ML20155J218

Insp Repts 50-313/88-25 & 50-368/88-25 on 880801-0915. Violations Noted.Major Areas Inspected:Followup of Events, Maint,Previously Identified Items,Operational Safety Verification & Surveillance

ML20155J218
Person / Time
Site:	Arkansas Nuclear
Issue date:	10/13/1988
From:	Chamberlain D, Gilbert L, Haag R, Johnson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20155J210	List: ML20155J207 ML20155J213 ML20155J218
References
50-313-88-25, 50-368-88-25, NUDOCS 8810250393
Download: ML20155J218 (13)

See also: IR 05000313/1988025

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APPENDIX B

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U. S. NllCLEAR REGULATORY COWi!SSION

. REGION IV

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Inspection Report: 50-313/88-25

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i.icenses : DPR-51

50-368/88-25 NPF-6

Dockets: 50-313

50-368 .

Licensee: Arkansas Power & Light Company

P. O. Box 551

Little Rock, Arkansas 72203-

Facility Name: Arkansas Nuclear One (ANO), Units 1 and 2

Iri'pection At: ANO Site, Russellville Arkansas

Inspr':on Conducted: August 1-September 15, 1988

Inspectors: ())JD 0

W. D. Jo W on, Senior Resident Reactor

InspectoV

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R_. C. Haag, Resideptt Reactor Inspector

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D. Gilbert,ReactorInspecflor '0 ate

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Approved: t>

D. D. Chamberlain, Chief, Reactor Project lO//2/88_

Da*?

j Section A Division of Reactor Projects

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Inspection Summary

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Inspection Conducted August 1 through Septtmber 15, 1988 (Report 50-313/88-25)

Areas Inspected: Routine, .unannou'nced inspection including followup of events, l

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maintenance, followup on previously identified items, operational safety

], verification, surveillance, and Part 21 reports. >

Results: Within the six areas inspected, one violation was identified (control

of components, paragraph 3).

Inspection Conducted August I through September 15, 1988 (Report 50-368/88-25) [

q Areas Inspected: Routine, unannounced inspection including followup of event. l

maintenance 3 f6110wup on previously identified items, operational safety i

verification, surveillance, control of possible moderator dilution events, and i

j Part 21 reports, j

Results: Within the seven areas inspected, one violation was identified f

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(failure to calibrate a torque wrench attachment, paragraph 4). t

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DETAILS

1. Persons Contacted

• J. Levine, Executive Director, ANO Site Operations

• B. Baker, Modifications Manager

E. Bickel, Health Physics Superintendent

M. Bolanis Health Physics Speutalist

B. Converse. Operations Assessment Superintendent

A. Cox, Unit 1 Operations Superintendent

E. Ewing, General Manager, Plant Support

M. Frala, Nuclear Chemistry Supervisor

J. Garrett, Materials Management Superintendent

H. Greene, Quality Assurance Superintendent

L. Gulick, Unit 2 Operations Superintendent

• D. Howard, Licensing Manager

• L. Humphrey, General Manager Nuclear Quality

G. Kendrick, I&C Maintenance Superintendent

• R. Lane, Engineering Manager

D. Lomax, Plant Licensing Supervisor

A. McGregor, Engineering Services Supervisor

• J. McWilliams, Maintenance Manager

B. Michalk, Mechanical Engineer

• P. Michalk, Licensing Engineer l

V. Pettus, Mechanical Maintenance Superintendent '

D. Provencher, Quality Assurance Supervisor I

S. Quennoz, General Manager

C. Shively, Plant Engineer Superintendent

G. Storey, Industrial Safety Coordinator

C. Taylor, Unit 2 Operations Technical Support Supervisor

l L. Taylor, Special Projects Coordinator

• J. Vandergrift, Operations Manager

, *R. Wewers, Work Contre' Center Mantger

! C. Zirunerman, Unit 1 Uperations Technical Support Supervisor

• Present at exii. interview.

The NRC inspectors also contacted other plant personnel, including

operators, technicians, and administrative personnel.

2. Plant Status (Units 1 and 2)

Unit 1 operated at near 85 percent power at the beginning of the month of

August then gradually r<:duced power to 69 percent on August 29, 1988. The

unit was then shut down for the start of the 8th refueling outage. Unit 2

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was manually tripped from 100 percent power on August 1,1988, due to a

t failure of a pressure sensing 1:ne for a reactor coolant pump seal.

