples:

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Improper processing of Procedure AD-1805.

- The alleger was directed to not properly update the procedure

numbering system.

- The alleger was directed to deviate from the established

procedure for updating the Test and Procedure Index.

- Security wasn't infonned that the alleger was fired on May 15,

1987; thus, it allowed him to come onsite on May 16, 1987.

(1) Findings- The inspector reviewed the first three items above

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in conjunction with inspection of other concerns. See previous

discussion in this report.

The inspector's review of the last item determined that the

alleger was not fired on May 15, 1987. The alleger was

repeatedly instructed by supervision not to come to work on

Saturday, May 16, 1987. The alleger disobeyed the directive and

came in to do additional work. After purportedly disrupting

work in DC he was asked tn leave the site. At that time,

termination proceedings were initiated by the alleger's

supervisor and site access privileges were denied.

(2) Conclusions: The conclusion:; regarding the first three items

are discussed above and within this report. The last item was

not substantiated.

g. Concern No. 7

Insufficient time was expended on the development of a new

maintenance procedure for the motor-driven auxiliary feedwater pump.

Had the procedure been developed earlier, two previous failures would

not have occurred. Also, the plant was inappropriately allowed to

operate with the pump out of service.

(1) Findings: The inspector datermined that the motor-driven

auxiliary feedwater pump failed to operate twice, as stated by

the alleger.

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Following the June 1985 loss of feedwater event, the licensee

initiated steps to install a motor-driven auxiliary feedwater

pump to supplement the two existing steam-driven auxiliary

feedwater pumps. Installation of this new pump was completed

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on January 10, 1986, without a maintenance procedure in place.

On January 4, 1987, the ticensee issued the pump vendcr's manual

with a licensee-cover sheet as an approved maintenance procedure.

Subsequent to the May 10, 1987 second failure, a licensee

maintenance procedure was issued on May 13, 1987. This procedure

was in the review cycle at the t!me of the May 10, 1987, failure.

Interviews indicated that the procedure issuance was expedited

after the event.

The first "failure" (January 11,1986) was not, in fact, a

failure. Rather, the control room operator became worried when

the pump apparently did not start when he initiated the starting

circuit. The plant at the time was In Mode 5, Cold Shutdown.

Had the operator been properly trained on a new modification,

he would have known that there was a 12-to 16-second time delay

in the starting circuit to permit the bearing oil pump to

develop normal oil pressure. This prelubrication is necessary

before starting the main electrical motor.

The second "failure" (May 10,1987) of the motor-driven

auxiliary feed water pump also occurred while the unit was in

cold shutdown. This failure occurred while operators were

performing a valve lineup in preparation for placing the steam

generators into wet layup and was also due to operator error.

In this instance, an operator mistakenly shut a pump suction

valve and caused the pump to seize. The pump was subsequently

repaired and is presently operational.

(2) Conclusions: The staff determined that the alleger was not

Enowledgerile about the Davis-Besse auxiliary feedwater system.

A maintenance procedura would not have prevented the problems

involving the new motor-driven pump, as the problems were in no

way related to maintenance. Finally, the plant was not allowed

to operate while the pump was not operational.

h. Concern No. 8

s Starting the plant nad a higher priority than quality. The alleger

presented no specific information to support this concern, and

indicated it was only an opinion based on "gut instinct" and information

ebtained from co-workers.

(1) Findings: The alleger's concern is based on hearsay information

obtained from conversations with co-workers. The alleger had no

first-hand knowledge of any startup irregularities, since the

plant was either at full power or being taken off-line for a

planned extended maintenance outage during his employment.

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The inspector's review indicated that the alleger's concerns

regardir;g startup were based or. his understanding of the June 9,

1985 event. After the event, Toledo Edison provided a

Course-of-Action Plan to the NRC to improve the performance at

the plant. The plan was designed to resolve NRC concerns and

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provide assurance that no undue risk to the health and safety

of the public would result from the resumption of power

generation. The NRC independently reviewed the status of the

actions required to be completed prior to restart and concluded

that licensee commitments had been satisfied, that necessary

plant systems were tested prior to use, and that the plant was

ready for power operations. Additionally, the NRC provided

24-hour :nspection coverage during the initial plant restart

operation to ensure a safe plant startup and noted no instances

in which quality was sacrificed to satisfy schedular

requirements.

