ML20207Q000
| ML20207Q000 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 01/12/1987 |
| From: | Hall D, Russell J, Strodl W TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20207P998 | List: |
| References | |
| 311.02-SQN-01, 311.02-SQN-1, 311.02-SQN-R05, 311.02-SQN-R5, NUDOCS 8701210040 | |
| Download: ML20207Q000 (13) | |
Text
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TVA EMPLOYEE CONC (NS REPORT NUMBER:
311.02-SQN SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant - Element-REVISION NUMBER:
5 TITLE:
Radioactive Material Control REASON FOR REVISION:
Revised to incorporate SRP coments.
Revision 1 Revised to incorporate SRP coments.
Revision 2 Ravised to incorporate SRP coments.
Revision 3
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Revised to incorporate SRP coments.
Revision 4 Revised to incorporate SRP cements.
Revision 5 PRRPARATION PREPARED BY:
D. C. Hall Jr.. W. R. Strodl 12/17/86
- SIGNATURE DATE REVIEWS y'9lcf'
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SIGNATURE DATE
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SIGNATURE DATE CONCURRENCES
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/~/2"87 SIGNATURE DATE -
SRP:
SIGNATURE
- DATE-APPROVED BY:
bl$~$Y N/A ECSP MAMGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences see in files.
1323T 8701210040 870113 _
PDR ADOCK 05000327 P
PDR:
TENNESSEE VALLEY AllTHORITY SEQUOYAH NUCLEAR PLANT
-EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Health Physics Element: Radioactive Material Control Report Number:
311.02-SQN Revision 5 00-85-005-011 JAM-86-001 XX-85-101-003 MRS-85-003 XX-85-005-001 W. R. Strodl 12/17/86 W. R. Strodl Date Evaluator:
D. C. Hall, Jr.
12/17/86 D. C.
all / Jr.
Date
![I Reviewed by:
/'
! 4/M OPS 4EVMember Date
]
f I/7/G7 Approved by:
g W. R. Lagergren Dato 1323T
Ravision 5 1.
Title:
Radioactive Material' Control, 311.02 - SQN The following report describes the evaluation of five (5) concerns.
The concerns and evaluations, described in section II of this report, deal with potential deficiencies in the handling of radioactive
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materials at Sequoyah Nuclear Plant (SQN).
II.
Specific Evaluation Methodology Concern 00-85-005-011 states:
"CI stated that TVA dumped radioactive material (water), carried in tanker trucks from Sequoyah, in one of the fields on the other side of Watts Bar project. This occurred about three years ago.
. Concern JAM-86-001 states:
" Radiological hygiene problem of contaminated material stored in lockers and cabinets which are not properly labeled. Material stored in auxiliary building."
Concern XI-85-101-003 states:
"Sequoyah-1980 there was an unknown quantity of radioactive water spilled into the uncontrolled drain system due to a valve on a water sampling station in the turbine building being left open. Construction Cept Concern. CI has no further information. No follow-up required."
Concern MRS-85-003 states:
" Green tag no longer required at clean tool room."
Concern XX-85-005-001 states: Sequoyah Plant; contaminated water dumped into river (Reference IN-85-049).
The evaluation of concern 00-85-005-011 included the review of similar concerns regarding the possible dumping of radioactive water from SQN at WBN from 1980 to 1984.
Individuals within the SQN Chemistry, Operations, Radwaste, Public Safety, and Power Stores organizations were contacted. Additional interviews were conducted with Environmental Planning personnel in Chattanooga.
Radioactive waste shipment procedures and data were reviewed.
Contracts involving the transport of water from SQN to WBN were also reviewed.
The evaluation of concern JAM-86-001 included verification that the incident occurred by examination of SQN Health Physics (HP) files and interviews with HP personnel. Documentation of the event consisted of correspondence between the concerned party and HP, HP and plant management, and internal HP log entries and survey forms. Actions taken by SQN HP to correct the situation were reviewed.
Page 1 of 11
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Ravisien 5 Concern XX-85-101-003'is a previously investigated concern (
Reference:
Memorandum from K. W. Whitt, Director of NSRS.1to H. L.'Abercrombie,-
tSite Director,'Sequoyah Nuclear Plant, dated February 7,:1986, "NSRS i
- report' Number I-85-543-SQN)."