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Following repair and modifications of lines connecting to the reactor

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coolant pump seals, Unit 2 reached 100 percent power on August 19, 1988,

and continued to operate at 100 percent for the remainder of the

inspection period.

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3. Followup of Events (93702) (Unit 1)

a. On August 29, 1988, the licensee tagged out a portion of the decay

heat removal system in order to repair the relief valve on the

discharge line from the Train A decay heat removal pump. After

system realignment on August 30, 1988, decay heat system flow could

not be achieved through Control Valve CV-1428. On August 31, 1988,

CV-1423 was disassembled for inspection. The NRC inspector observed

a portion of this work performed under Job Order 765137. This

inspection did not identify any failure which could restrict flow

through the valve. A licensee review found the following:

. Manual Valve OH-3A was found shut. This valve is in series with

CV-1428.

l . DH-3A had been inadvertently shut on August 29 while the system  !

l was being aligned for relief valve repairs. This valve was not

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listed on the hold card record sheet, and no hold card was

attached to the valve.

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. DH-3A had not been opened during system alignment follow'.ng '

l relief valve repairs on August 30.

I Section 6.6 of Procedure 1000.27, "Hold and Caution Card Control,"

covers hold card installation. Steo 6.6.2 states, "Verify the

component by label as being the component which is specified on the

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Hold Card." The unauthorized closing of Yalve DH-3A while installing

hold cards on the decay heat removal system is an apparent violation

of this procedure. (313/8825-01) This was not a violation of  ;

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Technical Sepcifications because the plant was not in an opentional

I condition where Train A of decay heat removal was required,

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The NRC inspector expressed concern to the licensee that operations

j personnel did not carefully check decay heat removal system alignment

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prior to requesting maintenance or. Valve CV-1428. During review of  ;

I thfs event, the NRC inspecter found that the licensee's method of

! controlling locked valves had a weakness. Licensee procedures include i

! requirements for obtaining shift supervisor approval e.d for l

documenting position changes for locked valves. These requirements

l have not been implenented during periuds when the unit was in a cold

shutdown or refueling shutdown condit. ion. The licensee's response to i

the above violation should address control of locked valves in the

decay heat removal system during cold and refueling shutdown

conditions.

b. On September 5, 1988, the decay heat removal 1.ystem was inadvertently

isolated. This was caused by inadvertent cirsure of one of the motor I

operated valves in the suction line to the decay heat removal pumps

from the reactor coolant system. Valve CV-1410 closed during

performance of Procedure 1304.53, "ESAS Analog Channel No. 2

Calibration." In addition te calibration of an engineered safety l

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features actuation system channel, this procedure calibrates the

setpoint for closure of a decay heat removal system isolation valve

(CV-1410) and calibrates the related pressure transmitter and

pressure indicator (PT-1041 and PI-1041). In order to prevent

inadvertent closure of CV-1410 during the calibrations, Step 6.2 of

Procedure 1304.53 requires the power supply breaker for CV-1410 to be

open with a hold card attachea. The licensee failed to comply with

this procedural requirement; and during performance of Step 7.7 of

the procedure, CV-1410 closed. The valve remained operable and was

reopened in about 11 minutes. This is a second example of the

licensee's failure to follow procedures concerning control of

components. (313/8825-01)

c. The NRC inspector performed a followup review of the event at ANO-2

which occurred on August 1, 1988. The event was determined to have

been caused by a failure of a reactor coolant pump seal pressure

sensing line and subsequent degradation of the reactor coolant pump

shaft seals. The licensee determined that the failure of the

3/8-inch stainless steel tubing sensing line was caused by fatigue.

The failure history for reactor coolant pumps indicated that pumps A

and B have had failures in the 3/8-inch tubing down stream of the

second isolation valve while pump C has had failures in the 3/4-inch

pipe welds between the two isolation valves. On the basis of a

review of the failure history and design analysis, the licensee

selected various areas for liquid penetrant examination to assure the

integrit

tubing. yThe

of other similar

licensee reactordesign

performed coolant reviews pumpand seal piping and

engineering

analyses to eliminate the fatigue failure in the pipe welds and

tubing. The licensee, in a conference call with NRC on August 5,

1988, committed to implementing design changes which would eliminate

the fatigue failure in the reactor coolant pump seal piping and

} tubing prior to taking the plant critical,

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On September 8, 1988, the licensee issued Licensee Event

Report 368/88-011-00. This LER described the event in detail. It

also discussed the root cause evaluation and described the repairs

and modifications which were implemented prior to plant startup. a

4. Monthly Maintenance Observation (62703) (Units 1 and 2)

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Station maintenance activities for the safety-related systems and

l components listed below were observed to ascertain that they were

l conducted in accordance with approved procedu?es, Regulatory Guides, and

I inuustry codes or standardr,; and in conformance with the Technical

Specificaticns.