(2) Conclusions: Based on the extensive NRC reviews and inspection

activity that went into the Davis-Besse restart after the long

outage, the inspector could find no basis for this concern,

i. Concern No. 9 The Temporary Procedure Modifications (T-Mods) Log may

not have been kept up to date after the alleger's termination. There

is also no one onsite with knowledge of how T-Mods are incorporated

into specification revisions.

(1) Findings: T-mods are temporary procedure changes. Currently,

they are called temporary approvals (TAs). Along with the name

change, the responsible group for processing these changes

changed from the Station Review Board (SRB) Clerk to Document

Control (DC) to S&P. These changes occurred in 1986.

The mechanism to handle these changes was generally described in

l site Procedure AD-1805, Revision 25. Up to April 7, 1986, the -

l SRB Clerk issued T-Mod numbers. These modifications were

l sequentially numbered after final approval of the changes by the

Plant Manager. The Clerk logged each approved modification in a

log book on her desk. The numbers were also entered into the old

PRIME compui.er system. The Clerk would then forward the procedure

change package to DC for processing. These T-Mods remained open

until a new revision to the affected procedure was issued which

incorporated the T-Mod. The SRB Clerk would then close the

T-Mod. Some T-Mods are still open today.

Revision 26 to Procedure AD-1805, dated April 7, 1986, changed

this mechanism and required that DC now issue the modification

numbers and keep the log of the new TAs. Since the procedure

wasn't very explicit, DC issued TAs without numbers. If the

TA was not incorporated into a procedure change within the

allowable 14 day timeframe, it ws voided. DC had made up

a separate control log book of 1.nese TAs. It was in the

process of computerizing this tracking system duririg the time

of the alleger's employment.

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Concurrently, Systems and Procedures (S&P) was in the process-

of taking over the T-Mod Log from the SRB Clerk and the TA Log

from Document Control. A new computer system (VAX) was to be

used by S&P to do this.. However, as it wasn't fully operational,

the numbers had to be entered into the old PRIME computer system

to ensure that no data was lost.

It wasn't until Revision 27 to AD-1805 was implemented that a

detailed TA numbering system was initiated. The first TA number

was issued on May 20, 1987.

In view of the transition which took place during the alleger's

term of employment the inspector could understand why the

alleger was concerned. This system as described was in fact

confusing. When the alleger left the site, the transition was

still in progress. After the alleger's termination, the

individuals in DC and S&P who originally had these assignments

kept the logs up to date. Subsequently, a Toledo Edison

employee was given the full-time assignment to keep the T-Mods

and TAs up to date.

(2) Conclusions: The concern was not substantiated.

J. Concer_n No. 10

Security did not remove the parking sticker from the alleger's car

when the alleger was terminated.

(1) Findings: The staff determined that Davis-Besse parking

stickers only allow one to park in the owner-controlled

parking areas outside of the protected area. NRC security

authority begins at the fence of the protected area.

(2) Conclusions: The explanation of this concern was discussed

with the alleger during the November 10, 1987 interview. The

alleger acknowledged that the NRC's jurisdiction doesn't extend

to the owner-controlled area rnd stated that no further action

was required,

k. Concern No. 11

The Ombudsman's Report No. 39 response on the alleger's concerns has

questionable independence and accuracy. The Ombudsman did not

properly record the alleger's concerns. The Ombudsman should have

informed the alleger of the Whistle-Blowers Act.

(1) Findings: The Ombudsman Program at Davis-Besse is a licensee

initiated program designed to provide an additional forum for

employees to express concerns about activities and events. It

has no regulatory basis. The program does not require that

investigations of concerns be independent of the focus of the

concerns, although that would be the ideal condition.