The evaluation of this concern consisted-of. determining-the validity of the previous investigation and-determination of generic applicability.
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Concern MRS-85-003 was'also.previously evaluated (line response,-see
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case file). Additional; investigation was conducted to verify the-findings and conclusions of the' previous investigation. SQN HP was-contacted to provide the information.necessary to answer-and resolve
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-this concern.
4 Because the statements of' concern XX-85-005-001 gave no details which could be used to pinpoint a specific incident-it was necessary to first determine potential applicability to known incidents and then investigate each of these. Two (2)' areas of potential applicability t'
were found and investigated. The first investigation assumed that the concern referred to the incidents of dumping SQN material at WBN (re:
concern 00-85-005-011 also evaluated herein). The second investigation consisted of evaluating the SQN liquid effluents release program, and included reviews of TVA~and SQN procedural ~ requirements,-technical specifications and periodic release reports and environmental sampling
-reports.
The evaluations of the concerns were conducted in accordance with the i.
Operations CEG Evaluation Plan and the Health Physics Subcategory Evaluation Plan. All K-forms, previous investigations and reports were reviewed and. cognizant personnel were interviewed in the preparation of this report.
III. Findings Evaluation Results A.
00-85-005-011 and XX-85-005-001 Shipment of radioactive material offsite is controlled through Radwaste Handling and Shipping Instructions (RHSIs) 2, 2.1, 3 L
and 4.
In addition, bills of lading are prepared by Power Stores on all radioactive waste shipments. The shipment of radioactive waste to locations other than licensed burial sites is prohibited by RHSIs and the " Radioactive Material Shipment Manual."
Information regarding the shipment of radioactive waste is submitted to NRC on a semiannual basis.
From 1981 through 1984 alum sludge was transported from SQN to L
WBN in tanker trucks. The sludge was drained onto the ground and l
disked into the soll. The alum sludge is generated at the SQN water treatment facility and routed to holding ponds.
l periodically, the sludge in these ponds is pumped into tanker l
trucks and transported to WBN.
private contractors were used to i
haul the sludge from SQN to WBN.
Contracts provided for Page 2 of 11 a
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e Ravision 5 transport of'approximately' 540,000 gallons of sludge from 1981 to 1984.
Records on the exact' amounts and dates are no longer-available. This procedure was stopped in 1985 due to changes in State regulations'.. Prior to 1985, the State of Tennessee permitted the use of alum sludge as a soil conditioner. Verbal-concurrence was obtained by the Tennessee Department of Solid Waste Management prior to the operation being started. Both sludge and soll samples were taken and analyzed by TVA at various times during this operation. -The alum sludge generated by.the
' water treatment facility'is not radioactively contaminated. The water treatment. facility is not connected to any radioactive or potentially radioactive systems at SQN In addition to the alum sludge ground spreading at WBN, SQN also dumped a boric acid solution in the WBN evaporation / percolation pond on January 15th, 16th. and 17th of 1980. The boric acid solution was used in the SQN-preoperational-testing. program prior to initial criticality of unit 1 and became unusable due to silica contamination (nonradioactive). TVA requested and was granted verbal permission to dump the solution in the WBN evaporation / percolation pond ~by the State of Tennessee on January i
1 11, 1986, and in writing on January 16 1986.
(re: Memorandum from R. Manning, P.E.,
Division of Solid Waste Management, Department of Public Health, State of Tennessee to Bruce A. Brye, Chief, Water Quality Branch, TVA) A total of 49,000 gallons of boric' acid with a boron concentration of 4,000 milligrams per
~11ter was dumped at WBN. A cognizant SQN employee interviewed stated that he had witnessed and confirmed that the boric' acid solution was dumped in the evaporation / percolation pond in accordance with the TVA/ State of Tennessee agreement. Because the boric acid solution was removed from SQN prior to the initial criticality of Unit 1, which occurred in July 1980, there was no possibility of it being radioactively contaminated. Soil samples taken by WBN Health Physics personnel at the request of QTC (re:
QTC report PH-85-026-001) were analyzed for radioactive contamination. No radioactivity above normal background was
. detected.