The following items were considered during this review: the limiting

conditions for operation were met while components or systems were removed

from service; approvals were obtained prior to initiating the work;

activities were accomplished using approved procedures and were inspected

as applicable; functional testing and/or calibrations were performed prior

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to returning components or systems to service; quality control records

were maintained; activities were accomplished by qualified personnel;

parts and materials used were properly certified; radiological controls l

were implemented; and fire prevention controls were implemented. l

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Work requests were reviewed to detennine the status of outstanding jobs '

and to ensure that priority is assigned to safety-related equipment  ;

maintenance which may affect system performance.  ;

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The following maintenance, activities were observed:

. Inspection of Unit 1 emergency diesel generator (Job Order 761574,

Procedure 1402.66) ,

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. 'nspection of decay heat removal cooler outlet Valve CV-1428 (Job '

Order 765137) .

. Disassembiy of turbine driven emergency feedwater pump for

installation of mechanical seals (Job Order 759543)

. Preventive maintenance on the operator for a service watcr discharge '

crossover valve (CV-3640) (Job Order 764721)  :

. Replacement of an emergency diesel generator fuel oil line. A defect i

in the fuel line had been corrected by silver brazing; however, that  ;

repair was considered tenporary. (Jcb Order 763593) l

. Replacement of Yalve SW410 (service water discharge valve for Makeup

Pump P-36C lube oil cooler). While troubleshooting the high lube oil ,

temperature for P-36C, the licensee 'scovered partially restricted '

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fl = in the service water discharge fivm the lube oil coolor. The '

initial investigation for the cause of restricted flow revealed that

the disc was separated from the valve stem but did not identify the

failure mechanism. The licensee is continuing to investigate the

cause of disc and stem separation and the resident inspectors will l

followup on licensee corrective actions during future inspections. ,

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. Troubleshooting Radiation Monitor RE-2400, reactor building air

sample monitor for reactor coolarit leakage (Procedure 1304.027, Job

Order 763759)  :

. Replacement of the upper motor bearing for Service Water Pump 2P-4C  !

(Procedures 2402.34 and 2403.04, Job Orders 765641 and 765460). The i

NRC inspector reviewed Technical Manuals G080-1710. "General Electric i

Vertical Induction Motors," and F091-010 "Fairbanks-Morse Vertical l

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Shaf t Deep Well Turbine Pumps," to verify that the licensee's

procedures contained the required instructions recornended by the .

vendors. l

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l . Eddy current testing in Steam Generator A  :

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. Installation of tubing for emergency feedwater pump Pressure ,

l Transmitter PT-2804 and Pressure Indicator Switch PDIS-2804. Oesign .

Change Package 86-1006.

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. Troubleshooting the electrical supply disconnects for service water

Pump 2P-48 (Job Order 717504and717361)  ;

. Repair of the body to cap leakage for boric acid makeup pump

discharge Check Valve 2CVC-41B (Job Order 742669). During repairs -

the licensee discovered the body to cap gasket had not been

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installed. Condition Report 2-88-138 was written to address the >

l. missing gasket and determine the root cause. The licensee has not l

l completed the condition report evaluation. The NRC inspector .