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The program does require that the concerns of individuals be

directed to a responsible Nuclear Group Director for

investigation and resolution. Based on inspector review, the

alleger's concerns were directed to the appropriate level of

management. After discussions with cognizant individuals

onsite, it appears that the resolution of Ombudsman's Report

No. 39 was not done by an independent source. The prime author

of the report was the alleger's second-level supervisor.

Based on the inspector's review of this concern, the following

observations were made:

1. Several sessions between the NRC and the alleger were

required to obtain a full characterization of the alleger's

concerns. The concerns listed in the report appear to be a

reasonable approxiination of the concerns expressed to the

NRC. No evidence of coverup or deliberate

misrepresentation was discovered.

ii. The responses made to the Ombudsman Report were not based

on an in-depth, comprehensive independent effort, with the

result that definitive answers were not provided to the

alleger by the licensee.

With regard to the Whistle-Blowers Act, the inspector determined

that the licensee is in compliance with NRC regulations, Part 19

of 10 CFR, which require that each licensee post current copies

of Form NRC-3, which states that if an employee believes he has been

discriminated against for talking to the NRC, the employee may

file a complaint with the U.S. Department of Labor within 30 days

of the occurrence. The inspector determined that the alleger was

required to take site training on the Ombudsman's program as well

as on Part 19 and did pass a written test on this subject.

(2) , Conclusions: The first portion of the alleger's concern was

substantiated. The second portion of the concern was not

l, substantiated in that the Ombudsman reasonably characterized the

l alleger's concerns. With regard to the Whistle-Blowers Act, the

inspector concluded that the olleger was made aware of the

provisions of the Act via mechanisms other than the Ombudsman

Program and that these mechanisms satisfy existing regulatory

requirements.

l. Concern No. 12

l The alleger has been "blackballed" from future employment at

j Davis-Besse as a result of going to the NRC with concerns about the

plant. The company also intentionally led the alleger on with

promises of future employment for the sole purpose of eclipsing the

30-day statute of limitations that the Department of Labor has for

investigating allegations of discrimination.

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(1) Findings: NRC regulations prohibit discrimination against

current employees for engaging in certain protected activities.

One protected activity is providing the Commission information

about possible violations of NRC requirements. The alleger

provided the NRC with information about the plant; however, this

was after his employment was terminated and after the alleger

had been placed on the Denied Access List.

An employee who believes that he has been discriminated against

may seek a remedy for the discrimination through an administrative

proceeding of the Department of Labor. This proceeding must be

initiated within 30 days after the alleged violation occurs. The

alleger stated that he did go to the Department of Labor; however,

he contacted it well after 30 days from being discharged. Thus,

the Department of Labor dismissed the case based on the fact that

the 30 days had expired.

Nevertheless, from interviews with personnel involved with the

alleger onsite and from reviewing documents onsite, there are

indications that the I&C Department wanted to hire the alleger

after he was escorted offsite May 16, 1987. In fact, it appears

that it was attempting to do so only to find out that the

alleger was on the Plant Denied Access List. Thus, the alleger

couldn't have been hired even if a position was open.

The staff could only find that individuals onsite probably

informed the alleger that they would attempt to obtain other

site employment in some other group. Co-workers attempted

to obtain employment for the alleger in their group. In fact,

the alleger was told privately that if a position opened up,

an offer would be made; however, a position never opened up.

(2) Conclusions: The first portion of the concern was not

substantiated in that, based on discussions with cognizant

personnel, the alleger did not bring concerns to the NRC until

after termination proceedings were completed. Regarding the

second portion, no positive evidence could be found that the

alleger was led to believe, by the Company, that there would be

a future job at Davis-Besse. There is evidence that individuals

attempted to hire him, but failed.

3. Exit Interview

During a conference call / telephonic exit interview with licensee

representatives identified in paragraph 1, the inspector sumarized the

scope and results of the inspection and discussed the likely content of

this inspection report. The licensee acknowledged the information and did

not indicate that any of the information disclosed during the inspection

could be considered proprietary in nature.

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