Concern XX-85-005-001 was also evaluated in relation to SQN liquid effluent release practices. The concern, as stated, is valid, in that SQN as well as all other nuclear plants, does release radioactive effluents to the environment. These releases are not contrary to regulatory requirements provided releases are kept within the limits specified by 10CFR20 ar.d 10CFR50 and conform to the plant's technical specification requirements.
This investigation' consisted of reviews of SQN Radiological Impact Assessment Reports for the years 1980 through 1985 and SQN Radiological Environmental Operating Reports for the years 1978 through 1985. These reports are prepared annually by the TVA Office of Nuclear Power, Division of Nuclear Services, Radiological Health Branch. The Radiological Impact Arsessment roports assess population doses and are based on actual effluent Page 3 of 11
Revision 5 release data and environmental factors obtained from the plant.
The Environmental-Operating reports provide actual radioisotope-deposition data cStained by an exten'sive environmental sampling program. -The review of these reports verified that during the t.'ird and fourth quarters of 1980 and the first two months of 1981, Sequoyah released Phosphorus-32 (P-32) to the Tennessee River in quantities that caused the calculated dose to the bone for an individual to exceed Technical Specification 3.11.1.2 quarterly limits (5 mrem to any organ) and/or 10 CFR 50 Appendix I annual dose limit (10 mrem to an organ).
Based on calculated doses for the third and fourth quarter of 1980, liquid releases resulted in doses of 9.1 meem and 11.9 meem to the bone.
respectively. Calculated doses for the first quarter of 1981 were then made which resulted in a dose of 28 mrem to the bone.
TVA verbally informed NRC of the calculations and stopped releases from the radwaste system in February 1981, pending confirmation of the source of radioactivity and the initiation of corrective actions.
Special Reports 80-3 and 81-3 were issued by TVA to describe the investigations and the actions taken to correct any problems.
The dose limits exceeded in the third and fourth quarters of 1980 caused by P-32 were primarily due to releases from the turbine building sump. Although circumstantial, the evidence provided by the investigations questioned the presence of P-32 in the secondary system. The investigation included: 1) independent analysis of P-32 in the primary cycle, however, since July 1980, gamma scans confirmed no leakage between the primary and secondary cycles; 2) verification that no activation of P-31 was occurring in the steam generators; 3) high probability of cross contamination between Turbine Building sump samples and a spiked (known P-32) cross-check sample; 4) evaluation of counting instrument sensitivity to outside sources; 5) questionable reliability of counting instrument for samples of very low activity; and 6) the lack of a logical pattern to explain why the activity showed up in the secondary system. Those above areas leaving questions on the reliability of both instruments and laboratory practices were reviewed further. A follow-up investigation was performed regarding the existence of P-32 in the secondary cycle following plant startup which concluded that for the raonths of March and April, no P-32 activity could be detected in the secondary cycle. Laboratory practices were improved to minimize the possibility of cross-contamination of samples during sample collection and analysis by setting up separate locations for primary and secondary samples, and revising procedures TI-12, TI-49, and SI-4.03.
These changes ensured that preparation and counting of these samples would be dono separately. Other corrective actions included revising the Offsite Dose Calculation Manual for determining dose levels for P-32 on a monthly basis instead of quarterly.
Page 4 of 11
Revision 5 For the effluent releases in January and February 1981, the source of the P-32 was determined to be from trace amounts of sulfate and phosphate impurities in the boric acid which became activated in the reactor coolant system. TVA had obtained permission from EPA and NRC in July 1980, to " discharge the chemical volume and control system holdup tanks before any treatment, as long as the specifications for radioactivity release concentrations, and boron concentration limits were met after mixing with the cooling tower blowdown" (reference 28) Sequoyah had released the holdup tank contents on a periodic basis from August 1, 1980, until February 12, 1981, when it was determined that this waste. water had contributed significantly to the dose from liquid effluents for 1981.
As of late February, 1981 all radwaste releases at Sequoyah, have been processed through portable demineralizers. Subsequent calculations in March and Apell, 1981 for this waste stream was 0.4 mrom and 0.78 mram, respectively. These are below those values required by the quarterly and annual limits.
In conjunction with the onsite investigation, the calculated data for the reported releases in July 1980 to March 1981, indicate compliance witt, the drinking water requirements of 40 CFR 141. The average concentration of manmade radionuclides were well below the annual dose equivalent of 4 meem/ year to any internal organ.