I observed reassembly of the valve and the use of a torque adapter '

(crow's foot) when torquing two of the six cap fasteners. When

questioned by the NRC inspector concerning calibrations, the mechanic ,

stated the torque wrench was calibrated; however, the crow's foot was i

l not included in the calibration. Nor had the indicated torque been l

l adjusted to compensate for the increase in applied torque when using

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Procedure 1405.011. "Bolting and Torquing Guidelines " provides

j requirements for the selection and use of wrenching devices. ,

Specifically, paragraph 8.4.2. A.2 requires the indicated torque to be  ;

adjusted in accordance with Attachment 4 when torque multipliers or l'

adapters that extend the point of applied torque are used. Also,

paragraph 8.4.4.C requires a torque wrench to be calibrated while ,

attached to any r.Japters or extenders that will be used during  :

torquing. Failure to adjust the indicated torque when using a torque  ;

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adapter or to include the torque adapter with the torque wrench

during calibration is an apparent violation. (368/8825-01) l

When reviewing Procedure 1405.011, the NRC inspecto,' questioned the

accuracy of Step 8.4.2.A.3. This step allows the use of universal

joints during torquing applications and requires the correction of

applied torque per Attachment 4. This attachment addresses the use

of torque multipliers and adapters that provide a mechanical advantag;

such that the applied torcue is greater than indicated torque. The  !

attachment does not provice sufficient instructions for adjusting the  ;

applied torque when using a universal joint. The licensee is 1

reviewing this issue,

i, 5. Followup on Previously identified Items (92701, 92702) (Units 1 and 2)

a. (Closed) Violations 368/8627-02 and 368/8615-08: Control of scaffold

erection near safety-related equipment.

The NRC inspector reviewed Revision 28 of Procedure 1000.24. "Control

of Maintenance." This procedure implemented controls on scaffold

erection. These controls appear to be adequate to prevent recurrence

of the violation. These items are closed.

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b. (Closed) Violation 368/8623-01: Failure to obey radiological

posting.

The NRC inspector reviewed the licensee's corrective actions

following this violation and found them to be appropriate. It was

concluded that this violation represented an isolated case. During

this review, the NRC inspector expressed concern that there was no

logging and tracking system for Radiological Safety

Infraction / Condition (RSIC) Reports. Procedure 1000.25 was

subsequently revised in July 1983. This procedure requireL RSIC

Reports to be assigned a unique serial number and to be logged and

tracked by health physics personnel. This item is closed,

c. (Closed) Open Item 368/8736-01: Root cause determination of

overspeed trip of Emergency Feedwater Pump 2P7A turbine.

The licensee cetermined that the root cause of the turbine overspeed

trip was inconsistent performance of the overspeed trip mechanism.

The governor tappet of the trip mechanism was bent due to excessive

thread length, causing inconsistent tripping of the turbine. Since

correction of the tappet length, tne licensee has been recording and

reviewing the peak turbine speed during the quarterly surveillance

tests. Three surveillance tests have been completed with consistent

peak speed and no overspeed trips. This item is closed.

d. (Closed) Unresolved Item 313/8429-02; 368/8429-02: Establishment of

a program for verification of operations procedures and associated

piping and instrumentation drawings (P& ids).

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In response to Unresolved Item 313/8501-01 and Dey!ation 313/8810-01,

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the licensee has comitted to perform reviews of P&fDs to identify

i discrepancies. In addition, the licensee has established a process

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such that P& ids are updated when procedural valve lineups are revised.

These items are closed.

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l e. (Closed)OpenItem 313/8636-01: Review of test results fer reactor

coolant system pressure test.

lhe NRC inpector reviewed the test records for the reactor coolant

system hydrostatic test that was performed subsecuent to the repair

on a h M pressure injection nozzle. The test was performed in

accordance with the ASME 8&PV Code with acceptable results. This

item is closed.

f. (Closed) Violation 313/8732-04; 368/8732-02. Failure to incorporate

correction factors into procedures for monitoring leakage across

pressure interface check valves.

The plant preheatup and precritical checklist procedures (1102.01

and 2101.01) were revised to include the pressure adjustment criteria

for surveillance testing of the RCS/LPSI interface check valves. The

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NRC inspector reviewed the procedures and verified that the pressure i

adjustment requirements specified in the Order For Modification of L

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License were included. These items are closed. [

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6. Operational Safety Verification (71707. 71709, 71710 and 71881) (Unit; 1 '

and 2)

The NRC inspectors observed control room operations, reviewed applicable

i logs, and conducted discussions with control room operators. The NRC ,

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inspectors verified the operability of selected emergency systems,  !

l reviewed tag-out records and verified proper return to service of affected  ;

l components, and ensured that maintenance requests had been initiated for l

l equipment in need of maintenance. The NRC inspectors made spot checks to ,

l Verify that the physical security plan was being implemented in accordance

with the station security plan. The NRC inspectors verified  ;

implementation of radiation protection controls during observation of ,

plant activities.

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The NRC inspectors toured accessible areas of the units to observe plant l

equipment conditions, includine potential fire ha?ards, fluid leaks, and

excessive vibration. The NRC inspectors also observed plant housekeeping l

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and cleanliness conditions during the tours.

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The NRC inspectors walked down the accessible portions of the Unit 1 i

emergency feedwater system to verify operability. The walkdown was  ;

conducted using Attachment A. "Emergency Feedwater Manual Valve Lineup " (

to Procedure 1106.06, "Emergency Feedwater Pump Operation." Drawings  :

reviewed during the preparation and conduct of the walkdown included l

M-204, Sheets 3 and 5, and M-212. Sheets 1 and 2. While no system  !

misalignments were identified, the NRC inspectors identified the following i

minor discrepancies to the licensee for corrective action: i

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. One valve, CS-2804C, listed on the lineup sheet does not exist. l

Licensee personnel had noted this discrepancy, and it was scheduled

for correction during the next proceoure revision. l

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. Several cases were noted in which drawings did not correctly identify l

the locked status of manual valves. The licensee is in the prccess i

of removing locked status information from piping rad instrumentation  :

drawings. I

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. Brass fittings were attached to Valve CS-28028, a manual pressure l

point isolation valve. The purpose of these fittings was not clear, t

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and they were removed by licensee personnel. l

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. The valve lineup listed Valve FW-68A as FW-68. Licensee  !

representatives stated that this discrapancy will be corrected in the l

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Valves CS-288 and CS-289 provide isolation for condensate storage  !

tank level transmitters. Both valves are required to be open.  :

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CS-288 was found to be 20 percent open and C5-289 was found to be 80

percent open. Upon notification, licensee operators confirmed the

reported valve positions and fully opened both valves. Although

these valves need not be fully o)en for proper operation of their

associated level transmitters, t1ey nortnally have been maintained

fully open. Licensee personnel were unable to determine why these

valves were not fully open.

. Insulation was missing from Valve CS-289. Job Request 810190 was

prepared for installation of insulation.

. Drawing M-204, Sheet 3, contained an incorrect reference to H-212

Sheet 1 Location Hl. This was corrected prior to the end of the

inspection.

. Drawing M-212. Sheet 2, indicated Valve CS-19 as normally throttled.

This should be changed to nonnally open.

These reviews and observations were conducted to verify that facility

operations were in conformance ith the requirements established under

Technical Specifications, 10 CF7, and administrative procedures.

No violations or deviations were identified.

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7. Monthly Surveillance Observation (61726) (Units 1 and 2)

The NRC inspector observed the Technical Specification required

surveillance testing on the various components listed below and verified

that testing was perforaed in accordance with adequate procedures, that

test instrumentation was calibrated, that limiting conditions for

operation were met, that removal and restoration of the affected

components were accomplished, that test results conformed with Technical

Specifications and procedure requirements, that test results were reviewed

by personnel other than the individual directing the test, and that any

deficiencies identified during the teding were properly reviewed and

resolved by appropriate management personnel.

The NRC inspector witnessed portions of the'following test activities:

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. Monthly test of Emergency Diesel Generator K4A (Procedure 1104.36,

Supplement 1)

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Postmaintenance test of Unit 2 emergency diesel generator

(Procedure 2104.36, Supplement 2)

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Calibration of Unit I reactor protection system Channel A (Job

Order 761681)

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Calibration of Unit I reactor protection system Channel C  !

(Procedure 1304.43)

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. Accuracy check on voltage and amperage meters on Control Panel C-10  :

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4 . Diesel fire pump test (Procedure 1104.32 Supplement 1)

. Process radiation monitoring system test (Job Order 765617,

Procedure 2304.16)

. Month'y test of Unit 1 reactor protection system Channel A f

(Procedure 1304.37, Job Order 761959) >

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. Monthly test of Unit 2 reactor protection system Channel A  ;

(Procedure 2304.37, Job Order 761%7). The hRC inspector identified c

the wording of Step 8.15.10 as incorrect. The step requireJ the test l

J voltage to be raised until a low refueling water tank level pretrip  ;

occurs. The test voltage must be lowered until a pretrip occurs.