Evaluhtions and compariso"
environmental media (surface water, fish, sediment) for the ss ime period indicated no significant differences between the upstream and downstream sources.
Because of reported effluent releases an NRC audit was performed in March 1981, to inspect the areas of radioactive effluent control, including release pathways, special reporting requirements, calculations of doses, laboratory procedures, and environmental sample results. 0f these six areas, two violations were found:
- 1) failure to make the required written report to the Commission, and 2) failure to follow approved chemistry procedures for quality control requirements. Corrective actions were implemented by TVA to comply with these requirements by improving communications betwe3n the operating plant and the Division of Occupational Health and Safety, and incorporating acceptance criteria to applicable procedures.
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.t Ravision 5 B.
JAM-86-001 Examination of HP files indicate that on January 30, 1986, HP management was informed via an internal SQN memorandum that an
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employee was concerned that contaminated material _was possibly
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being stored in unlabeled cabinets'and other containers in the LAuxiliary' Building and that_ surveys of these cabinets and
. containers were requested. -On February 7,1986, per.lHP log entries
-and radiological' survey form TVA 17096, survey number 0-86-308 HP technicians conducted searches and surveys of cabinets, carts, and storage boxes in the Auxiliary Building. --No untagged or_ unlabeled contaminated materials were found; however, one bagged and tagged hose was found in an unlabeled Operations Section storage box, elevation 669'.
On February 23, 1986, an informal memorandum _was sent from the HP Section Supervisor to the.SQh-Superintendent, Operations and Engineering, detailing the concern and HP action taken. This.
memorandum indicated a problem had been encountered by HP in that they could not gain access to some locked cabinets and boxes ~due to a lack of identification on them. HP requested that the containers be labeled to allow identification of the' person or organization
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responsiblo for them. Following receipt of the memorandum dated February 25, the SQN Plant Superintendent, O&E, called a meeting with applicable plant and construction management personnel. In this meeting he directed that'all. lockers, cabinets.. gang-boxes, and other containers should be labeled as requested by HP.
The-management-personnel in attendance agreed to comply with this directive.
Implementation of this program has been verified and-will allow HP to perform periodic surveyslof'all locked containers in the Auxiliary Building and other regulated areas of the plant.
F No additional concerns or complaints have been received by HP regarding this' matter.
C.
XX-85-101-003 (SQN)
The NSRS investigation report I-85-543-SQN revealed that on December 1, 1980, during the feedwater moisture carryover test, Ha24 contaminated water from a sample sink entered the Turbine Building sump and was pumped to the yard holding pond.
Cause of l
the incident was an open sample sink valve due to inadequate procedures requiring the valve to be checked. Na24 has a short half-life and HP established a regulated zone around the pond until i
the Na24 had decayed. No Na24 contamination was released beyond the confines of the pond and no unnecessary personnel exposures were noted. The moisture carryover test is a "one time" procedure h
and wil1 not be conducted at SQN again; therefore, this concern is
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no longer applicable to SQN. Applicability to WBN and BLN, which will' require this test, was investigated. Appropriate reports concerning the incident were made by the plant and TVA.
Page 6 of 11
Ravisicn 5 D.
MRS-85-003 This concern was subject to a line investigation at SQN on June 27, 1986. This investigation revealed the reason green tags are no longer required at the clean toolroom is that the power block concept, now in use at SQN, has removed the clean toolroom from the restricted area. Before the power block concept it was possible to return tools to the toolroom prior to having them surveyed by HP.
To ensure that tools were uncontaminated, the plant required that any tools being returned be accompanied by a green tag indicating an HP survey and clearance had been performed. The power block concept requires survey and green tag clearance at the point of exit from the regulated area; therefore, a green tag is no longer required at the clean toolroom.
The investigation was evaluated by an interview with the SQN HP Unit Supervisor on July 23, 1986, and the findings verified.
Conclusions A.
00-85-005-011 The concern that radioactively contaminated water from SQN was dumped at WBN was not validated. During the period in question, nonradioactive alum sludge was shipped in tanker trucks from SQN to WBN and dumped in fields around the plant, and boric acid solution was transportsd from SQN to WBN and dumped in the evaporation / percolation pond. All dumping was done in accordance with state and EPA requirements. The concern does not affect the scfe operation of the plant.