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The licensee was notified and it was verified that the other three i

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channel procedures had the correct wording. This procedure error

! appeared isolated and it had no effect on the serformance of the

surveillance test. The licensee is revising tie affected procedure

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to provide the correct instructions. .

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. Qusrterly surveillance inspection of Diesel Fire Pump Engine K-5 l

1 (Procedure 1306.27, Job Order 762741)  ;

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! . Monthly test of Unit 1 area radiation monitors (Procedure '1304.095, f

, Job Order 763129) j

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Monthly test of Containment Spray Pump'2P-35B (Procedure 2104.05,

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.. Monthly test of High Pressure Safety Injection Pump 2P-898  !

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. Monthly test of Unit 2 Emergency Diesel Generator 2K4B

(Procedure 2104.36 Supp % nt II). The NRC inspector observed the

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mcnthly test on August 9,1988, and September 8,1988 The August 9 i

test was the second attempt of the monthly surveillance. On  !

J August 8,1988, a fire occurred at' the south exhaust header and the )

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diesel generator was shut down. During the following test on  ;

a August 9, no fires were observed and the surveillance was cortpleted i

i satisfactorily. During the September 8 test a fire occurred at the  !

i north exhaust header. The operator promptly extinguished the fire  !

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and the remainder of the surveillance was completed. The fires were

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a result of oil leakage at exhaust header joints and the subsequent l

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ignition of the oil. The licensee has made recent modifications on '

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exhaust header joints in response to recurring fires; however, the

header joints which had the two recent fires had not been modified.

The licensee has issued two conditions reports for corrective action i

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investigation. Additional investigation and corrective action by the  !

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licensee are needed to correct the exhaust header fires. The l

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resident inspectors will continue to monitor the monthly surveillance

testing of tie emergency diesel generators and licensee actions taken

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No violations or deviations were identified.

8. Verification of Changes Made to Comply with PWR Moderator Dilution

Requirements (Temporary Instruction 2515/94) (Unit 2)

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The NRC inspector reviewed the licensee's response concerning the analysis

l of the potential for, and the consequene.es of, a boron dilution accident

!. foi Unit 2. During the licensee's analyses to identify and evaluate the ,

l potential for possible boron dilution events, no postulated dilution  !

scenarios were identified that would continue until reactor criticality.

On the basis of this review, the 'icensee determined no procedure changes

were required.

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In the safety evaluation for Unit 2. Cycle 2 reload, the NRC staff

addressed the inadvertent boron dilutien event for all modes of

operation. The staff's position was that a positive means for alerting

the operator to a boron dilution event in progress should be installed as

soon as practical. In response, the licensee proposed the addition of

audible control room alarms on count ra+.e from the startup range neutron

detectors. Each alarm was to be placed on "1 dependent channels and be

equipped with a variable setpoint to allow alarm adjustment to account for

n isting plant conditions. The NRC inspector reviewed tne installed baron '

dilution monitors and verified compliance with criteria in the safety ,

evaluation and with comitments stated by the licensee.

No violations or deviations were identified. ,

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9. Part 21 Reports (90714) (Units 1 and 2)_ '

The NRC inspector reviewed records pertaining to the licensee's evaluation

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of 10 CFR Part 21 reports. Copies of these reports had been provided to

the licensee as documented in NRC Inspection Reports 50-313/67-30;

50-368/87-30 and 50-313/87-38; 50-368/87-38. The NRC inspector found that

the licensee had reviewed each report for applicability and had taken

actiun when appropriate. The licensee's evaluation of three of the

reports was not complete at the time of the inspection. The following i

Part 21 r(ports, listed by NRC Region IV tracking numbers, are considered

closed:

86-002 87-011 87-035

86-003 87-016 87-036 l

86-009 87-019 87-038

86-013 87-020 87-042  !87-002 87-025 87-044

87-003 87-028 87-046  ;87-004 87-OL: 87-051 1

87-005 87-030 87-055

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87-006 87-031 87-065 '87-007

No siolations or deviations were identified. The licensee's operations

assessment group had implement 6' an effective system for performance of l

Plant Imaact Reviews and Plant Ieoact Evaluations for Part 21 reports and

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for tracking any resultant action assignments. '

10. Exit Interview

The NRC inspectors met with Mr. J. H. Levine, Director, Site Nuclear

Operations, and other members of the AP&L staff at the end of the

inspection. At this meeting, the inspectors summarized the scope of the i

intpection and the findings.

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