B.
JAM-86-001 The concern that contaminated material was being stored in unlabeled, unposted cabinets, boxes, or other containers was verified; however, no unbagged or unlabeled material was found.
Actions by HP to label or otherwise identify containers which may contain contaminated material have been implemented and are adequate to prevent an unnecessary hazard to plant personnel. HP appears to have addressed both present and potential future occurrences of this problem in an adequate manner. The concern does not affect the safe operation of the plant.
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Ravision 5
'C.
XX-85-101-003 The concern that radioactive water was spilled into an uncontrolled drain system due to inadequate procedural control was verified in that the incident did occur as stated; however, it should be emphasized that, upon discovery of the incident, due to a high radiation alarm on the turbine sump discharge, it has been determined that Operations and HP took appropriate action to prevent a release to the river and minimize personnel exposure.
It is, therefore, concluded that at the time this concern was expressed, the concern was no longer valid in that all required actions and reports were made by the plant following the event.
Generic applicability has been assessed (see section V below).
This evaluation concurs with the findings of the previous NSRS investigation. The concern does not affect the safe operation of the plant.
D.
MRS-85-003 The power block concept was shown to make green tags unnecessary at the clean toolroom and has resulted in better contamination control overall at SQN. This evaluation concurs with the previous line investigation at SQN. The concern was not validated and does not affect the safe operation of the plant.
E.
XX-85-005-001 The concern that SQN dumped contaminated water in the river was validated. SQN did and continues to release radioactive liquid effluents; however there was evidence in the first quarter, 1981 that effluent releases were made in excess of regulatory limits and tech spec requirements. Sequoyah took immediate steps to activate its radwaste equipment to prevent recurrence of the event which released radioactive liquid which exceeded regulatory and tech spec requirements. With regard to materials shipped offsite to WBN and dumped, the concern was not validated in that the incidents did not i-involve radioactive material and were done in accordance with state l
and EPA requirements. No further corrective action is required.
This concern does not affect the safe operation of the plant.
i IV.
Root Cause The root cause of JAM-86-001 was determined to be a procedural deficiency in that radioactive material was required to be wrapped and laboled but labeling of containers with radioactive material in them was not addressed. Appropriate corrective action has been taken to correct this.
Page 8 of 11
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Ravision 5
'.The root-cause of' concern XX-85-101-003 was determined to be a-procedural deficiency which' f ailed to include a means to double check
.the feedwater sample sink valve to ensure that it was closed..The
-procedure was corrected and applied to WBN's procedure.
The root causes of XX-85-005-001 appears to be a result of a lack of i
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communication between the SQN plant and TVA's Division of Occupational l
Health and Safety, and because_P-32 dose levels were calculated on a i
guarterly basis. This lack of communication between the two groups l
concerning the; calculated P-32 levels allowed the' releases from the-l
- Turbine Building sump for the fourth quarter of 1980.-
Effluent from l
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the Turbine Building sump.for third quarter of 1980 had been released l
before.any calculations had been made for that quarter. Releases from' I
the. Chemical Volume and Control System (CVCS) holdup tanks had occurred l-in January and February of 1981,-again, before calculations had j
determined that this waste water had contributed significantly to the i
f calculated dose from liquid effluents.
lR5.
l To ensure 1these incidents were not repeated.. corrective actions were i
implemented by TVA to improve cannunications between the operating i
plant and the Division of Occupational Health and Safety and to revise l
the Offsite DoseLCalculation Manual (ODCM) to require dose levels for i
P-32 be calculated on a monthly basis instead of quarterly.
l Additionally.. portable dominera112ers were used to process all radwaste l
releases at SQN by late February 1981. These corrective actions have I
effectively precluded recurrence to date.
l Root cause determinations were not necessary for those concerns which l
were found to be invalid.
1 V.
Generic Applicability Concern XX-85-101-003 is also applicable to WBN and BLN.
Examination of WBN Start-Up Test Procedure, SU 4.6, " Moisture Carryover Determination," indicated that the problems encountered at SQN have been specifically addressed and corrected at WBN. The BLN moisture carryover procedure has not yet been written.
Concern XX-85-005-001 is specific to SQN and is not applicable to other TVA sites.
Concern 00-85-005-011 is specific to both WBN and SQN and will not be evaluated at other-TVA sites.
l All other con: erns are not valid and are not applicable to other TVA sites.
7 4
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I Revision 5 VI.
References 1.
RHSI 2, Revision 2, " Shipment to 11 ".. Ecology, Richland, Washington"~
2.
RHSI 2.1, Revision 0,' "D. A.W. Ship.6.nt to Chem-Nuclear Barnwell, South Carolina" 3.
RHSI'3, Revision 7, " Shipment of Etiloactive Waste to. Chem-Nuclear Systems, Inc., Barnwell, SC" 4.
RHSI 4, Revision 1, " Shipping of Rotloactive Articles or Equipment Offsite and to Other Plants, Utille.es, or Vendors" 5.
TVA, Office of Nuclear Power, "Radissctive Material Shipment Manual" Revision 24 6.
Contract / Purchase Requisitions 82P56-187561-2 Roto-Rooter.. Sew *** Service 83P51-931802 Bryson Environmen.41 Services 83P51-931808 Valley Systems Cwpany 85P51-9644390 H.E.S., Inc.
7.
Memorandum from J. W. Shipp to D. t Cox, March 10, 1981, " Watts Bar Alum Sludge Analysis"
-8.
Form TVA 45, SWH to JGM, May 5, 196
" Chemical Anclysis of SQN Alum Sludge" 9.
" Preliminary Draft Report, Potentie Sanitary Landfill Sites for Loudon County, Tennessee," Divistor if Environmental Planning, TVA, December 1978 10.
" Final Geologic Evaluation of ProPwad Alum Sludge Landfill Site,"
State of Tennessee, Department of ihile Health, Division of Solid Waste Management, May 11, 1981 11.
Semiannual and Annual Radioactive trluent Release Reports 1980-1986 12.
Informal memorandum, R. W. Fortenb**y to D. E. Crawley, dated January 30, 1986, " Employee Concert 13.
Radiological Survey, Form TVA 1709' Iurvey Number 0-86-308, dated February 7, 1986 14.
Informal memorandum, D. E. Crawle)
L. M. Nobles, dated s
February 25, 1986, " Unlabeled Cabia t in Auxiliary Building" 15.
NSRS Report Number I-85-543-SQN, *.,loactive Spill into Uncontrolled Drain System," dated i'ruary 7,1986 Page 10 of 1;
Ravisien 5 16.
Watts Bar Nuclear Plant, Start-up and Test Procedure, SU 4.6, "Moiscure Carryover Determination" h,2 17.
10 CFR 20 18.
10 CFR 50 19.
10 C(R 61 20, 10 CFR 71 21.
49 CFR 170-178 22.
Memoranda from R. Manning to B. A. Brye dated 1/16/80 and 2/14/80 23.
Memoranda from B. A. Brye to R. Manning dated 2/11/80 and to J. G. Dewease dated 1/15/80 s
24.
Technical Specification 3.11.1.2, 3/4.11. " Radioactive Rffluents" January 14, 1986 25.
TVA Special Report 81-3 26.
TVA Special Report 80-3 21.
Memorandum from J. N. Ballentine to J. G. Dewease, dated May 26, 1981, L53-810526-988 28.
Memorandum from H. G. Parris to W. F. Willis, dated May 22, 1981,LO3-810521-800 29.
Letter from L. M. Mitts, TVA to J. P. O'Reilly, dated April 24, 1981 A27-810424-010 30.
Letter from R. C. Lewis to H. G. Parris, dated April 3, 1981,
[
A02-810407-005 31.
Memorandum from G. F. Stone to H. J. Green, dated April 6, 1981, 100-810409-495 l
32.
LER Review Sheet, March 30, 1981, from R. A. Sessoms to J. G. Dewease 33.
LER Review Sheet, June 15, 1981, from R. A. Sessoms to
(
J. G. Dowease 34.
NRC Inspection at Sequoyah Nuclear Plant near Daisy, Tennessee,
}
Report Number 50-327/81-10, March 27, 1981 VIII.
Immodlate or Long-Term Corrective Action None l
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